The state should close loopholes that allow teachers who have not met licensure requirements to continue teaching. This goal was reorganized in 2021.
Emergency License(s) Availability:
Colorado allows new teachers with proof of enrollment in a teacher preparation program to teach on an emergency authorization. These authorizations are issued at the request of the employing school district, when no certified teachers are available.
The state also has a Teacher of Record program, which may be implemented if the district "has determined that there is a critical teacher shortage, and if there are no other qualified, licensed applicants for a vacant position." The teacher of record license, available through this program, is issued to an applicant who:
Colorado Code of Regulations 301-37-3.13; -4.03 Colorado Revised Statute 22-60.5-111(b) and 18.104.22.168.7
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, Colorado 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.
Limit exceptions to one year.
Although suboptimal, there may be limited and exceptional circumstances under which conditional or emergency licenses are necessary. In these instances, it is reasonable for a state to give teachers up to one year to pass required licensing tests. Colorado's current policy puts students at risk by allowing teachers to teach on emergency authorizations and teacher of record licenses for up to three years.
Colorado recognized the factual accuracy of this analysis.
6B: Provisional and Emergency Licensure
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. 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.
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.