“We Need to Have Educator Voices:” A Look at New Hampshire’s Revised Ed 306
Ongoing educational reforms in New Hampshire have sparked a debate in schools and the media about the New Hampshire Minimum School Approval Standards, commonly referred to as Ed 306. The New Hampshire Center for Justice and Equity (NHCJE) spoke with Christine Downing, Director of Curriculum, Instruction, and Assessment for SAU 32 (Plainfield), SAU 75 (Grantham), and SAU 100 (Cornish) about her 20-page report compiling feedback from 176 state educators on the proposed changes to New Hampshire’s Ed 306.
Educator Feedback is in the Best Interest of NH Students
The 306 rules serve as the bedrock for public school approval in New Hampshire, defining the minimum standards that all public schools must adhere to. Covering a wide spectrum of operational aspects, from curriculum and instruction to staffing requirements and policies, these rules are intricately linked to the RSA 193 E, which delineates the content of an adequate education in the Granite State.
Downing identifies a fundamental issue with the draft of revised Ed 306 Rules presented to the New Hampshire State Board of Education on March 9, 2023 — the lack of educator input. Despite her previous efforts to incorporate educator voices during her tenure at the Department of Education, Downing notes that the absence of educator voices in recent revisions can lead to standards and rules that are detached from the on-the-ground realities of teaching and learning.
“During the sessions, we practiced having an empty chair in the room to represent the students these rules are supposed to serve. And every time we had a conversation we asked: Is this in the best interest of the students?” - Christine Downing, author of the 2023 Educator Review Sessions Report
According to Downing’s report, only 5% of responses specify that the revisions represent an improvement, while a significant 70% of feedback responses indicate that further changes are necessary, and 25% indicate the revisions show no changes.
Proposed Language Changes Can Lower the Bar for NH Public Schools
One significant concern raised by educators in Downing's report revolves around the potential for inequities that might arise if the proposed changes are enacted. Educators fear that the new language used in the rules allows for a minimalist approach to meeting standards, creating disparities between financially struggling communities and those with more resources. Shifting to being broader in the rules leaves much more room for inconsistency from community to community, with schools with fewer resources having fewer offerings for students. .
“There’s a lead-in statement in all the content areas that reads something like this: the school board shall require X, for example, a mathematics program in grades one through twelve, which may include Y, Z… What this language does is allow anything that comes after the ‘may’ to be cut.”
Additionally, the removal of the word “local,” in front of “school board” in some parts of the revised Ed 306 document resulted in feedback that shows concern with reduced local decisions and the ability to make decisions reflecting a community’s specific needs.
“The schools have been looking for guidance to define what are our academic standards as a state, which means what are our must-haves in science? What are our must-haves in math? What are our state graduation competencies? This was an opportunity for the Department of Ed to own that.”
Specific to concerns around equity, the current Ed 306 rules explicitly identify equity as a responsibility of public school administrators, while the draft revision removes that responsibility completely. The existing requirement is that “school administration and staff shall:
(1) Review ways in which equity gaps in achievement can be reduced and barriers to learning can be eliminated; and
(2) Work together to establish a fair and equitable code of discipline that is fairly and consistently implemented, which supports students’ understanding of the importance of norms, rules, and expectations for behavior.”
In the draft revision most recently made public, however, the proposed change would require only that “school administration and staff shall develop a plan to address academic under-performance of individual students and the elimination of barriers to learning.” This revision removes the acknowledgment of inequity as a specific barrier to learning and could stifle progress in the fair and equitable education for communities of color.
Missed Opportunities to Advance Competency-Based Education in NH
During the feedback sessions mobilized by Downing, educators emphasized missed opportunities to enhance competency-based education (CBE). The report suggests that the lack of consistent academic standards furthers the struggle to implement competency-based education at the local level, contrary to the premise that revisions to the Ed 306 rules will advance CBE.
Educators believe the definition of competency-based assessment in Ed 306.02 does not include language about the importance of application and transferability as students demonstrate their learning in alignment with competencies. For them, the language around CBE reduces the concept of competency-based assessment to a quantity, such as proficiency concerning one or more competencies.
For Downing, competency-based education is not about legislating on the how but letting each local community find unique avenues to achieve state learning outcomes.
“The learning outcomes from kids have to be clear and transparent. But in that same breath is choice and student agency, or the different pathways students can take to achieve the outcomes relative to their interests, passions, strengths, abilities, or whatever it may be. And then I think learning feedback loops are essential to achieve this in and create equity in schools.”
Closing the Gaps with Updated Research
The third major theme of the report captures educator concern regarding missed opportunities to use evidence-based research to align the rules with current challenges faced by public schools, especially following the COVID-19 pandemic and the widespread use of online learning.
Educator feedback relating to outdated standards encompasses a variety of topics including class sizes that hinder competency-based learning, removal of facility standards, social-emotional learning, vagueness of content standards, and removal of equity language. Those who participated in the feedback sessions also expressed concern with changes in wording that open the door for young students to learn completely online through automated learning programs, as these contradict the New Hampshire State Board of Education’s vision of providing a "world-class, personalized, student-centered, education.”
For Downing, public schools are at the core of our democratic society but don’t get the credit they should:
“I have felt for years that public schools have been dubbed as this failing institution. I don’t think people are taking a close look at all the good things we’re doing and all the services we provide now. Go anywhere and you’ll find that you can have mental health counseling in a school. You have school psychology and psychological services, you have school counseling. You have occupational therapy and physical therapy. Our teachers are playing multiple roles. They’re not only teachers of content but teachers of social, and emotional learning, social skills, and emotional development. I challenge anybody to find a type of public institution that provides all these related services.”
Looking Ahead: Proposed Changes and Next Steps
Christine Downing's report sheds light on the complexities of revising New Hampshire's minimum school standards. For Downing, the crucial role of educators in shaping these rules cannot be overstated, and their feedback provides valuable insights into the potential inequities and missed opportunities within the proposed changes. An agreed sentiment from educators is the need for a student-centric approach, with a focus on competency-based education and addressing existing gaps in operational programming.
The new set of draft rules is expected to be proposed in December. As the state moves forward with revisions, it is essential to incorporate the extensive feedback received from the 176 educators who contributed to the report is crucial to that the Ed 306 rules reflect the best interests of students and support the continued success of public education in New Hampshire.
Christine Downing
Christine Downing is the Director of Curriculum, Instruction, and Assessment for SAU 32 (Plainfield), SAU 75 (Grantham), and SAU 100 (Cornish). She has 30 years in education as an NHED consultant, middle school math and science teacher, elementary principal, and central office educator. Her current volunteer project is to gather specific feedback on ED 306 from school leaders and educators to help in the process of editing the latest version of the minimum standards. Christine is passionate about supporting public schools and competency-based learning in NH.