The Education Trust–New York submitted the following public comment on the new pathway to a New York State High School Equivalency Diploma:
December 12, 2017
Deputy Commissioner Kevin Smith
Adult Career and Continuing Education Services
New York State Education Department
89 Washington Avenue
Albany, NY 12234
Re: Public Comment on Proposed New Pathway to a NYS High School Equivalency Diploma
Dear Deputy Commissioner Smith:
We are submitting public comment on the proposed new pathway to a New York State High School Equivalency Diploma. The Education Trust–New York is an equity-driven, data-centered policy and advocacy organization that pursues educational justice by building awareness of equity, achievement and opportunity gaps and marshaling public and political will for solutions that will enable every child in New York State — especially those who are low-income or students of color — to achieve his or her full potential.
We support the New York State Education Department’s (NYSED’s) effort to provide greater flexibility to students pursuing a high school equivalency diploma by accepting passing Regents exam scores in place of the corresponding sub-tests on the Test Assessing Secondary Completion (TASC), the assessment leading to a New York State high school equivalency diploma. We believe that this new pathway can help re-engage students who have dropped out of high school and allow them to more quickly advance to post-secondary opportunities.
Consistent with the spirit of the proposed change, we respectfully request that an additional provision be included in the regulation as a safeguard. We are concerned that an unintended consequence of this new pathway may be that some post-compulsory aged youth are pushed out of high school and into TASC-preparation programs. For students who struggle on exit exams and have passed some, but not all, Regents exams required for a high school diploma, we fear that schools may encourage them to enroll in TASC-preparation programs instead of continuing to work with them and help them receive a high school diploma.
In order to protect against this practice, the regulation should specify that NYSED will require school districts to report the number of students who receive a high school equivalency diploma via this pathway, disaggregated by age and school last attended, as well as by race/ethnicity, low-income status, disability status, and English Language Learner status; that this data will be made publicly available; and that NYSED will audit those districts with higher numbers of older youth or disproportionalities by disaggregated group receiving a high school equivalency diploma via this pathway.
In addition, the regulation should specify that when school districts inform students and their families about the new high school equivalency diploma pathway, they must provide students and parents with notices, in a language they understand, about the right to remain in school until the year in which they turn 21 years old, or receive a high school diploma, whichever comes first.
Regards,
Abja Midha
Deputy Director, The Education Trust–New York