Provisional and Emergency Licensure:
California
Hiring Policy
Analysis of California's policies
Emergency License(s) Availability: California allows individuals to teach on either a Provisional Internship Permit (PIP) or a Short-Term Staff Permit (STSP). Both permits require a bachelor's degree, basic skills requirement, and applicable coursework requirements.
The PIP is available at the request of an employing agency to "fill an immediate staffing need." The employing agency's request for a PIP must verify "a diligent search has been conducted for a suitable credentialed teacher or suitable qualified intern teacher."
The STSP is also only available at the request of an employment agency to fill an acute staffing need. Examples of an acute staffing need include:
- "An individual needs additional time to complete pre-service requirements for enrollment into a Commission-approved intern program
- Enrollment adjustments require the addition of another teacher
- An individual is unable to enroll in a Commission-approved intern program due to timelines, lack of space in the program, or needs to complete NCLB core area subject matter (for education specialist permit)
- The unavailability of a third-year extension or withdrawal from an intern program
- The teacher of record is unable to finish the school year due to approved leave/illness"
Emergency License Validity Period: The PIP is valid for one year and only those permits issued prior to 2013 are renewable for one additional year. In order to issue a PIP, one of the requirements of the employing agency is to "assist the permit holder in meeting subject matter competence related to the permit." California no longer reissues a PIP in specialized science content areas.
The STSP expires at the end of the employing agency's school year and cannot be issued for more than one year. It is not renewable and is available to an individual only once in a lifetime.
COVID-19 State Policy: California has implemented the following changes to its rules regarding Provisional and Emergency Licensure. The Commission on Teacher Credentialing approved the use of Program Sponsor Variable Term Waivers (PS-VTW) for candidates that are unable to meet one or more program requirements. Program sponsors must submit the waiver requests. If, at the end of the one-year waiver term, a candidate has not finished all remaining requirements for a preliminary credential, it is possible to request a secondary PS-VTW through their preparation program. Although candidates who have not passed the RICA can apply for the PS-VTW, it is unclear whether candidates who have not passed a CSET test for preliminary credential requirements can apply for the PS- VTW. COVID-19 policies do not affect the state's grade in Provisional and Emergency Licensure.
Requirements for Out-of-State Teachers: Because licensure requirements for out-of-state teachers are scored in Requirements for Out-of-State Teachers, only the state's policies regarding emergency/provisional license(s) are considered as part of this goal.
Recommendations for California
Award standard licenses to teachers only after they have passed a subject-matter test.
All students are entitled to teachers who know the subject matter they are teaching. Permitting individuals who have not yet passed state licensing tests to teach neglects the needs of students, because it enables adults who may not be able to meet minimal state standards to earn teaching licenses. Licensing tests are an important minimum benchmark in the profession, and by not requiring such a test, California is abandoning one of the basic responsibilities of licensure. As such, in order to avoid putting students at risk, the state should require all teachers to pass subject-matter tests prior to entering the classroom as the teacher of record.
State response to our analysis
California asserted that it is not accurate that the state does not require passage of content tests as a condition of initial licensure. Regarding the proposed goal factors California asked, "What is the evidentiary basis for this policy's qualifying phrase, 'under any circumstances?'" For example, what if a local educational agency has had a vacancy in high school chemistry for six months and have demonstrated robust efforts to recruit? The state also asked for clarification on the definition of a license and asked whether substitute licenses are considered to be a license for this goal.
Updated: March 2021
Last word
California offers three methods for demonstrating content knowledge for an initial license, one of which is passage of a content test. Therefore content tests are not required for an initial license as candidates have other options available. The grading rationale for this goal indicates "If the state finds it necessary to confer emergency or provisional licenses to teachers who have not passed the required licensing tests, should do so only under limited and exceptional circumstances and ensure that all requirements are met within one year." The situation cited in California's response would be a "limited and exceptional circumstances." NCTQ understands that situations arise when a fully licensed teacher is not available, but advocates for states to maintain policies that ensure emergency or provisionally licensed teachers have adequate content knowledge for the subjects they will be teaching. Additionally, California is invited to review the research rationale for this goal for the evidentiary basis regarding the impacts teachers with in-depth content knowledge have on student learning. A link to the research rationale is provided below. Substitute licenses are not considered as part of this goal.
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How we graded
6B: Provisional and Emergency Licensure
- Content knowledge: The state:
- Should not, under any circumstance, award a license to a teacher who has not passed all required content licensing tests.
- If it finds it necessary to confer emergency or provisional licenses to teachers who have not passed the required licensing tests, should do so only under limited and exceptional circumstances and ensure that all requirements are met within one year.
The total goal score is earned based on the following:
- Full credit: The state will earn full credit if all new teachers are required to pass each required content test as a condition of receiving provisional or emergency licensure, or the state does not issue emergency or provisional licenses. A state cannot get full credit in this goal if content tests are not required as part of its initial licensure policy.
- Three-quarters credit: The state will earn three-quarters of a point if it grants emergency or provisional licenses to teachers who have not passed the required content tests, but such licenses are granted for no more than one year and are not renewable. OR The state will earn three-quarters of a point if it grants an emergency or provisional license to a licensed teacher to teach out-of-field for no more than one-year without passing the applicable content test.
- One-half credit: The state will earn up to one-half of a point if it allows for emergency or provisional licenses to be granted for longer than one year, but the state has strong requirements for applicants (e.g., content area major or preparation program completion without requiring a content test). The state will also earn one-half of a point if the state does not issue emergency/provisional licenses, or issues emergency/provisional licenses with strong requirements, but content tests are not required as part of the state's overall initial licensure policy.
- One-quarter credit: The state will earn one-quarter of a point if it maintains minimum requirements that fall short of the requirements listed above or only offers emergency or provisional licenses to teachers under "extenuating circumstances."
Research rationale
Teachers who have not passed content licensing tests place students at risk. While states may need a regulatory basis for filling classroom positions with a few people who do not hold full teaching credentials, many of the regulations permitting this put the instructional needs of children at risk, often year after year.[1] For example, schools can make liberal use of provisional certificates or waivers provided by the state if they fill classroom positions with instructors who have completed a teacher preparation program but have not passed their state licensing tests. These allowances are permitted for up to three years in some states. The unfortunate consequence is that students' needs are neglected in an effort to extend personal consideration to adults who cannot meet minimum state standards.[2]
While some flexibility may be necessary because licensing tests are not always administered with the needed frequency, making provisional certificates and waivers available year after year could signal that the state does not put much value on its licensing standards or what they represent. States accordingly need to ensure that all persons given full charge of children's learning are required to pass the relevant licensing tests in their first year of teaching, ideally before they enter the classroom. Licensing tests are an important minimum benchmark in the profession, and states that allow teachers to postpone passing these tests are abandoning one of the basic responsibilities of licensure.
[1] Research often finds a correlation between teachers' content knowledge and their effectiveness. For how this effect can play out in elementary ELA, see: Carlisle, J. F., Correnti, R., Phelps, G., & Zeng, J. (2009). Exploration of the contribution of teachers' knowledge about reading to their students' improvement in reading. Reading and Writing, 22(4), 457-486.; For how this effect can occur in secondary STEM subjects, see: Monk, D. (1994). Subject-area preparation of secondary mathematics and science teachers and student achievement. Economics of Education Review, 13(2), 125-145; For broader information about teacher qualities and student achievement, see: Goldhaber, D. D., & Brewer, D. J. (1997). Why don't schools and teachers seem to matter? Assessing the impact of unobservables on educational productivity. Journal of Human Research, 32(3), 505-523.; National Council on Teacher Quality. (2010). The all-purpose science teacher: An analysis of loopholes in state requirements for high school science teachers. Retrieved from http://www.nctq.org/p/publications/docs/NCTQ_All_Purpose_Science_Teacher.pdf.
[2] Research has shown that "the difference in student performance in a single academic year from having a good as opposed to a bad teacher can be more than one full year of standardized achievement." See: Hanushek, E. A. (1992). The trade-off between child quantity and quality. Journal of Political Economy, 100(1), 84-117.; Hanushek has also found that highly effective teachers can improve future student earnings by more than $400,000, assuming a class size of 20. Hanushek, E. A. (2011). The economic value of higher teacher quality. Economics of Education Review, 30(3), 466-479. Retrieved from http://www.nber.org/papers/w16606