Wisconsin Department of Public Instruction STATEMENT OF SCOPE FOR ADMINISTRATIVE RULES | LEGISLATIVE POLICY & OUTREACH TEAM ATTN: CARL BRYAN 266-3275 or adminrules@dpi.wi.gov |
GENERAL INFORMATION |
Rule No. PI 34 | Relating to Creating a pre-student teaching school setting exception for the speech-language pathologist license | 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). Wisconsin school districts face a severe shortage of speech-language pathologists. The American Speech-Language-Hearing Association (ASHA) requires school-based speech-language pathologists who supervise student teachers to maintain their ASHA Certificate of Clinical Competence (CCC). However, to find qualified supervisors in the schools for pre-student teaching placements, individuals must hold a CCC and a DPI-issued tier II or higher license, which has become a barrier for preparation. An emergency rule is therefore needed to provide additional avenues for students to complete the pre-student teaching portion of their clinical program, in compliance with ASHA requirements. Additionally, a permanent rule cannot be established in time for the current school year, making it necessary for the emergency rule to remain in effect until the permanent rule can be completed. |
2. A description of the objective of the proposed rule. The purpose of the proposed rule is to provide flexibility for individuals completing an educator preparation program leading to a speech-language pathologist license under s. PI 34.0475, Wis. Stats., to allow students to complete their pre-student teaching experience in alignment with ASHA requirements. |
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 rules governing the licensure of school personnel, including speech-language pathologists who may be authorized by holding a tier II, 3-year renewable license issued by the department. In order to receive a license to work as a speech-language pathologist, an individual completing an approved clinical program in speech-language pathology, including pre-student teaching in a school setting, and meet all content and pedagogical knowledge requirements under s. PI 34.021 (1) (c) and (d), Wis. Admin. Code. According to ASHA requirements for obtaining a CCC in Speech-Language Pathology, the student must complete a minimum of 375 supervised clinical practice hours that must span a variety of settings, including diverse experiences across various age groups and disorders to ensure broad preparation. This standard is separate from current pre-student teaching requirements under ch. PI 34, Wis. Admin. Code, which provide that each student shall having pre-student teaching clinical experiences that occur in a variety of school settings. In order to provide options for preparation programs looking to align ASHA and DPI requirements, a rule change is needed so students may complete their pre-student teaching experiences in alignment with ASHA requirements. Without a rule change, the department would be required to implement ch. PI 34, Wis. Admin. Code, as the rules currently exist, and individuals seeking a license to work as a speech-language pathologist would be required to meet pre-student teaching experience requirements as laid out in the current rule. |
4. The statutory authority for the proposed rule. Under s. 115.28 (7) (c), Wis. Stats., the state superintendent has the authority to license and make rules for the examination and licensing of persons, including teachers, employed to provide publicly funded special education and related services, including speech-language pathology services as provided under s. 115.76 (14) (a) 1., Wis. Stats. |
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. The proposed rule could impact educator preparation programs, school districts, educators, and professional organizations representing educators. |
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 300.34 (a) of the Individuals with Disabilities Education Act regulations includes speech-language pathology services as a related service with respect to educating a child who has a speech or language impairment. Under the 34 C.F.R. s. 300.34 (c) (15), speech-language pathology services include the identification of children with speech or language impairments, diagnosis and appraisal of specific speech or language impairments, referral for medical or other professional attention necessary for the habilitation of speech or language impairments, provision of speech and language services for the habilitation or prevention of communicative impairments and counseling and guidance of parents, children, and teachers regarding speech and language impairments. 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 licensure of speech-language pathologists as a related service. As such, states are permitted to choose how to license speech-language pathologists who provide services to children with an individualized education plan. |
