RCSN Public Comment to Proposed NY State Skills and Achievement Credential

Thank you for the opportunity to comment on the proposed Skills and Achievement Commencement Credential. As part of a group of advocates that have been meeting with representatives from SED for several years in an effort to change the name of Individualized Education Program (IEP) Diploma, we are pleased that the State has proposed that the IEP Diploma be eliminated. We appreciate the opportunity this affords to create a more meaningful credential that would drive curriculum development.  However, there are several issues that bear consideration as the State moves toward adopting this new credential.

Any discussion of the Skills and Achievement Commencement Credential must take place in the context of all of the diploma options available. This credential needs to be seen as part of a continually expanding array of options, particularly now that the elimination of the Safety Net for students currently entering high school in effect narrows the pathways that students can take to achieve a local  diploma. Without the opportunity to take the Regents Competency Test, too many students will be cut off from a legitimate diploma option unless an alternative to passing the Regents is offered to them.

There are several other issues that we would like to have addressed as the State moves forward: 

• We are concerned about the capacity of districts and schools to implement the credential. We want to be assured that the appropriate time and staff development are provided so that the new credential will be meaningfully individualized and not just another form to be routinely completed.

• If used correctly, the in-depth skills assessment can and should be used to drive curriculum, and thus needs to be integrated into the transition planning process at a very early stage, preferably as early as Middle School.

• Extensive and ongoing education and outreach to the business and higher education community about the meaning of the credential has to be built into its implementation. The credential and its Exit Summary needs to be perceived as meaningful tool for facilitating placement.

• Since there is little information about the Phase II populations and implementation, we would like clarification on this issue.

• Plans to assure that students identified to receive this credential will have access to the general curriculum have to be part of the planning process.

• We need to be assured that this option will not simply replace the IEP Diploma Option as the default option for students, and perhaps enlarge the pool of students graduating without any recognized  diploma.

• We urge that the language on the Exit Summary be strength-based, and not deficit- based as it currently is. The language, (particularly on Page 2) should emphasize the student’s strengths rather than minimizing achievement. (We would be happy to provide detailed input into the development of the next draft.)

  And finally, as the network of federally funded Parent Training and Information Centers (PTI’s), we are particularly concerned about the need to make parent  education an integral part of the outreach to the community. This should be part of the initial roll out of the credential and should provided on an ongoing basis in the future. It is imperative that parents and students alike understand the requirements of this credential and most importantly, the consequences of this and all other diploma options even before they enter high school.  The last thing we want to accomplish with this new credential is to create the same confusion about its meaning and value that existed with the IEP Diploma that we have worked so hard to eliminate.