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. Rosenberg believes that a pathway to earning a diploma may give students more 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
• Starting 2030-32, one semester of Financial Literacy

This means that only 13-15 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. In California, approximately 6.67% of students with disabilities will fall into the group representing 1% of the total student population.

While the alternative pathway to a diploma is aimed at students with the most significant cognitive disabilities only, there is no minimum requirement. No student is excluded from the pathway because they are not performing at a high enough level.

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 has a significant cognitive disability that qualifies them 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.

Note that students who are only eligible for an IEP based on specific learning disabilities do not qualify.

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.

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 worksheet for IEP teams to use in making this decision. Note that this worksheet was developed because California was overidentifying students for thee CAA; the process tends to exclude students that have significant cognitive disabilities but communicate well. This is an optional tool and is not mandatory to determine if a student is eligible for alternative assessment.

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. The state requirements are used for other populations, such as some military-connected students and foster youth.

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:

• Based on coursework that is standards-aligned
• Fulfills state requirements for the regular pathway high school diploma
• Obtained within the time period for which the state ensures the availability of free, appropriate public education (until age 22).

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 possibly 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 the same 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.

Schools in California can still give students who do not fulfill graduation requirements a “Certificate of Completion.” Many students still take this path, so if it is offered to you by your IEP team, it is worth a deeper conversation about why the alternative pathway to a diploma is not an option.

Can the coursework be modified?

A student with a significant cognitive disability is likely unable to complete high school-level coursework without modifications. The alternative pathway requires that the coursework they complete be aligned to the state standards but allows them to use only the most essential part of the standard. It's worth looking at the 11th grade Core Content Connectors and Essential Understandings to see how achievable these are for your student. The law does not require them to “pass” a class but simply to complete it, giving free reign to the school to determine whether that standard is met.

Schools are often confused about grading when using alternative achievement standards. The TIES center has created a useful guide for teachers on using Core Content Connectors in standards-based grading. Bear in mind that a D grade is sufficient for any student to earn a diploma, even if a C grade is expected for college entry. On the other hand, students should be graded on whether they met the expectations they were individually presented with, not the expectations that the rest of the class had an opportunity to meet that excluded their participation. It's worth asking in any grading discussion: "Based on the way their assignment is specially designed, is my student able to earn an A if they do really well?"

Does alternative pathway mean alternative curriculum?

Many schools have chosen to implement the alternative pathway to a diploma by adding a specialized curriculum to their life skills classes. For example, Everway has two curricula packages, Unique Learning Systems and TeachTown, that are designed to provide a full educational program aligned to the California State Standards and also focused on improving foundational skills such as reading and numeracy. These programs are a great asset for students who need a separate setting (such as SDC or NPS) and can still get access to a diploma through the alternative pathway. Everway curricula might also work well in a homeschool charter situation, where all the classmates are using different curricula chosen by their parents.

However, the alternative pathway was designed to give students access to the general education classroom and learning with their peers. These all-encompassing packages often make it difficult to implement the pathway in a general education classroom where teachers might teach the state standards using a wide variety of content and methods. It can sometimes also be difficult to extract one course, such as Modern History, from the program if you want to combine using these modified materials with general education instruction.

Do students on the alternative pathway need to be in segregated classes?

Schools cannot limit the pathway to a placement such as SDC, and the introduction of the alternative pathway does not change the least restrictive environment (LRE) requirement of IDEA.

An alternative way to provide access to the alternative pathway is for students to participate in general education classes with appropriate supports and services, with an educational specialist providing modified coursework to complete that is both aligned with the state standards and utilizes the content and class participation activities that the general education teacher uses to deliver the curriculum. This approach requires significant inclusion support in the IEP, such as minutes allotted to an education specialist to provide modification and collaboration time with general education teachers.

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 as soon as possible.

Special education services until age 22

Students on the alternative pathway to a diploma may qualify for a diploma by the end of 12th grade. Since they are still eligible for special education under IDEA, the school district will continue to hold IEP meetings until they turn 22. Their special education services often include a school district Adult Transition Program typically focused on life and employment skills. It could also include work experience and community college classes. In some cases, schools have funded college programs for students with intellectual disabilities. The school district is likely to work with the state Department of Rehabilitation and the local Regional Center to provide these supports.

The Adult Transition Program is not mandatory; students may prefer to work or to move to a college-based program. Bear in mind that any student eligible for the CAA has a significant cognitive disability that requires a high level of support for academic success. This means that college programs that are specifically designed for students with intellectual disabilities are better equipped for providing this support. While anyone, with or without a diploma, can take community college classes, community college degree programs that require a diploma are unlikely to have the support available that a student with a significant cognitive disability will need. On the other hand, vocational certificate programs may be open to working with the student. Colleges may be able to see that coursework has been modified from the student transcript.

For students who do not complete all their credits by 12th grade, there are several possibilities. They might be offered a "super senior” year, in which case they can choose to participate in senior events with their cohort or the following year. The option might be offered on their regular high school campus or at a continuation high school. (There is no legal impediment to students remaining at high school until they are 22, but many schools prefer to educate adults on separate campuses.) Some schools have also utilized online high school programs to complete the credits as part of the Adult Transition Program.

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. To be eligible, a student must have a documented significant cognitive disability, and inevitably their disability will impact their employment opportunities, with or without a diploma. By definition, it is likely that a student eligible for alternative assessment will require significant support throughout their lifetime.

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 more 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.

Dr. Pelangka also emphasizes the importance of starting discussions with your child’s IEP team now. “It is VERY important for parents to know that students in grades 7–12 already 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. It’s important that your child is taking grade-level classes so that they are ready and set up for success.

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 SELPA 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:

  • At any time after third grade, your IEP team should discuss eligibility for the CAA. You do not have to make the switch until high school. Review CDE’s Alternate Assessment IEP Team Guidance to assist in appropriately identifying students for alternate assessments.
  • Ideally, in eighth to tenth grade, 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 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 geared toward earning 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.