NEPC Review Finds Proposed Federal Regulations Likely to Harm Education

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Scholar concludes mandates unsupported by evidence impose needless costs on teacher education, are likely to choke off entry into teaching, and could discourage recruiting teachers for students with the greatest need

Recently proposed federal regulations that would impose new mandates on teacher education programs are likely to harm, rather than help, efforts to improve educational outcomes, according to a new review published today.

The draft regulations were reviewed for the Think Twice think tank review project by Kevin K. Kumashiro, dean of the School of Education at the University of San Francisco. The review is published by the National Education Policy Center, housed at the University of Colorado Boulder School of Education.

Dr. Kumashiro is the award-winning author or editor of 10 books on education and social justice, including Bad Teacher!: How Blaming Teachers Distorts the Bigger Picture.

Kumashiro examined the proposed new Teacher Preparation Regulations, issued under Title II of the Higher Education Act, that the U.S. Department of Education released in the Federal Register on December 3, 2014. The education department has set a deadline of Feb. 2, 2015, for public comments on the regulations.

The draft proposal, Kumashiro explains in his review, enumerates a series of regulations that would be mandated by the federal government but would be enforced by the individual states. The regulations would require states to assess all teacher preparation programs annually and to rate them as “exceptional,” “effective,” “at-risk,” or “low-performing,” based in large part on a test-based accountability approach that would attribute gains in student test scores to teachers and then attribute those teachers’ “scores” to the teacher education programs they attended.

The regulations also would require states to provide technical assistance to programs rated “low-performing,” and those programs would risk losing state approval, state funding, and federal financial aid for their students.

In his review, Kumashiro points to a series of “vital policy concerns” raised by the proposed regulations. They include:

  •     They underestimate the cost and burden of implementing them, which Kumashiro says would be not only “quite high,” but also “unnecessary.”
  •     With no foundation in evidence, they blame individual teachers – rather than root systemic causes – for the gap separating educational outcomes of affluent and white students from those of economically disadvantaged students and those belonging to racial minority groups.
  •     They rely on an “improperly narrow” definition of what it means for teachers to be ready to teach.
  •     They bank on test-based accountability and value-added measurement of teachers in analyzing data about teacher performance – even though those measures and tools have been “scientifically discredited.”
  •     They are premised on inaccurate explanations for the causes of student achievement and underachievement, and as a consequence will discourage teachers from working in high-needs schools.
  •     They will likely limit access to the teaching profession, especially for prospective teachers of color and from lower-income backgrounds, by choking off federal financial aid.

Finally, Kumashiro warns, the proposed regulations are rooted in “an unwarranted, narrow, and harmful view of the very purposes of education.”

Find Kevin K. Kumashiro’s review on the NEPC website at:

Find the draft regulations from the U.S. Department of Education on the web at:

The Think Twice think tank review project ( of the National Education Policy Center (NEPC) provides the public, policymakers, and the press with timely, academically sound reviews of selected publications. NEPC is housed at the University of Colorado Boulder School of Education. The Think Twice think tank review project is made possible in part by support provided by the Great Lakes Center for Education Research and Practice.

The mission of the National Education Policy Center is to produce and disseminate high-quality, peer-reviewed research to inform education policy discussions. We are guided by the belief that the democratic governance of public education is strengthened when policies are based on sound evidence. For more information on the NEPC, please visit

This review is also found on the GLC website at

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William J. Mathis

Kevin K. Kumashiro,

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National Education Policy Center (NEPC)
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