Until recently, many students in California were faced with a dilemma between working toward a high school diploma or a certificate of completion. Both should offer students the same access to general education curriculum, but there is often a big gap between reality and best practice. In 2023, new legislation came into force to allow districts to offer an alternate pathway to a diploma to students taking the California Alternate Assessment, adding to the options available.
The decision to work on the regular diploma track, a certificate track, or an alternate pathway requires some thought and should always be made with a focus on a child’s long-term goals and available supports. In this article, we explore what the four options are — including who is eligible for each and what the eligibility requirements are, how a modified curriculum is likely to take a student off a diploma track, how state testing (and alternate assessments) are tied to and impact a student’s eligibility for a diploma, what happens to special education services after graduation, and more.
For additional insights, 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).
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 need to meet state-mandated graduation requirements. Beyond state requirements, a standard high school diploma may also include district-mandated requirements, as well as 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.
There is currently no law that prevents an IEP team from allowing a student with disabilities to meet only minimum state requirements to earn a high school diploma. Parents have the right to ask that their child be exempt from additional local graduation requirements, as well as the Algebra 1 requirement (more on this later) — a student’s IEP team can ask their LEA to “request the State Board of Education (SBE) to grant a full or partial waiver from specific graduation requirements for individual students with disabilities.” Here's an example from LAUSD.
The trouble is, these waivers are rarely granted; the CDE has stated that “review and approval of these waivers will be stringent.” Local Education Agencies (LEAs) — which serve as public education boards as well as charter school governing bodies — can decide whether to add additional local graduation requirements for their students and whether they will allow some students to be exempt from them. So while there is no law that exists to prevent an IEP team from allowing a student with disabilities to only meet minimum state requirements, and IEP teams can ask their LEA for a waiver, many of them may not do so. The lack of a uniform policy means that opportunities for students with disabilities to earn a diploma are grossly unequal across the state.
On June 30, 2022, Assembly Bill (AB) 181 signed into law a number of changes to California special education laws, including the addition of Section 51225.31, an alternate pathway to a high school diploma for students with significant cognitive disabilities.
Under these new laws, qualifying students who don’t have a pathway to a diploma and who take the California Alternate Assessment (CAA) — which are aligned with alternate achievement standards — can obtain a high school diploma if they meet the state’s minimum coursework requirements.
A diploma earned under this pathway would still be standards-based and aligned with state requirements for the regular high school diploma. And under this new pathway to a diploma, eligible students will also be exempt from all coursework and requirements that are additional to the statewide coursework requirements, including local requirements for graduation and A-G requirements. While the high school diploma with a waiver can also do this, it doesn't allow students to pass under California’s alternate achievement standards.
As Sabia and Dr. Solone advise, 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! You can read much more about this in our article here. Note that the first cohort that school districts can offer the new alternate pathway to are students in 10th grade or below in the 2023-2024 school year.
The California Transition Alliance, which works to support students with disabilities through the transition to adulthood, 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.”)
Although a certificate is not recognized as a high school diploma, students on the certificate path attend graduation and participate in transition services from the school district. They also have access to more elective courses than students on the diploma track, 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.
The California standards for a high school diploma are:
“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 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).
A-G requirements
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.”
Algebra 1 waiver
Attorney Meira Amster tells us that in her experience, Algebra 1 — which many students find challenging — is the class that will determine whether 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 the requirement for two years of math. To find a list of classes that your specific high school offers, search here. Many schools are now adding new math classes aligned with grade-level state standards to work with both the new alternate pathway to a diploma and the new California Math Framework.
If a student has not been able to meet the standards for a course that is required for graduation, Clark says there is a workaround even if they are not eligible for a Section 51225.31 diploma. “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.
In California, the discussion about an “alternate curriculum” can surface early because in some school districts, some classes are labeled “core” or “alternate.” 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. Note that “curriculum” here refers to the content and standards to be studied in each grade, rather than the learning materials used, which can vary widely from school to school.
Does curriculum modification or an alternate assessment put your child on a certificate rather than a diploma track? Dr. Caitlin Solone, teacher educator at UCLA, explains that appropriate curriculum modifications give a child with significant support needs access to the same academic standards as their peers but at their developmental level. For example, a teacher may modify an essay-writing assignment by making it significantly shorter or about a less complex topic. “Adjusting expectations on the grade level content standards and assignments to have less breadth, depth, or complexity would be considered a modification,” Sabia also says.
With an alternate curriculum, however, students may have “an out of the box curriculum” that isn’t always aligned to the gen ed content standards. As Dr. Solone explains, “Alternate curriculum is something that is a curriculum that is designed for students with the most significant disabilities that is aligned with the alternate achievement standards, but often times has a different book, comes out of a box, doesn’t always have content in social studies, science, and doesn’t expose kids to all of the different content standards.” Students who are taking alternate assessments don’t have to be on an alternate curriculum, but in order to qualify they will have to be students who need modifications to their curriculum that are aligned with the state standards. (You can learn more about alternate and modified curriculum here).
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.”
Best practice vs. reality
The difference between best practice and reality, however, can be unfortunately large. Dr. Pelangka tells us that when students with significant cognitive impairments 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 modifications to curriculum are first recommended for their child. Parents should be given the information they need to understand what each path means. The earlier the decision that modifications are necessary, 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, Dr. Pelangka says that there are “examples of smaller-scale modifications that technically could happen in a gen ed class that wouldn’t necessarily bump a student to [an alternate pathway or non-diploma] 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.”
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 about California’s new pathway to a high school diploma).
While parents should be aware of the implications of using modified assessments or materials (or in some districts “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 they still meet grade-level standards. 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 [materials] 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 — in some school districts, you can see whether your child receives a regular or alternate report card and whether 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 or district.)
Whether you’re considering opting out of state testing or having a conversation about alternate testing with your IEP team, exploring early and knowing your rights as a parent can help you navigate your child’s options toward graduation. Assessments are tied to these options, and here's why:
Generally speaking, if a student with significant cognitive impairment meets eligibility requirements to take alternate state assessments [for California, see California Alternate Assessments (CAA)], districts are likely to recommend they do so.
While taking an alternate assessment doesn’t change the grade-level standards expected of the student, the standards are modified to California’s alternate achievement standards, and this will impact their eligibility for a diploma.
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.” This is where the new California alternative pathway to a diploma comes in — for qualifying students who take the California Alternate Assessment (CAA).
Note that if your child is pursuing a diploma under California’s alternative achievement standards, they must be eligible for the alternate assessments their 11th grade year. They are not required to take the state test that year in order to be eligible for a diploma.
Dr.Pelangka reminds us that a student has the option of opting out of state testing altogether. One of your rights in CA is opting out of state testing with no state-mandated consequences for students. A student can still pursue the new alternate diploma pathway, even if they opt out of state testing.
Listen to Dr. Solone's advice on questions parents can ask about alternate assessments or opting out of state testing:
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 them to take classes, gain work experience, and complete 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.”
Increasing post-secondary options for students
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 attend classes, live in the dorms, make friends, find peer support, and have access to the same college experiences as their neurotypical peers. In new legislation AB 447, signed by Governor Newsom in October 2023, all CSU and UC campuses are asked to develop non-degree programs to serve students with intellectual and developmental disabilities.
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. Check out our full article about college for students with intellectual disabilities to learn more.
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 age twenty-two might give students the last opportunity they’ll have to work toward academic goals. Note that students with significant cognitive disabilities who earn a diploma using the new Section 51225.31 alternate pathway are still eligible for special education in their school district’s program until age 22.
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.”
Once a student graduates with a traditional 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 or earns a diploma through the Section 51225.31 alternate pathway, Dr. Pelangka explains, then “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.
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, utilize an alternate pathway, or earn a 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 sometimes 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 Section 51225.31 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 whether the student would benefit from meeting only 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.
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. Even before recent legislation, “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 that you can better advocate for your child.
What conversations and questions can parents have with their districts and IEP teams?
Is your child working on standards-based goals and curricula to earn a diploma? Laying the groundwork for a diploma begins the moment a child enters school, so it’s critical to take a look at their 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.
Explore all the alternatives. Which option is best suited for your child?
If the new pathway based on the California Alternate Achievement standard is the best fit for your child, learn what the proposed state minimum requirements are and how your district defines “meeting the California Alternate Achievement standard.” Is your child moving toward meeting your district’s defined standards?
Learn about the state standards and ask your IEP team if a waiver might 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.)
If the diploma option 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. Dr. Pelangka urges parents to learn the state standards and their district’s waivers and talk to their IEP team. She explains, “Ask about things like independent PE options, work experience, etc., as alternatives to certain class requirements.”
Remember, students with disabilities have the option of staying in school until age 22 to meet the state graduation requirements, even under the new, alternate 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 your child’s 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? Let us know!
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