A Regular High School Diploma Cannot Be Based on Coursework Aligned with Iowa’s Alternative Academic Achievement Standards and Alternative Assessment

 In the past year, I've responded to several calls from parents who were struggling to respond to challenges from their child’s private and Medicaid insurers, asking the parents how their children, who the parents and school district said had substantially limited expressive and receptive communication skills and functioned at the level of a two-to-three-year old, had earned regular high school diplomas. 

Calls like this concern me because students whose high school instruction was entirely or mostly based on Iowa’s Essential Elements are not eligible to receive a regular high school diploma.  

Under state and federal law, a regular high school diploma may not be based on high school credits in courses based on Iowa’s Essential Elements for Students with the Most Significant Cognitive Disabilities. 34 C.F.R. § 300.102(a)(3)(iv); Iowa Admin. Code r. 281–41.102(1)(c)(4). A regular high school diploma is the high school diploma (or a higher form of diploma) awarded to the vast majority of graduating students, and doesn’t include any other form of diploma, GED, certificate of completion, certificate of attendance, or any similar lesser credential. 34 C.F.R. § 300.102(a)(3)(iv); Iowa Admin. Code r. 281–41.102(1)(c)(4).

The reasons state and federal law do not permit a regular high school diploma to be based on high school courses aligned with alternate academic achievement standards include:

1. Preserving the Integrity and Value of the High School Diploma. The legal requirement that a regular diploma must be aligned with a state's regular academic achievement standards prevents dilution of the diploma’s value in certifying to employers, postsecondary institutions, and others that a graduate has met the state’s academic requirements. 34 C.F.R. § 300.102; K.L. v. R.I. Bd. of Educ., 907 F.3d 639, 652 (1st Cir. 2018).

2. Preventing Premature Termination of Special Education. The IDEA requires that students with disabilities receive a FAPE until they either age out or graduate with a regular high school diploma. If a regular diploma could be awarded based on alternate, less rigorous academic standards, school districts could use such diplomas to terminate special education services before students with disabilities have aged out of special education eligibility at age 21. See e.g., K.L. at 652.

3. Ensuring Access to the General Curriculum. Requiring that alternate academic achievement standards are based on the state’s regular academic achievement standards ensures access of children with significant cognitive disabilities to the general curriculum (34 C.F.R. 300.39(b)(3)(ii); Iowa Admin. Code. r. 281-41.39(c)(3)(ii)) and to prepare for further education, employment, and independent living. 20 U.S.C. § 1400(d)(1)(A).

4. Ensuring Transparency and Informed Decision-Making. The IDEA and the Every Student Succeeds Act require that IEP teams and parents be informed about the implications of taking courses based on alternative academic achievement standards and alternate assessments. 34 C.F.R. § 300.160(3); 34 C.F.R. § 200.6; Iowa Admin. Code r. 281-41.160.