Counting Teacher Licenses: An Exegesis on Bureaucracy

An earlier post discussed the remarkably large number of unlicensed teachers in Richmond as reported in the 2018 USDoE Civil Rights Data Collection.

An email from the RPS Chief of Staff (added to that earlier post) responded that only four of about 2,100 Richmond teachers now are unlicensed, unless you also count 38 whose paperwork is hanging at VDOE because of COVID-related backups.

If true, that would show an astounding improvement in just three years. Unfortunately, it was not true, at least in the sense of the federal data.

The Feds count (pdf: “crdc-school-form”) as unlicensed all teachers

who did not meet all state licensing/certification requirements). Teachers working toward certification by way of alternative routes, or teachers with an emergency, temporary, or provisional credential are not considered to have met state requirements.

The Virginia regulation provides:

The Provisional License is a nonrenewable license valid for a period not to exceed three years issued to an individual who has allowable deficiencies for full licensure as set forth in this chapter. The Provisional License will be issued for a three-year validity period, with the exceptions of the Provisional (Career Switcher) License that will initially be issued for a one-year validity period and the Provisional Teach For America License issued for a two year validity period. Individuals shall complete all requirements for licensure, including passing all licensure assessments, for a renewable license within the validity period of the Provisional License.

But the Chief of Staff said in an email,

Provisionally licensed teachers count as licensed teachers by the VDOE (that was part of the business rules I had initially inquired on).  So that is not the same as the 4 or the 38 I referenced.

So, of course, the RPS numbers can be vastly different from the CRDC data because of VDOE’s and Richmond’s view of what “licensed” means.

We can get some insight into the difference by looking at the 2020 “School Quality Profile” (the only year available) on the VDOE Web site. There we see numbers of provisionally licensed teachers in RPS and the state:


That 2020 state number is 1.9 times the 2018 federal number of unlicensed teachers, while the 2020 Richmond value is 0.68 as large as that 2018 federal number.


To try to make some sense of the two approaches, we might consider the bureaucratic imperatives:

  • Federal: Grow the budget by finding “problems” that can be palliated with federal money. Thus, count all teachers who are not fully and finally licensed.
  • State: Have it both ways – look good (everybody licensed!) but show the need for more money (lots of provisional licenses). Thus, encourage Richmond to count the provisional licenses (in a sense, the learners’ permits) as licenses but also provide provisional license data for the division to use when talking to legislators.

See also the 2020 Annual Report of the Board of Education at pp. 20-21:

Like much of the nation, Virginia continues to face a shortage of quality educators entering and remaining in Virginia’s public schools. This decline is correlated with low teacher salaries and lack of commitment to tap financial resources to correct this crucial situation. Teacher vacancies are found in every region of the Commonwealth, but are not distributed evenly. The number of unfilled positions increased from 440 during the 2010-2011 school year to a height of 1,081 in the 2016-2017 school year, then dropped slightly in the 2017-2018 and 2018-2019 school year. In the 2019-2020 school year, the number went up to 1,063 (Chart II). The percent of provisionally licensed and inexperienced teachers has similarly climbed. This shortage has reached emergency levels in many high poverty school divisions that do not have the resources to compete with other school divisions

Make what you will of this. I think it speaks to the need to provide complete and detailed data to the taxpayers who are funding the education establishment.  For a start, RPS might pony up the complete counts for all classifications of its teachers, licensed vel non, for 2018-2020, so we can see what their situation really is.