February 13, 2019
To whom it may concern:
We are writing to express our concern at the recent MIAA decision to switch from NCAA to National Federation of High School (NFHS) rules. This decision was made without any input from the MIAA football committee, athletic directors, coaches or officials, the latter two being the major constituent groups relating to high school football in Massachusetts. A similar switch was attempted in the 1990’s, and when both groups vehemently opposed, the MIAA withdrew the proposal. This time around, the MIAA did not consult with any user groups and went right to a vote. A presentation was made to the Tournament Management Committee which voted in favor, it was passed on to the board of directors who voted in favor. It does not appear at any point in the process were the groups directly affected by the rule change asked for any input.
The MIAA’s stated reasons for the switch are (from the MIAA release):
• Accessibility of rule books and support for rules interpretation
• An opportunity for input in the rules making process; seat on the national committee
• Education of Coaches and Officials, less burdensome and perhaps increase the pool of officials
• Consistency-NFHS rules provide a level of consistency among sports re: mission, guidelines for management of concussions, equipment guidelines, general guidelines for sports hygiene/skin infections and communicable diseases, guidelines for handling thunder/lightning disturbances, coaches code of ethics and sportsmanship
• Legal vulnerability of school districts and State association adopting rules not written specifically for high school athletes.
• NFHS rules are high school rules for high school kids-NFHS is the only body of rules that incorporates sportsmanship and health and safety emphasis is specific to high school students
While these points are all valid and deserve consideration, we feel the MIAA has been shortsighted in the actual comparison of the two sets of playing codes. To each point:
Accessibility of rule books and support for rules interpretation: We are being asked to make a change from a set of rules used since at least the mid-1970’s, and officiated by officials for up to 40 years, in effectively less than 7 months. NFHS 2019 rule books are not available until at the earliest May with no definitive date in sight. The MIAA has stated they are trying to secure 2018 rule books (and case books which are separate in NFHS but are one volume in NCAA), but to date, these rule books have only been secured at an extensive cost to local official’s boards. In fact, the MIAA has stated they cannot guarantee that there will be enough rule books for every official in the state. They have also stated the MIAA is trying to get training aids (videos, film, etc.), but to date, nothing but the recent introductory meeting for board leaders and interpreters. These training aids the MIAA references seem to consist of videos produced from YouTube or other state groups, not the NFHS. NFHS rule and case books are available for download via an app or e-book format, but at a cost of $6.99 each. These cannot be reprinted for use by multiple members. NCAA rule books are available free online for download and can be reprinted. This allows for easy dissemination of information. In addition, the CFO (national officiating organization of the NCAA) produces preseason training videos on rules changes, subject videos (pass interference, blocking below the waist, etc.), weekly videos in season, and weekly rules interpretations as well as bi-weekly exams. MIAA football officials are offered a discount rate to join the CFO due to their use of NCAA playing rules. Any official can go to the website and view/download video, regular in season rules interpretations and the like. None of this is available by NFHS. The MIAA has not been able to provide any NFHS training videos other than what can be found on YouTube. Both codes do offer specialty subject manuals. These facts seem to refute the assertion that accessibility and interpretation is better under NFHS.
Input in the rules making process: Under the current set up with NCAA rules, the MIAA is the rule making body. They can make any changes they vote on with no consequences from the NCAA as the MIAA is not a member institution. Witness the MIAA blue book changes for time outs, timing, etc. As a member of the NFHS committee, the MIAA would be one of 50 voting members. It was noted at the recent officials’ meeting with the MIAA that many NFHS states vote as a bloc to either block or pass rules changes. In addition, if the MIAA wanted to make a change to the NFHS rules, i.e. changing the 12 minute quarters back to the current 10 or 11, this would be considered a change to the playing rules and would remove the MIAA from the rules committee, as they were in hockey for using 1 ½ minute penalties versus 2 minute penalties. As an example, for football, Super Bowl games at Gillette are played with 10-minute quarters. We are now the sole vote on how football rules apply to Massachusetts football players. After this move, 48 other states would have a say in how football rules apply to Massachusetts players. Again, the facts surrounding the rules making process would refute the assertion that using NFHS rules is a better option.
Education: as noted above, NFHS educational materials are hard to come by. The various officials’ associations in the state have spent years developing training and education programs and vast libraries of videos mostly from professionally produced sources. While we cannot speak for the coaches, to say switching to an NFHS based rules and education system seems to be far-fetched, given all the years of training and education. Forcing hundreds of officials to switch from a set of rules they are already well versed in to a set of rules with, according to a Rules Differences manual produced by Referee Magazine, 238 distinct rules differences would seem the polar opposite of less burdensome. There is a 300+ page book outlining the differences between the two codes. And as far as increasing the pool of officials, polls done by all state associations indicated that 25% of football officials would either not return to officiate under NFHS rules, or are leaning towards not returning. More than 50% of all officials who are also college officials are either not returning or not likely to return; putting a serious dent in highly qualified officials. Recruitment is tough enough in all sports, but to lose experienced officials in this manner does not bode well. This could also lead to a shortage of “varsity” officials able to officiate all the high school games week to week. Newer less qualified officials would be forced into games that are well over their heads putting safety of players at risk.
The MIAA consultant from Connecticut informed us that he has held six-week training courses to teach aspiring college football officials from NFHS states the differences between NCAA and NFHS rules. This
training course is just to get a look or possibly a low-level game or two initially. They could then potentially be put in game with a crew of veteran officials versed in the rules. High school officials in this state are being asked to learn these differences without the benefit of a training course and go onto the field week one with a crew full of officials in the same position as they are. There will no veterans. The only reference the MIAA has provided is this one consultant from Connecticut to educate the 1000+ football officials and 300+ coaches in the state on 238 rule differences by September. We would be doing the coaches, players and the game of football a huge disservice.
Consistency: On this topic, the MIAA release seems to read from the titles of the Appendices in the NFHS rule book; Mission statement, concussions, equipment, guidelines for hygiene, lightning/thunder, coaches ethics, etc. While the categories mentioned above are in the rule book, these items are for all sports and are not particular to the football rule book or the game of football. In fact, most of them are common sense. Football officials already take the NFHS concussion course each year to maintain our eligibility status, as do all officials in all sports. NCAA rules do cover lighting, has a rule for bleeding players, a section on coaches’ ethics and the like. The appendices in the NFHS can very easily be maintained in the blue book for all sports, not just football and do not, in and of themselves represent a reason to switch codes nor an improvement from NCAA rules.
Legal vulnerability: This point is confusing because we are unaware of any lawsuits or legal issues that have occurred pertaining to the fact that football is being played under NCAA rules. Any legal vulnerability comes into play when rules are wantonly ignored or someone is irresponsible, not because of the set of rules they play under. We would argue the legal vulnerability may increase by switching codes as you have officials, coaches and players who will be forced to compete under rules that have not had the proper time to be implemented and practiced. In the same poll mentioned above, 54% of officials statewide believed they would not be able to safely and competently officiate football games if the switch to NFHS rules is made. Student athletes will have 2-3 weeks (or less) to be coached and practice before they enter their first competition. The issues of training officials under a compressed timeframe will be discussed below.
Health and safety: This is the most important aspect, and one we, as officials, strive to put above all else. There are a myriad of issues with switching codes. The actual safety rules are one. A review of the differences in the codes reveals that NFHS rules have legal acts that are illegal under NCAA rules. These include:
- • A chop block, a very dangerous play, is much less strict under NFHS rules. Coupled with a high block, the low portion of the block against the same player under NCAA rules has to be at the thigh or below to make it a foul. Under NFHS rules, the low block only has to be below the knee to make it a foul. This increase in chop blocks can lead to serious player injuries.
• There is no avenue for a quarterback to legally ground the football under NFHS rules. Under NCAA rules, a quarterback who has left the tackle box may legally throw the ball away so long as the pass reaches the original line of scrimmage. Under NFHS rules, the quarterback may never throw the ball away without taking a penalty for intentional grounding. This will lead to quarterbacks holding on to the ball much longer for fear of penalty until they are eventually hit, seriously increasing injury potential.
• Wedges on kickoffs are legal under NFHS. This is a dangerous return tactic that allows three players or more to form up shoulder to shoulder with the ball carrier tucked in behind them.
• Overbuilt facemasks (facemasks with very small openings among a tangle of bars) are legal. The NCAA eliminated these as they can cause broken fingers when fingers are jammed into the small openings. The overbuilt facemasks also cause more strain to the neck because of the increased weight.
• Under NCAA rules, forcible contact at the knee or below of a player in a passing posture is illegal, whether the contact is late or not. (Think Tom Brady 2008)Under NFHS rules, this contact is legal.
• Leaping is legal under NFHS rules. This occurs when a defensive player can make a running start and leap up to vault over the offensive line. This creates a dangerous situation for not only the offensive players who are landed on, but the leapers themselves. The MIAA consultant stated that NFHS will only consider changing this rule when a player gets seriously hurt.
• The use of leverage to block a kick is legal under NFHS rules. This means a player may propel himself higher using the body of a teammate or opponent to leap up and block a kick. This is illegal under NCAA rules due to serious injury potential to the player making the block and/or the player being used for leverage.
• Blocking out of bounds is illegal under NCAA rules, but legal under the NFHS code. This occurs when a player blocks an opponent outside the field of play and can cause injury as the action continues to the bench, track, fence, or whatever is beyond the playing surface.
• Under NCAA rules, it is illegal to line up three defenders on a single offensive lineman with the intent of overpowering the offensive player. This can cause serious injury. NFHS rules allow this practice.
• Under NCAA rules, the kicker is protected from contact except by the player who blocks a kick. NFHS rules allow contact by any defender once a kick is blocked. This leads to unwarranted contact and potential injury to the kicker. It does not allow other types of personal fouls.
In recent years the NCAA has been proactive in protecting player safety, while the NFHS has been reactive. There are other rules in the NCAA code that encourage “behavior modification” for actions that can lead to injury if not checked. These include:
- • Touchbacks and fair catches inside the receiving team’s 25 on kickoffs result in placing the ball at the receiving team’s 25. Both the NCAA and NFL had modified this rule to reduce the number of kickoff returns, during which a disproportionate number of injuries occur. NFHS rules do not have this provision, which encourages more returns.
• Targeting is not an automatic disqualification under NFHS rules. Targeting is when a player uses the crown of his helmet, or makes forcible contact fitting certain parameters above the shoulders of a defenseless player. By disqualifying a player, it is a double whammy with both the yardage and the disqualification (with an additional game under MIAA guidelines). By not having an automatic disqualification, players are more inclined to target as the penalty is no different than for defensive pass interference. Forcible contact to the head of a player is the most serious type of play you encounter in a football game. The NCAA has done a tremendous job in changing the culture of high hits in football. According to the MIAA consultant on NFHS rules, “The NFHS still hasn’t decided what they want to do with targeting.” We are taking a serious step back by moving to a set of rules that does not require disqualification of a player that makes forcible contact to a defenseless player’s head.
• NFHS has retained the 5-yard face mask foul for an “inadvertent” facemask, while all facemask fouls are 15 yards under NCAA rules. The extra yardage is in a way a behavior modifier as players tend to think twice about even putting a hand on the facemask. Also, the NCAA realized that officials were more apt to penalize only the five yard penalty, even in the case of a sever act that was deemed dangerous. As a result, all penalties were made 15 yards.
• One of the major differences is the time of periods. NFHS rules mandate 12 minute quarters on all levels unless 9th graders are playing with 7th/8th graders. With the MIAA’s latitude under the current set up, high school varsity games are 11 or 10 minutes. It is a known fact, and common sense tells you, the longer the game, the more fatigued players get, and fatigue coupled with longer playing periods leads to more injuries. In addition, many of the small schools (the ones generally playing 10 minute quarters), have smaller rosters. Asking these schools especially to increase their playing time 20% is only looking for trouble on the injury front. This adds to the argument that there is more legal vulnerability to switching to NFHS rules. Keep in mind that modifying the playing time would drop the MIAA from the national rules committee, and thus defeat one of the reasons for the switch.
• NCAA rules consider the pushing and shoving after the play is over as unsportsmanlike fouls, as opposed to personal fouls under the NFHS rules. This gives officials a modicum of control in that two unsportsmanlike fouls result in a disqualification, as opposed to piling up personal foul after personal foul which can lead to bad blood and an incident we don’t want in the game. Coaches in MA many times take the offending player out of the game after his first unsportsmanlike foul in order to a) counsel him, b) protect him from disqualification and the further game suspension that results under MIAA ejection codes. Reverting back to calling these fouls personal fouls takes away a valuable tool for officials for game control and sportsmanship.
• Blocking below the waist by linemen on punt plays is legal on scrimmage kick plays under NFHS rules. The NCAA legislated this dangerous practice out of the rules many years ago.
• Blocking below the waist by defensive lineman against an offensive player in position to receive a backward pass is legal in NFHS.
• Tripping the ball carrier and including the name plate for horse collar tackles were just added to the NFHS rules for 2019 (both previously added by NCAA), which further indicates that we are taking a step back from a set of rules that is far more proactive.
There are some rules under the NFHS code that are “safer”, i.e. the blocking below the waist rule (although the NFHS rule is much more difficult to officiate), and horse collar tackle which is illegal anywhere on the field, despite being legal in the tackle box under NCAA rules. As previously noted, the MIAA is the rules making body under the current set up. If safety is the issue, modify the MIAA blue book to conform with not only the safety rules, but any rule that seems inequitable. This would be a much more measured and easily implemented approach. Changing a dozen rules and having to learn and implement them, is much easier that having to do the same with 238 rules not to mention a completely different means of penalty enforcement.
As noted above, playing time is 12 minute quarters under NFHS rules. According to the MIAA consultant, this has resulted in 2:45 games or longer in CT. This same consultant also states that many more injuries occur in the fourth quarter than any other due to fatigue. The typical MA game is shorter by 30 minutes or more, especially for games played with 10-minute quarters. In addition to the injury risk from fatigue and the longer length of games, there will be additional costs to schools due to the extra time for staff (grounds staff, custodial staff, police details, bus drivers, etc.) There is also the additional cost for officials who will have to be compensated for the increase in playing time. As noted above, only certain rules can be modified. Uniforms, especially jerseys, are not one of them. Under the current set up, the NCAA uniform rules are suspended by a modification in the MIAA rule book. Since the NFHS code does not allow this, it is likely many schools will need to purchase compliant uniforms and other equipment to comply with NFHS rules.
- The various officials associations have been looking at how to implement the new rules. The logistics are formidable and create a level of unease as to the ability of officials to prepare in a condensed time frame to be able to officiate in a safe manner and a high level. The issues include, but are not limited to:
• Attrition of experienced officials to concentrate on college officiating, or simply leaving the officiating ranks due to the lack of desire to spend the time and effort to learn a new set of rules given the time many have put in over 5, 10, 20+ years. This drain of experienced officials leaves a lack of “senior” officials to help assist younger/newer officials both on field and off.
• The current association that high school officiating boards have with the local college boards would be virtually gone. Massachusetts is proud to have many local officials who started in high school football and who have or currently officiate at the highest levels of college football. So many of these officials still officiate high school games and have been great mentors to our younger officials. The impact of the mentorship by these
highly experienced, seasoned officials will be greatly diminished if not completely lost with this significant change from NCAA rules.
• Lack of training materials is putting associations in a poor position to start their training programs. As noted above, books and materials are not available and until they are, associations cannot set up their programs in a timely manner and will be less prepared come September. Even after training programs are set and in full swing, it is naïve to think officials will be at the same proficiency level they are at now after 2-3 years of officiating under NFHS rules, let alone by September 2019. In essence, the first week of the season in September, high school games in MA will be officiated by officials doing their first game. It is hard enough to have one rookie official in the crew who is not trained in the rules, never mind the whole crew. Having officials not properly trained in the game puts the safety of student athletes at risk.
• Setting up training programs in the offseason is also a challenge. A large percentage of officials officiate other sports, and do not have the time to devote to football until football season. This will result in the inability of officials to attend training sessions put on by their associations. Some officials have decided to cut back on their other sports, which will take quality officials away from their other sports in order to learn the new rules. This will result in a shortage of quality officials in winter and spring sports. Another roadblock to attending training is family considerations. Many officials who are football only officials plan their family time and obligations around working football in the fall and spending the offseason attending to family. Attending offseason training can result in non-optimal family situations, which may drive even more officials away.
• Practice makes perfect: as with anything, repetition makes for good learning and training. A typical official will do a minimum of 10 sub-varsity or youth games in their training season, and will take 2-3 years to reach the varsity level. There will be no such opportunity going into this season, with the potential of 1-2 scrimmages available to each official, which are rarely played under game conditions and usually consist of 10 plays for one team, 10 for the other, with penalties not enforced. This lack of practice will also lessen the proficiency of officials.
We hope you consider the positions outlined above and have a meaningful dialogue with MIAA officials to rescind the decision to switch to NFHS rules. It seems foolish to make a change for what appears to be change’s sake. There is no discernable advantage to switching to NFHS, while the significant downside is clearly evident. Should you have any questions, do not hesitate to contact us at firstname.lastname@example.org.
Bill Graham, President
Massachusetts State Football Officials Association (MSFOA)