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**Comments on the U.S. Department's Notice of Proposed Rulemaking**

**Provided by the American Association of Colleges for Teacher
Education**

**Docket ID ED-2008-OPE-0001**

*p. 15363 High Need Fields --Proposed 686.2* - AACTE asks that the draft
regulations clarify if all foreign languages count as a high-need field
or just some. For example, would French and Spanish be considered
high-need fields? Would a teacher candidate intending to teach in a K-12
foreign language immersion program be eligible for a TEACH Grant under
the definition of "foreign languages" given in the draft regulations?
AACTE recommends that a K-12 foreign language immersion program be
considered part of the high-need foreign language subject area listed in
the statute and regulations. AACTE also recommends that all foreign
languages be considered high need fields.

*P. 15363 Numeric Equivalent -- Proposed 686.2 --* AACTE is pleased that
the proposed regulations would allow institutions to maintain their
grading structures so long as the institution develops a defensible
comparative scale.

*p. 15363 TEACH Grant eligible Programs: Proposed 686.2 -* AACTE agrees
with the draft regulations that an institution should be able to
designate which of its undergraduate and gradate programs are TEACH
Grant eligible programs/paths. This takes into account that many
institutions do not allow students to major in education (but rather
have them major in a content area while taking education courses that
will lead to certification) and also that there may be semesters where
teacher candidates are not taking any education courses because they
must fulfill institutional and major course requirements. Institutions
of higher education should have the option to determine whether these
first two years will be part of an eligible program.

*p. 15364 Institutional Participation -- Proposed 686.4* -- The
regulations should include that if an institution ceases to participate
in the TEACH Grant program, the TEACH Grant recipients at that
institution are not required to repay any TEACH Grant monies they have
received because it is the institution, not the student, that has
withdrawn from the program.

*p.153653 Eligibility to Receive the Grant -- Proposed 686.11 -* AACTE
is pleased that both the statute and clarifying information in the
regulations provide flexibility in how admissions tests are considered
as part of a student's eligibility for a TEACH Grant. It is appropriate
that the student could score above the 75^th^ percentile of a component
of an admissions test to be eligible for the TEACH Grants. This takes
into consideration tests like the SAT which have more than one
component.

*P.15345 Service Agreement -- Proposed 686.12(d)* -- The statute and the
proposed regulations seems to contradict each other on the issue of
whether a teacher candidate who begins a course of study in a high-need
field can complete the service obligation in that field regardless of
whether it loses its "high need" status during the course of preparation
or during the service obligation. The statute says "yes" (but not
clearly), the regulations say "no". We understand that the House Higher
Education reauthorization bill contains an amendment to the statute that
would clarify the language, but if that amendment does not make it into
the final bill, AACTE recommends that the draft regulations be
re-written to reflect the intention of the statute. The regulations
should allow a student who prepares to teach in a high-need field, as
listed in the statute or included in the Nationwide List for the State,
be able to teach in that field upon completion of his/her course of
study regardless of whether that field is still listed as high-need when
the course of study is completed. Teacher candidates, from the beginning
of their coursework, must decide in which field they will teach so that
they can obtain the necessary content and pedagogical courses necessary
to become certified and designated as "highly qualified".

*p.15372 -- Documenting the Service Obligation -- Proposed 686.40(a)* -
AACTE is pleased that the Department of Education will be responsible
for tracking a TEACH Grant recipient once he or she graduates from the
institution. Institutions do not have the capacity to follow its teacher
candidates into the classroom as candidates can move away from the local
school district and change teaching positions easily. By having the
student submit the annual report directly to the Secretary certifying
his/her teaching in a high-need field in a Title I school, the
Department can readily track compliance with the program.

*p.15338 Calculating and Applying Cohort Default Rates -- Proposed
668.183* - AACTE is pleased that the default rate on the TEACH Grants
will not be included in the institution's cohort default rate

**Question: AACTE would like to pose a few hypothetical questions for
further clarification.** Would a current teacher be eligible for a TEACH
Grant if she is working on a Master's in Curriculum and Development and
then works as a special education teacher during her service obligation?
In other words, does the master's degree have to be in the subject area
that the teacher plans to teach in for his or her service obligation?
Would a current math teacher who wants to get an MBA and then teach math
in a low-income school be eligible for a TEACH Grant? Regulations would
seem to allow for this, but it would be good to clarify that the
eligible TEACH Grant program may not necessarily be in the high-need
field but could contribute significantly to the TEACH Grant recipients
knowledge and instructional capacity in a high-need field.