Is OT/PT services credential needed?
CTC discusses feasibility of OT/PT services credential at February meeting
March 7, 2022
The February meeting of the California Commission on Teacher Credentialing was attended by ACSA CTC Liaison Doug Gephart, who filed the following report.
Over the past five years, several bills have been introduced to add credential requirements for Occupational Therapists and Physical Therapist services. ACSA, for several reasons, opposed this legislation and none of these proposals successfully made it through the legislative process. A summary of these attempts is provided below.
AB 1087 (Irwin, 2017): This bill would have required the Commission on Teacher Credentialing to develop a services credential with a specialization in occupational therapy or physical therapy. The author’s office pulled the bill from consideration in the Assembly Education committee before its first public hearing and the bill died in committee.
AB 2386 (Blanca Rubio, 2018): This bill was initially submitted as a proposal to authorize the commission to design a services credential for OT and PT. The terms of the bill were amended to require the commission to form a workgroup of stakeholders to study whether a credential is warranted and make recommendations to the Legislature, governor, and state superintendent of public instruction. The measure was held under submission by the Assembly Appropriations Committee and died in committee.
AB 2684 (Blanca Rubio, 2020): This bill was a reintroduction of AB 2368 and would have similarly required the commission to convene a workgroup to consider whether the development of a services credential with a specialization in occupational therapy or physical therapy services is warranted. The bill was pulled for lack of support.
To help better understand what need for increased preparation for OTs and PTs exists, commission staff requested input from LEAs on their assessment of the need for additional preparation and credentialing for OTs and PTs. Respondents were also asked if they support adding a credential requirement for individuals serving as OTs and PTs in public schools. Their responses, broken down by type of LEA, are as follows:
  • County office of education, 86 percent opposed
  • Large school districts, 78 percent opposed
  • Medium school districts, 100 percent opposed
  • Small school districts, 90 percent opposed
  • Charter schools, 43 percent opposed
  • School sites, 75 percent opposed
  • State special schools, 100 percent opposed
  • CSEA, 100 percent opposed
Occupational and Physical Therapists complete a rigorous education and training program that leads to a master’s and/or a doctoral degree. Therapists use their education and training to provide existing services to students without a credential and there is no apparent educational need or benefit to students to warrant the additional requirement of earning a credential. Stated rationale from advocates previously identified two key reasons for wanting a credential: 1) a credential would allow individuals to then earn an administrative credential to allow therapists a greater voice on issues involving Occupational and Physical Therapist services; 2) a credential would open the door for therapists to possibly earn a higher salary.
Adding the burden of a credential in addition to current education and training for Occupational and Physical Therapist will add significant time and cost for a credential that will not provide any additional benefit to Occupational and Physical Therapist. Further, the additional requirement will certainly restrict the current pipeline of candidates providing services to students and will be an irreversible requirement for all future Occupational and Physical Therapists. ACSA opposed this action in the Legislature on three previous occasions and does not support the commission taking action to develop a new credential.
In lieu of creating a new credential, commissioners and CTC staff will investigate alternatives that include consideration of modifying existing education code language that restricts Occupational and Physical Therapists from obtaining a credential under the medical services option. The commission believes the best course of action is to pursue changes to statutes that will remove existing restrictions and barriers for future certification.
Proposed Passing Score Standard for dance and theatre CSET
The purpose of standard setting studies is to provide the commission with recommendations, based on the informed judgments of California educators, relevant to the determination of the initial passing standards for the CSET: Dance and CSET: Theatre. The educators on the Standard Setting Panel represented credentialed TK-12 teachers with experience teaching dance and theatre, district-level administrators, and teacher preparation program faculty with experience in dance and theatre who are responsible for the preparation of single subject teachers via the program route. After this extensive training and the simulated test taking, panel members completed the following three rounds of standard setting activities, as described below.
Round One: For each multiple-choice item, the panel members were asked to independently rate the percent of minimally competent beginning teachers whom they think would likely answer the item correctly. For each constructed-response item, members were asked to independently indicate the level of response that would likely be achieved by the minimally competent beginning teacher.
Round Two: The second round moved the panel from individual item ratings to ratings at the section level (i.e., multiple-choice section and constructed-response section). They were asked the number of multiple-choice items that would be answered correctly and the total score points that would likely be achieved on the constructed-response items by the minimally competent beginning teacher. Round Three: Panel members were asked to make final independent recommendations for a passing standard based on the raw score points earned on each section of the test.
The commission directed staff to work with its examinations contractor to conduct additional standard setting workshops after a full year of test administration and return to the commission with a new passing standard recommendation based on the additional information available at that time.
Governor’s proposed 2022-23 CTC budget
The governor has placed a high priority on education funding since taking office that includes preparing, training and recruiting a diverse, expert workforce of administrative, credentialed and classified staff to work in public K-12 schools. This is a critical level of support given current staffing shortages that have been exacerbated by the COVID-19 pandemic. The 2022 Budget Act included $2.9 billion to accelerate the preparation and support the training and retention of well-prepared educators.
New Commission Investment: The commission budget is built with funds from fees from teacher examinations, credential applications, competitive grants and accreditation fees. COVID restrictions severely reduced these funds and placed the commission budget in jeopardy. To offset these budget shortfalls, the governor is proposing an increase of $54.4 million for the commission to build upon multi-year investments to support efforts to enhance schools’ ability to hire qualified teachers and substitutes. This includes:
  • $24 million one-time General Fund allotment to waive certain teacher examination fees.
  • $12 million one-time General Fund allotment to extend the waiver of select credentials fees.
  • $10 million one-time General Fund allotment to support a competitive grant program that provides grants to public and private institutions to develop and implement integrated teacher preparation programs.
  • $5.2 million from the Proposition 98 General Fund and $322,000 from the General Fund to re-establish the Personnel Management Assistance Teams to assist Local Education Agencies in improving hiring and recruitment practices.
  • $1.4 million General Fund expenditure to establish career counselors for prospective educators at the Commission on Teacher Credentialing.
  • $924,000 General Fund expenditure, of which $161,000 is one-time, to support the commission’s administration of multiple grant programs and fee waivers.
  • $900,000 General Fund expenditure for the commission to contract for public outreach to highlight the value and benefits of educational careers in California’s prekindergarten through grade 12 schools.
Extending statute authorizing any holder of a credential or permit issued by the commission to serve in a substitute teaching assignment aligned with their authorization, including for staff vacancies, for up to 60 cumulative days for any one assignment. The Legislature through its budget committees and subcommittees and the Legislative Analyst’s Office will examine the various proposals and will offer recommendations for changes. Commission staff will provide additional updated information as necessary during the spring budget hearings.
Proposed TPA requirement
Education Code establishes the minimum requirements for earning a preliminary multiple or single subject teaching credential, which includes passage of a Teacher Performance Assessment approved by the commission. AB 320 added passage of a TPA to the requirements for earning an Education Specialist Credential, which has raised questions in the educator preparation community regarding whether candidates or teachers seeking both a General Education and an Education Specialist credential or more than one Education Specialist credential would be required to take and pass a TPA in each credential area.
The General Education and Education Specialist TPAs developed by the commission have a common structure that requires candidates to: plan asset-based instruction; adapt it to the learners, content and context in which they are teaching; video record their teaching; reflect on the outcomes of their teaching; and apply their learning about meeting the needs of their students and their own teaching practice to the next lesson. Therefore, it can be argued that candidates who have taken and passed either a general education or an education specialist TPA have learned and applied these fundamental components of instruction and demonstrated their competency of the TPEs measured by the assessment.
Education Code 44320.2, which establishes a TPA as just one component for the recommendation for the preliminary Multiple Subject, Single Subject, and Education Specialist teaching credentials. Requiring only a single TPA would satisfy the performance assessment requirement. The commission directed staff to develop regulations that require educators to pass only a single Teacher Performance Assessment and adopted staff recommendations presented for teachers who hold different credential types and seek an additional teaching credential. Additionally, the commission will amend its prior action specifying which TPA should be taken by candidates seeking multiple credentials simultaneously.
Assessing literacy instruction: Implementation of SB 488
The CTC previously developed the Reading Instruction Competence Assessment in response to the previous version of Education Code sections 44283 and 44283.2. Current candidates have the option of taking and passing either the RICA Written Examination or the RICA Video Performance Assessment. Recent attempts to eliminate the RICA requirement have been aggressively opposed by some student advocacy groups despite the lack of evidence that the RICA requirement has a demonstrated benefit to reading instruction.
In lieu of eliminating RICA, Education Codes 44283 and 44283.2 were amended and Education Code 44259 (b) (4) (A) and (B) were added to require the commission to complete a series of actions related to literacy instruction. These sections of statute, specify that the effective means of teaching literacy and evidence-based means of teaching foundational reading skills are included as part of the minimum requirements for a Multiple Subject credential, Single Subject credential in English, and Education Specialist credentials.
Some of the primary requirements established by SB 488 (Rubio) include:
  • By Sept. 1, 2022, the CTC will ensure that all the requirements regarding the content of teacher preparation in literacy instruction are included in the standards of program quality and effectiveness for the preliminary Multiple Subject, Education Specialist, and Single Subject English Language Arts credentials.
  • By Sept. 1, 2024, commission standards and TPEs for preliminary Multiple Subject, Single Subject English Language Arts, and Education Specialist programs must include satisfactory completion of research-based comprehensive reading instruction; direct, systematic, explicit phonics; and all of the requirements of existing law for the content of teacher preparation in literacy instruction.
  • By July 1, 2025, the commission must develop and implement a literacy instruction performance assessment that assesses all Multiple Subject and Education Specialist candidates for competence in effective means of teaching literacy, including but not limited to evidence-based methods of teaching foundational reading skills aligned to the ELA/ELD framework, Teaching Performance Expectations, and program standards of quality and effectiveness.
Update on the work related to Early Childhood Education
The CTC received $3 million to expend over three years to a) develop a competency-based ECE Teaching Performance Assessment at the teacher level of the Child Development Permit to strengthen preparation and development of the early learning and care workforce, and b) support the development and piloting of a program quality peer review (accreditation) process for preparation leading to the permit.
ECE pilots 1 and 2 update: All 59 pilot institutions of higher education are currently working to implement TPE-aligned curriculum within their coursework and fieldwork/practicum experiences for candidates and are engaging in an initial self-study and analysis regarding the degree to which their current programs and administrative structures meet the commission’s adopted program guidelines.
ECE pilot 3 update: The development process for the assessment and scoring process is moving through a two-year development cycle, including a pilot test and field test with the system planned to be available for full operation the fall of 2023.
ECE pilot 4 update: To date, the ECE Design Team has collaborated to create a performance assessment with three distinct learning cycles. These cycles include Cycle 1, Observing Young Children; Cycle 2, Planning Learning Activities; and Cycle 3, Building Family Partnerships. These cycles focus on key competency areas of observation, intentional instructional planning of developmentally appropriate learning activities, and building positive connections with families.
Early Childhood Education Credentialing Workgroup: In the September 2021 commission agenda item, staff presented a rationale and a proposal to further develop a competency-based system for the ECE workforce providing multiple accessible pathways to an updated Early Childhood Specialist Credential that focuses specifically on grades PK-3. The ECE Workgroup was appointed by the executive director in early December 2021, and the first meeting of the workgroup was held on Dec. 16, 2021. The charge of the ECE Workgroup is to provide recommendations for the commission’s future consideration regarding the requirements for the proposed refocused PK-3 ECE Specialist Credential and the possible pathways for meeting these requirements.
The workgroup is scheduled to meet five times between December 2021 and March 2022, with recommendations from the advisory group expected to be presented to the commission for information at the April 2022 meeting. In addition, the goal is also to bring to the commission in April a set of draft Program Standards, including Teaching Performance Expectations for establishing a refocused and repurposed PK-3 ECE Specialist Credential.
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