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BILL: SB 645 TITLE: State Board of Sign Language Interpreters - Membership and Licensing DATE: February 26, 2026 POSITION: Support with Amendments COMMITTEE: Senate Education, Energy & the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM) and the Maryland Association of Boards of Education (MABE) jointly support Senate Bill 645 with amendments. This bill expands the membership of, and alters the quorum requirements for, the State Board of Sign Language Interpreters (the “Board”); clarifies the Board nomination process under which the Governor can remove members of the Board; alters the date from July, 2024 to December 31, 2026, by which the Board must establish licensing requirements and by which sign language interpreters must meet certain licensing requirements; and adds a requirement for the Board to produce a report providing key information related to sign language interpretation in the state before promulgating regulations.  This joint testimony represents the position of the twenty-four local superintendents and local boards of education — entities who serve and support students and school systems impacted by this legislation and the subsequent regulations the new Board will promulgate. Our goal is to support high-quality interpreting services for students while ensuring that implementation of new licensure requirements does not unintentionally undermine interpreter access or educational continuity.   We represent the expertise of education policy leaders, special education administrators, interpreter providers, and advocates for students who are deaf and hard of hearing, all committed to equitable access and inclusive educational practices. We appreciate the work of the existing Board to elevate standards and safeguard service quality, but we have consistently vocalized our concerns about the Board’s difficulties promulgating regulations, especially for educational interpreters. Our concerns range from very practical operational issues, to legal and systemic challenges for Maryland’s students and schools.   We believe this legislation will ensure that the Board’s representation is broader to include all relevant and affected stakeholders. We greatly appreciate the sponsor’s willingness to create a more suitable framework for this important policymaking Board.  Our requested amendments are outlined below and largely mirror those requested by the other implementing entities - specifically those representing medical, legal, and higher education institutions. The amendments are broadly organized in the following categories/concerns and are briefly described below.  Composition of the Board Enactment Date and other Important Milestones Consumer Choice Provisional Licenses  Other Operational Clarifications  Composition of the Board  Amendment #1  - Add to the Board one additional seat so that key public service areas (medical, legal, educational) can be represented.  We appreciate the increase in board membership and the inclusion of more interpreters, as well as representatives of implementing agencies in education, legal, and medical settings. However, since there are likely to be specialty regulations created in each of these three fields, we request a seat that represents each sector. Strike §9–2411(a)(2)(vi), and replace it with the following:  "THREE SHALL BE AFFILIATED WITH ENTITIES THAT OPERATE AND IMPLEMENT DEAF SERVICES, INCLUDING ONE IN AN EDUCATIONAL SETTING, ONE IN A LEGAL SETTING, AND ONE IN A MEDICAL SETTING"   Enactment Date and other Important Milestones We, too, are anxious to move the important work forward regarding licensure for interpreters. However, we believe some of the target dates in the legislation are unrealistic for the extensive work ahead. Below are five timelines we believe need to be adjusted or included in the bill:  Amendment #2  - Revise the effective date from October 1, 2026 to July 1, 2026. Moving the effective date will reflect the urgency of promulgating these regulations. Amendment #3  - Revise the establishment and publication of licensing requirements from December 31, 2026 to July 1, 2027.  After passage of this legislation, the Governor will be required to seat a new Board. That new Board will in short order promulgate regulations with the appropriate amount of public and stakeholder input; this will require more time than allocated in the bill as written. Amendment #4 - Revise the date by which interpreters need to be licensed from July 1, 2027 to July 1, 2028. This new date more adequately reflects the timeline needed to identify or develop the inevitable assessments for licenses. Based on our extensive experience in obtaining credentials for sign language interpreters in schools, we know there are several practical obstacles. A revised date of licensure requirements will allow for time to communicate the changes in the licensure requirements to practitioners, and to allow interpreters to obtain licensure. The timeline will also allow for LEAs to budget for these changes in licensure requirements. Lastly, a July date will create better conditions for hiring and not disrupt services in the middle of a school year.  Amendment #5  - Add an uncodified section to the bill that reflects the Legislature’s intent and prevents any proposed regulations from being published in the Maryland Register prior to the bill’s effective date.  Such an amendment will ensure that regulations resulting from this bill reflect the final policy framework enacted by the General Assembly and are developed through a deliberate process consistent with the updated statute.     Amendment #6 -   Require the Board to first promulgate regulations for a General and Provisional License before moving to any speciality areas. This prioritization recognizes the barriers to both promulgating regulations for multiple licenses at one time, but also some of the practical impediments for national assessments for speciality areas. For instance, the most commonly recognized educational assessment, the EIPA, requires interpreters to pass written and performance tests. However, both of these tests are only offered in two locations in Maryland, are costly to access, and are often booked well in advance. For the EIPA performance test specifically, results often take 10 to 12 months or longer to be returned, and unsuccessful candidates are required to wait an additional year after taking their test before retesting. This set of obstacles alone creates a near impossibility for interpreters not already certified to work by the deadline written in the current bill.  A longer phase-in period does not diminish the high standards contemplated, but enables the standards to be implemented with fairness, integrity, and in a sustainable way.   Provisional Licenses As discussed above, Amendment #6 would require the Board to first promulgate regulations for a General and Provisional License before moving to any speciality areas. We believe this will allow for a smoother transition from this unlicensed field. School systems will work diligently to ensure all interpreters are fully licensed but the practical implications of hiring and onboarding new staff will require a phased in approach.  A provisional license is integral to allow interpreters who are in pursuit of licensure to serve students and will also help attract new interpreters to the field.  A more adaptable approach to licensure entry is likely necessary to ensure that well-qualified interpreters are not excluded by outdated standards or procedural bottlenecks. This is a well-established practice in school systems with conditionally certified teachers and paraprofessionals acknowledging real world staffing shortages in education.  A scaffold approach also builds a state-supported training pipeline to help aspiring interpreters meet the proposed licensure requirements. There is a serious need for parallel investment in Maryland-based training programs to support those expectations, and a provisional license approach would help. For context, local school systems are already facing severe interpreter shortages. Some large LEAs report filling only 20% of interpreter positions , with vacancies in counties such as Howard and Prince George’s remaining open for more than two years. In Frederick County, nearly one-third of interpreter roles have been vacant since 2020. Many districts now outsource most or all interpretation services — often at rates exceeding $125 per hour , plus mileage — increasing costs and reducing service continuity for students.  We share the goal of increasing full-time, licensed interpreters — which is both more cost-effective and better for students — but given the existing workforce crisis, any new licensure requirements must be carefully phased to avoid destabilizing IEP and 504 services for deaf and hard of hearing students. Amendment #7 - Establish a straight-forward provisional licensing framework to ensure continued public access to interpretation services during phase-in.    While not currently contemplated in the bill, we respectfully request amending the current requirements for provisional licensure set forth in State Government Article. § 9–2425.  This amendment would streamline the requirements for provisional licensure by simplifying what is required to have a general provisional licensee. Each industry can and will  have their own requirements in addition to the general provisional license, but it is imperative to phase-in onboarding of licensure requirements in a thoughtful way.  This amendment simplifies the requirements for obtaining a provisional license by limiting them to the basic qualification of having a high school diploma, on top of which other requirements related to the specialty being sought can be required in the future. (a) subject to the provisions of this section, the board shall issue a provisional license to provide sign language interpretation services to an individual who has: (1) OBTAINED A HIGH SCHOOL DIPLOMA OR EQUIVALENT Consumer Choice Amendment #8 - Align this statute to the consumer choice standards set forth in the federal Americans with Disabilities Act (“ADA”).    Changing the consumer choice is not currently contemplated in this legislation but we believe it should be; we believe the current law does not properly reflect ADA allowances for the delivery of services to deaf and hard of hearing individuals. Therefore, we propose the following:  Modify §9–2415(C)(3):   (C)    The Board shall adopt regulations to: ALLOW DEAF AND HARD OF HEARING INDIVIDUALS TO DETERMINE INDICATE WHETHER THEY PREFER SIGN LANGUAGE INTEPRETATION SERVICES BEING PROVIDED IN A VIDEO REMOTE INTERPRETING ENVIRONMENT AND REQUIRE EMPLOYERS TO PROVIDE REASONABLE ACCOMMODATIONS TO SUPPORT THIS PREFERENCE TO THE EXTENT PRACTICABLE AND IN COMPLIANCE WITH ADA GENERAL RULES OUTLINED FOUND IN 28 C.F.R. § 35.160  This section of the ADA is included at the conclusion of this testimony.  Other Operational Clarifications Amendment #9 - Expressly identify “educational settings” as a specialty area.  This amendment would expressly designate “educational settings” as a recognized specialty area, alongside other enumerated specialties such as legal and medical interpreting. Educational environments present distinct professional standards, role expectations, and competency requirements that warrant the same level of formal recognition and regulatory consideration afforded to other specialty practice areas.   Further, the bill creates a new report requirement to address certification standards, workforce numbers, and specialty requirements across enumerated specialty areas. Including educational settings within that list ensures that the resulting data collection and analysis will meaningfully inform future regulations governing educational interpreters. Without explicit inclusion, the Board’s reporting and subsequent regulatory framework may lack the specificity necessary to establish standards that reflect the realities of educational practice. Add to §9–2415(a) as follows:           (9)     EDUCATIONAL SETTINGS. Amendment #10 - Correct the names for PSSAM and add MABE.  This amendment would fix likely unintentional drafting errors to correct the organization title for PSSAM, and add the Maryland Association of Boards of Education (MABE) as an organization to be consulted.  Modify §9–2415(b)(2) as follows: (VII)  THE PUBLIC SCHOOLS SUPERINTENDENTS’ ASSOCIATION OF  MARYLAND           (X)    THE MARYLAND ASSOCIATION OF BOARDS OF EDUCATION Amendment #11 & #12 - For video interpretation , honor out-of-state standards to make out-of-state interpreters available to the public when needed.  We recognize that requiring all video remote interpreters (especially out-of-state VRI) to be licensed in Maryland presents operational challenges. At the same time, it is clear that  waiving all requirements for VRI providers would undermine the purpose of this bill,  as a significant portion of interpreting services provided in this state are done remotely. Therefore we propose the following related amendments:  Amendment #11: Add subsection §9-2418(b)(3): (b) This section does not apply to an individual who: (3) PROVIDES SIGN LANGUAGE INTERPRETATION SERVICES AS PART OF A VIDEO REMOTE INTERPRETING SERVICE, HOLDS A RID OR BEI CERTIFICATION, AND IS LOCATED OUT-OF-STATE;   This would enable out-of-state video interpreters to provide services, still hold out-of-state interpreters to their own standards, but not undermine Maryland’s own licensure requirements. Amendment #12: Modify §9–2420(a) and (b) and delete §9–2420(c): Subject to the provisions of this section, the Board may SHALL waive any requirement of this part for an applicant who is licensed to provide sign language interpretation services in another state.  (b) The Board may grant a waiver under this section only if the applicant:   (1) pays to the Board:   (i) the nonrefundable application fee set by the Board; and   (ii) the license fee set by the Board; and   (2) provides satisfactory evidence that, at the time the applicant was licensed in the other state, the applicant was required to meet the qualifications for licensure that were substantially equivalent to the qualifications in the State.   (c ) The Board may grant a waiver under this section only if the state in which the applicant is licensed waives the qualifications of licensees of the State to a similar extent as the State waives the qualification requirements for individuals licensed in that state.  These amendments together would streamline out-of-state licensure recognition by requiring the Board to waive Maryland’s requirements for individuals already licensed in another state, eliminating the “substantially similar” standard, and removing the reciprocity condition. Together, these changes reduce barriers to entry and expand the available pool of qualified interpreters, while still relying on an existing state licensure determination as the baseline qualification.    Amendment #13 - Add an additional reporting requirement for the number of licensed interpreters in each county. This amendment will strengthen any future policies or regulatory action by ensuring that any promulgated regulations are made with an accurate understanding of the number of available interpreters across different jurisdictions in the State. We believe it is also worthwhile to disaggregate this data by an applicant’s county of residence and, if known, the county or region where the applicant plans to work at the time of issuance or renewal.  Update existing reporting requirements for the Board (§9–2407) by adding: (6) THE NUMBER OF LICENSED SIGN LANGUAGE INTERPRETERS IN EACH COUNTY AS DETERMINED BY THE APPLICANT’S HOME ADDRESSES AND THE APPLICANT’S COUNTY OR REGION OF PLANNED EMPLOYMENT, IF KNOWN.  Amendment #14 - Expressly account for due process provided in labor agreements for issues of suspension or discipline.    This amendment clarifies in statute that any regulations adopted by the Board concerning discipline or suspension of licensed interpreters must defer to existing bargaining agreements and establish due process protections for public employees. Elevating this principle ensures that regulatory requirements cannot and would not be interpreted to override negotiated labor terms or procedural safeguards, preserving established employment rights while implementing the licensure framework. Suggested language:   CONCERNING THE DISCIPLINE OR SUSPENSION OF QUALIFIED INTERPRETERS, NOTHING IN THIS SECTION OR REGULATIONS ADOPTED BY THE BOARD SHALL BE CONSTRUED TO SUPERSEDE, LIMIT, OR IMPAIR ANY COLLECTIVE BARGAINING AGREEMENT ENTERED INTO PURSUANT TO TITLE 6 OF THE EDUCATION ARTICLE, OR ANY PROCEDURAL OR DUE PROCESS RIGHTS AFFORDED TO PUBLIC EMPLOYEES UNDER STATE OR FEDERAL LAW.    Conclusion Our recommendations are grounded in practical experience serving students who are Deaf and Hard of Hearing, in our deep understanding of local infrastructure, and in precedent looking at successful regulatory frameworks in other states in the nation.  We appreciate your willingness to consider both our well-founded concerns and our proposed solutions. We share the goal of ensuring that all students have access to high-quality sign language interpretation and can meaningfully participate in their education.  As this legislation and subsequent regulations continue to take shape, we urge your attention to the infrastructure needed to support this work.  As always, we are available for continued collaboration in refining this framework that will simultaneously uphold professional standards and build a stronger, student-centered, sustainable system in Maryland.   Therefore, PSSAM and MABE support Senate Bill 645 with the  amendments outlined above. For REFERENCE ONLY  Americans with Disabilities Act   Regulations Nondiscrimination on the Basis of Disability in State and Local Government Services - Communications -  28 C.F.R. § 35.160 (a)   (1) A public entity shall take appropriate steps to ensure that communications with applicants, participants, members of the public, and companions with disabilities are as effective as communications with others.   (2) For purposes of this section, “companion” means a family member, friend, or associate of an individual seeking access to a service, program, or activity of a public entity, who, along with such individual, is an appropriate person with whom the public entity should communicate. (b)    (1) A public entity shall furnish appropriate auxiliary aids and services where necessary to afford individuals with disabilities, including applicants, participants, companions, and members of the public, an equal opportunity to participate in, and enjoy the benefits of, a service, program, or activity of a public entity.   (2) The type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place. In determining what types of auxiliary aids and services are necessary, a public entity shall give   primary consideration to the requests of individuals with disabilities .  In order to be effective, auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability. (c)   (1) A public entity shall not require an individual with a disability to bring another individual to interpret for him or her.  (2) A public entity shall not rely on an adult accompanying an individual with a disability to interpret or facilitate communication except—      (i) In an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available; or      (ii) Where the individual with a disability specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances.  (3) A public entity shall not rely on a minor child to interpret or facilitate communication, except in an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available. (d) Video Remote Interpreting (VRI) services.    A public entity that chooses to provide qualified interpreters via VRI services shall ensure that it provides:  (1) Real-time, full-motion video and audio over a dedicated high-speed, wide-bandwidth video connection or wireless connection that delivers high-quality video images that do not produce lags, choppy, blurry, or grainy images, or irregular pauses in communication;  (2) A sharply delineated image that is large enough to display the interpreter’s face, arms, hands, and fingers, and the participating individual’s face, arms, hands, and fingers, regardless of his or her body position;  (3) A clear, audible transmission of voices; and  (4) Adequate training to users of the technology and other involved individuals so that they may quickly and efficiently set up and operate the VRI.

BILL: SB 263 TITLE: Education - Dependent Children of Active Service Members - Advance Enrollment Procedures DATE: February 18, 2026 POSITION: Favorable COMMITTEE: Senate Education, Energy & the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports  Senate Bill 263. This bill requires local school systems to allow a dependent child of a service member to apply for advance enrollment in a public school and specifies requirements for advance enrollment procedures. The Secretary of Veterans and Military Families, in consultation with specified entities, must publish and maintain information on (1) advance enrollment procedures and (2) any assistance and services available to service members regarding advance enrollment. The bill takes effect July 1, 2026. Maryland is home to approximately 100,000 active-duty service members, and we recognize the important role military families play in our communities. Children in military families often face unique challenges due to frequent relocations, including disruptions in coursework, credit transfers, and social adjustment when enrolling in a new school. Supporting policies that streamline enrollment processes, ensure timely credit recognition, and provide consistent transitions across school systems helps reduce unnecessary stress on families who already shoulder significant sacrifice. This bill facilitates smoother school transitions and reflects Maryland’s commitment to supporting its service members.  PSSAM appreciates the intent of Senate Bill 263 in addressing the challenges faced by current enrollment procedures for dependent students of service members. Last year PSSAM supported this legislation with amendments that have been incorporated into this year’s version of the bill.  Therefore, PSSAM supports Senate Bill 263.

BILL: HB 562 TITLE: Primary and Secondary Education – Maintenance of Effort – Inflation Adjustment (Maintenance of Effort Modernization Act) DATE: February 24, 2026 POSITION: Favorable COMMITTEE: House Appropriations Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four Maryland local school superintendents, supports House Bill 562. This legislation alters the method for calculating the maintenance of effort county governing bodies are required to appropriate to the school operating budget by including an annual inflation adjustment. Maryland first embedded Maintenance of Effort (MoE) into statute in 1984 to ensure local governments remained meaningful and predictable partners in funding public education. The Blueprint for Maryland’s Future later added “local share” as a second potential funding calculation. While neither formula is perfect for every local school system, together they have provided stability, accountability, and a predictable budgeting framework. Under current law, counties must provide, at a minimum, the greater of: The local share of certain major education aid formulas, or The per pupil amount provided in the prior fiscal year (MoE). MoE has been a strong accountability tool. However, it no longer reflects the true cost of operating modern school systems.  We appreciate the difficult balancing act local governments face where education, public safety, health, infrastructure, and other essential services all compete for limited resources. But we are compelled to voraciously advocate for equitable and adequate local education funding.  MoE was designed to ensure predictable minimum funding. What it does not do is ensure that funding keeps pace with rising costs. Local funding increases have not materialized at the levels envisioned by the Kirwan Commission, nor have they consistently tracked with increases in county wealth or statewide per pupil investment. While the State foundation amount is adjusted annually using an inflation factor (the lesser of the Implicit Price Deflator, CPI, or 5%), the local MoE does not. That creates an imbalance. Meanwhile, the cost of running school systems has risen dramatically: Wage inflation for teachers and support staff  Escalating employee and retiree health benefits Transportation fuel and fleet costs Food service inflation School security and health services Building maintenance and capital improvements Skyrocketing utility costs The Blueprint embedded per pupil amounts in statute based on assumptions made pre-COVID. No one could have predicted the pandemic or the inflationary shock that followed and has fundamentally reshaped our economy in many ways. This legislation adds a modest, built-in inflation factor to the Maintenance of Effort amount. It does not overhaul local share. It does not impose unpredictable spikes. It simply ensures that the minimum local contribution keeps pace with economic reality. No one can predict the future, but we can rely on established economic indicators such as CPI or the Implicit Price Deflator. An inflation adjustment would: Preserve MoE’s predictability Protect against erosion of purchasing power Promote greater per pupil equity across jurisdictions Better align local contributions with the State’s inflation-adjusted investment Help balance the state-local partnership necessary for Blueprint success Unfortunately, some local governments provide no more than the statutory minimum and the real value of local education funding declines over time. Adding an inflation factor restores balance.  It reflects the shared responsibility envisioned by the Blueprint and ensures that local governments remain meaningful partners in advancing educational adequacy and equity. This is not a radical change. It is a modest modernization of an accountability tool that has served Maryland well for more than a decade. An inflationary adjustment to Maintenance of Effort will ensure Maryland’s education funding framework reflects today’s economic reality and continues moving us toward equitable per pupil investment statewide.  For these reasons, PSSAM supports HB 562 and requests a favorable committee report .

BILL: SB 502 TITLE: Language Acquisition Tracking Program for Deaf and Hard of Hearing Children – Establishment DATE: February 26, 2026 POSITION: Unfavorable COMMITTEE: Senate Education, Energy & the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four local school superintendents, opposes Senate Bill 502. This legislation establishes the Language Acquisition Tracking Program for Deaf and Hard of Hearing Children in the State Department of Education; establishes a State Coordinator within the Department to coordinate the Program and create a parent and guardian resource to help parents and guardians track a child’s language acquisition progress; establishes the Language Acquisition for Deaf and Hard of Hearing Children Advisory Council to advise and provide certain consultation services to the State Coordinator, approve a certain language assessment tool, and review a certain report; requires the Department, in consultation with the Maryland Department of Health and the Maryland School for the Deaf, to issue an annual report on the language acquisition of deaf or hard of hearing children. Maryland superintendents share the goal of ensuring that deaf and hard of hearing children receive timely, high-quality services and that families are supported with clear information. However, as drafted, this bill is overprescriptive and duplicative or conflicting with existing law and practice under IDEA. Further, it risks disrupting Maryland’s long-standing education governance structure where MSDE sets statewide policy expectations and standards, while local school systems retain flexibility to select curriculum and diagnostic tools to meet individual student needs. Maryland already has a strong legal framework under IDEA that governs services for children with disabilities and requires individualized supports and progress monitoring. Specifically, Part C  provides services for infants and toddlers through Individualized Family Service Plans (IFSPs) and is reviewed at least every six months. Part B  governs preschool and school-age services through Individualized Education Programs (IEPs) and is reviewed at least annually with regular progress reporting. These systems already require multidisciplinary teams to monitor child outcomes, revise plans when progress is insufficient, and ensure individualized supports. Many of the bill’s requirements - including regular assessment, family engagement, documented progress, and adjustments to plans are already occurring. The specific tool or process appropriately varies by child and needed services. The bill’s birth-to-nine framework is unusually expansive.  Part C and Part B are fundamentally different systems — IFSP versus IEP — with different statutory purposes, timelines, and service models. A single rigid tracking mandate across both systems risks confusing families and complicating transitions. The transition from Part C to Part B already requires careful coordination and documentation. Establishing a separate, parallel tracking structure through age nine risks layering complexity onto an already structured and carefully managed process. The required six-month testing cycle is also redundant.  IFSP reviews already occur every six months. IEP teams monitor progress regularly and may convene at any time to adjust services. A mandated statewide testing schedule every six months through age nine risks: Creating a paper compliance exercise rather than improving services; Diverting staff time away from direct instruction, therapy, and family engagement; and Encouraging tool-driven decisions rather than individualized, team-based determinations. Similarly, the bill’s requirement that IFSPs, IEPs, or 504 Plans be updated if a child does not demonstrate progress is already embedded in IDEA practice. When a child is not making expected progress, teams reconvene and revise services. Codifying this again and tying it to a single tool adds compliance burden without improving outcomes. This bill creates significant duplication of existing supports and risks confusion for families.  Once children enter school, language and literacy development are tracked through classroom-based assessments and structured progress monitoring systems. A separate mandated tool would likely overlap with or conflict with these existing systems. Adding a parallel, statewide tracking system risks sending mixed signals and generating duplicative paperwork rather than streamlining services.  By elementary school, students already participate in multiple literacy and academic assessments — including tools such as DIBELS and MAP — that provide detailed data on reading skills, comprehension, and language development. Layering a separate, uniform, state-mandated language acquisition assessment on top of these existing measures risks duplicating assessments already in place, increasing time away from instruction and services, and blurring the distinction between early language monitoring and broader academic achievement tracking. The bill significantly alters Maryland’s education governance structure by mandating a statewide assessment tool selected by a volunteer Advisory Council and creates a mandated coordinator position within MSDE with very specific performance requirements. This approach usurps the established balance between MSDE’s statewide oversight role and local school systems’ responsibility to select appropriate assessments. The legislation also substitutes the Council’s judgment for the individualized determinations made by legally required IFSP and IEP teams and risks imposing additional assessments beyond those already used for literacy, language development, and progress monitoring. Stakeholders and advocates — particularly families and the deaf and hard of hearing community — play a vital and important role.  However, education policy and assessment systems must ultimately be led by educators and implemented through legally accountable teams, not dictated by a multi-interest advisory body empowered to mandate a single statewide tool. We are also concerned about the composition of the Advisory Council and the exclusion of MSDE,  the State agency charged with educational oversight and implementation. While the Maryland Department of Health plays a critical role for children birth to three, its statutory authority does not extend into the K–12 environment in the same manner. Granting authority to mandate an assessment tool to a body without direct implementation responsibility raises concerns about alignment, accountability, and practical execution. The bill further establishes a new State Coordinator position required to consult with the Advisory Council. MSDE already maintains staff, workgroups, and structures dedicated to supporting deaf and hard of hearing students. Many of the bill’s stated goals - including improved parent resources and strengthened tracking supports - could be accomplished through MSDE guidance and collaboration without creating new statutory structures that reduce flexibility and insert a council into operational decision-making. Finally, creating a disability-specific council with approval authority over a statewide assessment tool sets a troubling precedent.  Maryland’s special education framework is grounded in individualized need - not disability category hierarchy. Establishing a unique governance structure for one group risks inequity and fragmentation across special education systems. Maryland already has a comprehensive IDEA-driven framework that requires individualized planning, progress monitoring, family engagement, and plan revision when needed. While we share the goal of improving outcomes for deaf and hard of hearing children, this bill duplicates existing requirements, creates governance conflicts, and imposes rigid structures that risk undermining individualized decision-making. For these reasons, PSSAM opposes Senate Bill 502.

BILL: SB 350 TITLE: Public Schools - Open Enrollment - Policies and Funding DATE: February 27, 2026 POSITION: Unfavorable COMMITTEE: Senate Education, Energy & the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, opposes  Senate Bill 350.  This bill authorizes local boards of education to adopt an open enrollment policy. If adopted the local boards would be required to (1) allow a child from a sending county to be enrolled in a receiving school free of charge; (2) reserve space for students who are enrolled in the receiving school during the previous school year for automatic enrollment in each subsequent school year without application; (3) be published in an easily accessible manner on the local board’s website; and (4) comply with applicable federal and State antidiscrimination laws.  The open enrollment policy authorized under Senate Bill 350, if adopted, would significantly limit local school boards’ flexibility to manage enrollment, staffing, and resources in response to changing conditions. While participation is optional, the bill prescribes detailed requirements that constrain how districts may design and administer enrollment decisions, effectively limiting local discretion.  Superintendents, with their local boards, must retain discretion over enrollment decisions in order to manage resources, staffing, and capacity based on local conditions. For example, using existing statutory authority, the Howard County Public School System  (HCPSS) allows students to apply for reassignment to schools with available capacity within the county. These enrollment decisions are discretionary, capacity-driven, and subject to ongoing review by the Superintendent, allowing the district to respond to changes in enrollment, staffing levels, and facility constraints. By contrast, this bill would impose a more prescriptive open enrollment framework. Once a student is accepted under an open enrollment policy, the bill would require the receiving district to prioritize that student for continued enrollment in subsequent years, limiting the district’s ability to reevaluate placements as enrollment patterns shift. This approach replaces locally tailored, flexible decision-making with a rigid structure that reduces superintendent authority and constrains districts’ ability to adapt to changing student populations.  In addition, the policy would introduce fiscal unpredictability for a ‘sending county’ that experiences a large number of students moving to other districts as budgets are mainly driven by enrollment. While revenues “follow students,” many costs remain fixed so shifting enrollment does not always result in an equal staffing or fixed cost adjustment. Current law also requires the State to cover the difference when a student transfers to a higher-cost district. As proposed under the bill a district can choose to participate. However, students moving from “non-participating” districts to “participating districts” creates even more fiscal instability and the State would likely see increases in expenditures to cover the different enrollment shifts between low and high-cost districts. PSSAM has a longstanding policy of resisting legislation that would restrict local authority and limit superintendents’ ability to respond to local needs. We ask the Legislature to support the historical balance in crafting education policy by allowing superintendents, along with their boards of education, to enact locally-appropriate eligibility and enrollment policies.                                                   For these reasons, PSSAM opposes Senate Bill 350  and kindly requests an unfavorable  committee report.

BILL: SB 299 TITLE: County Boards of Education - Therapy Dogs - Policy for Handling  and Use in Schools  DATE: February 27, 2026 POSITION: Unfavorable COMMITTEE: Senate Education, Energy & the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four local school superintendents, sadly opposes Senate Bill 299 . This bill requires each local board of education to allow, and adopt a policy for, the use of therapy dogs in public schools, and requires a handler to accompany each therapy dog in school. The policy must include (1) certification requirements for therapy dogs; (2) guidelines for handlers; (3) guidelines for when and where therapy dogs and handlers are allowed in school buildings; (4) notification requirements; and (5) guidelines for the management of students and staff with allergies or who are uncomfortable around dogs. Under the bill, a “therapy dog” is a dog that is trained to provide affection and comfort to children who need emotional support in a school setting and is certified or registered as a therapy dog. A “handler” is an individual who provides care and training for the therapy dog.  PSSAM appreciates the intent of this legislation and the focus on supporting students’ emotional and mental well-being. Local school systems share that goal and are deeply invested in creating safe, supportive learning environments for all students. Federal and State law already allow for the use of service animals  in schools when they are trained to perform specific, documented tasks—such as alerting individuals of an oncoming seizure, reminding someone to take medication, or assisting with mobility or medical needs. These service animals are subject to well-established legal standards and protections. This bill goes beyond those existing frameworks by requiring every local board of education to allow and adopt policies for therapy dogs , which are not covered under federal disability law in the same way.  While well-intentioned, this raises several concerns. First , the bill relies on a concept of “certification” for therapy dogs that is not legally recognized . There is currently no uniform, legally defined certification standard for therapy dogs providing affection and comfort in schools. As written, the bill would leave substantial room for interpretation regarding what qualifications are sufficient for a dog to serve in this role, creating inconsistency and potential risk across school systems. Second , the bill would unreasonably mandate the presence of a handler  to accompany each therapy dog in a school setting. This raises practical and operational questions about supervision, staffing, training, liability, and cost—particularly in environments where schools are already managing complex student needs with limited resources. Third , dogs that are not otherwise trained for structured school environments may unintentionally become a distraction or disturbance  to other students and staff. Schools must also consider unintended consequences, including classroom disruptions, safety concerns, and the management of students and employees with allergies, fears, or cultural discomfort around dogs. Finally , this legislation would expand the scope and complexity of student supports  that schools would be required to manage without requiring a documented need for this intervention. Local school systems already use a range of evidence-based supports—social workers, counselors, psychologists, behavioral interventions, and targeted programs—tailored to individual student needs. Mandating a specific support tool without an individualized determination could undermine that existing framework. We welcome continued dialogue on how best to support students’ social and emotional well-being in a manner that is flexible, legally sound, and responsive to local conditions. Therefore, PSSAM sadly opposes Senate Bill 299.

BILL: SB 292 TITLE: County Boards of Education - Student Transportation - Sunset Repeal DATE: February 27, 2026 POSITION: Favorable COMMITTEE: Senate Education, Energy & the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports  Senate Bill 292. This bill repeals the termination date of certain provisions of law that authorize a county board of education to provide transportation for certain students using a vehicle other than a standard school bus.                                                                    PSSAM strongly supported the original legislation in 2021 authorizing alternative vehicles in circumstances when a school bus cannot reasonably be provided. Further, certain student groups were identified as eligible for these services, including (1) preschool-age students; (2) students with disabilities; (3) homeless youth; (4) children in foster care; (5) students without access to school buses; (6) students in a nonpublic school placement; (7) students in dual enrollment programs or work programs or other educational programs based off the school campus. Additionally, the law allowed school systems to provide this transportation to other student groups through a written determination by the board. Transportation is one of the fastest growing costs for school systems with limited ability by LEAs to minimize costs. This legislation has given us the ability and flexibility to provide transportation in challenging circumstances such as geography and student need.  For the reasons stated above, PSSAM requests a favorable report on Senate Bill 292.

BILL: HB 943 TITLE: State Board of Education - Financial Literacy - Graduation Requirement  DATE: February 25, 2026 POSITION: Unfavorable COMMITTEE: House Ways & Means Committees CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, opposes  House Bill 943. This bill requires students, beginning with a specified graduating class, to successfully complete a personal financial literacy course. The bill also requires county boards to award credit upon successful completion and to allow students to satisfy certain remaining credit requirements through existing coursework. In effect, the legislation codifies financial literacy as a standalone graduation requirement under State law. This act shall take effect July 1, 2026 beginning with the graduating class of 2030.  PSSAM recognizes the importance of financial literacy and acknowledges that financial literacy concepts are already taught in grades 3-12 across Maryland’s public schools. The issue before the Committee is not the value of financial literacy, but the mechanism by which it is required. Graduation requirements have historically been determined through a balance of state standards and local decision-making, allowing school systems to align requirements with community priorities, staffing capacity, and student pathways. Codifying a semester-long financial literacy course as a standalone graduation requirement reduces that flexibility and may require adjustments to existing credit structures, potentially displacing other locally valued courses or student electives. Maryland currently requires 22 state-mandated credits across specific subject areas, leaving limited space within a student’s four-year schedule for local priorities and emerging instructional needs. While financial literacy may be a priority today, areas where students require growth and emphasis will continue to evolve. Local education agencies need flexibility to adjust credit structures as workforce demands, higher education expectations, and student needs evolve, without having those decisions fixed in statute. When instructional priorities are embedded in law, modification requires legislative repeal or amendment, significantly slowing a school system’s ability to respond compared to local policy revision.                                                                                    Given the need for school systems to design adaptable graduation pathways, PSSAM opposes House Bill 943 and respectfully requests an unfavorable  committee report.

BILL: HB 879 TITLE: Language Acquisition Tracking Program for Deaf and Hard of Hearing Children – Establishment  DATE: February 25, 2026 POSITION: Unfavorable COMMITTEE: House Ways & Means Committees CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four local school superintendents, opposes House Bill 879. This legislation establishes the Language Acquisition Tracking Program for Deaf and Hard of Hearing Children in the State Department of Education; establishes a State Coordinator within the Department to coordinate the Program and create a parent and guardian resource to help parents and guardians track a child’s language acquisition progress; establishes the Language Acquisition for Deaf and Hard of Hearing Children Advisory Council to advise and provide certain consultation services to the State Coordinator, approve a certain language assessment tool, and review a certain report; requires the Department, in consultation with the Maryland Department of Health and the Maryland School for the Deaf, to issue an annual report on the language acquisition of deaf or hard of hearing children. Maryland superintendents share the goal of ensuring that deaf and hard of hearing children receive timely, high-quality services and that families are supported with clear information. However, as drafted, this bill is overprescriptive and duplicative or conflicting with existing law and practice under IDEA. Further, it risks disrupting Maryland’s long-standing education governance structure where MSDE sets statewide policy expectations and standards, while local school systems retain flexibility to select curriculum and diagnostic tools to meet individual student needs. Maryland already has a strong legal framework under IDEA that governs services for children with disabilities and requires individualized supports and progress monitoring. Specifically, Part C  provides services for infants and toddlers through Individualized Family Service Plans (IFSPs) and is reviewed at least every six months. Part B  governs preschool and school-age services through Individualized Education Programs (IEPs) and is reviewed at least annually with regular progress reporting. These systems already require multidisciplinary teams to monitor child outcomes, revise plans when progress is insufficient, and ensure individualized supports. Many of the bill’s requirements - including regular assessment, family engagement, documented progress, and adjustments to plans are already occurring. The specific tool or process appropriately varies by child and needed services. The bill’s birth-to-nine framework is unusually expansive.  Part C and Part B are fundamentally different systems — IFSP versus IEP — with different statutory purposes, timelines, and service models. A single rigid tracking mandate across both systems risks confusing families and complicating transitions. The transition from Part C to Part B already requires careful coordination and documentation. Establishing a separate, parallel tracking structure through age nine risks layering complexity onto an already structured and carefully managed process. The required six-month testing cycle is also redundant.  IFSP reviews already occur every six months. IEP teams monitor progress regularly and may convene at any time to adjust services. A mandated statewide testing schedule every six months through age nine risks: Creating a paper compliance exercise rather than improving services; Diverting staff time away from direct instruction, therapy, and family engagement; and Encouraging tool-driven decisions rather than individualized, team-based determinations. Similarly, the bill’s requirement that IFSPs, IEPs, or 504 Plans be updated if a child does not demonstrate progress is already embedded in IDEA practice. When a child is not making expected progress, teams reconvene and revise services. Codifying this again and tying it to a single tool adds compliance burden without improving outcomes. This bill creates significant duplication of existing supports and risks confusion for families.  Once children enter school, language and literacy development are tracked through classroom-based assessments and structured progress monitoring systems. A separate mandated tool would likely overlap with or conflict with these existing systems. Adding a parallel, statewide tracking system risks sending mixed signals and generating duplicative paperwork rather than streamlining services.  By elementary school, students already participate in multiple literacy and academic assessments — including tools such as DIBELS and MAP — that provide detailed data on reading skills, comprehension, and language development. Layering a separate, uniform, state-mandated language acquisition assessment on top of these existing measures risks duplicating assessments already in place, increasing time away from instruction and services, and blurring the distinction between early language monitoring and broader academic achievement tracking. The bill significantly alters Maryland’s education governance structure by mandating a statewide assessment tool selected by a volunteer Advisory Council and creates a mandated coordinator position within MSDE with very specific performance requirements. This approach usurps the established balance between MSDE’s statewide oversight role and local school systems’ responsibility to select appropriate assessments. The legislation also substitutes the Council’s judgment for the individualized determinations made by legally required IFSP and IEP teams and risks imposing additional assessments beyond those already used for literacy, language development, and progress monitoring. Stakeholders and advocates — particularly families and the deaf and hard of hearing community — play a vital and important role.  However, education policy and assessment systems must ultimately be led by educators and implemented through legally accountable teams, not dictated by a multi-interest advisory body empowered to mandate a single statewide tool. We are also concerned about the composition of the Advisory Council and the exclusion of MSDE,  the State agency charged with educational oversight and implementation. While the Maryland Department of Health plays a critical role for children birth to three, its statutory authority does not extend into the K–12 environment in the same manner. Granting authority to mandate an assessment tool to a body without direct implementation responsibility raises concerns about alignment, accountability, and practical execution. The bill further establishes a new State Coordinator position required to consult with the Advisory Council. MSDE already maintains staff, workgroups, and structures dedicated to supporting deaf and hard of hearing students. Many of the bill’s stated goals - including improved parent resources and strengthened tracking supports - could be accomplished through MSDE guidance and collaboration without creating new statutory structures that reduce flexibility and insert a council into operational decision-making. Finally, creating a disability-specific council with approval authority over a statewide assessment tool sets a troubling precedent.  Maryland’s special education framework is grounded in individualized need - not disability category hierarchy. Establishing a unique governance structure for one group risks inequity and fragmentation across special education systems. Maryland already has a comprehensive IDEA-driven framework that requires individualized planning, progress monitoring, family engagement, and plan revision when needed. While we share the goal of improving outcomes for deaf and hard of hearing children, this bill duplicates existing requirements, creates governance conflicts, and imposes rigid structures that risk undermining individualized decision-making. For these reasons, PSSAM opposes House Bill 879.

BILL: HB 856 TITLE: Local Education Agencies - Educator Screening - Educator Identification Clearinghouse (School Personnel Vetting and Hiring Transparency Act) DATE: February 24, 2026 POSITION: Support with Amendments COMMITTEE: House Ways & Means Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four local school superintendents, supports House Bill 856 with amendments. This bill requires the Maryland State Department of Education (MSDE) to register each local school system (LSS) in the State as an associate member of a national membership organization that provides access to the Educator Identification Clearinghouse and to pay any applicable fees and dues associated with the membership. Each LSS must use the clearinghouse to screen individuals who receive an offer of employment for an educator position that requires a license. In addition, each local school system must ensure that each individual who receives such an offer (1) applies for the appropriate license after the offer of employment and before the start of employment and (2) obtains the appropriate license before any interaction with children. Nothing in the bill may be construed to impair or affect existing statutory prohibitions against hiring or retaining individuals convicted of specified crimes, including child sexual abuse. Maryland school systems take their responsibility to ensure the safety of students and staff extremely seriously. We appreciate the bill’s emphasis on strengthening student safety and reinforcing the integrity of the licensure process. In particular, we support the provision requiring candidates to apply for licensure at the time they receive an offer of employment. This requirement adds an important layer of screening and reinforces the shared commitment of school systems and the State to student protection. A review of Maryland’s 24 local school systems confirms that extensive safeguards are already in place, including existing federal and state mandates, including: State and FBI fingerprinting (criminal background checks and the Adam Walsh Background Clearance Request form, DHR/SSA 1279A) Form I-9 verification (paper and E-Verify where available) Md. Code, Educ. § 6-113.2 Child Sexual Abuse and Sexual Misconduct review (“HB 486 review”) Maryland State Department of Education (MSDE) TEACH database review CJIS fingerprinting and background checks MSDE Disqualified Substitute List review Department of Social Services child abuse registry checks Maryland Judiciary Case Search inquiries, where applicable Internal database reviews Drug testing, where required Recruiting and tracking systems such as Workday, AppliTrack (Unified Talent/PowerSchool), TalentEd (PowerSchool), and Frontline Basic online screening and employment verification processes These layers of review reflect a strong and proactive screening infrastructure across the State. While we support the bill’s intent, we respectfully request a clarifying amendment to remove the language requiring a license to be fully issued before “any interaction with students.”  Although well-intentioned, this provision could unintentionally create barriers for pre-screened, qualified educators whose paperwork is still being processed. In practice, licensure issuance can be delayed for reasons outside of a candidate’s control, even when all safety screenings have been successfully completed. Removing this final clause, while retaining the requirement that candidates apply for licensure upon offer of employment, preserves the bill’s important safety objectives while allowing reasonable operational flexibility during the hiring and licensure process. Finally, we support an amendment to move the date from October 1, 2026 to August 1, 2026 by which local school systems must utilize the clearinghouse to screen individuals offered employment.  House Bill 856 builds upon current protections aimed at ensuring only qualified and appropriate individuals enter our classrooms. We recognize the bill’s focus on student safety and maintaining the credibility of the licensure system. Therefore, PSSAM supports House Bill 856 with the  amendments outlined above.

BILL: HB 649 TITLE: Advancing Equal Educational Opportunities for All Students in Maryland DATE: February 24, 2026 POSITION: Letter of Information COMMITTEE: House Government, Labor & Elections Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four Maryland local school superintendents, provides this letter of information on House Bill 649. House Bill 649 would repeal the existing statutory framework for civil rights enforcement in schools, and replace it with a new framework that authorizes the Maryland Commission on Civil Rights (MCCR), concurrently with the Maryland State Department of Education (MSDE), to enforce the prohibition against discrimination and retaliation in school systems. The bill also concurrently authorizes a private right of action for individuals alleging discrimination in schools to bring civil lawsuits in court.  PSSAM and our members unequivocally care deeply about the civil rights of students and families. Strong, effective civil rights enforcement is essential to ensuring equitable educational opportunity for all Maryland students. Recent changes and disruptions at the U.S. Department of Education’s Office for Civil Rights (OCR) have understandably created concern nationwide.  In the absence of a viable federal system, we do not question the importance of maintaining strong protections. But it is important to acknowledge that this restructuring is driven by temporary federal circumstances. That context should inform whether Maryland creates a permanent, parallel enforcement system that may remain long after federal conditions change. Maryland has a statutory civil rights enforcement framework under Education Article §§ 26-649 and 26-705 . In 2022, the General Assembly granted MSDE new authority to investigate discrimination claims within local school systems. To our knowledge, this framework has been implemented and is functioning effectively. HB 649 would significantly expand authority by: Granting the Maryland Commission on Civil Rights (MCCR) concurrent enforcement power alongside MSDE; and Authorizing individuals to file lawsuits in court while simultaneously pursuing investigations before MCCR or MSDE. This expansion raises important legal and practical concerns. The existence of  parallel enforcement risks duplication, inconsistent findings, and confusion for families already navigating an emotionally and procedurally complex process. It also increases administrative and legal burdens on school systems responding to unsubstantiated claims. There are several legal and operational concerns the Committee should consider, including:   Overlapping investigative authority between MSDE and MCCR; Potential conflicting evidentiary standards; The scope of newly created civil remedies; Fiscal and operational impacts on school systems; Interaction with federal IDEA procedures in special education disputes; and The due process rights of teachers and staff who are subject to allegations. The delivery of special education services , in particular, is governed by an extensive and longstanding adjudication framework under federal law. Creating additional or parallel remedies without careful coordination could introduce confusion and unintended legal conflict. We understand that significant amendments are being developed by both the sponsoring department and MSDE . While we have had an opportunity to review some of these concepts, the complexity of the subject matter makes it difficult to offer a definitive position or specific amendment language at this time. We respectfully request meaningful engagement in the Committee’s deliberative process  and allow stakeholders, including local school systems, a seat at the table as these significant structural changes are considered. Our legal colleagues at MABE have provided a more detailed legal analysis of this legislation, and we support their work and conclusions. Our comments here highlight key policy and operational concerns but do not fully capture the scope of the legal implications. We strongly support civil rights enforcement and the protection of students and families. At the same time, we must carefully balance those protections within an already complex legal framework. Permanent restructuring of Maryland’s civil rights enforcement system requires serious consideration. Without that deliberation, there is risk of creating legal confusion, increased costs, procedural delays, and unintended barriers to the very remedies families seek. PSSAM appreciates the opportunity to provide this letter of information and we urge thoughtful review, robust stakeholder collaboration, and careful refinement before enacting permanent changes of this magnitude.

BILL: HB 490 TITLE: Education – The Blueprint for Maryland’s Future – Revisions  DATE: February 24, 2026 POSITION: Support with Amendments COMMITTEE: House Ways & Means Committee House Appropriations Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports HB 490 with one amendment .  This legislation makes several changes to the law governing the Blueprint for Maryland’s Future, including, repealing a technology report due each year; extending a hold harmless provision for the calculation of compensatory education; repealing a termination date for the use of funds under the Concentration of Poverty Grant Program for the purpose of funding Fine Arts and World Languages and altering the qualifications for an initial teacher certificate. The bill also extends the date by which a teacher must be a National Board Certified teacher before becoming a licensed principal; extends the time during which the State Board of Education and Accountability and Implementation Board may limit the number and types of dual enrollment; alters the definition of “wraparound services” as it applies to community schools to include the offering of certain academic interventions; alters the purpose, composition, and duties of the Career and Technical Education (CTE) Committee; repeals the CTE Skills Standards Advisory Committee; requires State agencies and workforce development and education programs use a certain list of occupations; and generally relates to revisions to the Blueprint for Maryland’s Future.  PSSAM appreciates several technical and clarifying improvements in this omnibus bill; however, our testimony is limited to three provisions we strongly support. 1. Extension of the National Board Certification Requirement for Principals We support extending the date by which a teacher must become National Board Certified before serving as a licensed principal. However, as we recommended in 2025  (#7), we firmly believe that administrators should not be included on the Career Ladder. Assistant principals and principals are not teachers under collective bargaining structures, and National Board Certification (NBC) is not an appropriate benchmark for school leadership roles. While we would prefer complete removal of this requirement in the Blueprint, we support extending the timeline to allow the Accountability and Implementation Board (AIB) and MSDE to study the issue more carefully. We have provided a comprehensive white paper  to the AIB and MSDE outlining our concerns with this Blueprint provision. We strongly support rigorous instructional leadership, however, these provisions unintentionally restrict leadership capacity and undermine the development of effective school leaders. In addition, after reviewing the Kirwan Commission materials, there is no cited research supporting this requirement. Therefore, if aspects of NBC are deemed valuable for administrators, we believe they should be incorporated into licensure standards through State Board regulation - not embedded in statute.  2. Extension of Dual Enrollment Flexibility  We appreciate the collaboration between MSDE and the AIB in adopting Joint Implementation Policy #1, which has provided essential flexibility for LEAs in implementing post-CCR dual enrollment opportunities. This Policy is only possible due to the statutory authority granted a few years ago; HB 490 proposes to extend this authority. Last year PSSAM requested this legislative action in letters dated July 9  and August 14, 2025 . The CCR standards adopted for the 2025-2026 school year significantly expanded eligibility for dual enrollment. While this was a positive step, it increased fiscal and operational demands on local systems. Extending the statutory authority for the AIB and MSDE to adjust as needed to meet these demands and provide stability will ensure that systems are able to: Budget and staff appropriately, Coordinate with higher education partners,  Ensure equitable expansion, and Communicate clearly with students and families. 3. Extension — and Permanence — of Compensatory Education Hold Harmless We support the AIB’s amendment extending the compensatory education hold harmless provision for two years. However, we believe the most appropriate action is to make the hold harmless permanent until a new statewide poverty measure is adopted and seek the committees’ support of this as an amendment. This compensatory education hold harmless is consistent with our November 25, 2025 letter to the Governor requesting his support as school systems face enrollment fluctuations. This particular hold harmless provision is crucial for districts participating in the Community Eligibility Program (CEP). As this committee is aware, the statutory language in 5-222 changed the funding formula for compensatory education beginning in FY ‘27. However, this change was made anticipating that a new methodology would have been established by now, along with an alternative form created by MSDE. This was to be informed by a study and broad consultation with stakeholders; that work is not complete and a new methodology has yet to be created.  In the absence of a reliable statewide poverty measure, districts face significant uncertainty. CEP calculations alone do not capture a complete picture of poverty, yet compensatory education funding remains heavily dependent on those counts. A refined statewide methodology is crucial to: Target resources to the most vulnerable students, Provide confidence for expanded CEP participation, Improve identification of Community Schools, and Strengthen Title I allocation accuracy. And most importantly, ensuring that funding is distributed in a way that achieves true equity under the Blueprint. We encourage continued attention to funding sufficiency, and the development of a comprehensive poverty-counting methodology to ensure that this investment delivers the maximum impact for Maryland’s students.  For these reasons, PSSAM respectfully supports HB 490 with an amendment to make the hold harmless permanent until a new statewide poverty measure is adopted.