Outpouring Of Public Comments on Learn Everywhere

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On February 14, teachers, administrators, school board members, and parents lined up to testify on the Learn Everywhere program and the proposed rules that authorize it.

The proposal would allow the State Board to approve programs that would award academic credits for learning outside the classroom, including programs run by nonprofit and for-profit organizations like the Girl Scouts of America, Big Fish Learning Academy, and others. Read more about the Learn Everywhere program and how it compares with existing opportunities for our students here.

Overall themes from the public comments:

  • Many noted that by giving the State Board the authority to grant academic credits, the Learn Everywhere program would supercede local control;
  • There are a wide range of existing opportunities for students to earn academic credits learning outside of the classroom, including Extended Learning Opportunities (ELOs), the most frequently referenced, and many members of the public expressed concern that Learn Everywhere would jeopardize those programs;
  • Some highlighted that there is a lack of clarity around the implications for students with disabilities and the impact it would have on their learning and access to Learn Everywhere programs (which unlike programs offered via public schools, like ELOs, are not required to accept and work to meet the needs of students with disabilities);
  • Some raised concerns that programs authorized as a part of Learn Everywhere will have costs (enrollment, materials, supplies, etc.) that would make them inaccessible to many students;
  • Some commented that Learn Everywhere would further promote innovation and maximize learning by allowing students to earn credits for more of what they are already doing outside the classroom.

The hearing lasted nearly two hours. A video of the hearing is available here.

About Learn Everywhere

As noted in this post, Learn Everywhere comes from the rules proposed in response to Senate Bill 435, legislation passed in spring 2018. Learn Everywhere authorizes the SBOE to grant credits towards high school graduation for out-of-school learning opportunities, which the student’s school must count as academic credits towards the student’s graduation.

Once nonprofits and for-profit institutions receive a license from the State Board of Education, they can begin to offer credit-bearing opportunities to students. Students and families are required to pay any program expenses that the institution may charge, including tuition costs, registration fees, transportation, etc. The credits students earn through the Learn Everywhere programs authorized centrally at the SBOE (as opposed to locally at the district level), must be accepted by the student’s school district. Those credits would then go toward earning a diploma, issued by that district. In public comment during the February 14 SBOE meeting, it was noted that a student could then earn all the credits needed to be issued a school district’s diploma, without ever attending a public school in that district, and without meeting the district’s own locally-established standards for a high school diploma.

In some respects, Learn Everywhere is similar to opportunities currently available to students across NH. The differences are largely in process. For example, while ELOs are developed and authorized locally, Learn Everywhere proposes using the SBOE as the authorizer. It is the job of ELO coordinators and educators to ensure that ELOs adhere to the school’s academic standards. In Learn Everywhere, the State Board is responsible for ensuring that the licensed program meets minimum standards.

Concerns over local control

New Hampshire does not have state-mandated academic standards. Districts are responsible for adopting their own standards, creating their own curriculum, and ensuring that their course offerings are meeting locally-determined benchmarks for learning. School boards and administrators set policies regarding courses and graduation requirements (though the state does set minimum graduation requirements) with input from their community members and taxpayers.

Residents like Janet Ward from Hopkinton are concerned that Learn Everywhere could supercede local control:

“Only local school districts should have authority to grant credits toward graduation. I live in Hopkinton, I pay taxes which support my local high school. Each year, I can participate in discussions of Hopkinton High School’s curriculum, teaching staff, and facilities at local school board meetings and at the annual school board meeting…”

“I have input and oversight on where my tax dollars are being spent… the State Board must not be allowed to overrule local control of education,” she continued.

Dr. Bonnie Robinson, the Director of Curriculum, Instruction, and Assessment at Lebanon High School, echoed Ward’s sentiment:

“The cornerstone of support of our ELO program is the ELO coordinator as the gatekeeper of experiences and credits. It is through this path that academic integrity is maintained, that certified educators oversee all student learning, and that community members become partners in our students’ education. We feel the strength of our program would be jeopardized without the ELO coordinator there to assure accountability.”

“We believe in the rights and responsibilities of school boards to create the policies, establish the funding, and make all decisions of what is best and most important for the town they serve. Well-meaning nonprofit agencies already have a pathway to participate in our students’ learning, but the control of credits is, and should be, the responsibility of the local school.”

Giving students an alternative path

Diane Murphy, founder of Big Fish Learning Academy in Dover, told the State Board that she was excited when the DOE Commissioner met with her last summer to talk about how her school, a self-directed learning community, is helping students to learn outside of the system. She expressed support for Learn Everywhere:

“We’re not in the business of counting credits. We help students navigate their own way… I think Learn Everywhere could help families with their children have an alternative path, and access places like Big Fish. We all can agree that we have a shared vision that kids need a good way forward.”

She continued about how places like Big Fish’s model is different than the traditional public school:

“Our model is centered in mentorship, we have a good community of mentors… we do offer classes, we have a few certified teachers but we have a lot of non-certified teachers and that’s the beauty of it. We want to see a more intergenerational piece to it–aunts, uncles, grandparents, college students coming in [and teaching].”

Concerns for students with disabilities

Bonnie Dunham, a parent and well-known advocate for students with disabilities, testified on the rules authorizing Learn Everywhere and their potential impact on students with disabilities. She went on to urge the State Board to address the potential costs to families when they enroll students in a program that grants credits under Learn Everywhere:

“If an LEA [local educational authority, or the student’s assigned public school] is only responsible for paying for special education-related services and other supports and services a child needs to participate in the Learn Everywhere program, I believe the rule should make this very clear so the parents know when they might have to be responsible for paying and providing the services that their child needs.”

Families and students could still incur significant costs, as they are still responsible for program costs and any other services that may be required, even if they are mandated by an IEP.

A statewide credentialing approach

Over 10,000 girls participate in Girl Scouts of Green and White Mountains, with programs focused on STEM, healthy living, and the outdoors. Patricia Miller, CEO of the Girl Scouts, told the State Board that through Learn Everywhere, girls could receive credit for the programs they participate in.

“This proposal allows girls to experience what they want to do in a way that still meets their educational requirements and needs today. We believe that allowing girls to receive credits for our signature programs… will provide a double educational benefit for all of our students,” she told the State Board.

She also supported the centralized structure of the proposed rules and disagreed with other comments that the authority to grant credits for learning outside the classroom should remain under the control of local districts:

We strongly support a statewide credentialing approach, as it would allow statewide nonprofits such as ours to ensure uniform standards across jurisdictions. It would be extremely difficult for our organization to seek district-by-district approval for our programs. And we run the risk of each district requiring different standards, different paperwork, different processes, and different proposals to be filed. We must ensure that our resources go to the girls we serve rather than being spent on multiple applications across multiple school districts.”

Concerns about state overreach and lack of support

The NH School Boards Association (NHSBA) offered comments in opposition to the proposed rules. “Simply stated, Learn Everywhere represents an overreach of the state,” said Nicole Heimarck, Director of Governmental Relations at NHSBA.

“We have had some concerns about the narratives out there about Learn Everywhere. One of those is that ELOs are spotty, are in pockets, and that that is evidenced by the 41 ELO Coordinators we have here in New Hampshire. NHSBA attempted to collect some data, the metric of 41 ELO coordinators is not a measurement for the implementation of ELOs and we have built a wordle that demonstrates all the different titles and all the different roles that support ELOs in our schools: School to Work Coordinator; Counsellor, Career Counsellor, College and Career Readiness Counsellor and the list goes on… What we were able to uncover, is there are a myriad of titles in our schools that facilitate ELOs across our state and that is not a fair metric,” Heimarck explained.

“We had 52% of the state’s high schools respond to our survey… 2500 opportunities were reported last year…over 3300 have been reported this year, and that does not account for spring semester enrollments. So these opportunities are robust and growing,” Heimarck added.

In his comments, Barrett Christina, Executive Director of NHSBA, told the State Board that the proposed rules don’t address the challenges that schools face in giving students out-of-classroom learning opportunities like ELOs, namely transportation costs and liability. He said that districts have faced these problems for years, but Learn Everywhere does not solve or address them.

Christina went on to note that guidance from the DOE in support of ELO implementation does not exist.

“Please go to the Department of Education website and look for the technical assistance advisories on there regarding Extended Learning Opportunities, or go to the technical assistance advisory page and look for the one on Extended Learning Opportunities. I direct you there because you won’t find one.”

Christina urged the SBOE and the DOE to redirect their efforts to supporting the work already underway across NH.

“So, instead of creating a new program, let’s focus our efforts on helping those behind us who are already implementing these things, and on helping the school boards, administrators, and more importantly students, fully engage in these Extended Learning Opportunities within the system of program that districts have already spent the better part of a decade trying to build up.”

Concerns for the future of existing programs

Extended Learning Opportunities are available to every student in New Hampshire. Working in collaboration, school faculty, students, and community partners develop an ELO that is relevant to each student and his or her course of study. This can take the form of an independent study, private instruction, internships, community service, or work-study.

These are immersive and rigorous learning experiences where students can earn course credits, develop soft skills, professional skills, and research experience that they can leverage in the college and career application process.

But according to John Freeman, the Superintendent of Pittsfield School District, the Learn Everywhere program could put ELOs in jeopardy.

“In a small town in Pittsfield, we have several hundred opportunities for ELOs. [We have worked with] folks who are not likely to approach the SBOE or DOE–and they are not likely–to list themselves as providers of credit-bearing programs, but are willing to respond to our ELO coordinator and connect kids to real folks in the community.  Because of their community spirit, their generosity, and their association to Pittsfield, they have made significant contributions. But I see that evaporating under this plan.”

What happens next

As outlined in the NH Department of Education Rulemaking Process, the rulemaking process can take several months. During the hearing, Chairman Drew Cline announced that the SBOE would receive public testimony in written form through February 20.

Below is the contact list for current state board members. Your comments and viewpoints will be welcome and appreciated.

State Board Member Contact List

Drew Cline, Chairman: ACBOE@comcast.net
Sally Griffin: griffinweb1@gmail.com
Kate Cassady: kcassady@allstaffcorp.com
Helen Honorow: hhonorow@barrylawoffice.com
Cindy Chagnon: chags@comcast.net
Ann Lane: annlanenhsboe@gmail.com
Phil Nazzaro: pnazzaronhboe@gmail.com

After the close of the public comment period on the 20th, the Department of Education will review and consider the public comments. They will draft a final version of the rules, which should consider input from the public and incorporate any edits from the Office of Legislative Services staff attorneys.

The final draft of the rules are then brought before the State Board of Education. Given the timeframe, this could be as early as their next scheduled meeting on March 14. If the State Board approves the rules, they are sent to the Joint Legislative Committee on Administrative Rules (JLCAR) for review. If the SBOE does not approve the rules, they are sent back to the DOE.

Once submitted to JCLAR, the committee will consider the proposed rules at their next meeting. If the DOE submits the final rules to the SBOE in March, the SBOE could vote as early as April and send the rules to JCLAR for review in June.

JCLAR accepts written comment and welcomes public comment at the meeting. Agendas are posted here.

Do you have questions on experiential learning programs available to students in New Hampshire? Do you have thoughts to share about new proposals like Learn Everywhere? Let us know at staff@reachinghighernh.org.