The California Commission on Teacher Credentialing (CTC) on Feb. 12-13 discussed the extension of substitute teaching time limits; revised Teacher Performance Assessment (TPA) standards and the new TPA Pass Rate Identification Framework, among other items.

CTC staff brought back an item from December regarding the veto message by Gov. Gavin Newsom for the 2025 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. The veto directed the commission 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 presented revised recommendations based on feedback from commissioners and stakeholders in the field. The refined proposal is in stark contrast to AB 1224 and would place additional requirements on a substitute teacher before they may serve in the same classroom beyond 30 days. CTC staff proposed the following recommendations:

• Recommendation 1: Expand the 30-Day Substitute Authorization for Credentialed Teachers to allow fully credentialed teachers in substitute assignments to serve up to 60 cumulative instructional days for any one teacher of record in general education classrooms.
• Recommendation 2: Require a substitute to complete 15 hours of pre-service preparation aligned with existing preparation standards in Education Code Section 80022 within the first 30 days of serving in a classroom and then complete another 30 hours within the 60-day permit timeline. This pathway would be in addition to the existing ability for individuals who do not yet meet the Career Substitute Permit’s three-year experience requirement.

Both recommendations place additional mandates on local educational agencies rather than the more responsive requirements included in AB 1224. Whereas AB 1224 would have required LEAs to provide an orientation training and professional development opportunities, the CTC’s proposed regulations mandate a minimum number of pre-service and in-service professional development hours a substitute teacher must complete before serving for more than 30 days in a classroom.

Although staff explained their process of soliciting feedback from “at least 11 different partner groups representing employers, labor unions, state education agencies, equity advocates, disability rights groups and the Legislature,” the proposed regulations were only available for review for six days prior to the CTC adopting the two recommendations. The CTC did not meet with CSBA prior to it publishing the proposed recommendations.

Citing concerns about possible conflict with the federal Individuals with Disabilities Education Act, CTC staff did not recommend expanding the ability of a substitute teacher to serve for more than 20 days in a special education classroom.

The majority of public comment opposed the recommendations due to their exclusion of special education classrooms and the lack of time the public and stakeholders in the field had to review the recommendations.

CSBA Legislative Director Chris Reefe was the only commenter to focus on how these proposed regulations would have a negative effect on small school districts.

“On behalf of the nearly 5,000 school board members who represent nearly a thousand school districts, the vast majority of them are very small. These are sometimes single school-site districts where they’re only allowed to have one administrator on staff,” Reefe said. “That one administrator can also serve as the teacher. They can survive as the transportation director, the special ed director, the facilities director, the high school coach. And so, to expect a small school district administrator to be able to undertake additional administrative tasks to seek out a waiver is placing additional burdens on an already burdened position. This is something that has been a product of our sponsored bill, where we tried to reach agreement on a temporary approach. The proposed regulations are a permanent approach and will create greater disparities across the state, and so we strongly urge the commission to table this for further discussion.

“CSBA, as you’ll notice, wasn’t on the list in terms of organizations that had the opportunity to meet with the CTC. We would continue to encourage that stakeholder engagement be continued and be more thorough and inclusive,” Reefe concluded.

Staff noted this is just the “pre-step” in a six-month to one-year process, with the next step being submitting the regulatory language to the Office of Administrative Law as a public notice.

After lengthy discussion between commissioners, including the need for a meeting of stakeholders in one room so everyone’s perspective is represented, the proposed regulations were moved forward.

Continuing work from last year, proposed revisions to the Performance Assessment Design Standards (PADS) after further refining seven recommendations were approved by the commission.

Any TPA approved by the commission for operational use must first demonstrate its alignment with PADS. Senate Bill 1263 (2024) required the formation of a workgroup to review the design and implementation of teaching performance assessments and related systems.

The recommendations developed from that review, presented to the commission in June 2025, included specific revisions to PADS regarding culturally responsive pedagogy, streamlined assessment structure, flexible assessment design, rubric-aligned feedback, timely technical condition code notification, expanded program materials and administering a standardized candidate experience survey.

Using the recommendations from the workgroup as a guide, staff completed an initial revision of the PADS in fall 2025, adding language to further clarify that tasks must be constructed to build on candidates’ strengths and assets and require candidates to engage in instructional activities that also build on their students’ strengths and assets by centering culturally and linguistically diverse practices and aligning with the Universal Design for Learning principles.

SB 1263 also requires the commission to report the number of teacher preparation programs with low TPA pass rates and to assist those programs in using evidence-based strategies to support candidates to pass the assessment, with such instructional supports provided at no cost to candidates. In response, another item presented a proposed statewide TPA Pass Rate Identification Framework.

The proposed framework, includes recommended performance bands and the use of first-attempt, second-attempt and cumulative pass rate measures. It would also include an annual identification and continuous improvement cycle and describes the respective roles of preparation programs and commission staff in data analysis, planning, support and monitoring.

Commissioners directed staff to return with a refined plan, in the form of draft regulations, for further consideration and/or adoption.