Career development and occupational studies (CDOS) graduation pathway option.
Purpose:
To establish a Career Development and Occupational Studies (CDOS) graduation pathway option for all students who meet the requirements to earn a CDOS Commencement Credential, meet graduation course and credit requirements, and pass four required Regents Exams.
Text or summary was published
in the April 6, 2016 issue of the Register, I.D. No. EDU-14-16-00002-EP.
Final rule as compared with last published rule:
No changes.
Text of rule and any required statements and analyses may be obtained from:
Kirti Goswami, State Education Department, Office of Counsel, State Education Building, Room 148, 89 Washington Ave., Albany, NY 12234, (518) 474-6400, email: legal@nysed.gov
Initial Review of Rule
As a rule that requires a RFA, RAFA or JIS, this rule will be initially reviewed in the calendar year 2019, which is no later than the 3rd year after the year in which this rule is being adopted.
Assessment of Public Comment
Since publication of a Notice of Proposed Rule Making in the State Register on April 6, 2016, the State Education Department (SED) received the following comments on the proposed amendment.
1. COMMENT:
Many commenters supported Career Development Occupational Studies (CDOS) pathway as additional graduation pathway. Students are diverse and diploma pathways should be too. CDOS pathway will: prepare students to be college/career ready; increase opportunity for students to graduate/graduation rates; allow students to continue Career and Technical Education (CTE) pathway without being limited by traditional graduation pathway; recognize students for work-based learning (WBL); provide valuable work-readiness credential; help increase students’ skill levels and work-based practices; allow students to participate in WBL opportunities that build on strengths, interests and preferences; provide increased flexibility to meet graduation requirements (e.g., substitute credential for Global or US History Regents exams) while holding students to high standards; help students gain meaningful education; and put students in strong position to get jobs.
DEPARTMENT RESPONSE:
Comments supportive; no response necessary.
2. COMMENT:
Support expanding CDOS credential to all students. Districts will be more committed to developing robust coursework and WBL experiences and not have separate courses for students with disabilities. Important to place emphasis on CDOS; all students can benefit from WBL. Proposal gives general education students opportunity to develop entry-level employment skills. Limiting credential to students with disabilities and documenting credential on transcript unfairly stigmatized students and forced disclosure of disability to employers.
DEPARTMENT RESPONSE:
Comments supportive; no response necessary.
3. COMMENT:
CDOS pathway: lacks sequential/focused coursework and does not provide foundation to fully prepare students to be college/career ready and enter workforce; requires minimal unrelated coursework and limited WBL and career guidance; 216 hours of WBL without specific instruction in CTE coursework is insufficient to ensure career readiness; has potential to affect expansion and improvement of original five pathways by allowing districts to offer less rigorous pathway; may result in fewer students participating in more rigorous pathways; requires no measure of student achievement and conflicts with time and money spent ensuring 4+1 pathway exams were comparably rigorous to Regents exams; requires no evaluation of WBL experiences; requires no career programming; and does not address needed financial management skills. Pathway must have defined coursework and WBL (216 hours of both CTE coursework and WBL) aligned with students’ interests to strengthen work-readiness knowledge and skills.
DEPARTMENT RESPONSE:
We do not agree the CDOS pathway is less rigorous. Pathway allows students to earn a diploma when they have demonstrated State’s standards for academic achievement in math, English, science, social studies, and for essential work-readiness knowledge and skills necessary for successful employment. While not requiring 5th assessment, pathway is comparably rigorous because it is based upon successful completion of instruction and educational experiences that prepare students to meet commencement-level CDOS Learning Standards and demonstrate work-readiness knowledge and skills. In addition to meeting CDOS credential requirements, students must earn required course credits and pass four Regents exams, one in each of four discipline areas.
4. COMMENT:
Change CDOS credential to diploma.
DEPARTMENT RESPONSE:
Standards for a diploma must be comparably rigorous to assessment pathways and represent readiness for employment and/or postsecondary education. Requirements for CDOS credential only relate to minimum standards necessary for students to demonstrate entry-level work-readiness skills.
5. COMMENT:
Current WBL opportunities may be limited and placements will quickly reach capacity; affecting schools’ ability to offer range of experiences for students with disabilities who may require additional supports/accommodations. Concerned how students will be selected to participate in limited WBL experiences. Opportunities planned for students with disabilities may be reduced as proposal does not indicate that students with disabilities must be afforded equal opportunity for placements.
DEPARTMENT RESPONSE:
Schools must ensure that all students, including students with disabilities, have meaningful access to CTE courses and WBL experiences necessary to earn CDOS credential.
6. COMMENT:
Support CDOS pathway as dual exit criteria, not as graduation option for general education students. Exiting students without a diploma limits employment and post-secondary education opportunities.
DEPARTMENT RESPONSE:
Districts remain responsible for ensuring students are provided appropriate opportunities to earn a diploma. We believe the proposal will expand these opportunities. Although the credential could be a student’s only exiting credential, we expect this number will be small. Credential documents student attainment of CDOS learning standards and preparation for entry-level employment; many entry-level positions do not require a diploma.
7. COMMENT:
Work-readiness exams to earn credential (Option 2) is test substitution and does not ensure students received instruction to build workforce skill and knowledge.
DEPARTMENT RESPONSE:
Although districts may allow students to earn CDOS credential by meeting requirements of a nationally recognized work readiness credential, this should not be the only option available. Schools are expected to prepare students for Option 2 assessments. All four credentials offer suggested resources and/or recommend comprehensive curriculum to assist schools in preparing students.
8. COMMENT:
CDOS pathway does not ensure rigor of WBL placement. Recommend WBL be SED approved/registered programs and supervised by NYS certified WBL coordinator, who is knowledgeable of Labor laws and operates under SED’s guidelines, to increase quality of WBL experience; prevent districts from accepting unsupervised work experience hours; ensure safe work environments; and add rigor and relevance to pathway. Certified teacher required for all other programs; require same for WBL component of CDOS pathway.
DEPARTMENT RESPONSE:
Individuals providing WBL experiences through SED registered programs must, depending upon type of program, be certified WBL coordinators. Although those supervising locally approved community-based work programs do not require certification, SED recommends certification.
9. COMMENT:
To ensure CDOS pathway rigor and serve as alternative to Regents exam, require both Option 1 (i.e., develop career plan; achieve CDOS learning standards 1, 2 and 3a; complete 216 hours of CTE coursework and/or WBL; and employability profile and Option 2 (i.e., nationally recognized work-readiness credential) plus additional performance-based assessment using CDOS standards and range of strategies that provides learners interactive role and incorporates WBL into CDOS pathway.
DEPARTMENT RESPONSE:
SED declines to make proposed changes. CDOS pathway was intended to expand the opportunities for students to earn a regular high school diploma while ensuring standards for a diploma are comparably rigorous.
10. COMMENT:
Better define difference between CTE and CDOS pathway, or perception will be CDOS is lesser CTE pathway.
DEPARTMENT RESPONSE:
CTE pathway ensures students meet CDOS learning standard 3b-Career Majors (students choosing a career major acquire career-specific technical knowledge/skills necessary to progress toward gainful employment, career advancement, and postsecondary success) and pass corresponding technical assessment. CDOS pathway does not require students to meet CDOS learning standard 3b.
11. COMMENT:
Concerned districts will certify afterschool jobs lacking adult support or relevant coursework as WBL. Backlash from unsupported/poorly supported experiences could be immense (e.g., students getting hurt/not performing adequately and alienating businesses willing to participate).
DEPARTMENT RESPONSE:
Independent employment outside of school cannot count toward WBL for credential. WBL must be consistent with SED guidelines, including safety instruction, and under district’s supervision.
12. COMMENT:
Proposal should be retroactive to class of 2015.
DEPARTMENT RESPONSE:
Law prohibits adoption of regulations that impose retroactive policy. Under Education Law, students continue to be eligible for a free public education until end of the school year in which they turn age 21 or until receipt of a diploma. Any age-eligible student who has not earned a diploma may re-enroll in school and utilize CDOS pathway to meet diploma requirements.
13. COMMENT:
Modify CDOS and other pathways using program of study to allow students to work towards CDOS credential within existing five pathways and build upon skill, knowledge and competence in career pathway framework (i.e., 15/7 proposal)). This model includes required and elective focused coursework, beginning in middle school, to pursue career interests, participate in WBL and achieve CDOS learning standards. CDOS pathway criteria, as incorporated into the five pathways, could be used as local diploma safety net for students not passing fifth exam.
Review impact of CDOS pathway after 2016-2017 school year and make necessary adjustments to ensure rigor and access.
DEPARTMENT RESPONSE:
SED will take consider these recommendations when considering future policy changes.
14. COMMENT:
Department provided no projected number of students using CDOS pathway.
DEPARTMENT RESPONSE:
Number of students who will use CDOS pathway cannot be projected as students may use any pathway option to meet diploma requirements.
15. COMMENT:
Pathway does not mandate prescribed coursework in career exploration; required coursework is purely academic.
DEPARTMENT RESPONSE:
To earn CDOS credential, district must document students have met commencement-level CDOS learning standard 1 (Career Development): Students will be knowledgeable about world of work, explore career options, and relate personal skills, aptitudes, and abilities to future career decisions. Although CDOS pathway does not require career exploration coursework, WBL experiences must relate to career awareness, exploration and/or preparation. Students may also complete CTE coursework, combined with WBL, to meet credential requirements.
16. COMMENT:
Clarify if evidence is required for each commencement-level CDOS indicator and how many sample tasks students must successfully complete to determine achievement of standards. Regents exams and SED approved assessments have specific scores. Award point value to sample tasks to determine achievement of CDOS learning standards.
DEPARTMENT RESPONSE:
Evidence is required for all performance indicators within a standard. It is not necessary for students to complete all sample tasks to demonstrate attainment of each commencement-level CDOS learning standard. Number of sample tasks students must successfully complete is a local decision.
17. COMMENT:
Inconsistent implementation of minimum 216 hours of CTE coursework and/or WBL experiences. Clarify if credential requires two credits of CTE and WBL or if 216 hours can be WBL only.
DEPARTMENT RESPONSE:
Students must successfully complete not less than equivalent of two units of study (216 hours) in either CTE courses and/or WBL(must include minimum of 54 hours of school supervised WBL). Students may complete all 216 hours through WBL. WBL experiences may, but are not required to, be completed in conjunction with CTE course(s).
18. COMMENT:
Concerned how credential will be awarded with fidelity and intended purpose of readiness for entry-level employment, and as comparably rigorous pathway, for students who successfully complete CDOS learning standards but receive mostly “unsatisfactory”/“needs improvement” on employability profile.
DEPARTMENT RESPONSE:
Schools must have evidence that students have satisfactorily completed credential requirements, including CTE and/or WBL hours as documented on employability profile. To award credential, principals must determine, based upon all requirements, whether students demonstrate entry-level work-readiness skills.
19. COMMENT:
Provides limited relief for students who struggle to demonstrate knowledge/skills on high-stakes standardized exams. Requirements still too challenging. Step away from one-size-fits-all graduation model by changing number of required exiting exams (i.e., one English, Math and Science Regents with other exams optional for honors or advanced Regents diploma) and developing performance-based assessments in lieu of Regents exams. Need sweeping changes so students unable to pass Regents exams may earn a diploma. Continue discussion to further extend diploma options. Bring back local diploma. Need more vocational credentials.
DEPARTMENT RESPONSE:
Regents continue to discuss multiple pathways to a diploma and alternative ways to assess students’ proficiency toward State’s learning standards for purposes of graduation with a regular diploma.
20. COMMENT:
Recommend SED publicize CDOS credential to employers.
DEPARTMENT RESPONSE:
SED met with many constituents in developing policy framework and documentation requirements for credential. Informational materials were widely disseminated to businesses statewide. SED will continue to provide further public awareness information.
21. COMMENT:
Clarify if General Educational Development (GED) and Test Assessing Secondary Completion (TASC) are equivalent to high school diploma and whether students under 21 earning these can return to school for a Regents or local diploma.
DEPARTMENT RESPONSE:
TASC, replaced GED in 2014 and is the test used in NYS for earning high school equivalency diploma (HSE), which is not a regular high school diploma. Students earning HSE diploma are entitled to remain in school until age 21 or receipt of Regents or local high school diploma.
22. COMMENT:
Content of proposal in NYS Register was confusing. Question how individuals are supposed to keep up with Regents decisions.
DEPARTMENT RESPONSE:
SED is required to post all proposed regulatory changes in NYS Register in prescribed format. Information on Regents’ decisions is available at http://www.regents.nysed.gov/.
