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Last week, the U.S. Department of Education released for public comment proposed regulations concerning teacher preparation programs across the country.

The proposed rules not only manifest federal overreach but also present an unfunded mandate that would result in a significant fiscal impact at the state and potentially even the local level. In addition, they will draw energy, funding and attention away from innovative programs and practices currently gaining steam in teacher preparation programs across the country.

The American Association of Colleges for Teacher Education and its 800 member institutions are committed to preparing effective teachers — and to improving programs that fall short of that goal — but requiring states to rate programs and institute other costly changes is counterproductive.

Related: How an Australian company won the top spot in teacher training in New York City

States are responsible for the oversight of teacher preparation programs and of the institutions implementing these programs, yet the proposed federal regulations would largely bypass this responsibility.

American Association of Colleges for Teacher Education
Sharon P. Robinson is the president and chief executive officer of the American Association of Colleges for Teacher Education.

The price tag for states to implement these regulations would be steep —higher, we believe, than the fiscal estimates provided in the proposed rules. Most states would need to develop new or change existing data collection and reporting systems to comply with the required metrics. Additionally, the regulations ask that program graduates be tracked over time — a process that is both time and staff intensive. Without federal financial support, these regulations would impose an unfunded mandate on the states, which are required to have balanced budgets.

Furthermore, the proposed regulations mirror misguided rating systems and incentives that have created the unproductive, test-driven accountability environment of today’s K-12 schools — even as the administration has sought to address that very issue with increased flexibility for states in recent months. The regulations also would tie federal student financial aid to the rating system, and recommend the use of metrics and methodology to measure program effectiveness that have proven to be unreliable in K-12 education.

Related: Effective teacher training critical to success of Common Core math

“AACTE and its 800 member institutions are committed to preparing effective teachers — and to improving programs that fall short of that goal — but requiring states to rate programs and institute other costly changes is counterproductive.”

If these fallacies are not sufficient cause for concern, the government should beware the potential for the proposed regulations to hamper key reforms, including those that are supported by federal dollars. Teacher preparation programs have significant improvements under way addressing many of the concerns to which these regulations appear to be responding. Since 2009, the federal government has funded innovation and reform through Teacher Quality Partnership grants, which have been awarded to more than 50 collaborations of high-need school districts and educator preparation programs working to ensure fully prepared teachers are in high-need schools.

Yet programs would be forced to shift investments of time, money and attention from innovations and reforms such as the Teacher Quality Partnerships in order to meet the new—and unfunded—federal requirements.

The proposed regulations would tie federal TEACH grants to the new ratings system, effectively directing federal aid only to students in programs whose graduates teach in high-performing schools. This limitation could unfairly punish programs that work predominantly with high-need schools.

Related: Teacher-training schools under pressure to prepare for Common Core

In addition, we know from recent data that low- and middle-income students, as well as students of color, are disproportionately affected by changes in financial aid for higher education. Restricting access to financial aid would turn back progress made by AACTE and other organizations and institutions to build an educator workforce that is culturally and racially representative of the communities in which they serve.

Finally, given the current decline in teacher preparation program enrollment seen across the country and the continued increase in the cost of higher education, the connection of students’ financial aid to a misguided rating system would likely exacerbate problems, not solve them.

More than a dozen states have begun or just completed profound changes to their program approval practices to ensure that program completers are classroom ready on day one. Adding federal reporting and rating requirements would not only impose a burden on resources but also detract from this progress by setting up a potentially conflicting system. Further, the accountability structure proposed in the regulations relies on methodology, metrics and data that are untested or have been proven unreliable.

Related: How to save teachers from burning out, dropping out and other hazards of experience

The program assessment metrics suggested in the proposed regulations are neither valid nor reliable enough to be used to make high-stakes decisions about an educator or a preparation program. Value-added modeling has proven problematic for evaluating teachers and preparation programs, as have teacher evaluations, which often include student test scores or growth models such as VAM as a factor. In addition, the placement and retention of a graduate may have little causal connection to the graduate’s preparation program. For example, a teacher may leave a school due to the lack of resources, the cultural environment, the school leadership, or for personal reasons—none of which is directly related to his or her teacher preparation program.

High-quality teacher preparation is an essential component of ensuring all students equitably receive the best education our nation offers. Our education system is best served by supporting educator preparation programs’ pursuit of innovations and reforms that are based on research and relevant to their state context — not by imposing burdensome federal regulations that would ultimately undermine the best interest of the nation’s students.

Sharon P. Robinson is the president and chief executive officer of the American Association of Colleges for Teacher Education.

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