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State board warns updating CTE rules will require funding and careful sequencing, board chair says
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Summary
The Vermont State Board of Education told the House Commerce & Economic Development Committee that modernizing career and technical education rules will require funded pre‑work, counsel and careful sequencing to avoid repeated, costly rule openings. The committee discussed tactical vs. comprehensive updates and possible legislative support.
The Vermont State Board of Education urged the House Commerce & Economic Development Committee on April 16 to fund pre‑rulemaking work and coordinate sequencing before formally opening updates to career and technical education (CTE) rules. Jennifer Jack Samuelson, chair of the State Board, told lawmakers the board is volunteer‑led, has limited staff counsel and that a single rule update can cost about $50,000–$60,000.
"It would be really, really challenging to open a rule and write the rule in live time," Samuelson said, noting the eight‑month APA window for formal rulemaking and the board’s limited capacity. She recommended that the board perform stakeholder pre‑work and prepare drafts before any formal filing to streamline the formal process.
The recommendation responds to draft 2.1 of the committee’s proposed strike‑all amendment to H.313 (technical education), which directs the State Board to update CTE rules and sets a multi‑party working group to explore governance, licensure and transition issues. Legislative counsel walked committee members through the draft’s provisions, including a new requirement that the Agency of Education and the Standards Board for Professional Educators submit a Jan. 15 report on CTE educator endorsement and a proposed pre‑enforcement intervention pathway.
Committee members and witnesses debated whether the statutory direction should require a ‘‘comprehensive’’ update or a more limited, tactical set of rule changes. Jay Ramsey, director of workforce development at the Vermont Department of Labor, suggested limited tactical changes to address pressing operational issues while broader governance work proceeds.
"Could the State Board do some tactical rule changes that address the concerns of CTE directors around transportation and other items while the agency and the general assembly work through the broader processes?" Ramsey asked, urging the Department of Labor be included in the rulemaking process for child‑labor and wage/hour regulatory issues.
Legislative counsel and members discussed pairing the board’s pre‑work with assistance from the Agency of Education to produce an initial draft, then opening the rule series once the working group completes its recommendations. Samuelson said that approach—if funded—would allow the board to incorporate working‑group outcomes and reduce the risk of reopening the series multiple times.
The committee did not take formal action on the bill at the hearing. Members asked staff to coordinate with the Agency of Education and the board on funding options and to clarify the optimal sequencing for updates so CTE centers are not left in operational limbo while broader governance or funding changes are considered.
