Changes to PDE's Evaluation of Master's Equivalency Applications
The Pennsylvania Department of Education recently finalized the changes it is making to its review of Master’s Equivalency (MEQ) applications. At issue is PDE’s interpretation of the following longstanding language from Chapter 49, specifically the underlined language:
“The Letter of Equivalency for Master’s Degree is issued to persons holding a valid Instructional I, Instructional II, Educational Specialist I, Educational Specialist II certificate, Vocational Instructional I, Vocational Instructional II certificate, or their equivalents, upon the accumulation of 36 hours of graduate level credit. A minimum of 18 academic graduate credits shall be earned in the content area of the applicant’s primary teaching assignment at a college or university approved to offer graduate work. A maximum of 18 of the credit requirement may be satisfied through in-service programs approved by the Secretary for meeting master’s equivalency requirements.” 22 Pa. Code §49.191(2)
While the above language has been in the certification regulations for many years, the Department used a very liberal interpretation to the extent that approximately 40% of the applications contained credits related to neither the applicant’s certification nor assignment. An example cited is a school nurse’s application that contained 36 credits in Art. That application was approved.
In the late summer/early fall of 2006, PSEA became aware that PDE had changed its practice and was rejecting MEQ applications. PDE began to apply a stricter interpretation of the language and our members complained of the change. Specifically, the Department reduced the latitude regarding what kinds of credits were acceptable. After a number of discussions between PSEA and PDE, PDE realized that the dramatic change without warning was, at best, unfair. PDE subsequently reevaluated the applications and approved those that would have been approved under the old standard.
When Will the Change Take Place?
The Department considers November 1, 2007 as the date by which all teachers in the state have been notified of the change. This notification was accomplished via a Penn*Link on October 25. While this may appear to be short notice, the Department is not using that date in terms of “applications received after...”; but rather “courses taken after” that date. Applications received with all courses taken before November 1, 2007 will be reviewed under the more flexible interpretation. Teachers registering for courses after that date will need to make sure the courses will be applicable under the new interpretation by PDE.
What Will Change?
PDE officials believe the current standard of review is not in compliance with the regulation. To bring its practice in line with the regulations, the Department “will no longer accept graduate credits submitted by an educator that are not in an educator’s certified content area. The Department will permit the required 18 academic graduate credits to be in any certified content area held by the educator rather than in just the content area of the educator’s primary teaching assignment.” In other words, the following apply:
- Realizing that assignments change, sometimes annually, the Department’s review of the credits will be based on the applicant’s certification(s). If there are multiple certifications, the credits can be related to any/all regardless of whether the certification is being used.
- Any applicant can take up to 18 credits of in-service (IU) courses approved by the Secretary, as the regulations clearly state.
- Elementary certified applicants will be expected to take at least 18 credits in content. The remaining 18 credits (of the required 36) may be taken in content and/or pedagogy, methodology, curriculum, or instructional environment related to elementary.
- Secondary certified applicants will be expected to take at least 18 credits in their content area(s). The remaining 18 credits (of the required 36) may be taken in content and/or pedagogy, methodology, curriculum, or instructional environment related to secondary.
- All course credits must be graduate-level or PDE-approved IU credits and completed with a grade of “C” or higher.
- If you are unsure of whether a graduate level course will meet the requirements for “content” credit for your certificate area and current assignment, you are strongly encouraged to submit an official course description from the college/university course catalog of the course in question to the Bureau of School Leadership and Teacher Quality. The course description should include the front of the catalog cover sheet corresponding in year and semester to the course taken.
A question often raised with this issue is “Isn’t this a violation of a past practice?” The answer is no. Past practice is a term used to argue that the prior behavior of one party or the other to a bargained agreement constitutes practice under that agreement; whether the language of the agreement specifies the behavior or not. We are in no such situation with the state. The regulatory language is not bargained language and the behavior of the Department, when found to be out of compliance with the regulations, can be corrected at any time. PSEA was fortunate to procure a delay in the implementation of the correction.
Questions or Concerns
PSEA fully realizes that this change creates some hardship for some of our members. PSEA has worked very hard to ameliorate the impact and, as the language of the regulation is clear, had little latitude with which to work. If you have any questions or concerns, please contact Chris Budano in PSEA’s Education Services Division via email at firstname.lastname@example.org or phone at 1-800-944-7732, Ext. 7028.
Updated January 5, 2011.