Joint Council Recommendations Regarding
Licensure and Professional Development Code Revisions

Proposed revisions to the Licensure and Professional Development Code presented to the State Board of Education in early June require all new candidates for special education certification to possess or be eligible for a standard or provisional instructional certificate appropriate to the subject or grade level being taught (NJAC 6A:0-11.3). The Joint Council of County Special Services Schools Districts, representing eight regional public school districts serving some of the state’s most severely disabled students, is concerned this new proposal will drastically reduce the supply of teachers certified in special education.

The goal for the revision of special education certification must be to balance rigorous preparation/certification requirements with the need for an adequate supply of qualified special education teachers and professional staff members. Given the highly specialized needs of their students, teachers of students with disabilities need specialized instruction and training. The Joint Council recognizes that the federal No Child Left Behind Act also requires teachers to be "highly qualified" in the subject areas they teach. Certainly, this has merit and is intended to raise the quality of instruction for students with disabilities in most settings. But, NCLB and the proposed code revisions fail to recognize the unique nature of New Jersey’s county special services school districts and their 4,500 students with multiple disabilities, autism, behavioral disorders, severe cognitive and physical impairments, and other severe disabilities. These students, who do not typically perform at a high academic level, require experienced teachers with an understanding of their cognitive, physical, and emotional needs and training in the specialized teaching techniques that address these issues.

Certainly, we support efforts to improve the quality of instruction, and the county special services school districts will work with teachers currently certified to ensure that they can demonstrate content knowledge appropriate for the level and subjects taught. We also support increased requirements in academic and special education content for new teachers entering the field.

However, this additional emphasis on academic content knowledge must not come at the expense of an adequate supply of trained special education teachers. New academic content standards will accelerate retirement of many experienced teachers. It is essential to balance this attrition with a strong cadre of new candidates for special education certification. Yet, the proposal to require all new special education teachers to meet the requirements for an elementary or subject-area provisional certificate will have the opposite effect, and will reduce the number of new special education teachers entering the field. It is a misguided approach to ensuring that special education teachers possess the necessary academic content knowledge.

As currently worded, the code states that a candidate must possess or be eligible for a standard or provisional certificate, not a certificate of eligibility (CE or CEAS). This means a candidate would have to obtain and accept an offer of employment in a position that requires instructional certification. Surely the Department of Education does not intend to require candidates to seek a teaching job in regular education in order to qualify for a special education certificate.

Even if reworded, the requirement raises very serious concerns. The code relies upon in-state and out-of-state colleges to revise their teacher education programs to dovetail the requirements for instructional and special education certificates; however, it makes no statement about the need for this to occur. While some of the required 30 credits in professional preparation for a regular instructional certificate can be merged with the required credits in special education instruction, it seems likely that special education certification programs will require substantially more credits than other areas. Special education candidates may well need a fifth year of college study to earn their bachelor’s degree and teaching certificate. Clearly, this will discourage many teacher candidates from pursing special education certification and exacerbate the shortage of qualified teachers in this critical area.

While the proposed code would require all special education teachers to meet the requirements for instructional certification, it requires regular classroom teachers to have only modest exposure to special education topics. The new requirement for study of special education as part of professional preparation is a step in the right direction, but the current emphasis on inclusion of students with disabilities means that all teachers need substantial knowledge in special education topics.

If special education teachers, including those who serve students with the most severe disabilities, need expertise in all subject areas they cover, shouldn’t elementary and subject-area teachers who serve included students with a wide range of disabilities have an equivalent level of expertise in special education topics? To ensure that all teachers are well-qualified to teach and address the needs of students with different learning styles, particularly students with disabilities, the Department and State Board of Education should require all teachers to experience a common core of professional preparation that emphasizes special education topics such as those included in NJAC 6A:9-11.3(e)2. Such a change would require all teacher preparation institutions to revise their programs and increase the number of credits required for all teaching certificates.

This approach will meet the requirements of No Child Left Behind by ensuring that all teachers are qualified to teach the appropriate core academic subjects and meet the special needs of students with disabilities. It will also "level the field" between the requirements for certification in special education and regular instruction. This will help to ameliorate the shortage of certified special education teachers, rather than exacerbating it.

The Joint Council of County Special Services School Districts recognizes that this recommendation constitutes a major change in state policy that will require extensive discussion and consensus-building. In the meantime, interim changes are needed to ensure that pending revisions to the Licensure and Professional Development Code do not reduce the already-limited supply of special education teachers.

The Joint Council supports revising the code to require new candidates for special education to complete an academic major in liberal arts, science, dual content, or at least 30 credits in a coherent sequence of courses appropriate to the specific instructional field. Candidates for a CE through the alternate route should also complete 6 credits in special education before entering the classroom and 24 additional credits over five years. Candidates for the CEAS should complete one of the collegiate preparation options listed in NJAC 6A:9-11.3 (c) 1-4. However, until the State is ready to make long-term changes that equalize preparation for regular and special education candidates, the requirement that all candidates "possess or be eligible for a standard or provisional New Jersey instructional certificate appropriate to the subject or grade level to be taught as defined in the student’s IEP" should be eliminated.

In summary, the Joint Council of County Special Services School Districts recommends a common core of professional preparation that will prepare all new teachers to meet the needs of regular students and those with disabilities. This will raise the bar for all new teachers, equalize preparation requirements for elementary, subject area, and special education certificates, and ensure that all new teachers meet the NCLB definition of "highly qualified." Until that goal is addressed, the state must meet academic content requirements with focused preparation requirements rather than prerequisite eligibility for a regular instructional certificate.