Undivided: Certificate of Completion vs. IEP Diploma

Building a Goal-Oriented Future: Diploma vs. Certificate of Completion

Feb. 15, 2022Updated Dec. 15, 2022
Working toward a high school diploma or a certificate of completion should offer students the same access to general education curriculum. The decision to work on one versus the other requires some thought, however, and should always be made with a focus on a child’s long-term goals and available supports. To help parents understand the differences between earning a diploma and a certificate of completion, we spoke with Meira Amster, special education attorney; Grace Clark, special education attorney; Dr. Caitlin Solone, education advocate, teacher-educator, and Academic Administrator for the Disability Studies program at UCLA; Dr. Sarah Pelangka, special education advocate, BCBA-D, and owner of KnowIEPs; and Ricki Sabia, J.D., Senior Education Policy Advisor with the National Down Syndrome Congress (NDSC).

What a referral to “alternate curriculum” can mean for a diploma

In California, the discussion about an “alternate curriculum” can surface early because some classes are labeled “core” and some are labeled “alternative.” Sometimes, it comes up in third grade when standardized state testing starts. In fact, Dr. Solone tells us there are some special day class (SDC) or non-public school (NPS) programs that label a child “certificate-bound” even earlier.

But according to the TIES Center, there should be no such thing as an alternate curriculum. As they put it in this brief (which Sabia co-authored), “alternate curriculum” should not mean that the student has alternate content standards: “U.S. Department of Education regulations explaining how IDEA should be implemented state that the general education curriculum is ‘the same curriculum as for nondisabled children’ (300.320(a)(1)(i)). In other words, “all instruction [should start] from the same content standards, regardless of the student’s disabilities. However, the expectations for how much a student will master of the grade-level general education curriculum can be modified.”

As Sabia explains, “Students must work on — participate and make progress in — the enrolled grade-level, general ed curriculum. Modifications, accommodations, and adapted materials are allowed but based on individual needs, not some lock-step alternate curriculum for all students who take alternate assessments.”

The difference between best practice and reality, however, can be unfortunately large. Dr. Pelangka tells us that when students are using modified curriculum in high school due to a significant cognitive impairment and are not working toward the general education standards, they are unlikely to graduate with a diploma. Dr. Pelangka believes that parents should be made aware of this as early as when their student is first referred for a modified curriculum. Parents should be given the information they need to understand what each path means. The earlier the referral to modified curriculum happens, the larger the gap may be in terms of a student’s ability to access the general education curriculum. As the years progress, the academics only become more rigorous.

However, she says, there are “examples of smaller-scale modifications that technically could happen in a gen ed class that wouldn’t necessarily bump a student to a certificate track. As long as the student can reflect mastery of the grade-level standards, they can access their diploma.”

Dr. Solone says, “It is definitely case-by-case, but if your child is in the younger grades, I would not agree to an ‘alternate’ curriculum until fourth, maybe fifth grade. I think it does really lower expectations for your child.” ​​She continues, “Once state testing begins, the school will determine whether a child will take alternate or standard assessments, so it’s a good time to wait at least until then.”

For this reason, Dr. Solone advises parents to keep students in their general education classroom as long as possible, and continuously work to find entry points for them through the use of accommodations and modifications — you can read much more about that here. If and when students do work from a modified curriculum, they should still have a standards-based education and IEP goals, and they should be making meaningful progress on those goals.

How can I make sure my child is given all opportunities to work toward a diploma?

The Every Student Succeeds Act (ESSA) regulations include a provision — 200.6 (d) — that says the state must “promote, consistent with requirements under the IDEA, the involvement and progress of students with the most significant cognitive disabilities in the general education curriculum that is based on the State’s academic content standards for the grade in which the student is enrolled.”

Sabia explains, “The important piece of the ESSA provision is that the student should be allowed to work toward [a diploma] and go as far as they can go — even if they don’t meet the requirements in the end, they will get a more individualized, standards-based education.” And, she adds, the ESSA regulations “have the force of law.”

For this reason, Sabia suggests making sure your child isn’t taken off the diploma track prematurely because “you just don’t know what a student is going to be able to accomplish.” She points out that states often give students with IEPs more time to graduate, and graduation requirements evolve over time. (For more on this, see our article New Pathways to a Diploma for Students with Cognitive Disabilities.

While parents should be aware of the implications of using modified or “alternate” curriculum in elementary and middle school, Sabia feels that high school is the best time to make diploma decisions. “The more we keep kids on grade-level content and try to find entry points for them on that, the further they’re going to go.”

If the student is able to pass a required class per state guidelines to obtain a diploma — with or without accommodations — they will be eligible for a passing grade. If the student receives modifications in the class, they may pass as long as the modification does not significantly alter what is being taught and what the student is required to produce. Dr. Pelangka explains in this clip:

She adds that if a student is placed on an alternate report card early on, it may lead to the student not being held to grade-level standards. “Many districts utilize certain curriculums that are not directly correlated to grade-level standards; rather, they are reported out as ‘grade bands,’” she says — and parents aren’t told what grade-level equivalent their child is working toward. “Just look for those little details within the IEP and ensure that your kid is being held to grade-level standards and that they are being promoted based on grade-level criteria,” she advises.

When you review your child’s IEP, pay attention to the section on modifications and accommodations — you can see if your child receives a regular or alternate report card and if they meet regular district criteria for promotion. (However, Dr. Pelangka reminds us that in California, every IEP template will look different depending on the SELPA (Special Education Local Plan Area) or district.)

Standardized state testing, alternate testing, and opting out

Generally speaking, if a student with significant cognitive impairment meets eligibility requirements to take alternate state assessments (for CA, see California Alternative Assessments), districts are likely to recommend they do so. These eligibility requirements include:

  • Whether the child has a “significant cognitive disability”

  • Whether “the student is learning content linked to (derived from) the Common Core State Standards (CCSS)”

  • Whether the child requires “extensive, direct individualized methods of accessing information in alternate ways.”

Listen to Dr. Solone's advice about opting out of testing in this clip:

Sabia recommends that parents find the alternate assessment participation criteria on their state’s Department of Education website. If possible, it’s a good idea to become familiar with the criteria before an IEP meeting so you have the information you need to decide whether or not your child should take an alternate assessment. (See guidance on California’s alternate assessment criteria here.)

Remember that taking an alternate assessment does not change the grade level standards expected of the student. The TIES Center says that “students who take an alternate assessment are expected to master the same standards as other students but with less breadth, depth, and complexity—depending on each student’s unique needs and abilities.”

And remember that taking alternate assessments does not mean a student cannot still work toward a diploma. According to IDEA 300.160, a state should “not preclude a student with the most significant cognitive disabilities who takes an alternate assessment aligned with alternate academic achievement standards from attempting to complete the requirements for a regular high school diploma.”

While state assessments help keep schools accountable and provide teachers — and parents — with a measure of a student’s progress, Dr. Pelangka reminds us that a student has the option of opting out of state testing altogether. To opt out, parents should inform the school in writing and make sure the decision is also included in the IEP notes.

Note that if your child is pursuing a diploma under California’s Alternative Achievement Standards, they cannot opt out of the alternate assessments their 11th grade year. They are required to take the state test that year in order to be eligible for a diploma. We will update this article as we receive clarifications on testing requirements for any year outside of 11th grade.

What are the requirements for a high school diploma?

Every state has its own graduation requirements. Therefore, parents should carefully research what classes students are required to take in high school and what standards they need to meet. In California, students will need to meet state-mandated graduation requirements, and district requirements can vary in addition to the state minimum.

The California standards for a high school diploma are:

  • Three years of English
  • Two years of math (including Algebra 1)
  • Three years of social science (U.S. History and geography; world history, culture and geography; and one semester each of American government and economics)
  • Two years of science (biological and physical)
  • Two years of physical education
  • One year of foreign language (including American Sign Language is considered a foreign language) or visual/performing arts or career technical education

“Vast discretion is given to school districts about what qualifies for graduation requirements,” Clark says, “and beyond that, there are minimum requirements provided by the state.” The California Transition Alliance, which works to support students through the transition to adulthood, argues against school districts setting requirements that exceed those set by the state. These additional district requirements can usually be found on a district’s website (such as LAUSD’s here).

So how do A-G requirements fit in? Dr. Pelangka explains that there are state- and district-mandated requirements for graduating with a diploma, and then there are the A-G requirements, which are courses (or a required period of time studying a required subject) needed to meet the minimum admission criteria set by schools in the University of California and California State University systems. For example, A-G requirements include Algebra 1 plus Intermediate Algebra, versus just Algebra 1. You can compare the differences in this chart.

According to a major 2020 report commissioned by the Sacramento County Office of Education, many districts or Local Education Agencies (LEAs) “choose to adopt the University of California and California State University coursework requirements for freshman admissions — known as the ‘A–G courses’ — in addition to the state minimum requirements to ensure that all students graduate ready to enter a four-year college. According to a 2017 survey from the Public Policy Institute of California, 51 percent of LEAs required students to complete the A–G courses to receive a high school diploma, including some of the state’s largest LEAs and LEAs with significant numbers of high-need students.”

However, as the report also points out, there is currently no California law that prevents an IEP team from allowing a student with disabilities to earn a diploma with only the minimum state requirements. Parents have the right to ask that their child be exempt from additional local graduation requirements — a student’s IEP team can ask their LEA to allow these additional requirements to be waived.

Attorney Meira Amster tells us that in her experience, Algebra 1 — which many students find challenging — is the class that will determine whether or not a student graduates. She adds that using modifications in Algebra 1 is likely to bump a student to a certificate track. That said, some high schools provide a four-year algebra class that fulfills both the requirement to pass algebra and two years of math. To find a list of classes that your specific high school offers, search here.

However, if a student has not been able to meet the standards for a course that is required for graduation, Clark says there is a work-around. “Students, along with their school, can petition for a waiver under California Education Code section 56101. For example, it could look like this: A student who had been on a modified math curriculum and was not able to pass Algebra 1, despite support and remediation from their school, still receives a high school diploma after obtaining a waiver for Algebra 1.” She explains that while this strategy depends on each individual student, it can be used to help students who receive modifications obtain diplomas.

Due to the pandemic, some four-year universities have suspended their requirement for SAT and ACT test scores — and thanks to plenty of research showing that the SAT and ACT disadvantage students with disabilities and students of color, many schools (such as those in the University of California system) have permanently dropped these test requirements. (Students with disabilities who want to take these and other tests can apply for accommodations from the College Board, which should be done as early as possible, in eighth or ninth grade.)

A new, alternative pathway

As we explore the requirements for a high school diploma, it’s important to remember that graduation requirements evolve over time. A look at the existing barriers to a diploma that students with disabilities face has created some headway into new opportunities. Thanks to a major effort by the Department of Education, a new pathway to a full diploma for students with significant cognitive disabilities is underway and will be available to students as soon as next year.

Under this new pathway, students with significant cognitive disabilities will be able to earn a diploma if they meet new, proposed minimum state requirements that are based on California’s Alternative Achievement Standards, and participate in the state’s alternate assessments. A diploma earned under this pathway would still be standards-based and aligned with state requirements for the regular high school diploma, just modified with supports provided through a student’s IEP.

For example, instead of the current state minimum requirement of two years of math, including Algebra, a student under the new pathway would take two years of math under the CA Alternate Achievement Standards, and Algebra would not be a requirement. How does this help? Well, as Attorney Meira Amster tells us, currently, using modifications in Algebra 1 would likely bump a student to a certificate track, but not under this new pathway. Similarly, there wouldn’t even be a need to obtain a waiver for Algebra I.

All of this echoes what Sabia and Dr. Solone have advised: that despite being on a modified or “alternate” curriculum, students should still have a standards-based education and IEP goals. And more good news: a diploma earned under this new pathway is considered to be the equivalent of a traditional high school diploma, and labeled as such!

The new pathway also opens doors to another option, which waives local requirements for graduation and only holds students to the minimum state standards for graduation (not additional local requirements like A–G courses).

You can read much more about that, including what the proposed state minimum requirements would be, in our article New Pathways to a Diploma for Students with Cognitive Disabilities.

What are the consequences of not receiving a diploma?

Strictly speaking, earning a diploma means that a student has met the requirements for graduation, and earning a certificate of completion means the student has finished high school without completing all the requirements. Having a certificate rather than a diploma will disqualify a student from some post-secondary options but not permanently. For example, many students with disabilities who do not receive a diploma transition to community college after high school, as this allows for engagement with career classes, work experience, and completing post-secondary educational goals without having to meet the university system requirements. They still have the option of transferring to a four-year university later. As Dr. Pelangka puts it, “The certificate track does not mean one cannot attend college, become employed, or get student aid; it is simply a different post-secondary route.”

The “consequences” fully depend on each family and the desires for their child, Dr. Pelangka says. “Some families value education and going to a four-year university more than others. Some families want their child to experience graduation with a diploma. With a certificate, the student participates in graduation but then has the option to return to the district in a post-secondary program.”

It’s important to note that many colleges, employers, and some branches of the military require a diploma. (Students without a diploma can still apply for federal financial aid, thanks to the Ability to Benefit Act.) More opportunities are becoming available as universities become more inclusive. For example, UC Davis has the Redwood SEED Scholars Program, a four-year, non-degree program for students with intellectual disabilities. These students will be able to attend classes, live in the dorms, make friends, find peer support, and have access to the same college experiences as their neurotypical peers.

California offers College to Career (C2C) programs throughout the state, including Pathway at UCLA Extension, the College of Adaptive Arts in San Jose, and private college opportunities. Think College’s College Search Tool includes inclusive college programs across the country. The California Department of Education also suggests using the Big Future College Board website to search for schools that meet your child’s needs.

What to expect on a certificate of completion track

The CA Transition Alliance states that students working toward a certificate should “have significant cognitive impairments, take alternative assessments, and [be] unable to demonstrate subject matter competence in diploma track classes, even with differential proficiency standards, accommodations, and modifications to the courses and curriculum required to do so.” (They define a student with significant cognitive impairments as “one who requires extensive individualized instruction and a substantial amount of supports in order to meet and progress with the state academic standards.”)

Students on the certificate path will attend graduation and participate in transition services from the school district. They will also have access to more elective courses and many (non-degree) community college classes. Students without a diploma may still attend community colleges and trade schools that don’t require diplomas, and they can transition to independent living classes available at inclusive colleges. Here’s a list of California community colleges, as well as a list of state-approved trade and technical schools.

Is there a reason not to earn a high school diploma?

Attorney Meira Amster cautions parents that “a lot of considerations should go into whether a child graduates, based on the services and supports they can receive and what services Regional Center might provide.” She says that in some cases, the decision to pursue a diploma can wait until as late as twelfth grade, and that the decision should be made according to the goals of the individual student and what services and supports they’ll need after high school. While there are some transition services, such as job coaching, that Regional Center will not offer until after a student graduates, the option of staying within the school district until twenty-two might give students the last opportunity they’ll have to work toward academic goals.

Attorney Grace Clark adds that it’s essential to weigh “the likelihood that the child can meet all the standards necessary to graduate with the benefits of working at a pace that is appropriate for them, among same-aged peers.”

What happens to special education services once a diploma or certificate is earned?

Once a student graduates with a high school diploma, they are no longer eligible for special education and related services through the school district. Dr. Pelangka explains, “If a student has their certificate of completion, they can, by law, remain in the post-secondary program until their twenty-second birthday, give or take, depending on when their birthday falls within the year. If they graduate with a diploma, their special education services end.” The CA Transition Alliance notes that an LEA (Local Education Agency) is required to issue a notice of graduation and termination of disability services when a student meets diploma requirements, and any measure taken to withhold the diploma in order to continue to meet the requirements of IDEA is prohibited.

While the school district is no longer allowed to provide services after graduation, a student does have access to services through other agencies. Dr. Pelangka reminds us that all students with an IEP are “required to receive a transition plan by the age of fifteen.” The Individual Transition Plan, or ITP, is developed with the school district in collaboration with other agencies, including Regional Center. She explains that while the goals for students working toward a diploma may differ from those of students working toward a certificate, all ITPs should include specific goals and supports for post-secondary school or employment. “It’s important to avoid writing generic plans that will push kids into cookie-cutter roles,” she says. “The more detailed and tailored to your child the plan is, the better the outcome will be.” For more details, read our article Individual Transition Plan (ITP) 101.

What if I disagree with the IEP team’s decision?

Dr. Pelangka notes that just as with any other part of the IEP, a parent should never consent to an IEP team’s decision on whether a student will work toward a diploma or certificate of completion if they do not agree. The parent should go through the IEP in detail to ensure that all appropriate accommodations and modifications are in place, work to refine a student’s goals, and request any additional assessments they feel are needed. Moving from a certificate to a diploma track (or vice-versa) may also require a change of placement, which would require additional evaluations and a meeting with the IEP team. And if the student meets the requirements for the new diploma pathway, it would be up to the student’s IEP team to determine how a student can meet the proposed state requirements for graduation, and if the student would benefit from only meeting state (and not local) minimum graduation requirements.

Dr. Pelangka explains: “Realistically it’s a matter of what the student can access in high school, but the rights are the same as everything else. A parent can disagree and go up the ladder from there.” For more information on what to do if you disagree with any part of your child’s IEP, read our article, How to Review Your IEP Before Signing.

What can parents do now?

Dr. Pelangka emphasizes that it’s imperative to start the discussion with your child’s IEP team now so that your child will not miss any opportunities available to them. Per the existing law, “students in grades 7–12 have the right to ‘alternative means and modes to complete the prescribed course of study of the district and to meet or exceed proficiency standards for graduation,’” she says. And with new, alternative diploma pathways opening up, it’s important to be informed so you can better advocate for your child.

What are the conversations and questions that parents can have with their districts and IEP teams?

  • Explore all the alternatives. Which pathway is best suited for your child to earn a diploma?
  • If the new pathway based on the CA Alternative Achievements Standard is the best fit for your child, learn what the proposed state minimum requirements are and how your district defines “meeting the CA Alternate Achievements Standard.” Is your child moving toward meeting your district’s defined standards?
  • If the new pathway that waives local requirements for graduation is the best fit, learn what local requirements your child doesn’t need, such as A–G requirements, and open up the discussion with your IEP team.
  • Learn about the state standards and ask your district what waivers are available to allow your child to earn a diploma. (California ed code 56101 allows a waiver to be granted in certain circumstances, such as with the requirement for Algebra 1.) Dr. Pelangka urges parents to learn what the state standards and their district’s waivers are, and talk to their IEP team.
  • Take a look at your child’s IEP goals and make sure they are based on the state standards. Learn about standards-based goals so you can discuss this with your child’s IEP team. Is your child working on standards-based goals and curriculum to earn a diploma?
  • Every district in California must offer the new pathway by the end of the 2023–24 school year, so start the discussion now!

Remember, students with disabilities have the option of staying in school until age 22 to meet the state graduation requirements, even under the new, alternative pathway. Some kids take longer to reach the standards-based goals and that’s okay. As a parent and member of their IEP team, make sure that their goals and accommodations/modifications are being discussed frequently with the IEP team, and that all options are explored.

Do you have questions about supporting your child in working toward a high school diploma or certificate of completion? Let us know!




What a referral to “alternate curriculum” can mean for a diploma

How can I make sure my child is given all opportunities to work toward a diploma?

Standardized state testing, alternate testing, and opting out

What are the requirements for a high school diploma?

A new, alternative pathway

What are the consequences of not receiving a diploma?

What to expect on a certificate of completion track

Is there a reason not to earn a high school diploma?

What happens to special education services once a diploma or certificate is earned?

What if I disagree with the IEP team’s decision?

What can parents do now?

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Related Parent Questions

What is a strength-based IEP?
Because IEPs are the documents that teachers first read when they get new students, IEPs shape their first impressions of our kids. Strength-based IEPs foster self-determination, self-efficacy, self-control, and academic achievement.
Can students with intellectual disabilities go to college?
Many colleges, employers, and some branches of the military require a diploma. More opportunities are becoming available as universities become more inclusive for students with disabilities to attend classes, live in the dorms, make friends, and find peer support.
Can my child still get special education services after they graduate high school?
Once a student graduates with a high school diploma, they are no longer eligible for special education and related services through the school district. If a student has their certificate of completion, they can, by law, remain in the post-secondary program until their twenty-second birthday.

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