Questions and answers about the proposed Learn Everywhere program

On Thursday, June 13, the State Board of Education (SBOE) will decide on whether to move forward with “Learn Everywhere,” a proposal from Department of Education (DOE) Commissioner Edelblut, that would outsource classes in New Hampshire public high schools to private and nonprofit organizations that apply directly to, and are approved by, the SBOE.

Learn Everywhere would require public high schools to award credits toward high school graduation for programs that students attend at approved private and nonprofit organizations separate from school. The most recent draft of the rules is available here, and is included in the SBOE’s public meeting materials.

Over the last seven months, we have heard a number of questions regarding the program — we have provided answers below. If you have a question, let us know at!


“Can’t students already participate in programs that offer credit outside of their high school building?”

Yes, high schools across the state are already capturing the student learning that happens outside of the four walls of the school through internships, volunteer work, independent studies, online learning, and Extended Learning Opportunities (ELOs), all of which are approved and offered through local school districts. This year alone, almost 7,000 high schoolers have participated in at least one ELO, in industries such as nursing, physics, dentistry, engineering and defense, law enforcement, and media art. Students took ELOs in advanced art, automotive mechanics, calculus, quantitative reasoning, US Government and History, cultural climate exploration, equine therapy, horticulture, and more. Students have received credit for student teaching experiences, participation in robotics programs, and online courses.

ELOs are offered through local school districts and allow students to pursue their interests outside of the classroom and earn credit toward graduation. Students work with a dedicated educator (sometimes an ELO coordinator, other times another mentor within the school), who helps the student create an ELO that is rigorous, meaningful, and tailored to that individual student’s needs and interests, yet are aligned to the school’s requirements.

Many New Hampshire schools also participate in Early College programs, where students take courses at their local community college, taught by college professors and with other college students, while earning both high school and college credit.

Learn Everywhere, on the other hand, would remove the school’s ability to determine whether or not the Learn Everywhere course meets the school’s academic rigor and aligns with the school’s course sequencing. For example, if a student takes Algebra I through a Learn Everywhere program, there is no guarantee that it will prepare them appropriately for a school’s Algebra II course because Learn Everywhere courses do not have to align to that school’s curriculum.

“What prompted these rules?”

Learn Everywhere was made possible by Senate Bill 435, passed in 2018. The bill added a line to existing state law:

(b)  The state board of education shall adopt rules, pursuant to RSA 541-A, relative to the approval of alternative programs for granting credit leading to graduation.

However, both the House and Senate have passed Senate Bill 140 this session, which would reverse the authority of the State Board to adopt the Learn Everywhere rules and give credit granting authority solely to the local school district. As of the publishing date of this post, Governor Sununu has not signed SB 140.

SB 140’s sponsor, Senator Jay Kahn, introduced the bill in February, telling the Senate Education and Workforce Development Committee that the “reach of the [Learn Everywhere] rules raises the question of what the legislative intent of SB 435 was. The legislative record leaves the impression that the alternative programs would be approved by school districts.”

During a public hearing on SB 140, House Education Chair Mel Myler, who voted in favor of SB 435 in 2018, was “shocked” and “stunned” at how the Department of Education had interpreted the rules, and that the proposed program went “far beyond anything that was ever spoken about during the hearing” on SB 435.

Representative Mary Heath also testified, saying that she asked the DOE Commissioner “if this would change the authority or usurp it from the local school board and was told it would not.”

The bill goes to the Governor’s desk, where he can sign it, veto it, or do nothing, where it will become “law without signature.”


“Would my student have to apply for a Learn Everywhere course?”

Because these are privately-run programs, Learn Everywhere providers may have an application for admission and/or cap the number of students they accept. However, the rules state that the admissions process must not be designed, intended, or used to discriminate or violate individual civil rights.

“What would my student learn in a Learn Everywhere course?”

As written, it is unclear if/how Learn Everywhere programs would align with the state’s academic requirements. The rules specifically state that the Learn Everywhere programs must align with the Minimum Standards for Public School Approval (MSPSA), but these do not include the specific learning benchmarks that are set out in the State Model Competencies. MSPSA only lays out the overall content that must be offered in a public high school.

It is unclear whether Learn Everywhere programs would have to align their course objectives and content with those of the student’s local public school. If Learn Everywhere programs are allowed to create their own course objectives, there is no guarantee that they would prepare students for higher level coursework.

For example, if a student receives their credits for Algebra I and II, Geometry, and Pre-Calculus through a Learn Everywhere course, it may not properly prepare them for Calculus at their local public school because the learning benchmarks of those prerequisites may not align.

“Would a Learn Everywhere course count for my student’s prerequisites?”

This is unclear. The rules state that a district must accept a Learn Everywhere certificate of completion and must award credit toward the student’s graduation credit requirement, but it is unknown whether a district must accept that credit as a prerequisite.

For example, a student wishes to take AP Physics and must take a lower-level science course. If they receive credit for the lower-level course through a Learn Everywhere provider, it is unclear whether that would satisfy the requirement for the AP Physics course.

Students with Disabilities

“Would Learn Everywhere courses be included in my child’s Individualized Education Program (IEP)?”

The rules state that districts, through the IEP team, may decide “to redraft, revise, amend, or modify the [student’s] IEP” to include a Learn Everywhere program. Since they are privately-run programs, any student who meets the eligibility criteria could take a Learn Everywhere course, and the district must accept the credits.

“Will there be additional money for schools to support Special Education students in receiving services?”

The rules state that a student’s home district is responsible for all costs relating to special education, including accommodations.

For example, if a student requires a one-on-one paraeducator in the classroom, the district would be responsible for providing that paraeducator to the student’s Learn Everywhere program site, even if the program is off of school grounds, outside of regular school hours, and/or held during weekends and/or the summer.

There is no additional funding allocated for Learn Everywhere programs or the accommodations required by a student’s IEP. Any additional funding would have to be awarded by the Legislature.


“Would Learn Everywhere programs save districts money?”

At his presentation in Dublin, the DOE Commissioner discussed how districts could save money through “shrinking” programs offered in their public high schools and sending students to privately-run Learn Everywhere programs.

With courses offered through Learn Everywhere programs, schools may cut their course offerings due to the availability of off-site courses, low course enrollment, and other factors–potentially saving districts money. However, since families are responsible for program costs, fees, and transportation, students without the means or ability to attend an off-site class would not have access to such programs.

“Will all Learn Everywhere programs cost families money?”

There is not a clear answer. The references made in SBOE meetings have been examples that would likely cost families money: participating in the McAuliffe Shepard Discovery Center summer camp, for example, is listed as $345 for a five-day program. Read more about the potential costs to families, including other programs that have expressed interest in participating in Learn Everywhere, here.

Additionally, there may be costs for the organizations to offer Learn Everywhere programs: staff, for example.

Next Steps

“What is the next step?”

The State Board of Education is set to vote on the proposed rules that authorize Learn Everywhere on Thursday, June 13. If the State Board votes to accept the rules, they will go to a legislative committee called the Joint Legislative Committee on Administrative Rules (JLCAR). JLCAR will review the rules and ensure that they are within the scope of the department.

“What will JLCAR look for?”

JLCAR must make sure that proposed rules are not:

(a) Beyond the authority of the agency;

(b) Contrary to the intent of the legislature;

(c) Determined not to be in the public interest; or

(d) Deemed by the committee to have a substantial economic impact not recognized in the fiscal impact statement.

“Will there be another public hearing?”

Although the SBOE’s public hearing was in February, they are accepting public comments right up until their vote on June 13 via email, phone call, or in person during their meeting. All State Board meetings have a public comment period at the beginning of the meeting, typically around 9 a.m. Read more about offering public comments to the State Board here.

JLCAR also accepts public comment at the beginning of their meeting. If the State Board approves the rules, JLCAR could hold a public meeting on them as early as Friday, June 21. JLCAR meets in Rooms 306/308 of the Legislative Office Building in Concord.