The petition was properly before the Department, as it appears that the question has not been previously determined and is not pending before any entity authorized to issue a declaratory order or ruling on the same.

The rule to be interpreted states in pertinent part: "Activity program." The following standards shall apply to the activity program of accredited schools and school districts. (1) General guidelines. Each board shall sponsor a pupil activity program sufficiently broad and balanced to offer opportunities for all pupils to participate. The program shall be supervised by qualified professional staff and shall be designed to meet the needs and interests and challenge the abilities of the pupils ...; contribute to the physical, mental, athletic, civic, social, moral, and emotional growth of all pupils; offer oppor-tunities for both individual and group activities; be integrated with the instructional program; and provide balance so a limited number of activities will not be perpetuated at the expense of others.

The issue before the Department may be best addressed by; narrowing its scope. The first sentence of the rule directs the governing body of each school and school district to sponsor "a pupil" activity program. This language fits most comfortably within a meaning that provides that "program" is the whole menu of extracurricular activities. Thus the requirements of the qualifications of the supervisor of the pupil activity program concern only those of the supervisor of the entire program (such as an "activities director"). To clarify, coaches of most athletic activities do not have to possess a valid Iowa teaching license if they possess the appropriate coaching authorization.

The word "program" in 281 IAC 12.6(1) refers to the entire menu of extracurricular activities offered by a school or school district. While the overall supervisor of the program of pupil activities must be a "qualified professional", there is no requirement that the sponsor of each individual non-athletic activity be a holder of a teaching license or any type of coaching authorization.