Wisconsin Department of Public Instruction
STATEMENT OF SCOPE
FOR ADMINISTRATIVE RULES
POLICY, BUDGET & RESEARCH TEAM
ATTN: ERIN FATH
266-2804 or adminrules@dpi.wi.gov
GENERAL INFORMATION
Rule No.
PI 34
Relating to
Educator preparation program and licensing revisions
Rule Type
Permanent and Emergency
SIGNATURE
State Superintendent Review
Approved. Begin Drafting Rule
Disapproved. Reason for Disapproval
State Superintendent Signature
Date Signed Mo./Day/Yr.
NARRATIVE
1.   Finding/nature of the emergency (Emergency Rule only).
Chapter PI 34 of the Wisconsin Administrative Code contains the current rules governing the licensure of school personnel, including completion standards for each educator preparation program as a condition for teaching in a Wisconsin school district. Educator preparation programs have been struggling to find placements for pre-service and student teachers, which can impact the ability of school districts to hire adequately trained school personnel. The department has identified the need for emergency changes to ch. PI 34 for educator preparation programs to help school districts in the state address school staffing needs. These changes expand the ability of educator preparation programs to make pre-service and student teaching clinical experiences more widely available, especially in rural parts of the state. The proposed emergency rule also provides the ability for university supervisors to use in-person or virtual observations to allow for student teaching placements that are remote from the preparation program. A permanent rule would help educator preparation programs to find placements for pre-service and student teachers in time for the 2022-23 school year. However, an emergency rule would create additional flexibility for educator preparation programs to address teacher education requirements for the upcoming school year while a permanent rule completes the promulgation process.
2.   A description of the objective of the proposed rule.
The proposed rule amends ch. PI 34 to provide educator preparation programs the flexibility to address student teaching requirements in the clinical programs they offer. Under this proposed rule, a teaching candidate’s pre-student teaching requirements may be completed in a variety of settings related to effective instruction, safe and supported students, family and community engagement, or building meaningful relationships with students in prekindergarten through grade 12. The proposed rule will also provide that a teaching candidate’s student teaching may also occur in alignment with the cooperating school’s current plan for teaching and learning, which may include face-to-face, virtual, hybrid, synchronous, or asynchronous settings, and shall be for full school days for a full semester of the cooperating school or its equivalent as approved by the state superintendent. Finally, the proposed rule creates flexibility by allowing cooperating teachers, who would otherwise not meet current rule experience requirements, to be assigned if they have been recommended by their principal and deemed acceptable by the approved program.
3.   A description of the existing policies and new policies included in the proposed rule and an analysis of policy alternatives.
Chapter PI 34 of the Wisconsin Administrative Code contains the current rules governing the licensure of school personnel, including rules around completion standards for each educator preparation program as a condition for receiving educator licensure. Since the rules were rewritten in August 2018, the department has identified flexibilities in ch. PI 34 for educator preparation programs to help school districts in the state address school staffing needs. Under current rule, each student shall have onsite, supervised pre-student teaching clinical experiences which meet the following: 1) are developmental in scope and sequence; 2) occur in a variety of school settings; 3) result in the student being able to demonstrate knowledge and understanding of the standards under s. PI 34.002, as demonstrated by the assessments required under s. PI 34.021; and 4) evaluates each student's performance by using at least 2 written evaluations based upon observations by the cooperating teacher or the program supervisor, whereby the written evaluations shall be kept as part of the student file required under s. PI 34.016 (3) (b). The proposed rule under this statement of scope provides that a teaching candidate’s pre-student teaching requirements may be completed in a variety of education-related settings. Observations may include recorded instruction, reviews of lesson plans, and teaching materials that include reflections by students about what went well with the teaching and learning events and how they would improve them next time.
Further, ch. PI 34 provides that for educator preparation programs leading to a teaching license, each student shall have student teaching experience which meets all of the following requirements: 1) is developmental in scope and sequence; 2) occurs in school settings; 3) meets the statutory requirements under s. 118.19 (3) (a), Stats.; 4) provides the student opportunities to interact with and adapt instruction for children with disabilities; 5) assigns the student a cooperating teacher or team of cooperating teachers; 6) is the duration for full school days for a full semester of the cooperating school, for educator preparation programs leading to the student's first license, or for a duration determined by the educator preparation program to be necessary for the student to gain the necessary clinical experience for the additional license, for educator preparation programs leading to the student obtaining an additional teacher license; 7) results in the student being able to demonstrate greater knowledge and understanding of the standards under s. PI 34.002, as demonstrated by the assessments required under s. PI 34.020; and 8) evaluates each student's performance using a minimum of 3 classroom observations, either in person or real-time virtual, by a program supervisor with relevant teaching experience, and at least 3 written evaluations of each student based upon classroom observations. The proposed rule under this statement of scope additionally provides that a student’s teaching experience may occur in alignment with the cooperating school’s current plan for teaching and learning, which may include face-to-face, virtual, hybrid, synchronous, or asynchronous settings, and shall be for full school days for a full semester of the cooperating school or its equivalent as approved by the state superintendent.
Finally, under current rule, the clinical program may only use cooperating teachers and school-based supervisors who meet all of the following requirements: 1) hold a valid Wisconsin license, or an equivalent license if the clinical program is located outside of Wisconsin; 2) volunteered for an assignment as a cooperating teacher or school-based supervisor; 3) have at least 3 years of teaching experience, including one year of experience at the current place of employment, or at least 3 years of pupil services or administrator experience, including one year of experience at the current place of employment; and 4) have completed training in the supervision of clinical students and the applicable standards under subch. II of ch. PI 34. The proposed rule under this statement of scope allows cooperating teachers who do not meet current experience requirements if they have been recommended by their principal and deemed acceptable by the approved program.

The effect of these changes would increase opportunities for placement in school districts that are farther away from preparation programs. Without a rule change, the department will continue to administer the rules governing educator licensure as they exist in PI 34, meaning teacher preparation programs will be required to meet requirements under the existing rule.
4.   The statutory authority for the proposed rule.
115.28 General duties. The state superintendent shall:
(7) Licensing of teachers.
(a) License all teachers for the public schools of the state; make rules establishing standards of attainment and procedures for the examination and licensing of teachers within the limits prescribed in ss. 118.19 (2) and (3), 118.191, 118.192, 118.193, 118.194, and 118.195; prescribe by rule standards, requirements, and procedures for the approval of teacher preparatory programs leading to licensure, including a requirement that, beginning on July 1, 2012, and annually thereafter, each teacher preparatory program located in this state shall submit to the department a list of individuals who have completed the program and who have been recommended by the program for licensure under this subsection, together with each individual's date of program completion, from each term or semester of the program's most recently completed academic year; file in the state superintendent's office all papers relating to state teachers' licenses; and register each such license.
5.   An estimate of the amount of time agency employees will spend developing the proposed rule and of other resources needed to develop the rule.
The amount of time needed for rule development by Department staff and the amount of other resources necessary are indeterminate.
6.   A description of all of the entities that will be affected by the proposed rule.
This rule change would impact educator preparation programs and individuals seeking an educator license under s. 115.28 (7) (a), Stats.
7.   A summary and preliminary comparison of any existing or proposed federal regulation that addresses or is intended to address the activities to be regulated by the proposed rule.
Section 300.156 of the Individuals with Disabilities Education Act requires state education agencies to establish and maintain qualifications to ensure that special education personnel are appropriately and adequately prepared and trained, including that those personnel have the content knowledge and skills to serve children with disabilities. However, because education in the United States is typically governed by each state and local government, the Act does not address how states administer the preparation and licensure of teachers.
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