Some new teachers will have to take additional certification test

After releasing a preliminary “reinterpretation” of the federal No Child Left Behind (NCLB) highly qualified provisions last fall, USDE recently issued a final interpretation, effectively requiring new Texas elementary teachers (new to the profession when hired for the 2009-10 school year) holding subject-specific certification and those holding EC-12 Special Education certification to take and pass an additional generalist certification exam. 

Although USDE exempted new elementary teachers holding all-level art, music, theater from the additional exam requirement, elementary teachers holding 4-8 math, 4-8 science, 4-8 social studies, 4-8 math/science, 4-8 ELA/reading, 4-8 ELA/reading/social studies, and EC-12 Special Education certificates will now have to take and pass the EC-6 Generalist exam. It is not clear yet when the deadline for taking and passing the test will be; TEA is expected to issue a letter to school districts on the subject soon.

TCTA immediately contacted (see USDE Letter below) USDE and members of the Texas Congressional delegation last fall in response to USDE’s preliminary interpretation, arguing forcefully that USDE’s reinterpretation of the law did not make sense if NCLB, as written, was meant to logically apply to all elementary school situations, including departmentalized grades.

Under USDE’s reinterpretation, new elementary teachers holding subject-specific and all-level teaching certificates were no longer considered highly qualified, because they had not passed a subject knowledge tests in all of the areas of the basic elementary school curriculum. 

USDE based its decision on its reinterpretation of the language of the federal NCLB Act, which states that the term “highly qualified,” when used with respect to an elementary school teacher who is new to the profession, means that the teacher holds at least a bachelor’s degree; and “has demonstrated, by passing a rigorous State test, subject knowledge and teaching skills in reading, writing, mathematics, and other areas of the basic elementary school curriculum."

At issue was whether the phrase “in reading, writing, mathematics, and other areas of the basic elementary school curriculum” modifies the words “subject knowledge” or “teaching skills.” 

Heretofore, the interpretation had been that it modifies “teaching skills” and teachers’ passage of the applicable Pedagogy and Professional Responsibilities (PPR) certification exam met that requirement. 

However, USDE’s reinterpretation was that the phrase modifies “subject knowledge” such that a new elementary teacher would have to have passed a subject knowledge certification test in reading, writing, mathematics and other areas of the basic elementary school curriculum.

Accordingly, any elementary teacher who was new to the profession when hired for the 2009-10 school year and whose demonstration of subject competency was based on passing one of the following exams would not be considered highly qualified for elementary grades until he/she has also passed a Generalist exam that tests subject knowledge in reading, writing, mathematics, science, and social studies:

In response to this, TCTA argued that in addition to being an illogical read of the statute, this requirement could potentially serve to discourage elementary departmentalized instruction at a time when students need deeper acquisition of subject matter earlier in the education pipeline in order to meet college readiness goals upon graduation from high school. 

Additionally, requiring teachers to take a certification exam that will do little to benefit their own instruction or the students they teach is likely to cause widespread resentment among the very content specialists we want to encourage to teach in our elementary schools.

However, USDE chose to stick with this illogical reading of the statute, except for EC-12 art, music and theater teachers, who were exempted on the basis that they were not teaching a subject covered by the certification test of the general elementary curriculum (generalist exam). 

As previously stated, TEA is expected to issue a letter detailing deadlines and requirements that must be met as a result of USDE’s final interpretation. 

TCTA will continue to monitor developments as they occur.