A certificate or a diploma--which is better for your child with special needs?

January 16, 2018

The recent decision by the United States Supreme Court in Endrew F. v. Douglas County School District creates higher expectations for students with special needs than what had previously been articulated by lower courts over the years. In Endrew F., the Supreme Court held  that "to meet its substantive obligation under the IDEA, a school district must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances." These higher expectations should affect the IEP team's long-range planning for any given student, including whether the student will be on a certificate track or a diploma track.


California public schools provide two different “tracks” by which a special education student can complete high school. If the student is capable of meeting the requirements to obtain a high school diploma, the student is said to be on a “diploma” track. If, on the other hand, the student is incapable of meeting the requirements for a diploma, the child may be placed on a "certificate" track. 


The state sets minimum requirements. Local school districts have the authority and responsibility for establishing any requirements for awarding a California high school diploma from their secondary schools. The minimum requirements for a high school diploma in California are that the student complete the following one-year courses: three English courses; two mathematics courses, or more if the school board requires more; two science courses; three social studies courses; one course in visual or performing arts or foreign language or career technical education; and two P.E. courses. Most school districts in California require between twenty-two and twenty-six one-year courses (or the equivalent) for graduation. 


At present, the old graduation requirement that students pass the California High School Exit Examination has been suspended. 


The requirements for a certificate or document of achievement or completion are as follows: 1) The student must have completed an alternative prescribed course of study approved by the school board; 2) the student is to have satisfactorily met their IEP goals and objectives as determined by the IEP team; 3) the student must have attended high school, participated in the instruction described in their IEP and met the objectives of the statement of transition services. 


There are several benefits to receiving a diploma as opposed to a certificate. For instance, community colleges in California, as a prerequisite of enrollment, require a student to have received a diploma or its equivalent, such as having passed the GED or the High School Equivalency Test. And most employers will require job applicants to have received a high school diploma or its equivalent or require applicants to work toward completion of one of these. 


Given the higher expectations for children with special needs resulting from the Endrew F. case, if appropriate, carefully look into whether as a result of these higher expectations, your child might be able to graduate with a diploma or its equivalent. 


Please read our disclaimer.


Martha Millar

A California special education attorney



Tel: 916-724-5211 or 530-274-2740





Please reload

Featured Posts

Two mental health bills introduced in the Senate

August 22, 2015

Please reload

Recent Posts

March 22, 2019

Please reload