- 25 .. . years of Service Testimony of the New Jersey Principals & Supervisors Association on Proposed Changes to N.J.A.C. 6A:9 (Certification of State District Chief School Administrators) May 4, 2011 Thank you for the opportunity to share the concerns of the New Jersey Principals and Supervisors Association, and its statewide membership on recently proposed amendments to NJ.A.C. 6A:9 which seek to modify the certification requirements for certain chief school administrators. NJPSA is dedicated to the improvement of the quality of teaching and learning in New Jersey. We believe that educational and instructional leadership are key components to student success. Our members are the principals, assistant principals and supervisory employees at the school building level who work daily with parents and professionals to ensure that our students thrive in an environment that maximizes their learning potential. The Need for Sound Educational & Instructional Leadership New Jersey's superintendents serve as not just the administrative, but more importantly perhaps, the educational and instructional leaders in our districts. While supervising school operations, managing budgets and taking personnel actions, they are, more importantly, providing educational and instructional leadership by setting educational goals and priorities; evaluating school staffs' effectiveness; and directing the activities of school-level leaders and teachers. Effective education leadership is second only to teaching among school-related factors in its impact on student learning, and the impact of leadership tends to be greatest in schools where the learning needs of students are most acute. See Wahlstrom, Kyle et. aI., "Learning from Leadership," Leadership: Investigating the Links to Improved Student Learning (July 20, 2010) available at http://www.cehd.umn.edu/carei/. "Teachers are on the front lines of learning, but principals at the school level, and superintendents at the district level, are uniquely positioned to provide a climate of high expectations, a clear vision for better teaching and learning, and the means for everyone in the system - adults and children - to realize that vision." See DeVita, M. Christina, Education Leadership: A Bridge to School Reform, 2 (October 22-24, 2007) available at http://www.waliacefoundation.org/SiteCollectionDocuments/WF /Knowledge%20Center/ Attachments/PDF ABridgetoSchoolReformfinalPDF .pdf. New Jersey Principals and Supervisors Association 12 Centre Drive. Monroe Township, New Jersey 08831-1564 Tel.: 609-860-1200 Fax.: 609-860-2999 E-Mail: NJPSA@aol.com Web: http://\wlW.njpsa.org If today's chief school administrators are responsible for: developing the educational and instructional vision of the district; directing curriculum and assessment changes; and leading school staff they need the educational background and experience to ensure success. The state's authority to license school leaders can be an effective tool for ensuring that schools have highquality leaders. See Shelton, Sara Vitaska, Strong Leaders Strong Schools: 2008 State Laws, 7 (June 2009) available at htt : www.wallacefoundation.or Knowled eCenter Knowled eTo ics CurrentAreasofFocus Educationlea dership/Documents/strong-leaders-strong-schools-2008.pdf. Increasingly, states are attempting to move toward a performance-based system by creating standards and requiring administrators to demonstrate knowledge and skills in order to be licensed. Id. licensure candidates, via traditional, and in a quarter of states, non-traditional pathways, must demonstrate they possess the skills and behaviors to improve student learning, not just administrative capabilities. Id. These states' tiered certification requirements include a combination of graduate course work, educational leadership experience, a robust internship or clinical experience, participation in a mentoring and induction program or professional portfolio documents. Id. New Jersey's System New Jersey's current licensure system is grounded in professional standards that recognize the needs of a strong educational leader during pre-service preparation, at certification, during induction, and throughout their professional lives via professional development and evaluation. In fact, this State Board has taken a leading role in the development, review and adoption of the current system. Today all candidates for certification as chief school administrators must hold a Master's or higher degree from a regionally accredited college or university and participate in 150 hours of a school-based internship prior to receiving their provisional certificate. This is followed by a rigorous residency/mentoring program which includes performance appraisals prior to a determination of whether to grant a provisional certificate holder a standard certificate. Under this system, the mentor assigned decides whether to recommend certification; continuation of the individual for another year under a provisional certificate, or not granting certification. The system is based on high-quality educational standards that are not only efficient but also effective. These standards, derived from the Interstate School leader licensure Consortium (ISllC) standards, have instrumentally helped 43 states define how leaders can positively influence learning and establish guidelines to ensure that they do so. See Council of Chief State School Officers, Equcational Leadership Policy Standards: ISLLC 2008 As Adopted by the National Policy Board for Educational Administration, 2 (2008) available at WWW.ccsso.org. They play an important role in informing key policies affecting the training, licensing, induction, professional development and evaluation of school leaders. The standards form the basis for the requisite knowledge, skills and disposition for effective school leaders in four quadrants: · Instructional leadership · Visionary leadership · Community leadership 21Page . Strategic Management While we applaud attempts to increase the pool of potential candidates in our schools, as well as the recent changes to the amendment which seek to establish some criteria, we are concerned with the amendment's lack of significant focus on educational leadership as well as its departure from the current licensure system, which is based upon high-quality educational standards. We therefore recommend: 1) Ensuring that any licensure paradigm accepted by this Board is firmly aligned with high-quality educational and instructional leadership standards that do not significantly depart from the current professional standards; 2) Pledging that the development of any alternative pathway be conducted by a deliberative body including stakeholders; . 3) Allowing the recent changes associated with reciprocity for out of state school leaders to take hold as a more moderate approach in the interim; 4) Guaranteeing that the evaluation of staff be conducted by those with actual educational and instructional experience, particularly given recent proposed changes in evaluation; S) Developing a true pilot of a very limited number of districts to allow for comprehensive monitoring of candidates and review of the program; 6) Conducting a comprehensive and independent review of the districts involved in the pilot. A Licensure System Grounded In Educational and Instructional Leadership Standards NJPSA firmly believes that New Jersey should not depart from its current licensure standards because they address the needs of strong educational leaders at all stages of their professional careers. We believe that any significant departure would erode the quality of educational and instructional leaders at the helms of our schools and risk impacting student learning and achievement. NJ Expedited Certification for Educational Leadership (NJ EXCEL) is an innovative state approved program that provides alternatives to the traditional graduate coursework required for school administrator certification, among other titles. The program design, curriculum, and assessments are aligned with the New Jersey Standards for School Leaders. The program is grounded in the need to prepare visionary school leaders as agents of change and improvement, as well as ensuring they are educational leaders who guide and support student achievement and effective teaching. Individuals participate in classroom instruction, supervised job-embedded experiences, and field based clinical experiences. But, the program also recognizes the need for educational mastery via an advanced degree as well as real-world experience in a school setting. While we are open to widening the pools of candidates, a quality framework must serve as the spine to any such policy changes. Therefore, any alternative pathway to certification must be as rigorous, and grounded in the same professional standards, as those achieving certification via "traditional" means. We appreciate the recent revision that would require this class of provisional superintendents to complete the same residency as all other provisional superintendents and pass the same test as all other candidates. But, the amendments as drafted, fail to provide an adequate immersion in educational and instructional leadership to ensure success. Recommendations NJPSA recommends that rather than a simple review by the Commissioner of a candidate's credentials against a non-weighted set of criteria, the Department develop a comprehensive rubric from which to 31Page - evaluate the credentials and skills of potential candidates, consistent with current licensure requirements, to establish an alternative multi-year pathway which would include: . Instruction in areas that a candidate may not have experience in such as curriculum, instruction, effective teaching practices, and academic coaching; . Supervised job-embedded experiences; Field based clinical opportunities. . Because candidates would likely lack exposure or experience in teaching and learning as well as educational and instructional leadership, the alternative pathway would immerse candidates in these topics before they entered a district to ensure success. This could be included within the 150 hours of school-based internship required for those seeking a provisional certificate currently. In addition, the pathway would recognize the need for advanced education beyond a bachelor's degree (as currently required of candidates) and include a rigorous residencyjmentorship with performance appraisals and review prior to a determination of whether to grant a provisional certificate holder a standard certificate by a highly qualified mentor. Educational mastery sets an important example for other district personnel as we strive to make our schools stronger. An individual who serves as counsel to a defendant in court, or assesses what certain symptoms mean in a patient in a hospital are required to attain advanced knowledge and skills. Why would the profession of education be any different? We also recommend that individuals be required to participate in a two-year residencyjmentoring program to ensure they receive the support and mentoring they need to succeed. Such a program should include regular, possibly monthly, inquiry groups which examine current challenges in educational j instructional leadership via real world scenarios. A two year mentorship is already required for teachers and school principals. Any developed pathway must recognize the need for advanced education, as well as exposure to, and experience with, education, students and schools. Finally, mentors would continue to retain the authority to recommend, or not recommend certification, and any recommendation would carry a presumption of validity, absent evidence by the candidate to the contrary. Such a change would require the current criteria for mentors be reviewed and potentially amended. Moreover, the qualifications of mentors would need to be considered carefully when matching candidates to mentors. While individuals coming from outside education may possess the administrative skills necessary to run the operational aspects of a district, they will likely lack the educational leadership expertise to drive student achievement. Rather than a one year residencyjmentoring program for individuals considering accepting the challenge of serving as the educational leader in a district, consider a comprehensive alternative pathway to certification, consistent with current professional standards, which pr~vides them the requisite tools to complete the toolbox they need to effectively lead a district before, during and after their inaugural year within a district. Comprehensive Development by a Deliberative Body To ensure the success of such a goal, the Department must have buy-in from the educational community as well as the community at large. The Department seeks to establish a new category of leader in schools. Such a significant change requires public input, stakeholder participation, and a research review of what our 41Page -- -- --- neighbor states are doing, culminating a complete record from which to decide whether to pursue such a dramatic policy change. A public body, such as this State Board, or even the legislature, are entities that could accomplish a thorough review and implementation of such a sea change in the area of certification. While the Department sees the legislative process as "unpredictable and lengthy" it could be characterized as "deliberate and comprehensive". Regardless, a public body should ensure a true public vetting and deliberate review of this policy change, prior to introduction of this regulation, and at the end of the pilot. This regulatory change could have long standing implications for New Jersey's students and deserves a comprehensive and deliberate review. Allowing Reciprocity Changes To Fill the Gap Recent proposed amendments to N.J.A.C. 6A:14 would allow increased reciprocity for out of state educational professionals, permitting New Jersey access to invaluable experienced staff. These changes are not yet finalized and their impact is unknown. Prior to considering such a dramatic change in certification for chief school administrators consider what impact the reciprocity change will have to our pool of candidates. At a minimum, this change should allow for a more comprehensive and deliberate development of an alternative pathway to certification as outlined above. Evaluating Staff Assisting in the evaluation of staff where candidates lack educational and instructional leadership backgrounds, or exposure to teaching and learning, will be essential to the success of the program. Particularly with significant changes in educator evaluation on the horizon which tie property rights, such as tenure retention, to a successful evaluation, individuals lacking a background in instructional leadership will have difficulty coaching, directing and evaluating staff absent instruction and experience. Further, they will struggle in being able to adequately evaluate the success of staff in providing good teaching and supporting student learning absent experience. In order to avoid potential conflict, the Department should consider adding language to the amendment that would require candidates lacking educational and instructional leadership experience to delegate evaluative authority to another individual within the district possessing such experience and adequate credentials to complete staff evaluations. A True Pilot The Department acknowledges that over SO districts, or more than 10 percent of districts statewide, would be eligible to utilize this process to choose their school leader. Without changes at the federal level, that number will likely grow as we approach 2014 (the year in which all districts must ensure that all students are 100 percent proficient under No Child left Behind). A true pilot is discrete in scope so as to ensure that it can be monitored and that a comprehensive review of the impact of a change can be conducted. The population of districts implicated by this change is simply too large to ensure appropriate monitoring and a true analysis. The Department should limit the scope of the pilot to state takeover districts. This will ensure that adequate support systems are in place in all districts within the pilot to guarantee proper review and evaluation by appropriate State personnel of provisional certificate holders during the residency period. Comprehensive & Independent Review of the Program Finally, in order to accurately assess the benefits or detriments of such a policy change, a comprehensive and independent review process of the districts involved must be conducted. 51Page NJPSA thanks you for the opportunity to share our concerns with you about this proposal. We look forward to working with the State Board and the Department on this, and other, policy changes. Submitted by: Jennifer Keyes-Maloney, Esq., NJPSA Assistant Director of Government Relations 61Page -- -- -