Support modifications to the Wisconsin PI-34 educator licensing rule

Wisconsin Reading Coalition E-Alert:

We have sent the following message and attachment to the members of the Joint Committee for Review of Administrative Rules, urging modifications to the proposed PI-34 educator licensing rule that will maintain the integrity of the statutory requirement that all new elementary, special education, and reading teachers, along with reading specialists, pass the Foundations of Reading Test. To see where these modifications fit in, use the most recent version of PI-34, which can be found at

Please contact the committee to express your support of these modifications. Your message will have extra impact if you are a constituent of any of the following committee members. Thank you for your assistance! Your voice is important.

Representative Ballweg (Co-Chair)

Senator Nass (Co-Chair)

Senator LeMahieu

Senator Stroebel

Senator Larson

Senator Wirch

Representative Neylon

Representative Ott

Representative Hebl

Representative Anderson

Memo to the Joint Committee for Review of Administrative Rules

Thank you for putting the PI-34 licensing rule on hold to consider whether modifications should be made. As you know, Wisconsin Reading Coalition is interested in upholding the intent and integrity of the Wisconsin Foundations of Reading Test (FORT) for elementary, special education, and reading teachers, as well as the administrative position of reading specialist. We suggest the attached PI-34 modifications, which we drafted as narrowly as possible to impact only the FORT requirement. You may want to hold final action on PI-34 until the recommendations of the legislative study committee on dyslexia have been received.

In cases where a school district cannot find a fully licensed teacher of reading, we do support a one-year exemption from the FORT via a tier I license. However, we must remember that granting 1400 tier I licenses to individuals who failed the FORT means that approximately 28,000 beginning and struggling readers will have an underqualified teacher for that year. The teachers have that year to get up to speed, but the students don’t get a do-over. Exemption from the FORT for district need is a major concession, as it undoes statutory protection for students. This exemption should be as restrictive as possible, with passage of the FORT required before any license renewal.

We see no reason for PI-34 to allow exemptions from the FORT beyond situations of school district need or where it is statutorily required (e.g., online preparation under 118.197 and certain out-of-state teachers under 118.193). Further exemptions undo statutory protection for students without a compelling, overriding public interest. In promulgating these additional exemptions, DPI is essentially usurping legislative authority.

Ironically, while providing numerous avenues to get around the FORT, PI-34 does nothing to ensure that more individuals will be able to clear the FORT hurdle in the future. Subchapter III of PI-34 provides an opportunity for DPI to exercise its responsibility to set standards for educator preparation program approval, and to implement improvement plans for programs where large numbers of potential teachers are failing the FORT. We hope that the 2018 legislative study committee on dyslexia will put forward draft legislation that addresses this problem, as DPI has not addressed it on its own.

Despite being called “stakeholder revisions,” PI-34 ignores the important stakeholder groups of students and their families. The current draft heavily represents the special interests of school district administrators. In fact, this is what the director of one administrators’ organization said about PI-34: “ . . . you should understand that the rules proposal is not a product of DPI. It resulted from nearly two years of work by critical stakeholders to address the significant workforce issues facing the learning environments for children in Wisconsin’s schools.” Our recent conversations with DPI indicate that they may be amendable to amending the draft document. Undoubtedly, they have been under considerable pressure from school district administrators, judging from the talking points below.


Wisconsin Reading Coalition

Talking Points for School District Administrators with WRC comments:

1. Wisconsin school districts are facing growing school staffing issues including high turnover, fewer applicants for positions, and candidate shortages in a variety of disciplines. With fewer new teachers entering the profession, new approaches to educator recruitment and retention are critical to ensure all children have access to high-quality educators. We are not opposed to an exemption from the FORT in true emergency cases where a district shows it is unable to hire a fully-licensed teacher, but we should not call these individuals high-quality educators. We are opposed to allowing those licenses to be renewed year-after-year without the teacher passing the FORT. A one-year time limit for passing the FORT would be sufficient to help districts meet immediate candidate shortages while working toward having a highly-qualified educator in that classroom.

2. The licensure flexibility afforded under CR17-093 is universally supported by school leaders in their effort to address the growing workforce challenges faced by Wisconsin school districts. This is simply inaccurate. There are school leaders, both superintendents and school board members, who have spoken against exemptions from the FORT.

3. We must also point out that districts are currently operating under these proposed rule changes as part of the current Emergency Rule. These proposals are already making a positive difference in meeting these workforce challenges in districts throughout Wisconsin. This is also inaccurate. The current Emergency Rule is much narrower than the proposed PI-34. It allows 1-year, renewable licenses with a FORT exemption only if the district shows it cannot find a fully-licensed teacher. The PI-34 draft allows any in-state or out-of-state graduate of an educator preparation program to obtain a Tier I license and teach in districts that have not shown shortages.

4. School administrators support all aspects of the proposed rule but, of particular importance are the flexibilities and candidate expanding aspects in the Tier 1 license. This will allow for a much-needed district sponsored pathway to licensure, immediate licensure for out of state candidates, licensing for speech and language pathologists with a Department of Safety and Professional Services license and licensing for individuals coming into a district on an internship or residency status. These are effective, no-cost solutions to a significant workforce need in Wisconsin school districts. We are opposed to district-sponsored and out-of-state pathways to licensure where the candidates do not have to take and pass the same outcome exams required of other educators. There is no reason to hold these programs to a lower standard. District-sponsored pathways to licensure surely come at some cost to the district, which is obligated to provide “appropriate professional development and supervision to assist the applicant in becoming proficient in the license program content guidelines.” They can also come at great cost to beginning and struggling readers if they are taught by someone who has not passed the FORT.

5. Educator licensure is simply a minimum requirement. District leadership is responsible for hiring and developing successful educators, and ultimately determining educator quality based on actual teacher performance and student outcomes. Districts and families should be able to count on licensed applicants having the basic information about reading that they will need to successfully teach all students on day one. This is particularly important in districts that have fewer applicants from which to choose. Leaving educator quality standards to Wisconsin districts over the years produced stagnant reading scores and a declining national ranking. Section 118.19(14) of the statutes was enacted to protect students and provide better outcomes for our society, not to provide ultimate flexibility to local administrators.

6. Reducing the Tier 1 license flexibility in the rule has the potential to impact as many as 2,400 teaching licenses, many of which are FORT-related stipulations. Any portion of these licensees that lose their ability to teach will exacerbate an already troubling workforce challenge and reduce educational opportunities for children. This concern can be met by maintaining a one-year emergency Tier I exception for districts that can show a fully-licensed candidate is not available. Eliminating the continuous renewal option for these licenses and requiring the FORT for district-sponsored pathway and other licenses will help ensure quality educational opportunities for children. The quality of the teachers is just as important as the quantity. Meanwhile, DPI should set appropriate standards in reading for educator preparation programs, and institute improvement plans for institutions that have low passing rates on the FORT. What does it say about Wisconsin that DPI reports there are over 1400 teachers in the classroom under Emergency Rules specifically because they have not passed the FORT? At some point, we need to address the root of the problem if we are to have sufficient numbers of highly-qualified teachers for every beginning or struggling reader.

Suggested Modifications (PDF).

Foundations of Reading: Wisconsin’ only teacher content knowledge requirement…

Compare with MTEL

Mark Seidenberg on Reading:

“Too often, according to Mark Seidenberg’s important, alarming new book, “Language at the Speed of Sight,” Johnny can’t read because schools of education didn’t give Johnny’s teachers the proper tools to show him how”

Madison’s long term, disastrous reading results.

Tony Evers, currently runnng for Governor, has lead the Wisconsin Department of Public Instruction since 2009. I wonder if anyone has addressed Wisconsin achievement challenges vis a vis his DPI record?

An emphasis on adult employment, also Zimman.

Alan Borsuk:

“I didn’t have one phone call, I don’t have one email about this NAEP data. But my phone can ring all day if there’s a fight at a school or can ring all day because a video has gone out about a board meeting. That’s got to change, that’s just got to change. …

“My best day will be when we have an auditorium full of people who are upset because of our student performance and our student achievement and because of the achievement gaps that we have. My question is, where is our community around these issues?