Dek: Teachers, administrators and advocates worry that the revision of the 306 rules is being used to destabilize public education.

By Kelly Burch

Granite State News Collaborative

New Hampshire is nearing the end of a more than three-year effort to revamp the state’s core educational standards. When approved early next year, these new rules will steer the course of public education for at least the next decade. In this continuing series of stories, the Granite State New Collaborative will explore what those changes are, how they came about and what they mean for the future of public education in the Granite State.

There's no tongue in Fred Bramante's cheek when he calls himself the father of the competency-based learning movement.

“I want to destabilize the 20th-century system,” he said. “I want to disrupt it. That has been my goal since 2003 when we first stumbled upon this thing [CBE].”

For the president of the Durham-based National Center for Competency-Based Learning (NCCBL), which received a $50,000 contract in 2020 to revise the current minimum requirements for public school approval, it's pedal to the medal as he continues a decades-long push for competency-based learning, more commonly known as competency-based education (CBE). 

“I’m a 60’s kind of guy who was taught to question authority, and I like asking questions,” he said.

Bramante’s preoccupation with education reform dates even further back than his 2004 embrace of CBE. He twice ran for governor focusing on systemic educational change: first in 1996 as an independent, finishing third in a four-person race, and in 2000 as a Republican. On dropping out shortly before the 2000 GOP primary, Bramate told the Portsmouth Herald he had "no burning desire to be governor," but that his passion was to transform education.

That passion translated into his role as Chairman of the New Hampshire State Board of Education between 2003 and 2005 where he helped spearhead the state’s pivot toward competency-based education, convinced its focus on student-led learning and learning opportunities outside the traditional classroom was the way of the future. Bramante says he’s the longest serving member on the board of education, with stints from 1992-1995, and again from 2003-2013.

Bramante’s educational bloodlines go even deeper. Bramante taught eighth-grade science from 1970-1976 in Stanford, Connecticut, he said. His four children attended public school in New Hampshire in the Salem and Oyster River school districts, although Bramante himself attended a private Catholic School, Central Catholic in Lawrence, Massachusetts. There, he graduated 206th out of the 212 students in his high school class–an example, he says, of what’s wrong with the traditional approach to education. 

“School taught me that I wasn’t very bright and life taught me school was wrong,” Bramante said. “They totally missed me. How many other kids do they miss?”

Atmosphere of distrust

As the high-profile lead pilot for Granite State CBE reforms, Bramante continues to face flack for how the process is being conducted, particularly involving issues of transparency and inclusion. He, however, is undeterred.

“Too many efforts around [educational reform] have crashed and burned,” he said. “This one is not going to.”

Others, including about 30 people who gathered at Concord High School auditorium on September 12, aren’t so sure. The topic at hand was proposed changes to ED306, also known as the 306s, an administrative rules document that lays out the minimum standards for public school approval in the state. Yet much of the discussion focused on the mistrust between educators on one side and the state department of education and the Bramante-lead task force revising the 306s on the other.

“There was a lot of skepticism about the whole process here,” Val Zanchuk, a businessman and member of the 13-member committee, told the crowd, acknowledging a worry that parts of the revision could “create loopholes for people who had an anti-public school bent.” 

That’s at the root of the mistrust and skepticism for many educators: a belief that the Department of Education (DOE), led by Commissioner Frank Edelblut, cannot be trusted to protect the institutions of public education. 

“The real issue at hand is the people in control of this decision-making have been explicit in what their goals are for education,” said Sarah Robinson, a Concord School Board member and education justice campaign director at Granite State Progress, a progressive advocacy organization

Lack of transparency about the 306 revision process and concerns that the voices of educators are not adequately being considered as compounding their wariness over the changes, educators say.

“The trust isn’t there,” said William Furbush, superintendent of Epping School District. Without trust, educators are always concerned about the DOE’s “end goal,” Furbush said. “Are they trying to undermine public education?” 

The breakdown of the relationship between the DOE and educators in the state has led to an impasse, according to Furbush. 

“The trust isn’t there, so it feels like everything is a fight and not a collaboration to find solutions.”

A lack of educator input

The NCCBL formed the 13-person task force that began working on the revisions in January 2021, according to a letter the task force sent to educators in June 2022. Task force members, appointed by Bramante, included business leaders, educational policymakers and consultants, and two principals. However, the group did not include any current teachers. In fact, most educators didn’t know the process had started until the letter went out nearly two years after the contract to revise the 306s was awarded, they say.

“Our state’s educators are our state’s experts in education,” said Nicole Heimarck, executive director of Reaching Higher New Hampshire, a nonpartisan nonprofit focused on providing public policy resources around K-12 education in the state. “Their voice has been minimized in this process. Minimized at best.”

Bramante said that the task force “tried recruiting a little bit” to get more teachers, but “ultimately ended up doing a couple of things” to get teachers involved in the process. With that, he pointed to the work of Christine Downing, director of curriculum and instruction in SAUs 32 (Plainfield), 75 (Grantham), and 100 (Cornish).

Downing has held group sessions to review the proposed changes to the 306s with educators in the state. As of September 15, she had met with and received input from more than 160 teachers and administrators, she said. But when she first tried to start these focus groups in December of 2022, she “heard crickets” when she reached out to Bramante. Frustrated, she began collecting feedback from educators and ultimately shared it at a May public listening session held in the Kearsarge School District. Only after that, she said, did Bramante ask to see more of her work. 

“I am not representing the Department of Education, I do not represent Fred [Bramante]’s group. I just said I’m going to do this on my own as service,” Downing said. “I see how it’s been twisted here and there into different things.”

A revision process unfolding out of view

In the past, revisions to the 306s have been handled by the DOE, educators say. This time, the department contracted with the NCCBL, a nonprofit that Bramante founded in 2013, the same year his tenure on the state board of education ended. The NCCBL has the stated mission "to institutionalize real world, hands-on, learning opportunities for our students by serving as the prime catalyst in harnessing mentors at the local, state, and national levels."

According to its most recent tax filing for the fiscal year ending Dec. 2022, of the NCCBL’s 10 listed key personnel, only Bramante drew a salary– $37,262. The NCCBL reported a total revenue of $49,000 that year.

The contract between the DOE and NCCBL is a sole source contract, meaning that it did not go through a competitive bidding process, so there was little, if any, public awareness about the proceedings.

“I think it would go a long way if you named the fact that this relationship—with the way the contract came through and with the way it’s been communicated—that that’s been problematic,” Tina Philibotte, the chief equity officer in Manchester School District, told Bramante at a recent Concord public listening session. She noted that most educators didn’t know the task force had been contracted until nearly two years into the process.

“I think that’s part of the reason why that mistrust is coming,” she said. 

Partly in response to criticism, the NCCBL began hosting 11 public listening sessions to inform the public about the proposed revisions to the 306s and receive feedback. Critics pointed out that the listening sessions were not well publicized, highlighting another frustration around the 306 revisions: the process happens largely in private and with little legislative oversight.

This has been compounded by the fact that the current revision process is the fulfillment of a contract between the DOE and the NCCBL, with no requirement for public insight. 

"This is not a legislative process,” Zanchuk, a member of the 306 Taskforce, said at the Sept. 12 listening session. “It was a contract. Our contractual obligation is with the DOE. It’s not a public process. It’s a private process.”

That comment drew ire from the meeting’s attendees, especially when Zanchuck and Bramante mentioned that the proposed revisions suggested by the committee have sometimes been “gutted” by the DOE as iterations of the document are shared between the DOE and the task force.

"It’s not fair to us as community members to know there’s this negotiation going on out of the public view,” said Zandra Rice Hawkins, who was speaking at the session as a mother of school-aged children, but who is also the founding executive director of Granite State Progress. 

The only required public listening session for the 306 revision will happen after Bramante’s task force delivers their final recommendations to the DOE sometime next month and the state Board of Education enters the rule-making phase, a 180-day legislative process, Bramante said.

“All this stuff [including listening sessions] we’ve been doing for the last two and a half years, that was not required,” Bramante said. 

In fact, he noted, the DOE doesn’t need to accept his task force’s recommendations–or the public input they’ve integrated–at all. 

“They can throw the whole thing out,” he said. “I don’t think they will, but I don’t know.” 

The end of a competency-based assessment

Still another flash point between educators and the state was the failed attempt to reform how student achievement is assessed in a competency-based system.

“You can’t measure a competency by asking a series of multiple choice questions,” said Carla Evans, a senior associate at the Center for Assessment, a New Hampshire non-profit that has contracted with the DOE to create assessments that are compatible with CBE..

To address this problem, beginning in 2004, educators, consultants and members of the DOE developed the Performance Assessment of Competency Education, or PACE. The assessment was designed to reduce the amount of standardized testing that students took in order to better align with competency-based learning. 

The program started in four school districts and eventually expanded to 20.

However, in March 2022 the DOE scrapped the program citing concerns over scalability, a move many educators felt was at odds with the department’s stated goal of advancing competency-based education in the state.

Although PACE and state assessment is not tied directly to the 306 revisions, the decision to discontinue a program that many educators had worked hard to implement further damaged the relationship between educators and the state.

Brian Stack, former principal of Sanborn Regional High School in Kingston and a member of the task force drafting the 306 revision, said there’s an “absolute trust issue amongst educators, educator organization and the state right now.”

"I would probably join some of the skeptics in saying I don’t always have the trust either, because there have been an awful lot of changes that have happened in the department over the past several years—lots of different things, not just dropping of PACE…” he said. “I would question why that is as well.”

These articles are being shared by partners in The Granite State News Collaborative. For more information visit collaborativenh.org. 

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