Analysis: NHED’s Recommendations Overlook Concerns with Minimum Standards Overhaul 

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Concord, NH — On Wednesday, the NH State Board of Education is holding the first of two public hearings on two initial proposals that overhaul the state’s Minimum Standards for Public School Approval, which are the foundational rules that govern all public schools in New Hampshire. The initial proposals have been met with concern from the public, including parents, educators, and community leaders. 

draft document obtained by Reaching Higher NH outlined several recommended changes that Commissioner Frank Edelblut is expected to present to the NH State Board of Education for consideration, in order to influence public comment during the hearing. However, the changes appear to be superficial, creating the appearance of having addressed the multitude of concerns that the public has raised since the first draft was released in 2022. 

Since the release of the initial proposal on February 15, 2024, Reaching Higher NH has conducted an extensive analysis on the document and has identified the following major themes or takeaways:

  1. Redefines the purpose and structure of school
  2. Hollows out instructional requirements 
  3. Removes local authority
  4. Lawmaking through rules
  5. Potential school funding implications

In addition to the analysis conducted by Reaching Higher NH (RHNH), numerous professional organizations, local school boards, and individual Granite State residents have vocalized serious concerns about the potential impact of the proposal.  

In response to the identified concerns, Commissioner Frank Edelblut of the NH Department of Education sent a document with recommended changes to the minimum standards to a working group on March 28th. The recommended changes would apply to the initial proposal that was approved by the State Board of Education on February 15, 2024, and which has a public hearing on Wednesday, April 3. 

The email states that the purpose of the document is to notify the involved organizations of changes that the NHED has “agreed to” and to refocus the public’s comment on “further areas of concern.”  

However, an analysis by Reaching Higher NH found that the recommended changes do not encompass the most substantial and concerning elements included in the initial proposal that is before the State Board of Education and that will be discussed during the public hearing on Wednesday. 

The changes that are included ignore the system level impact of the initial proposal including: redefining the purpose and structure of school, hollowing out instructional requirements, removal of local authority, lawmaking through rules, and potentially significant school funding implications. Failure to address these issues will lead to a public education system that is deeply inequitable, where the value of a New Hampshire high school diploma is questioned.

The public hearing on the first half of the rule proposal, which includes ED 301.01 through ED 306.25, will be held at the NH Department of Education building, 25 Hall Street, Concord, NH beginning at 1 p.m. Public comment can also be submitted electronically until April 30, 2024 to Julie Shea, Administrative Rules Coordinator, at and by CC’ing Angela Adams at

Download a copy of the initial proposal as presented to the State Board of Education on February 15, 2024, here: 

Download a copy of the NHED’s proposed recommendations here: 


Reaching Higher NH is a nonpartisan 501c3. Our mission is to provide all New Hampshire children with the opportunity to prepare for college, for immediate careers, and for the challenges and opportunities of life in 21st century NH, by serving as a public education policy and community engagement resource for New Hampshire families, educators, and elected officials.

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