The proposed changes to the School Administrator Certification Code represent important progress in clarifying and updating Michigan’s regulatory
framework, but two elements merit revision to preserve quality, consistency, and fairness in administrator preparation. Concern 1: Loss of Minimum
Credit Standards for Traditional Programs Under the current code, building-level and central office preparation programs are explicitly anchored in
minimum graduate credit expectations: at least 18 semester hours of graduate credit in PK–12 school administration for the PK–12 building endorsement
and at least 21 semester hours of post master’s credit for the central office endorsement in an approved Michigan program. These thresholds have
functioned as a statewide quality floor, ensuring that “traditional school administrator preparation programs” provide sufficient depth and breadth of
coursework, regardless of institutional variation. As revised, R 380.104 removes these minimum graduate credit references and instead requires
completion of an “approved” Michigan traditional preparation program at the appropriate degree level plus a supervised internship. While program
approval and accreditation standards are important, eliminating any statewide numerical baseline opens the door to substantial variation in program
length and rigor, with some providers potentially compressing preparation into a minimal number of credits to reduce cost or time to completion. This
risks undermining both the comparability of credentials across institutions and districts’ confidence that newly certified administrators have engaged in a
robust course of study in educational leadership, finance, law, and instructional improvement. To balance institutional flexibility with statewide equity and
quality assurance, the rule should retain or restate clear minimum credit expectations for traditional programs, even if framed as “not less than” language
aligned with current practice (e.g., at least 18 graduate semester hours in PK–12 administration for building level endorsements and at least 21 post
master’s credits for central office endorsements). This would preserve the longstanding quality floor, support districts in interpreting credentials, and still
allow preparation providers to exceed these minima where appropriate. Concern 2: Removal of Experience-Based Internship Waiver in Traditional
Programs Current state guidance allows approved traditional school administrator preparation programs to waive the internship requirement for
candidates who bring substantial, documented, recent administrative experience (generally 6 or more months of successful experience in a school or
district-level administrative role, as determined and documented by the preparation program). This practice is reflected in institutional policies that apply
the Michigan Department of Education’s allowance for “administrative experience in lieu of internship,” with careful documentation of leadership
responsibilities aligned to the Michigan Standards for the Preparation of School Administrators. In the proposed revisions, R 380.104 requires completion
of “a supervised internship” in the Michigan traditional school administrator preparation program but does not reference any option for programs to
recognize prior, verified administrative experience in lieu of, or in partial fulfillment of, the internship requirement. At the same time, the code continues to
recognize experience more broadly in other contexts, such as alternative route pathways and out-of-state equivalency determinations. The result is an
inconsistency: experienced practitioners can have their leadership practice recognized under alternative or out-of-state routes, but not under a Michigan
university’s traditional route. Eliminating the internship waiver option for experienced candidates has several unintended consequences. It may
discourage highly qualified, already serving administrators from pursuing full certification through a traditional preparation program, particularly when they
are already working full-time in the very roles an internship is designed to approximate. It also limits programs’ ability to individualize preparation based
on a comprehensive assessment of candidates’ existing leadership practice and to focus formal internship or field-based requirements on areas of
documented need rather than repeating experiences already mastered. A more balanced approach would be to explicitly preserve a narrowly tailored
experience based waiver option in R 380.104, paralleling current MDE guidance, with safeguards such as: (1) a minimum of 6–12 months of recent,
successful PK–12 or central office administrative experience; (2) documented alignment of that experience to state administrator standards; and (3) a
program faculty review and formal determination that the candidate’s practice meets or exceeds internship expectations. This would maintain the primacy
of supervised clinical preparation for new and aspiring leaders, while allowing Michigan’s traditional preparation programs to honor and appropriately
recognize documented leadership practice for experienced candidates. Requested Modifications To address these concerns while still advancing the
Department’s goals for clarity and consistency, the following targeted revisions are respectfully recommended: • Reinstate explicit minimum graduate
credit language in R 380.104 for both PK–12 building and central office endorsements (e.g., “including not fewer than 18 semester hours of graduate
credit in PK–12 school administration” for building level and “not fewer than 21 semester hours of post master’s credit in PK–12 district level
administration” for central office), aligned with long standing practice. • Add a subsection in R 380.104 authorizing traditional program providers, under
state-approved standards and documentation requirements, to accept qualifying recent administrative experience in lieu of all or part of the internship
requirement for candidates who can demonstrate at least 6 months of successful PK–12 or central office administrative service aligned to Michigan
administrator standards. By preserving clear minimum coursework expectations and a carefully bounded experience-based internship waiver, the revised
School Administrator Certification Code will continue to elevate preparation quality, maintain statewide consistency across traditional programs, and
ensure that experienced Michigan educators have reasonable, rigorous pathways to administrator certification that recognize both their formal study and
their demonstrated leadership in schools and districts.
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