California’s Alternative Pathway to a High School Diploma for Students with Intellectual Disabilities

Thanks to the Individuals with Disabilities Education Act (IDEA), children with disabilities have the same rights and opportunities as those of their peers without disabilities. But between the idea and the reality, there is quite a bit of shadow. This is especially true when it comes to the ability of all students, disabled and not, to earn a high school diploma.

The Every Student Succeeds Act (ESSA) ― a federal education law passed in 2015 ― allows states to create state-defined alternative diplomas that align with regular requirements. Many states already offer this option for students with significant cognitive disabilities. And as of 2022, California offers its own.

To learn more about this alternative pathway to a diploma, we sat down with Richard L. Rosenberg, PhD, a board member of the California Transition Alliance; special education advocate (and owner of Know IEPs) Dr. Sarah Pelangka, BCBA-D; and Kristin Wright and Stephanie Coleman from Inclusive Practices and Integrated Systems at the Sacramento County Office of Education.

Wright says, “[The alternative pathway] gives you, as parents, a mechanism to go in and say not ‘Can my student get a diploma?’ but ‘How is my student going to get a diploma, and how are they going to get access to their grade-level standards?’”

Earning a high school diploma does offer many benefits: it creates more options and opportunities, and is a tool for inclusion as students transition into adulthood. A pathway to earning a diploma gives students greater access to higher education, higher-income jobs, greater independence, and a higher quality of life. As Rosenberg tells us, “Full inclusion is the most logical transition from school to adult life. Having the diploma is a rite of passage.” He explains that having a diploma can give students something to be proud of; that they worked hard through their IEP to demonstrate that they have competency.

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.

What this means is that qualifying students who are eligible to take the California Alternate Assessment (CAA) — which is aligned with alternate achievement standards — can now obtain a diploma from high school if they meet the state’s minimum coursework requirements by taking classes that align with the California state standards.

Students earning a diploma, including students on the alternative pathway, must pass:

• Three year-long courses in English
• Two year-long courses in mathematics, including one year of Algebra I (EC Section 51224.5)
• Two year-long courses in science, including biological and physical sciences
• Three year-long courses in social studies, including United States history and geography; world history, culture, and geography; a one-semester course in American government and civics, and a one-semester course in economics
• One course in visual or performing arts, world language (including ASL), or career technical education.
• Two courses in physical education, unless exempted EC Sec. 51241
• Starting 2029–30, one semester of Ethnic Studies

This means that only 13 classes are required during a student’s high school years. The intent of the statute is for students to attempt to complete this alongside their same-age peers, but students with IEPs continue to have until they age out at 22 to complete the required coursework. This makes it possible for students to also take many career, technical, and vocational classes, as well as performance and visual arts. Students also have room in their schedule to take classes that are not eligible for diploma credits.

California’s alternative achievement standards

California chose not to adopt their own alternate achievement standards. The California Department of Education pointed districts to those adopted by other states, developed specifically for students with significant cognitive disabilities. California Alternate Assessments provide access to the same California state standards as their peers without disabilities, but with aligned but modified achievement expectations using Core Content Connectors (CCCs) with supports provided through each student’s IEP — set out in the California Prioritized Understandings.

Note that this is a very small group of students — the federal Every Student Succeeds Act (ESSA) limits the number of students who take alternate assessments to no more than 1% of all students. The U.S. Department of Education estimates this to be approximately 10% of all students with disabilities.

Significant cognitive disability

Students who qualify for the alternative pathway to a diploma must have a significant cognitive disability, but what exactly is a significant cognitive disability? Under ESSA, states are guided to develop their own definition. For California, the CDE defines significant cognitive disability as “a disability or multiple disabilities that significantly impact intellectual functioning and adaptive behavior essential for a person to live independently and to function safely in daily life.” This isn’t determined by an IQ score but a holistic understanding of the student. It also rules out students with a specific learning disability, as “the determination of a specific learning disability rules out cognitive impairment.” The California Department of Education has provided a useful worksheet for IEP teams to use in making this decision.

Coursework: requirements & exemptions

Under the alternative pathway to a diploma, eligible students will also be exempt from all coursework and requirements that are additional to the state diploma requirements, including local requirements for graduation, including A-G requirements.

Many school districts and charter schools have increased their coursework requirements for their diploma to incentivize more students to complete the A-G requirements to apply to California State University and University of California. However the alternative pathway aligns with the state requirements which identify fewer course requirements than outlined by the university system.

In sum, a diploma earned under the new pathway must be:

• Standards-based
• Aligned with state requirements for the regular high school diploma
• Obtained within the time period for which the state ensures the availability of free, appropriate public education (until age 22 in California).

This diploma option will give students with significant cognitive disabilities the opportunity to earn a diploma that shows they have completed a rigorous, standards-based program of study, and potentially provides them access to post-secondary education and employment opportunities that previously may have been denied to them.

Stephanie Coleman shares, “Every student deserves and has a right to learn grade-level standards and be challenged to realize their greatest potential. The opportunity for students who have historically not had access to a diploma to now have a way to earn one aligns our actions with the idea of presumed competence, equity, and our belief that all students can learn at high levels. Working toward a diploma does not mean we don’t also continue to work on foundational skills using age appropriate themes, topics and materials.”

It’s important to emphasize that this alternative pathway to a diploma is a regular high school diploma. According to the California Department of Education, “Students exiting with this School Completion Status Code within four or five years of their initial ninth grade cohort entry year will be counted as graduates in the Four-Year and Five-Year Adjusted Cohort Graduation Rate.” Also, graduates can receive the same diploma that all students receive and participate in all graduation activities and ceremonies. The diploma should not indicate that it was achieved using the “alternative diploma pathway.” Graduation via the “alternative pathway to a diploma” does not end a school district’s obligation to provide a FAPE to an eligible special education student.

The IEP team (which includes the parent) must determine whether the student is eligible to receive a high school diploma via the alternative pathway.

To be eligible, the IEP must show that:

• The student is eligible to take the California Alternate Assessment (CAA) aligned to alternate achievement standards in 11th grade.
• The student will complete state standards–aligned coursework meeting the California statewide minimum coursework requirements, specified in Section 51225.3 of the Education Code.
• The student has a significant cognitive disability (excludes students eligible for an IEP based on specific learning disabilities).

FAPE and LEA obligations:

• LEAs must exempt qualifying students from any additional local diploma requirements.
• There is no change in an LEA’s obligation to provide FAPE to an eligible student (until the student ages out of special education at age 22).
• This diploma pathway does not constitute a change in placement.
• Students receiving a diploma through this pathway must be permitted to participate in graduation ceremonies and activities with similar-age peers, but the alternative pathway to a diploma under EC 51225.31 does not end their right to special education services and FAPE.

Rosenberg tells us that navigating the pathway to a diploma doesn’t typically start right at 10th grade, but at birth, and continues every year after birth. In this clip, he explains why goals are important and how a transcript can be a great tool in earning a diploma:

Even if your child is partway through high school, they may still have time to complete the coursework before aging out at age 22. You should request an IEP team meeting to discuss it with your team, sooner than later.

Will this diploma affect employment?

A diploma is a diploma, Rosenberg effectively tells us. In this clip, he explains that employers won’t know whether a diploma is earned through an alternate pathway and what that means:

Will this diploma affect school services or public benefits?

Earning a diploma on the alternative pathway does not preclude students from social services after graduation. Unlike students who graduate at age 18 and exit special education then, students on the alternative pathway can continue to receive IEP services until age 22. At that time, local Regional Centers assume responsibility for services for individuals who are eligible.

While the alternative pathway to a diploma opens many doors for students with significant cognitive disabilities, some questions still remain. First of all, this new diploma pathway leaves out a large group of students who are not eligible for the CAA, but who still struggle to complete the state and local graduation requirements necessary to receive a regular high school diploma.

For example, if the IEP determines that a student has a specific learning disability and can’t take the CAA, they would not be eligible for a diploma under this pathway. How is this being addressed? The California Budget Act of 2022 designated IDEA funds for CDE to develop alternative coursework and tasks for these students to demonstrate completion of the state graduation requirements through alternate means. The work from this project was used to develop a website, Inclusive Access to a Diploma, to provide guidance to educators on using alternative means and modes to help students with disabilities graduate.

While this does not provide a third pathway to a diploma, the project provides schools with examples of how coursework can be accommodated to make it possible for students with IEPs to be successful.

It is also possible for students to apply for a waiver when there are graduation requirements that they cannot meet. Any local requirement for graduation can be waived for particular students by the local Board of Education (AB 2251 2024 Sec. 51225.3). It is also possible to apply for a waiver (for example, for Algebra) from the State Board of Education. Be sure to check out our full article Accessible Algebra for EVERY Learner for more resources on helping kids with disabilities with algebra.

The alternative pathway is an exciting opportunity for many of our kids. While there are some challenges to be aware of, there are also some great ways you can advocate as a parent.

Guidance was issued by the Director of Special Education at the California Department of Education, Dr. Rachel Heenan in April 2024, providing a central reference that can be shared with local administrators if they are unsure of how the new diploma works.

Implementation at the local level has varied, with some parents reporting that their school is trying to put all the students on the alternative pathway in segregated classes. Coleman encourages parents to invite school teams to attend Community of Practice meetings intended specifically for districts to share best practices.

You can also ask your district Special Education Department leadership. Wright says, “Your local SELPA directors are very aware of this and could be a valuable resource. SELPA can play a big role in helping to support their districts. So if you haven't talked to your SELPA director, I recommend you do that.”

Wright and Coleman also invite parents to contact their office for help; Coleman says, “We are happy to help kickstart people that are feeling like it's a major barrier that they feel is insurmountable. We can help with that, so we want to make sure that there's not something that's getting stuck. If you're feeling like nothing's happening, you can refer them to us. We'll do the best we can to help and support and get things moving along.”

Check out our alternative pathway Q&A with Wright and Coleman for more advice about working with districts.

There are some important conversations that parents need to have with their districts and IEP teams as soon as possible:

• Outside of California: Check if your state already offers an alternate pathway to a diploma for students with cognitive disabilities under ESSA.

• If you’re in California:

  • Your child’s IEP team needs to assess and determine whether your child is eligible for a Section 51225.31 diploma. Districts do not have an obligation to inform you about the pathway, so make sure you ask about it.
  • Your LEA should review CDE’s Alternate Assessment IEP Team Guidance to assist in appropriately identifying students for alternate assessments.
  • Your district needs to define precisely what “meeting the CA Alternate Achievements standards” means. Your child’s progress toward meeting your district’s defined standards should be a topic of every IEP meeting.

• Whether your child is in a special day classroom, included in their general education class for the majority of their day, or homeschooled, they need to be working on standards-based goals and curriculum to earn a diploma. If your child works on functional life skills for most of their school day, this could definitely be a barrier to earning a diploma. We encourage families to discuss this with your child’s IEP team and clearly communicate the vision that you and your child have for their future.

• Explore all your options! Every state is different with the pathways they offer. Whatever path is right for you, remember that under IDEA, students with disabilities are allowed to stay in public schools until they earn a diploma or through age 21. In California, students are still entitled to public education through to age 22 if they earn a certificate or a diploma through the alternative pathway.

For more information, see this padlet of resources on the alternative pathway put together by SCCOE and High Quality IEPs.