Special Education

NYS CDOS Commencement Credential - Questions and Answers

B. Instruction

CDOS Learning Standards

  1. Are the CDOS Learning Standards aligned with the NYS Common Core Learning Standards (CCLS)?

The CDOS learning standards have not yet been revised to incorporate the CCLS.  However, the NYS Career and Technical Education (CTE) Technical Assistance Center has developed a crosswalk between the CCLS and the CDOS learning standards. The crosswalk is available at http://nyctecenter.org/content/userfiles/files/CCSS%20CDOS%20Crosswalk%20ELA.pdfexternal link.

  1. If the student does not meet all standards (1, 2 and 3a) at the commencement level, is he/she eligible for an award of the CDOS Commencement Credential? 

No.  The school district must have evidence that the student has demonstrated commencement level knowledge and skills relating to the CDOS learning standards (career development, integrated learning and the universal foundation skills) to award this credential to a student.  However, it is not necessary for the student to complete all of the sample tasks to demonstrate attainment of that standard.

Opportunities to Earn a Diploma

  1. What are appropriate opportunities to earn a Regents/local diploma? 

A student with a disability must be provided with appropriate opportunities to earn a Regents or local high school diploma.  This includes providing a student with meaningful access to participate and progress in the general curriculum and coursework to assist the student to meet the State’s learning standards and the requirements for graduation with a regular (local or Regents) high school diploma.  Meaningful access to the general education curriculum means that a student with a disability is participating in credit-bearing courses with the appropriate supports, services and accommodations to address his or her disability.  The student’s individualized education program (IEP) indicates the special education programs, services, and supports the student needs to be involved and progress in the general education curriculum.  All students with disabilities, except those with severe cognitive disabilities who are assessed against alternate standards, must be engaged in courses and coursework required to earn the necessary credits and to take the required Regents assessments.  Students with disabilities should not be placed on a “separate track” to receive the CDOS Commencement Credential. 

  1. Is seat time in general education classes a way to provide opportunities to earn a regular high school diploma and access to participate and progress in the general education curriculum if the student is not able to pass the curriculum?

Access to and participation in the general education curriculum does not occur solely because a student is placed in a general education classroom, but rather when he or she is engaged in learning the content and skills that define the general education curriculum.  Specially designed instruction is provided through a continuum of services designed to meet the unique needs of each student with a disability.  For some students with disabilities, a special class for all or part of the day may be an appropriate special education program necessary for the student to have access to participate and progress in the general curriculum.  The student’s IEP, as developed by the committee on special education (CSE), indicates the special education programs, services, and supports the student needs to be involved and progress in the general education curriculum to meet the student’s unique needs.

  1. Are modified curriculum classes for students with disabilities considered access to participate and progress in general education?

Yes.  Modified curriculum classes for students with disabilities may be considered access to participate and progress in general education if documented as a special education support or service in the student’s IEP.  Access to the general education curriculum not only means that students are taking the appropriate courses needed to earn a Regents or local high school diploma, but also that they are being provided with appropriate specially designed instruction, accommodations, supports and services to progress in the curriculum.

  1. Does a student with a disability have to participate in Regents examinations, including those participating in expanded delivery of coursework over two - three years?

A student with a disability who completes a Regents course must have the opportunity to take the required Regents exam.  The CSE may not exempt any student from such participation.  Regents exams may be taken multiple times, and there are safety net options available so that students with disabilities may graduate with a local diploma.  More information regarding these options is available at http://www.p12.nysed.gov/specialed/publications/safetynet-qa.htm

In addition, the student’s IEP must indicate, if appropriate, any testing accommodations the student needs in order to participate in testing programs on an equal basis with his/her nondisabled peers.  Such accommodations provide students with the ability to demonstrate mastery of skills and attainment of knowledge without being limited or unfairly restricted due to the effects of a disability.  Guidance on test access and accommodations for students with disabilities is available at http://www.p12.nysed.gov/specialed/publications/policy/testaccess/policyguide.htm.

  1. When is a decision made to have a student stop working toward a diploma and concentrate on earning this credential?

At no point should a decision be made that a student stops working toward a regular high school diploma in order to concentrate on earning this credential.  Preparation for attainment of the CDOS Commencement Credential is not a track.  A student with a disability must be provided with appropriate opportunities to earn a Regents or local high school diploma, including providing a student with meaningful access to participate and progress in the general curriculum to assist the student to meet the State’s learning standards.

  1. If a student with a disability has completed transition planning, the CTE coursework and work-based learning requirements to earn a CDOS Commencement Credential, and remains in or returns to school, must districts provide programming other than access to the general education curriculum for students who have not yet earned a Regents diploma?

Transition planning and activities are not completed until the student exits high school.  In addition, the hours of instruction and work-based learning requirements to earn the CDOS Commencement Credential is a minimum standard.  All students should be encouraged to evolve their work readiness skills beyond the minimum requirements, and all districts should provide students with additional coursework and work-based learning experiences beyond the 216 hour requirement while the student continues in school to earn a regular high school diploma.

  1. How will students have time to work toward both the CDOS Commencement Credential and a regular high school diploma?

Each student with a disability who is age 15 and older must have an IEP that includes a coordinated set of activities that prepare the student to meet his/her post-secondary goals, including employment goals.  In developing this plan, CSEs should consider the student’s need for courses of study that will prepare him/her to earn this credential.  To earn the CDOS Commencement Credential, a student must have successfully completed in grades 9-12, a minimum of 216 hours of CTE coursework and/or work-based learning activities.  Fifty-four (54) of the 216 hours must include documented, school-supervised work-based learning experiences related to career awareness, exploration and/or preparation which may, but are not required to, be completed in conjunction with the student’s CTE course(s).  Over a four (or more) year period of time (grades 9-12), it is reasonably expected that schools can provide students with work-based learning activities such as job shadowing, community service, volunteering, service learning, senior project(s) and/or school-based enterprise(s).  Although work-based learning experiences must be provided consistent with New York State Education Department (NYSED) guidelines and under the supervision of the district, participation in these activities may occur outside of regular school hours.

In addition to the minimum 216 hours of career preparation, the district must have documentation that a student has achieved the commencement level CDOS learning standards in the areas of career development, integrated learning and universal foundation skills.  NYSED has existing guidance on sample instructional activities as examples of how the CDOS standards can be presented in the classroom (http://www.p12.nysed.gov/cte/cdlearn/documents/CDOS-intro.pdf).  Some activities are short, one-day events that focus on a single topic or concept.  Others are multi-day instructional units that lead students through inquiry processes that increase their understanding.  While there are specific CDOS standards, there are unlimited ways to teach those standards. 

To provide additional flexibility, a student with a disability has the option to earn the CDOS Commencement Credential if he/she has earned one of the nationally recognized work readiness credentials in lieu of the other minimum career plan, instruction and employability profile requirements. 

  1. The regulations indicate that a school district that awards the credential to more than 20 percent of students with disabilities in the cohort, where the credential is not a supplement to a regular diploma, may be subject to redirection of a portion of their IDEA funds.  What portion of these funds will be reallocated?  How is the 20 percent ceiling being calculated?

To clarify, there is no cap on the percentage number of students with disabilities that can receive the CDOS Commencement Credential where the credential is not a supplement to a regular diploma.  However, when a district awards the credential to more than 20 percent of the students with disabilities in the cohort, where such credential is not a supplement to a regular high school diploma, NYSED may, at its discretion, determine that the reason for the numbers of students receiving the CDOS Commencement Credential as their sole credential is because the district failed to provide students with disabilities with appropriate access to participate and progress in the general education curriculum necessary to earn a regular high school diploma.  The amount of funds to be redirected would be determined on a case by case basis, depending on the findings of the State.

Work-Based Learning

  1. If the student achieves the required 216 equivalent hours through coursework, can the individual “opt out” of the 54 hours of work-based learning?

No.  The student cannot “opt out” of the work-based learning requirement if he/she is earning the credential through option 1.  However, where at least 54 hours of work-based learning is a component of a CTE course, the student’s successful completion of the CTE course would demonstrate that the student completed the minimum 54 hours of work-based learning.

  1. How can schools get approval of their work-based learning programs?

Only those work-based learning programs associated with registered CTE programs must be approved by NYSED.  These include the Career Exploration Internship Program (CEIP); General Education Work Experience Program (GEWEP); Work Experience and Career Exploration Program (WECEP); and CTE Cooperative Work Experience Program (CO-OP).  Other work-based learning options (e.g., job shadowing; community service; volunteering; service learning; senior projects; school-based enterprises and community based work programs) are developed at the local level and must be provided consistent with NYSED guidance.  Information regarding work-based learning requirements and the application for an NYSED registered program is available at http://www.p12.nysed.gov/cte/wbl/home.html.

  1. Could a student with a disability use part-time/full-time employment outside of school to count toward the work-based learning requirement?  If so, could school supervision be a collection of documented evidence of hours completed per work supervisor (time card/anecdotal meeting with employer)?

A school district may enter into formalized agreements for the provision of transition services such as vocational training programs approved by NYSED or by another State agency.  In these cases, a student’s employment could be counted toward the work-based learning requirement.  However, a student cannot use his/her independent employment outside of school to count toward the number of hours of work-based learning that is required for the CDOS Commencement Credential.  Work-based learning experiences must be provided consistent with NYSED guidelines, under the supervision of the district and documented in a student’s transcript.  Guidance on these and other work-based learning programs is available at http://www.p12.nysed.gov/cte/wbl/home.html.

  1. What are the duties of a job coach?

A job coach is a person who provides on-the-job training to individuals to help them adjust to the work environment.  A job coach’s duties include:

  • assistance with learning specific work duties and performance standards (doing the task);
  • development of work-related behaviors such as time and attendance, dress, communication skills, accepting supervision and travel skills; and
  • helping the student acquire a sense of belonging at the work site and encouraging an understanding of and a participation in employee programs which involves socialization with coworkers.
  1. Are teaching assistants qualified to accompany and/or monitor students during community work-based experiences, or will they need to be a job coach?

Yes. Teaching assistants may accompany and/or monitor students during community-based work experiences provided they do so under the supervision of a teacher who may or may not be present at the work site.  Teaching assistants often fulfill the role of job coach, providing ongoing, on-site coaching for students that have more intense needs and require more direct supervision and training in order to work at a job site.  It is recommended that job coaches complete a job coach training program.

  1. Can a teacher aide serve as a job coach?

No.  The job duties of a teacher aide are limited to nonteaching duties such as:

  • managing records, materials and equipment;
  • attending to the physical needs of children; and
  • supervising students and performing such other services to support teaching duties when such services are determined and supervised by teacher.
Because a job coach must assist students with disabilities learning specific work duties and performance standards, it would be inconsistent with the responsibilities of a teacher aide to perform such duties. 

To assist in determining the appropriate roles for a teacher assistant and a teacher aide, a description of duties is provided at: http://www.highered.nysed.gov/tcert/career/tavsta.html.

  1. Can a district contract with a community agency to provide job coaching services?

Yes.  Section 4401(2)(n) of NYS Education Law authorizes districts to enter into formal agreements or contracts with community agencies approved by NYSED or another State agency to provide transition services, which may include job coach services, to students with disabilities.  Transition services including, but not limited to, participation in work experiences, job coaching, and acquisition of employment skills as documented in a student’s IEP, may be funded through excess cost aid and are considered purchased services.  Additionally, another State agency may provide or pay for any transition service that the agency would otherwise provide to students with disabilities who meet the eligibility criteria of that agency.

  1. Will teachers providing work-based learning experiences need to have a specific certification such as a work-based learning extension?

Those providing work-based learning experiences associated with NYSED registered programs must, depending upon the type of program, be certified as a work-based learning coordinator completing an 8981 extension (Coordinator of Work-Based Learning Programs for Career Awareness) or an 8982 extension (Coordinator of Work-Based Learning Programs for Career Development). For individuals supervising locally approved community-based work programs, it is highly recommended but not required that they complete the certification requirements for Coordinator of Work Based Learning Programs for Career Awareness – extension #8981 (http://www.p12.nysed.gov/cte/wbl/home.html).

  1. Can a district arrange for students with disabilities to participate in work-based learning experiences provided by a community organization?  If so, can that experience be counted toward the work-based learning requirement for the CDOS Commencement Credential? (Updated February 2014)

Yes, provided the community organization has been approved by NYSED or another State agency to provide such services.  Education Law section 4401(2)(n) authorizes school districts to enter into formalized agreements for the provision of transition services (as defined in Education Law section 4401[9]) with programs such as vocational training programs that are approved by NYSED or by another State agency (e.g., Office for People With Developmental Disabilities, Office of Mental Health, Adult Career and Continuing Education Services (ACCES), Commission for the Blind).  All formalized agreements and contracts for instruction must be consistent with State requirements as clarified at http://www.p12.nysed.gov/resources/contractsforinstruction/qa.html

  1. If a school district enters into a contract or formalized agreement with a community agency to provide work-based learning experiences as a transition service, who would be responsible for funding the activity? (Updated February 2014)

School districts must ensure that a student with a disability receives his/her transition services at no cost to the parent.  Transition services may be provided by the school district or by a participating agency.  Participating agency, as defined in section 200.1(jj) of the Regulations of the Commissioner of Education, means a State or local agency, other than the public agency responsible for the student’s education, that is financially and legally responsible for the provision of transition services. 

Beginning with the first IEP in effect for students age 15 and older, and at a younger age if determined appropriate, the IEP must include a statement of the responsibilities of the school district and, when applicable, participating agencies for the provision of such services and activities that promote student movement from school to post-school opportunities (8 NYCRR section 200.4 (d)(2)(ix)(e)).  Such services would be documented in the coordinated set of activities section of the student’s IEP.

If a participating agency fails to provide agreed-upon transition services contained in the student's IEP, the district responsible for the student's education must, as soon as possible, initiate a meeting to identify alternative strategies to meet the transition objectives and, if necessary, revise the student’s IEP (8 NYCRR section 200.4(e)(6)). Nothing relieves a participating agency of its responsibility to provide or pay for any transition service that the agency would otherwise provide to students with disabilities who meet its eligibility criteria (8 NYCRR section 200.4 (e)(6)). 

  1. Is there any funding mechanism in the System to Track and Account for Children (STAC) to reimburse districts and/or community agencies for specific transition services provided by a community agency? (Updated February 2014)

Districts may contract with the entities identified in section 4401 of the Education law to provide special education services, including transition services.  Education Law sections 4401(2) and 4402(2)(b) authorize school districts to enter into contracts for special education services or programs, including related services, with other school districts, Boards of Cooperative Educational Services (BOCES), State-operated and State-supported schools, approved private residential and nonresidential schools both in and out of NYS, and the State University at Binghamton for nonresidential special education services and programs at the Children’s Unit.  Education Law section 4401(2)(n) authorizes school districts to enter into formalized agreements for the provision of transition services (as defined in Education Law section 4401(9)) in programs such as vocational training programs approved by NYSED or by another State agency.  A district may not contract or enter into a formalized agreement with community agencies to provide transition services if the community agency programs are not an approved program pursuant to Education Law section 4401(9), nor may the district submit a STAC for tuition reimbursement of such programs and services.

Districts may use their 611 Individuals with Disabilities Education Act funds to pay for transition services and, to the extent a contract for services is consistent with Education Law section 4401, it may be appropriate to submit a STAC.  For guidance on STAC and State Aid for students with disabilities, see http://www.oms.nysed.gov/stac/schoolage/schoolage_placement_summary/home.html.
For additional information, contact omsstac@nysed.gov .

Coursework

  1. Does the requirement for completion of CTE coursework and/or work-based learning experiences mean that the student will have to be enrolled in separate specific courses, or can the hours be completed through integration in other courses or settings?

To earn the CDOS Commencement Credential, the student must successfully complete the equivalent of two units of study or 216 hours in CTE course(s) and/or work-based learning experiences.  The CTE coursework can consist of specialized and integrated courses (grades 9-12) that are approved by the local board of education or through NYSED registered CTE programs.  Students must have a minimum of 54 hours of the total 216 hours in documented, school-supervised work-based learning experiences related to career awareness, exploration and/or preparation which may, but are not required to, be completed in conjunction with the student’s CTE course(s).  Students may complete all of the 216 hours through participation in work-based learning.  The 216 hours, whether achieved through completion of CTE coursework and/or work-based learning, may begin accumulating in 9th grade.

  1. Could school district general education courses that integrate CDOS learning standards (e.g., English language arts (ELA) where an activity is creating a resume) count toward 2 units of study in CTE coursework?

No.  General education courses (e.g., ELA) do not count toward the two units of study required for this credential.  The equivalent units of study must be earned through coursework in CTE and/or work-based learning experiences.  A CTE course means a grade 9-12 course in career and technical education that consists of specialized and integrated courses that are approved by the local board of education or by NYSED. 

  1. If a student is enrolled in a course(s) that would provide him or her with 216 hours of work-based learning, but the student is absent several times, does the student need to make up lost hours in order to meet the requirement for award of the credential?

In order to satisfactorily complete the course, students must meet class attendance requirements as established by the district.

  1. If a school district develops a locally approved CTE course, what must the coursework/curriculum include?

The majority of all courses that districts offer are locally developed and locally approved.  For purposes of this credential, CTE coursework, whether locally approved or approved by NYSED, means courses completed in grades 9-12 which could be specialized or integrated courses in CTE.  Such courses must:

  • be aligned to the learning standards (in this case, the CDOS learning standards);
  • be taught by a CTE teacher with CTE certification appropriate to the course description;
  • meet the unit of study requirement consistent with section 100.1(a) of the Regulations of the Commissioner of Education (at least 180 minutes of instruction per week throughout the school year or the equivalent); and
  • if credit is being awarded, meet the unit of credit requirements established in section 100.1(b) of the Regulations of the Commissioner of Education.  A unit of credit is earned by:
    • the mastery of the learning outcomes set forth in a NYS-developed or locally developed syllabus for a given high school subject, after a student has had the opportunity to complete a unit of study in the given subject matter area; or
    • pursuant to section 100.5(d)(1) of the Regulations, a passing score of at least 85 percent or its equivalent on a NYSED-approved examination in a given high school subject without the completion of a unit of study, and the successful completion of either an oral examination or a special project.

CTE course offerings approved at the local level are in the following content areas:

  • Agricultural;
  • Business and Marketing;
  • Family and Consumer Sciences; and
  • Technology.
While courses for this credential must be CTE content area specific (e.g., Agricultural), a course may focus specifically on Agriculture, or one or more of the four CTE content specific areas (e.g., Agricultural and Technology) may be combined to comprise one course.  One course may also expose students to the four different content areas (i.e., Agricultural; Business and Marketing; Family and Consumer Sciences; and Technology).

Coursework in which a student participates should also be consistent with his/her strengths, preferences and interests.

  1. Do schools or agencies need to get approval of their CTE courses in order to award the NYS CDOS Commencement Credential?

For purposes of this credential, CTE course(s) include grade 9-12 course(s) in CTE consisting of specialized and integrated courses that are either approved by the local board of education (locally approved) or included in an NYSED registered CTE program (NYSED approved).  Students working toward the CDOS Commencement Credential may participate in NYSED-approved CTE programs or take locally approved courses.  For locally approved courses, the local board of education has much flexibility in designing and/or realigning existing courses to meet the needs of the students pursuing the CDOS Commencement Credential.  For example, CTE course offerings approved at the local level include those in Agricultural; Business and Marketing; Family and Consumer Sciences; and Technology.  While the locally approved courses must be CTE content area specific (e.g., Agricultural), a course may focus specifically on Agriculture, or one or more of the four CTE content specific areas (e.g., Agricultural and Technology) may be combined to comprise one course.  One course may also expose students to the four different content areas (i.e., Agricultural; Business and Marketing; Family and Consumer Sciences; and Technology).  For locally approved courses, approval from NYSED is not required.

Information regarding the approval process and required coursework for NYSED registered CTE programs is available at http://www.p12.nysed.gov/cte/ctepolicy.

  1. If a two unit CTE course(s) for the CDOS credential is a board (locally) approved program, who can teach the course?

As with NYSED-approved (registered) programs, locally developed CTE courses must also be taught by CTE teachers.  Unless also certified as a CTE teacher, a special and/or general education teacher cannot teach courses required for award of this credential.  However, the CTE teacher and special and/or general education teacher may work together to co-plan and/or deliver the coursework. 

Last Updated: August 5, 2014