While school may be wrapping up, Summer is an ideal time to embark on transition assessment and services to ensure that your child’s IEP process is preparing them for learning, living, and working after their public education. The ultimate goal of transition assessment is to identify the necessary skills and services to ready a student age 13-21 for transitioning from high school to the next phase of life. To book an intake and consultation appointment, visit: www.nesca-newton.com/intake. Not sure if you need an assessment? You can schedule a one-hour parent/caregiver intake and consultation.

Diplomas, Graduation Dates and IEP Transition Services Revisited

By: Kelley Challen, Ed.M., CAS
Director of Transition Services; Assistant Director, NESCA

Three years ago, on March 26, 2019, the Massachusetts Department of Elementary and Secondary Education (DESE) sent out an important administrative advisory regarding transition services and graduating with a high school diploma (Administrative Advisory SPED 2018-2: Secondary Transition Services and Graduation with a High School Diploma). At the time, I wrote a blog about the advisory, wanting to bring attention to the much-needed guidance clarifying when and how students with IEPs (Individualized Education Programs) should be issued a high school diploma.

Today, more than a year into the COVID-19 pandemic, seems like a very important time to revisit what it means for a student on an IEP to be ready to graduate high school with a diploma this June. Given the lengthy school shutdown in Spring 2020—followed by ongoing limitations in social contact, community engagement, employment opportunities, and more—many students and their families are questioning whether they are ready for graduation. In fact, I sat in a team meeting last week where a special educator asked an adult student whether they would like to take their diploma or “refuse” their diploma in June. [This phrasing, “refusing” or “rejecting” a diploma, is often used but is inaccurate as a student is not refusing to take their diploma. Rather, the team is instead delaying or deferring graduation in certain circumstances.]

As a parent and professional regularly involved in the IEP process, a comfort throughout this pandemic is that while education has been reinvented several times, and community safety and engagement is highly variable, special education laws (including the Individuals with Disabilities Education Act of 2004, which outlines the requirement for school districts to provide transition services) remain the same. The decision for a student receiving special education services to take a diploma, or defer taking a diploma, continues to be based primarily on the same variables:

  1. Meeting local graduation requirements;
  2. Passing the state Competency Determination (CD); and
  3. Receiving Free and Appropriate Public Education (FAPE) that includes secondary transition services based on age-appropriate transition assessment.

Prior to COVID-19, passing the state CD in Massachusetts typically involved passing on-demand tests in English Language Arts (ELA), Mathematics and Science or successfully completing an alternate assessment competency portfolio. For students who have an anticipated graduation date prior to October 1, 2021 (as noted in their most recent signed IEP), something that has changed during the pandemic is that there are now Modified CD requirements that allow for CD in ELA and mathematics to be awarded upon district certification that the student earned full credit for a relevant course aligned to the curriculum framework in the subject matter and demonstrated competency in that subject. A similar Modified CD requirement for science is also available for students graduating in classes of 2021-2023. Therefore, a student who did not pass on-demand MCAS testing in 2019 may be eligible to graduate with a diploma using the Modified CD requirements.

However, as students, their parents, and their education teams ponder June 2021 graduation dates, it is important to keep focus on the same variables that we have always used for considering whether a student is ready to accept a local diploma. Here are some questions that may help when considering these variables.

  1. Has the student met all local graduation requirements? Did they complete the core courses required by the district? Or, were they given credit for courses/activities that varied greatly from courses that general education students completed? What about attendance requirements? Did the student stop attending classes or have a significantly lower rate of attendance than general education peers in the past year? Did the student meet requirements for community service hours or a capstone project if those were required of general education students?
  2. Did the student pass the state Competency Determination? Did the student have the opportunity to participate in MCAS on-demand testing? If they did not, did the student have a track record of passing MCAS tests? Was the student scheduled to graduate this June or did someone from the school district propose changing the student’s graduation date to take advantage of the Modified CD requirements currently being used by the department of education due to COVID-19?
  3. Did the student receive FAPE including secondary transition services based on age-appropriate transition assessment while in high school? Is there a Transition Planning Form (28M/9) that the team has been updating annually? Are there appropriate measurable postsecondary goals in the student’s IEP vision statement that are based on transition assessment (PLEASE remember that interview is an important assessment tool for many students)? Was the student’s voice part of team meetings where transition services were discussed? Does the student’s IEP have measurable goals that will reasonably help the student to progress toward their IEP vision statement? Has the student made effective progress on the goals outlined in the IEP over the past year? Has the student been able to engage in transition services that were described in the IEP? Was the student’s graduation date supposed to be this June or was it “TBD”? And, if appropriate, was a representative of an adult human service agency (e.g., Department of Mental Health, Department of Developmental Services, Massachusetts Rehabilitation Commission, Massachusetts Commission for the Blind, Massachusetts Commission for the Deaf and Hard of Hearing) involved in one or more IEP meetings?

Having missed out on school and community-based activities in the past year can create an immediate concern that a student needs to hang on to their special education protections and should not graduate this June. But the truth is that the pandemic created opportunities for students to generalize skills and practice functional skills, and some students are more ready than ever to move on from special education. And, as I stated in my previous blog, there is no universal set of skills or level of knowledge that deems a student on an IEP “ready” to graduate. In fact, students on IEPs, just as with mainstream students, graduate all the time without being ready for many adult activities (e.g., apartment hunting, changing jobs, applying for a bank loan, comparing health insurance plans).

When you are considering whether the student has received FAPE, it is important to remember that every student missed some typical high school planning steps over the past year. When school buildings closed down and community engagement came to a halt, educators and special educators had to pivot many times. Transition planning steps may have been missed or services may not have been delivered in originally anticipated ways without any clear fault or person to blame. If a student’s progress towards their measurable postsecondary goals was substantially halted, this might be important for the team to discuss. But there are many circumstances where students continued to make progress in spite of the missed opportunities. Perhaps the pandemic even created new opportunities for progress that would not typically be available until a student exits high school (e.g., a paid job, increased self-direction through participation in remote learning, easier access to pre-employment transition services, increased communication with peers through technology, etc.).

Regardless, as you are thinking about graduation, please remember that the most important question to ask is not, “Is my child/student ready to graduate?” Instead, the critical question to ask when a student approaches their graduation date is, “Has the student received a Free and Appropriate Public Education (FAPE)?” If the answer is “yes,” it is vital to give the student the opportunity to step into adult postsecondary life and begin applying the skills they have learned through their education and special education. Although the pandemic has created a lot of anxiety and uncertainty, let’s not fall victim to a pattern of rejecting IEPs (essentially rejecting/refusing diplomas) out of fear.

If you are interested in working with a transition specialist at NESCA for consultation, planning, or evaluation, please complete our online intake form: https://nesca-newton.com/intake-form/.


Transition Resources and Advisories from MA Department of Elementary and Secondary Education:

While this blog includes some specific content that applies only to families of students in IEPs in Massachusetts, the requirement to deliver transition services for students on IEP is a federal mandate and impacts graduation in all states.


About the Author
Kelley Challen, Ed.M., CAS, is NESCA’s Director of Transition Services, overseeing planning, consultation, evaluation, coaching, case management, training and program development services. Ms. Challen also provides expert witness testimony in legal proceedings related to special education. She is also the Assistant Director of NESCA, working under Dr. Ann Helmus to support day-to-day operations of the practice. Ms. Challen began facilitating programs for children and adolescents with special needs in 2004. After receiving her Master’s Degree and Certificate of Advanced Study in Risk and Prevention Counseling from Harvard Graduate School of Education, Ms. Challen spent several years at the MGH Aspire Program where she founded an array of social, life and career skill development programs for teens and young adults with Asperger’s Syndrome and related profiles. She additionally worked at the Northeast Arc as Program Director for the Spotlight Program, a drama-based social pragmatics program, serving youth with a wide range of diagnoses and collaborating with several school districts to design in-house social skills and transition programs. Ms. Challen is co-author of the chapter “Technologies to Support Interventions for Social- Emotional Intelligence, Self-Awareness, Personality Style, and Self-Regulation” for the book Technology Tools for Students with Autism. She is also a proud mother of two energetic boys, ages six and three. While Ms. Challen has special expertise in supporting students with Autism Spectrum Disorders, she provides support to individuals with a wide range of developmental and learning abilities, including students with complex medical needs.


Neuropsychology & Education Services for Children & Adolescents (NESCA) is a pediatric neuropsychology practice and integrative treatment center with offices in Newton, Massachusetts, Plainville, Massachusetts, and Londonderry, New Hampshire, serving clients from preschool through young adulthood and their families. For more information, please email info@nesca-newton.com or call 617-658-9800.