The Coalition strongly supports providing more flexibility to students who have mastered State standards, but struggle to demonstrate their knowledge and skills on the Regents exams. We were very pleased that the emergency measure approved in December 2017 acknowledges this need and removes Regents exams as a barrier to graduation for young people with disabilities who have passed Regents-level courses and demonstrated mastery of State Standards.

At the same time, we are concerned that limiting this new pathway to students with Individualized Education Programs (IEPs), could lead to discrimination, stigma, and devaluation of both the CDOS Commencement Credential and the local diploma. Without clear standards for implementation, we also worry about the burden this new pathway puts on families to ensure that schools do not push students with disabilities into less rigorous courses than their non-disabled peers and what that means for students who do not have parents able to advocate for their interests. Finally, we are concerned that the new pathway is another piecemeal adjustment to a system that relies on high-stakes exams rather than a rethinking of the diploma requirements, based on input from diverse stakeholders, to ensure that all students have the opportunity to demonstrate that they are college and career ready using meaningful assessments.

The Coalition urges NYSED to make the following changes before this amendment is permanently adopted:

• Make the superintendent determination pathway available to all students.
• Develop and expand resources for schools to meaningfully implement the CDOS Commencement Credential.
• Develop Superintendent Determination procedures to prevent push-out.
• Engage stakeholders in re-examining the existing graduation framework to develop pathways to a diploma that are not based on high-stakes assessments.
• Provide resources to families and schools to clarify existing graduation rights and requirements.