Cross-certification is the process by which a teacher seeks to satisfy the statutory requirements of tenure by relying on a professional, permanent, or life certificate in a field other than the field in which the teacher is employed. The Ohio Revised Code does not directly address the question of whether a teacher can cross-certify to obtain tenure. The appellate courts of Ohio are evenly divided on the question of whether cross-certification is statutorily permissible: three decisions have concluded that it is permissible, and three have concluded that it is not. This note will examine the decisions and statutes which pertain to cross-certification and will suggest that the better statutory interpretation is to permit cross-certification.
Note, Cross-Certification Teacher Tenure Problems in Ohio, 28 Clev. St. L. Rev. 481 (1979)