The Dec. 11-12 meeting of the California Commission on Teacher Credentialing focused on how to address persistent certificated teacher misassignments, a lengthy discussion on how and when to use substitutes to uphold instructional continuity, and advanced amendments to the Child Development Permit.

The commission reviewed a proposed plan to address recommendations from the California State Auditor’s report on educator misassignments at Highlands Community Charter and Technical Schools. While labeled as “recommendations,” staff said the report mandates the commission to act or formally report lack of progress to both the auditor and the Legislature, and impose sanctions on local educational agencies that misassign educators. The audit emphasized the commission’s role in responding to misassignments statewide and required progress updates at 60 days, six months and one year after the audit’s release.

Staff proposed a non-punitive, mandatory training as the primary sanction for LEAs that exceed a yet-to-be-determined misassignment threshold. The training would target those responsible for educator assignments and focus on credentialing laws, authorization options, correction of misassignments and prevention strategies. Delivery would be through a self-paced, on-demand e-learning system with modular content and knowledge checks, allowing flexibility for LEAs and scalability for the commission.

Staff emphasized that misassignments often result from two factors: statewide teacher shortages — especially in rural and high-need areas — and the complexity of assignment laws. The proposed approach aligns with California’s Statewide System of Support by addressing knowledge gaps rather than imposing punitive penalties. Staff also committed to engaging education partners to ensure thresholds are equitable and do not disproportionately impact shortage-impacted LEAs.

Public comment highlighted concerns about teacher shortages, limited alternatives and suggested expanding training to include board members and administrators. Commissioners ultimately approved the plan, directing staff to incorporate public feedback, engage stakeholders on threshold development and return with more detailed misassignment data before finalizing regulations.

California continues to experience shortages of fully credentialed teachers, with the extent of these shortages varying by region and credential area. These shortages have increased reliance on substitute educators to maintain classroom coverage during extended absences and vacancies, while recruiting for a credentialed teacher.

In the first year of the current two-year legislative session, CSBA co-sponsored Assembly Bill 1224, which proposed to extend pandemic-era flexibilities that allowed substitute teachers to stay in both general education and special education classrooms from 30 days to 60 days. While the bill passed the Legislature, it was vetoed by Gov. Gavin Newsom due to concerns about underprepared substitutes.

A portion of the Governor’s veto message stated: “I recognize the author’s goal of providing more continuity in challenging staffing situations. As such, I encourage the Commission on Teacher Credentialing to utilize its existing authority to engage stakeholders and expeditiously re-examine and amend its short-term staffing pathways to support continuity of instruction, and to address the minimum levels of preparation and support required.”

Staff engaged human resources leaders, educator representatives and student-focused civil rights advocates to better understand challenges related to extended absences and temporary vacancies. Across groups, a consistent picture emerged: LEAs — particularly those in rural or hard-to-staff areas — continue to face persistent vacancies, limited applicant pools and difficulty attracting credentialed teachers despite ongoing recruitment efforts.

LEAs emphasized that the expiration of the temporary 60-day flexibility has intensified operational strain. When absences or vacancies exceed current limits, LEAs are forced to rotate multiple substitutes through the same classroom, a practice described as disruptive to instruction and student stability.

Educator representatives shared concerns about over-reliance on extended substitute placements, noting risks related to instructional quality, preparation and classroom management. Civil rights advocates reinforced these concerns, highlighting that students with disabilities, English learners and students from low-income communities are disproportionately affected by staffing disruptions. They stressed that any expanded flexibility must be paired with clear requirements for preparation, support, transparency and documentation.

Staff presented a set of discussion recommendations intended to create a structured “mid-length” staffing spectrum while preserving fully credentialed teachers as the long-term goal. These include:

• Expanding the 30-Day Substitute Authorization for credentialed teachers to 60 cumulative days;
• Creating an alternate pathway to a 60-Day Career Substitute Permit with defined preservice preparation (15 hours), on-the-job training to meet a 45-hour requirement and LEA support; and
• Establishing a 60-Day Limited Teaching Permit for Vacancies, with 45 hours of preparation required before beginning any 60-day role, including in special education settings, along with LEA support requirements.

Public comment reflected both urgency and concern. County offices, administrators, small districts and education support organizations such as CSBA called the proposed recommendations too restrictive and broadly supported additional flexibility to ensure instructional continuity. Some advocates raised legal and equity concerns, particularly regarding special education and IDEA compliance. Others urged more flexibility in crisis situations or questioned whether the proposals go far enough to meet workforce realities. Several organizations requested continued discussion rather than immediate action.

After much discussion by commissioners, the CTC directed staff to continue exploring the issue and return in February with a more refined proposal that incorporates public and commissioner feedback.

The commission continued work on refining amendments to the Childhood Development Permit, which has not been restructured since 1993. The proposed amendments remove the outdated Child Development Permit Levels and replace them with the new Child Development Permit matrix levels, which were approved at the February meeting.

Importantly, the revised structure retains and honors the expertise of the existing workforce, responding to major feedback from the field. Also presented were the results of a commission field survey conducted between October and November 2025 on the recommendations of the Commission’s Child Development Permit Performance Expectations Field Survey. Respondents overwhelmingly agreed with the performance expectation adjustments and the CTC approved the changes to both the matrix levels and performance expectations.