Specific Comments on Changes to Teacher Certification Code (2011-018 ED)

Rule 390.1122 (4) states: Applicants who complete an approved alternate route program under section 1531i of 1976 PA 451, MCL 380.1531i are considered to have met the requirements of this rule.

They may be “considered to have met the requirements of this rule”, but they clearly have not. Herein lies the problem: this allows a double standard in who is certified in Michigan.  The alternative programs are not held to the same standard as teacher preparation institutions in Michigan. How is this fair and in the best interests of the state and its children? The introduction of language “approved planned program or equivalent” at the beginning of this rule combined with closing statement #4 above leaves the expectations of alternative programs open to much interpretation. Simpler and more direct language such as “We will hold alternative programs to as few standards as we can get away with” might be more honest and clearer. The inclusion of “instructional settings” in this rule also suggests a broadening of the definition of field experiences for teacher candidates that does not seem warranted.

For example, alternative programs in Part 2 R 390.1124 Scholastic averages; directed teaching says:


R 390.1124  (3) An applicant completing an alternate route program under section 1531i of 1976 PA 451, MCL 380.1531 shall complete either of the following to satisfy the field-based experience:

(a) If the applicant is employed under the interim certificate, the first 4 weeks of employment shall be supported by intensive observation, mentoring or coaching, and feedback provided by an assigned mentor or coach with experience and expertise in the candidate’s certificate endorsement area or appropriate level of certification. An additional 8 weeks of continued supervision, mentoring or coaching, and evaluation shall be completed to meet the field-based student teaching requirement.

(b) If the applicant is not employed while completing an alternate route program, the candidate shall complete at least 6 weeks of full-time field-based student teaching or 12 weeks of part-time field-based student teaching under a mentor or coach with expertise and experience in the candidate’s proposed endorsement area or appropriate level of certification.


This directed teaching does not begin to compare with the rigor, quality and quantity of the much more comprehensive, “intensive observation, mentoring or coaching, and feedback” candidates receive in TPIs over two years in pre-methods through methods course and clinical experiences, and if successful, then into student teaching, all supervised by university faculty and classroom teachers. Beyond these very limited time requirements, there are no expectations set through this alternative route process at all. For (b), why would they have even less requirements than (a)? In (a) they must complete 12 weeks of directed and supervised teaching, however in (b) they only have to do 6 weeks full-time or 12 weeks part-time. What is the rationale behind this disparity of requirements?

Michigan Governor Snyder called for “more in-classroom clinical experience for all teacher candidates” (p. 10) in his April 27 reform message, but the above change greatly reduces it. He says we need “rigorous performance-centered assessment of teaching” (p. 10), which the TPIs currently provide, however the code does not include such standards for alternative routes to teaching. The Governor also says that no one should be allowed “to practice on our young people without demonstrating sufficient proficiency with the highly skilled work needed for teaching” (p. 10) while this proposed change allows just that.

In PART 3, R 390.1132, (3) states:

Beginning September 1, 2013 a professional education certificate may be issued to an applicant who presents evidence that he or she has completed all of the following: (a) At least 3 consecutive highly effective annual evaluations with at least 4 years of teaching experience or 3 consecutive effective annual evaluations with at least 5 years of teaching experience or 4 nonconsecutive effective or highly effective annual evaluations with at least 5 years of teaching experiences under section 1249 of 1976 PA 451, MCL380.1249.

(b) The applicant has completed at least 1 of the following:

  (i) Eighteen state continuing education hours.  Eighteen state continuing education hours is 180 clock hours of approved professional development activities appropriate to the grade level and content endorsement(s) of the certificate. 

   (ii) Annual district provided professional development under section 1527 of 1976 PA 451, MCL 380.1527 completed through professional development programs that are appropriate to the grade level and content endorsement(s) of the certificate.

  (iii) A combination of state continuing education hours under subrule (3)(b)(i) of this rule or district provided annual professional development under subrule (3)(b)(ii) of this rule.  Annual district provided professional development (30 clock hours) is equivalent to 3 state continuing education hours.


This change is unfair and unreasonable. I greatly appreciate Superintendent Flanagan’s email response on October 26, 2011 informing teacher educators that he will “have any language removed that revokes or prevents teacher certification licensure based upon annual evaluations” (see http://www.michigan.gov/documents/mde/StatementProposedTeacherCertRules_367145_7.pdf). As he has said he will remove that language, I therefore trust that will happen and will not further address the reasons it needs to be omitted here.

However, the allowing options ii and iii above will greatly lessen the professional development standards expected for professional certification. They should be struck from the code. The leaders of the states continue to state we need better prepared teachers, but we are taking away one of the most established methods of professional development by not requiring that teacher complete a planned program of further education through university programs. Interestingly, not only do our leaders call for higher education and many institutions and states actually require a master’s degree to teach. For example, in Finland, which has the highest regarded education in the world, all teachers must have a master’s degree to become a teacher. Why would we go backwards in our expectation of teachers by both lower the requirements to become a teacher and to obtain a professional certificate? Based on the lesson from countries like Finland, instead of reducing the number of graduate credits required for continuing service and professional development, we should be requiring a master’s degree.

Rule 390.1135(a)(1), Rule 390.1137(1)(b) Rule 390.1145(1) and Rule 390.1146(1)-(3) suffer from lack of clarity.


In Part 4, R 390.1147 Expert in residence permit, why add this provision? What problem does it solve? Does it not open the doors even wider for non-certified and unqualified individuals to teach?


In Part 5, R 390.1151 (4) says: “An approved teacher preparation institution shall hold national accreditation beginning December 31, 2013”. The TPI’s agreed to this change several years ago. We did it to improve TPI’s in Michigan. National accreditation is another way to assure quality programs. Why are the TPI’s in Michigan required to hold national accreditation, but the alternative programs are not? Why would we lowering of standards that the TPI’s are holding themselves to but not requiring it of all alternative teacher preparation programs in Michigan?


(5) An approved teacher preparation institution shall submit required data that is used to determine its annual teacher preparation institution performance score as approved by the superintendent of public instruction.


Will alternative programs also be required to submit data and be scored?


(6)(8) All specialty programs offered by an approved teacher preparation institution shall be in subject matter fields pertinent to teaching at the level for which certification is to be recommended as approved by the state board. The superintendent of public instruction state board reserves the right to may determine the criteria for accepting certification of candidates prepared in out-of-state teacher preparation institutions and in accordance with state law. 23


Why take this power form a democratically elected state board of education who has traditionally be given this authority and giving it to an individual? How does this better serve the interests of the citizens of Michigan? There are several instances throughout the code where this change has been made. Why “may”? Why not “will”?

Rule 390.1154(6) seems to allows out-of-state candidate for teaching certificate to meet a lesser standards for teaching experience, which does not seem reasonable.


About rodclarken

Dr. Rodney H Clarken is professor emeritus, School of Education, Northern Michigan University.
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