US Department of Education Public Hearing, ESSA Regulations – Statement prepared by Paul Hirsch


My name is Paul Hirsch and I am the principal of the STEM Academy at Bernstein High School in Los Angeles, California. It is a pleasure to be here today to provide recommendations to the U.S. Department of Education for the regulations that will guide the implementation of the Every Student Succeeds Act, or ESSA.

California has made great progress in improving its graduation rate. From 2011 to 2014, the state’s graduation rate increased by 5 percentage points, from 76 percent to 81 percent. This includes graduation rate gains for students who have been traditionally underserved in our public schools. The graduation rates for African Americans increased by five percentage points (63 percent to 68 percent), and for Latino students by 7 percentage points (70 percent to 77 percent). Despite these gains, there remains an 11 percentage point gap between the graduation rates of Latino and White students, and a 20 percentage point gap between African American students and White students.[i]

ESSA provides the opportunity to redouble our efforts to close these gaps and ensure that all students receive an equitable and excellent education. To do so, I urge the Department to ensure that ESSA regulations reflect the policy and practices that have contributed to the progress California has made in preparing students for postsecondary education and the workforce.

Undoubtedly one of the major developments that has fostered gains for California’s students is the state’s focus on high school reform through Linked Learning. Linked Learning is not simply a program; it is a new way to approach high school in the 21st century that integrates rigorous academics, career and technical education (CTE), work-based learning, and wraparound services. Linked Learning ignites high school students’ passions by creating meaningful learning experiences through career-oriented pathways in fields such as engineering, health care, performing arts, law, and more. When students love what they’re learning, they work harder, dream bigger, and learn more. Evidence shows that Linked Learning is increasing achievement and graduation rates across the state, particularly among students with low prior achievement and high dropout rates.[ii]

Let me take a moment to describe the transformational effect this approach to high school has had on my school. In my own school, the adoption of the Linked Learning approach has been truly transformative. We have experienced huge gains in graduation rates, attendance, enrollment in advanced coursework and postsecondary readiness.

ESSA regulations should not mandate Linked Learning or any other specific approach to school reform. However, the regulations should create the space for evidence-based, systemic reform such as Linked Learning by embedding the principles of this approach into the regulations, consistent with the statutory authority provided to the Department of Education through ESSA. I will highlight several opportunities to do so:

First, ESSA requires a multiple measure accountability system and provides flexibility to states in selecting an indicator of school quality or success, which may include an indicator of “access to and completion of advanced coursework.” I encourage the Department to clarify that this indicator may include “student participation and success in coursework that integrates preparation for postsecondary education and the workforce, including performance in course work sequences that integrate rigorous academics, work-based learning, and career and technical education”

ESSA also stipulates that the indicator of school quality or success may include a measure of “postsecondary readiness.” I encourage the Department to clarify that this indicator may include “(1) completion of and performance in dual enrollment programs, (2) performance on assessments of career readiness and acquisition of industry-recognized credentials that meet the quality criteria established by the State under the Workforce Innovation and Opportunity Act, and (3) rates of participation in postsecondary education, which may include enrollment, remediation, persistence, and completion.

Second, ESSA allows states to utilize up to 3 percent of their Title I funds to support Direct Student Services, which may include CTE coursework that leads to an industry-recognized credential. ESSA regulations should clarify that this includes, and that funds provided through Direct Student Services may support, approaches such as Linked Learning that integrate rigorous academics, CTE, work-based learning, and wraparound services.

Third, ESSA regulations should clarify that State Title I plans must comply with the report language accompanying the requirement for states to support students at all levels of schooling (Sec.1111(g)(1)(D)). The report language says that states should work with school districts to assist in developing effective transitions from high school to postsecondary education, including strategies that integrate rigorous academics, CTE, and work-based learning.

Finally, ESSA regulations should assert the authority of states, districts and schools under Title II to utilize funding for professional development on the effective integration of rigorous academics, CTE and work-based learning. ESSA regulations should clarify that such funds may be used to support professional development for all educators, including CTE teachers.

Thank you very much for the opportunity to inform the ESSA regulations. I and the Linked Learning community look forward to working with you to ensure the regulations provide the opportunity for every student to graduate from high school prepared for postsecondary education and the workforce.

[i] Data retrieved from, January 15, 2016
[ii] For additional information, visit