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Donald,

This type of industry sounds like a great field for graduate placement. If you have not submitted a variance request before, I suggest you find as qualified a candidate (s) as possible prior to submitting for approval. You could also call the TWC for guidance first. They can't tell you approved/unapproved until they review the variance instructor application but they would likely provide good input.

JP Mehlmann

Would it be necessary to submit a variance if the proposed instructor was a graduate of a college in a foreign country and the the individual's transcripts were either so old they could not be easily verified or the subjects completed were difficult to compare with U.S. subjects?

Gemma,

That is an excellent question. The correct answer would depend on the specific circumstances. If you have an official foreign transcript, I suggest using a reputable document translation service to obtain a documented translation. If your school is not required to submit instructor applications to the TWC CSC, you should consider contacting them for input prior to utilizing the instructor. You could also follow the variance procedures for assurance and documentation that the instructor is competent.

JP Mehlmann

If a potential instructor has answered yes to any question regarding professional conduct or has had a felony, one should submit a letter of explanation and variance for approval. If a potential instructor does not have the minimum required related practical experience, one should submit a variance for approval.

Pam,
Good answer but I am not sure if "yes" answers in the professional conduct section fall in the Variance category. I reviewed the TWC CSC Rules, Section 807.81 - .83, especially page 25(d), and perhaps, instead, this falls under "instructor...shall be of good reputation" which is on page 22(a). There are certain types of crimes that will exclude an instructor from receiving approval regardless of their experience/educational qualifications for the position. I suggest if you have a candidate with a "Yes" answer to any of those professional conduct questions, that you can call your designated contact person at TWC CSC for input prior to submitting the application (with the explanation included).

JP Mehlmann

If a prospective instructor had strong qualities that I was looking for but not enough years of experience to meet TWC's standards, I would ask for a variable allowance. The prospective instructor would have to prove they were worthy of the position.

Ashley,
Yes - and if you've looked at the TWC CSC Instructor Application (PS-002) instructions on page nine, there is documentation required to make your case that the Instructor candidate is otherwise qualified. The following is a portion of those instructions:

Write a letter addressed to Career Schools and Colleges, requesting a variance from current rules which includes:

1. Subject(s) for which the variance is being requested as listed in the school catalog.
2. Current rule requirements in comparison to the applicant’s qualifications. See formatted example below.
3. Statement ensuring that the program quality will not be diminished using the applicant as an instructor and why.
4. Statement by the school director that this instructor applicant has demonstrated sufficient knowledge and skill to teach the subject.
(see PS-002 for the complete requirement).

JP Mehlmann

The key for me is ammount of exceptional experience and/or education the instructor brings to the table. Variance requests should be handled judiciously and be requested when they make good sense.

One possible reason to request an instructor variance would be if the candidate is qualified in all areas but lacks just a few months of the experience requirement. A variance letter would need to be submitted explaining how the instructor compensates for this variance and ensure that the quality of instruction delivered would equal that offered by a fully qualified instructor.

Marcy,
I agree. One challenge with the variance request process is making your case that the instructor will be effective.

JP Mehlmann

Do you know of any school that has exercised this option? My accrediting agency allows for a similar recourse requiring us do develop portfolios for each instructor highlighting their extensive industry experience to include letters from previous employers.

Miguel,
I cannot recall any specific schools that have submitted instructor variance applications. If I did, I don't believe it would be appropriate to list in this forum. The variance process is an option if you believe you have a person who would be an effective teacher but does not meet the stated qualification requirements. Hence, the "variance" process where you would need to somehow demonstrate the person's abilities and that the education provided will be acceptable. Given the state of career education today, and the high unemployment rate, it makes sense to focus on finding instructor candidates who meet or exceed the stated criteria. The variance should be a last resort, or an option for specific career fields where qualified candidates are scarce due to the characteristics of that industry.

JP Mehlmann

The prospective instructor may have the proper education to teach a subject, due to the amount of hours that instructor has to their credit from an accredited university, but does not have an actual certificate of completion for the program they are teaching. If the CSC determines that program quality will not diminish, the CSC may approve a variance for that instructor.

Well,a variance can be submitted when the instructor may not have, let's say, a bachelor's in the area but the Director may feel is still qualified to teach.

Kristina,
Yes, technically speaking, a variance is required for any instructor application where the instructor candidate does not meet the TWC CSC requirements. Any variance should be an exception and not a common practice unless, the characteristics of the specific career field are such that it is difficult to find people who meet the TWC CSC requirements.
JP Mehlmann

For example, a meddical instuctor who does not have a Bachelore's but has certificates and has more than 5 years of expirence in the field.

TWC may approve a variance from the specific
qualifications contained in Section 807.81 of the Rules with
sufficient justification and an assurance of continued
program quality.
To qualify for an Instructor Variance, the applicant must
write a letter to the CSC program manager requesting a
variance from current rules including:
• the subjects for which the variance is requested, as listed
in the school catalog
• the current rule requirements in comparison to the
applicant’s qualifications
• a statement ensuring that the program quality will not be
diminished using the applicant as an instructor and why
• a statement by the school director that the instructor
applicant has demonstrated sufficient knowledge and
skill to teach the subject.
If the instructor has taught the subject(s) for which the
variance has been requested, include:
• student evaluations of the instructor for each subject
taught
• the school director’s evaluation of the applicant’s ability
to communicate knowledge on the subject, instructional
methods used, preparedness for class, interpersonal skills,
and ability to satisfactorily answer the students’
questions.
If the applicant has not taught the subject(s), include:
• a commitment by the school director to submit student
evaluations of the instructor for each subject taught
within three months of approval by variance

Cecilia,

Your answer is very thorough. One way to demonstrate and document the candidate's proficiency is to have them take the final exam(s) for the specific subject(s) for which you seek approval. Are there other methods you can think of to prove their qualifications?
JP Mehlmann

An other method that may offer proof of teaching qualificatins may come from time served or documented hours in the military as an instructor or trainer.

Karina,

Military experience as an instructor can be beneficial if you can document that the experience relates to your courses. Many times, such an instructor candidate also has training certificates from their military experience that may be included in the variance request.
.

JP Mehlmann

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