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

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

Published: Aug. 12, 2022Updated: Apr. 22, 2024

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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 recently, California decided to offer its own. Students with the most significant cognitive disabilities can now obtain a diploma in California under Section 51225.31 of the education code. This means is that qualifying students who who take the California Alternate Assessment (CAA) 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.

To learn more about this new alternative pathway to a diploma, we sat down with Richard L. Rosenberg, PhD, a board member of the California Transition Alliance, as well as special education advocate (and owner of Know IEPs) Dr. Sarah Pelangka, BCBA-D.

Note: we have updated this article with recent changes, including news alerts from Atkinson, Andelson, Loya, Ruud & Romo — a law firm that represents many school districts — that “anticipates there will be additional information stemming from California court decisions, the Office of Administrative Hearings, and the California Department of Education as LEAs wade through this process.”

Options for graduating high school with an IEP

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.

Historically, most students in California who have significant cognitive disabilities have earned a high school certificate of completion. Earning a high school diploma requires meeting state graduation requirements and, in many districts, additional A–G coursework required to attend a public university in California. (You can read more about these requirements below.)

​​Earning a high school diploma requires meeting state graduation requirements and, in many districts, additional A–G coursework required to attend a public university in California.

For some students, not earning a traditional diploma “is not necessarily life-shattering or life-altering,” says Dr. Pelangka. “There are now universities that offer four-year program options for students who have significant cognitive disabilities and received a certificate of completion — such as UC Davis’s Redwood SEED Scholars program. Not receiving a diploma does not equate to not having access to post-secondary opportunities.” It may prevent students from enrolling in a degree program, but there are other post-secondary options. (You can read more about these considerations in our article about high school graduation options for students with disabilities).

Richard Rosenberg, PhD, parallels Dr. Pelangka’s sentiment, telling us that the effect of earning a diploma “is dynamic, in that with the online applications for employment, if a young adult with an IEP does not have a diploma, they will not be screened for a job because it will be stopped the minute they say they just have a certificate.” He continues to say that earning a certificate of completion or attendance isn’t the worst thing in the world, and that “there are other ways to navigate employment, college, postsecondary. It makes it more difficult but there are other ways to get a job, continue your education, and have a life.” Many individuals with IDD need help applying for a job and may do so through a job coach or supported employment agency partnering with a competitive integrated employer.

But the reality is that having a high school diploma 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. Having a diploma gives me something to be proud of that I worked hard through my IEP and my team to demonstrate I have competency.”

California’s new pathway to a diploma: what to know

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 don’t have a pathway to a diploma and who take the California Alternate Assessment (CAA) — which are 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.

California’s alternative achievement standards

California’s alternate achievement standards were developed specifically for students with significant cognitive disabilities who take the California Alternate Assessment to provide access to the same California state standards as their peers without disabilities, but in a modified format using Core Content Connectors (CCCs) with supports provided through each student’s IEP. 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

But what exactly is a significant cognitive disability? Under ESSA, states are guided to develop their own definition, but generally this refers to students who are within one or more of the existing categories of disability under the IDEA and whose cognitive impairments may prevent them from attaining grade-level achievement standards. 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.”

Coursework: requirements & exemptions

Under the 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, including A-G requirements. Rosenberg explains that “If a district has higher standards, like A-G to go to a UC, a student with an IEP can state that they are on the basic pathway to a diploma and not have to have A-G. It is a local decision, but we believe the IEP process should be able to modify that so an individual with an IEP doesn't have to excel at A-G; they have to meet the minimum requirements for a high school diploma in the state of California.”

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 (age 21 federally, 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. Rosenberg tells us that under this pathway, “We still have the IEP process. We have local control. We have transcripts. We have standards. And that is a way to earn a diploma.” It’s important to emphasize that this new diploma is considered the equivalent of a traditional high school diploma. Because of that, under ESSA, students earning this diploma will be counted in the Adjusted Cohort Graduation Rate (ACGR), which is not allowed for other equivalents of diplomas (such as the general equivalency diploma, certificate of completion, certificate of attendance, and other similar “lesser credentials”).

What to know about California's new high school diploma for students with cognitive disabilities

How do I know if my child is eligible for a Section 51225.31 diploma?

To ensure compliance with this new law, before your child begins 10th grade, the IEP team must determine and inform you whether your child may be eligible to receive a high school diploma under this exemption.

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 significant cognitive difficulties (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 this diploma 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.

And what about students who are homeschooled? Rosenberg tells us that students being homeschooled can still earn a diploma through an alternate pathway if the homeschool has standards showing achievement aligned with the California Alternate Achievement standards.

How can parents navigate this pathway?

While parents can assess and determine whether their child is eligible for a Section 51225.31 diploma before the start of 10th grade, 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:

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:

What about students who are ineligible for this pathway?

While this new diploma pathway 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 most recent 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. This is due to the state legislature by June 30, 2024.

What steps can parents take NOW?

This new pathway is an exciting opportunity for many of our kids — while there are some challenges to be aware of during this transition period, there are also some great ways you can advocate as a parent. Because the new California Ed Code was passed in 2022, to be implemented immediately, it didn’t come with much guidance at the local level. Local district administrators we spoke to told Undivided they don’t have enough information about the new pathway just yet, and that they are anxiously awaiting for the LA County Office of Education, the California Department of Education, and SELPAs to provide districts with further details and guidance.

Given this level of uncertainty, parents should still advocate for keeping all possible pathways open.

Rosenberg tells us that “[t]he IEP team still has some power and authority at a local level to assist with energy towards a diploma. The challenge right now is we do not have a cookbook, procedural manual, or template that has been blessed and supported by the State Department of Education, SELPAS, or the districts.” Rosenberg reminds us that even though this new Ed Code is very recent, parents can start advocating for their children now:

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. And now, with this new CA education code, in effect as of June 2022, it’s important that your child is taking grade-level classes so that they are ready, and set up for success, once guidance from the CDE is issued to schools.

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

  • Check if your state already offers an alternate pathway to a diploma for students with cognitive disabilities under ESSA (as of 2016, California and 24 other states had alternate diploma or certificate options specifically for students with disabilities).

  • 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 before they start 10th grade. 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! Some parents don’t want their children to be in an alternate diploma pathway, especially if the pathway isn’t aligned to graduation standards and limits their child’s future. Some parents want their child to earn a regular diploma, even if it takes them a bit longer than other students. Every state is different with the programs they offer. Whatever path is right for you, remember that under IDEA, special education students are allowed to stay in public schools (and earn a diploma) up to the age of 21 (22 in California).



Options for graduating high school with an IEP

California’s new pathway to a diploma: what to know

How do I know if my child is eligible for a Section 51225.31 diploma?

What about students who are ineligible for this pathway?

What steps can parents take NOW?

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Karen Ford CullUndivided Content Specialist and Writer
With a passion for fostering inclusive education and empowering families in the disability community, Karen Ford Cull brings a wealth of experience as a Content Specialist and Advocate. With a diverse background spanning education, advocacy, and volunteer work, Karen is committed to creating a more inclusive and supportive world for children with disabilities. Karen, her husband, and three sons are committed to ensuring that their son with Down syndrome has every opportunity to lead an enviable life. As the Content Specialist at Undivided, Karen guides writers to produce informative and impactful content that ensures families have access to comprehensive and reliable resources. #### Reviewed by Adelina Sarkisyan, Undivided Writer and Editor #### Contributors Richard L. Rosenberg, PhD, board member of the California Transition Alliance, faculty at Cal State LA, Chapman University, and San Diego State University Dr. Sarah Pelangka, Special Education Advocate, BCBA-D, and owner of KnowIEPs

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