scorecardresearch Skip to main content
NH Education

Report: New N.H. education rules lower standards, usher in privatization

Educators sound the alarm on an overhaul of education rules that the report’s author, Christine Downing, said would dismantle public schools in the state

A social studies classroom at a New Hampshire high school.Vanessa Leroy

CONCORD, N.H. — Christine Downing left a November 2022 meeting in Laconia troubled but determined.

A group of about 50 teachers and administrators had gathered to give input on new education rules with broad implications for public schools.

But Downing, who has worked in education for 30 years and is the director of curriculum, instruction, and assessment for Plainfield, Grantham, and Cornish school districts, said two days to review snippets of the sweeping changes was not enough time. Nor, she said, were all the right people in the room: Content experts needed to weigh in.

She made it her mission to correct that over the past year, insisting that teacher feedback be considered and then gathering that feedback herself, which she has now published in a new report.


“When you start looking down in the details, this is a complete dismantling of public schools as we know it in New Hampshire,” she said.

The state contracted the National Center for Competency Based Learning, led by Fred Bramante, to create the new rules.

Downing’s report found that proposed updates to the state’s education rules would lower the standards schools are legally required to meet, while opening the door to privatization. It raised concerns about education being moved increasingly online, which Downing said could lead to more programs like a recently approved controversial PragerU financial literacy course.

Educators were also worried the rules could bolster other controversial programs, such as the voucher-like Education Freedom Account program that allows eligible families to spend public school funding on private education or supplies for homeschooling.

“It seems the Commissioner, in particular, is more interested in pushing the controversial voucher program, and stretching rules and laws in support of it, than in a real commitment to funding and encouraging the work being done with the majority of NH students, who are learning in our public schools, supported by the public school teachers whose voices are missing from these rules revisions,” an educator quoted in the report said. Educator feedback in the report was kept anonymous.


In a written statement, the New Hampshire Education Department responded, and said the department and its commissioner “are laser focused on trying to make sure that all New Hampshire students, in any learning environment, can achieve bright futures.”

“Different educational systems need not be pitted against one another, but should work in concert to help students succeed,” the statement continued. The department rejected the idea that the new rules lower standards and argued they will do the opposite, “by enabling all students to work toward high academic outcomes.”

Addressing concerns about privatization, the department’s statement said, “The proposal will increase educational opportunity so that all students can succeed and so that students in our traditional public schools are not disadvantaged.”

Downing wants the issues teachers highlighted in her report to be addressed before Bramante presents a final draft to the New Hampshire State Board of Education for review, which he expects to happen as early as December. Downing said that, as proposed, lowering minimum standards means school districts without financial means will have to cut programs they are no longer required to maintain.

The report included the participation of 176 educators, and 57 left responses through an online feedback system.

“What’s the impact to our public schools? It’s going to be a commodification and privatization of education that is going to widen this gap of haves and have nots across our state,” Downing said.


Bramante said he has met with Downing and plans to meet with her again. He said she raised some good points, but he rejects the idea that the new rules lower standards, arguing it does just the opposite and that some educators are committed to an old educational model.

“There are folks — and I get it — that are protective of the system we are trying to change,” he said.

Rather than a teacher imparting knowledge to a student, he said he’s working to create a system that isn’t predominantly in the classroom, but happens “anytime, anyplace, anyhow, any case, with students being a primary driver of their own learning and students making decisions on how they want their learning.”

According to Bramante, the concerns Downing raised over privatization and commodification are a feature of this new system, not a bug. He encouraged more businesses, nonprofits, or “talented individuals” to “bring those talents to public education.”

“We’re saying, absolutely, we want more,” he said.

The report comes after Bramante presented an initial proposal to the State Board of Education in March. The nonprofit he leads, the National Center for Competency Based Learning, created a 13-member task force to work on the initiative.

He said he will meet with a working group to go over recommendations on Nov. 7 and then meet with the task force one more time, before the final draft is brought forward.


Bramante said there will be “significant” changes to the final draft he plans to present to the board.

In a written statement, Megan Tuttle, the president of the National Education Association of New Hampshire, a union that represents teachers, urged the department and Board of Education to “truly listen to and incorporate the collective wisdom of the experts — educators.”

She praised Downing for her work facilitating educator feedback, and noted the overhaul will impact students, teachers, and outcomes.

“That’s why it is so disappointing that educators have not been meaningfully involved by Commissioner Edelblut, the Department of Education, and its subcontractors in this process,” she said. “This lack of input has led to a process that allows the DOE to undermine public education directly through administrative rulemaking.”

Amanda Gokee can be reached at Follow her @amanda_gokee.