Rochester School Board Member Susan O’Connor submitted this letter to the Joint Legislative Committee on Administrative Rules, which is reviewing proposed rules changes to ED 306 submitted by the NH Department of Education.  According to the NH School Boards Association, these rules would impose significant burdens on school districts across the state.  Critics are also questioning the broad powers granted to districts to perform psychological evaluations on students.  The primary mission of these rules changes is to install the Common Core national standards in NH, standards which the Alton and Manchester school boards have rejected and others, like Londonderry have sought, have sought alternatives to for testing.    ~Rich Girard

Dear Members of the Joint Legislative Committee on Administrative Rules:

My name is Susan O’Connor and I am a member of the Rochester School Board, I have seen first hand the poor outcomes associated with a number of decisions made by the NH BoE, I ask you to please take the time to read what I have sent as we are drifting so far away from teaching our children academics, the only reason why we send our children to school.  Our children are not being taught what they will need to be prepared for college or even the military.  Please reject Ed 306 and send it back to the NH BoE.


As a board member and taxpayer the following are my concerns with regard to the SAMSHA grant.


The grant is intended to address Substance Abuse and provide Mental Health Services/Safe Schools/Healthy Students Program.As a board member, I asked to review the data regarding the so-called “evidence-based programs”, what are they, who developed them, who has utilized them and what are the “effective policies” and “innovative strategies” that are going to be utilized in our schools? To date, I have received none of this information.


Actual award amounts are subject to the availability of funds. If we do not receive our “allotted” funding of 1/2 a million, what teaching positions are we to cut?  I would find it very difficult to eliminate a teaching position to accommodate the positions being hired through the grant.  If one is hired through the grant it should be made perfectly clear that no grant funding = no job.


RSA 189:49 IV lists psychological services as an optional service. The DoE has overstepped its bounds in its attempt to mandate this program. I am concerned the district and their “community partners” ignoring parental consent.  When asked about parental consent, the board was informed that this was an area that was being looked at.  Parental consent is paramount. Parents need to make their own decisions regarding a psychologist or any treatment, if truly necessary, to ensure that their child’s medical records remain confidential.


Parents are their child’s primary educational providers and control over their children begins and ends with them.  A parents desire to protect their child’s privacy is rational and they have the right to decide whom their child’s most sensitive information is shared with.  The lines between family and school are becoming very blurred and should be raising red flags with everyone.


As LEGISLATORS you should have full knowledge of what the liability to districts will be with regard to referrals. What will the liability of the district be if a child is referred for services under this grant when the grant expires? This will definitely impact all budgets and how teaching positions will be funded. Unfunded, mandated social programs always survive.


The governor estimates 2500 children a year in the three communities will require psychological support services and 10,000 in four years.  That is a very high number, and I wonder what Rochester’s quota will be?


As the district is set to hire a social worker at the Middle School, drug and alcohol counseling for the district, behavioral interventionists at the middle and high school, and staff members to facilitate connections between families in need and community resources that meet those needs is nothing more than a duplication of services provided by a number of agencies at the state and local level.


As this grant was presented under the guise of Substance Abuse and Mental Health Services, who actually decides what child/children will be assessed, especially at birth?  What does that have to do with Substance Abuse and Mental Health Services? Who will assess these children/infants?  How far is the district/state prepared to go when a parent refuses to give their permission to have their child assessed?


What legal, ethical and professional practices are going to be put in place with regard to interaction with minor children and ensuring parental consent?


We appear to be moving away from academics and attempting to focus more on social, emotional and behavioral goals, It is the role of the public schools to educate our children for the future, not mold and decide what is or is not appropriate behavior, values and morals.


Competency Based Education:


Competency Based Education is the repackaging of Outcome Based Education, a system that failed our children miserably when introduced into our public schools over 30 years ago, and was subsequently removed.


Rochester implemented Competency Based Education throughout the district this school year. We were not ready whatsoever to have this thrust upon or teachers or our students.  As a board member and taxpayer, the community was lied to with regard to competencies. I have been made aware that teachers who questioned the competencies and did not let the issues drop were removed from the committee. To me this is a red flag.  Is this not why we have teachers on a committee, for their opinion?


Our children who excel are now bored, unmotivated, and suffer from mediocrity. There is absolutely no “rigor” to the competencies and I have seen the work from 2nd, 4th, and 6th grades and, in my opinion, it is substandard. There is less work performed this year than last.  No homework, children can redo work and assessments again and again and again. This is a practice in the middle and high school. Adults know that they cannot make the same mistakes again and again and again and expect to have a job. Why teach our children that way?


A lack of responsibility has reared its ugly head on the part of some teachers, administrators, and students.  An example of what is being taught in our schools in 6th grade ELA: For a 6th grade class’s first book report one must COLOR four pictures and label the pictures.  This may be rigorous for the students who struggle, but insulting to those who do not.  Those who are pushing Competency Based Education do not tell parents that “success” for all children means “success” in demonstrating only the dumbed-down outcomes that the slowest learners in the class can attain. Competency Based Education means “success” in mediocrity rather than excellence, as a true competency is precise and complex and needs to constantly be reviewed and updated.  There is no funding for special programs for gifted children.


Competency Based Education is based on the fact that the student has “mastered” the material. Most research/opinion papers/point papers are based on the fact that Competency Based Education had been implemented in the post-secondary education setting, with a major influence in the health science field, as competency based education takes into account life skills the learner needs and the demands of the workplace.  Given the age of the students who will be subjected to Competency Based/Outcome Based Education, if they have not “mastered” the material in the elementary grades what “life skills” will they be bringing to their future employer?


In elementary grades, Competency Based Education does not teach children essential reading, writing, and arithmetic skills, but pretends to teach them “higher order thinking skills” instead. Competency Based Education ignores the obvious fact that one cannot engage in higher order thinking until one has some facts to think about.


All of you should be asking, “Where is the replicable research or studies that show that it works?”


From research that I have read there is, as yet, no collection of mutually accepted achievements in terms of new theories on Outcome Based Education/Competency Based Education, there are no exemplary solutions to the challenge of total intellectual and potential development of learners, predication of the value of Outcome Based Education/Competency Based Education have not been proven and laws validating Competency Based Education as an acceptable practice and construct are not apparent.  In other words, no research base to verify the claims of Competency Based Education has yet been established and the claim of a major paradigm shift can therefore not be substantiated.


Competency Based Education raises the fundamental questions of who should decide what values, attitudes, and beliefs a child should be taught. It is a parent’s unalienable right to instill THEIR values and develop the attitudes and beliefs they want for their children, not teachers, not administrators and certainly not politicians.  The public school system has become a political battleground for adults and politicians and the one thing everyone has forgotten is the CHILDREN in this mess.


Susan O’Connor
Rochester, NH