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All Students

1. Who is eligible to earn a Career Development and Occupational Studies (CDOS) Commencement Credential?

Any student who meets all of the credential requirements pursuant to section 100.6(b) of the Regulations of the Commissioner of Education, is eligible to earn a CDOS Commencement Credential, except for those students with disabilities deemed eligible for a Skills and Achievement Commencement Credential.

2. Can a student receive the CDOS Commencement Credential if they continue in high school beyond four years?

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3. Can a student be awarded the CDOS Commencement Credential if they have met all of the criteria for the CDOS Commencement Credential; attended school for at least 12 years, excluding kindergarten; have not yet earned a diploma; and are not planning to return to school the next year?

Yes. Students who are unable to earn a regular diploma may leave school with the NYS CDOS Commencement Credential as their only exiting credential.��

4. May a student who earns the CDOS Commencement Credential as their only exiting credential participate in the high school graduation ceremony and walk across the stage?�� �� �� �� ����

The board of education or the board of trustees of each school district must establish policy and adopt procedures to allow any student who has been awarded a Skills and Achievement Commencement Credential or the CDOS Commencement Credential, but has not otherwise qualified for a Regents or local high school diploma, to participate in the graduation ceremony of the student's high school graduating class (i.e., the twelfth-grade class with which such student entered into ninth grade) and all related activities.�� School districts must also provide annual written notice to all students and their parents or guardians about the graduation policy and procedures adopted by the school district.

5. May a student who earns the CDOS Commencement Credential as their only exiting credential return to school to pursue a high school diploma?

Yes. The CDOS Commencement Credential is not considered equivalent to receipt of a high school diploma and does not terminate a student's entitlement to a free public education.�� Such student continues to be eligible to attend the public school without payment of tuition until the student has earned a Regents or local high school diploma or until the end of the school year in which such student turns age 21, whichever shall occur first.

6. May a student who has graduated with a high school diploma return to school to work toward the CDOS Commencement Credential?

No. Receipt of a high school diploma ends a student’s entitlement to free public education.

7. How can a student use the CDOS Commencement Credential to meet graduation requirements for a high school diploma?

Beginning June 2016 and thereafter, under the “4+CDOS” pathway option, any student may graduate with a high school diploma if such student meets the graduation course and credit requirements; passes four required Regents Exams or Department-approved alternative assessments (one in each of the following subjects: English, mathematics, science, and social studies); and meets the requirements to earn the NYS CDOS Commencement Credential.

8. How can districts ensure that the CDOS Commencement Credential is awarded with fidelity, consistent with the requirements and intended purpose as a certificate of readiness for entry level employment?

Districts should be able to answer “yes” to each of the following questions to ensure that the student has met the requirements for award of the credential:

• Does the student have a career plan in which they participated in the development?�� Does the school have a copy of the career plan in effect during the student’s final year of school?
• Does the school have evidence that the student has demonstrated achievement of the CDOS Learning Standards (1, 2, and 3a) at the commencement level?
• Did the student successfully complete at least 216 hours of career and technical education (CTE) coursework and/or work-based learning? (Note: Students must complete a minimum of 54 hours of work-based learning; however, all 216 hours could be work-based learning.)
• Does the student have at least one employability profile completed within their last year of high school by an individual knowledgeable about their skills?�� Is the name and title of that person included and is it signed and dated?�� Does the employability profile document the student’s employability skills and experiences and, as appropriate, attainment of technical knowledge and work-related skills, work experiences, performance on industry-based assessments, and other work-related and academic achievements?
• Is the student graduating with a regular high school diploma or has the student attended school for at least 12 years, excluding kindergarten?

9. How are students that leave school with the New York State (NYS) CDOS Commencement Credential or the Skills and Achievement Commencement Credential as their only exiting credential counted in “high school completers” and “noncompleter” data?�� ��Do they affect a district’s graduation and drop-out rate?

Students leaving school with the CDOS Commencement Credential or the Skills and Achievement Commencement Credential are included in the “Non-Degree Completers” category. They are not counted as graduates or dropouts. For additional information or to submit questions about reporting data for school districts, public schools, charter schools, and nonpublic schools in New York State contact the .����

10. What notification is required if a student exits with the CDOS Commencement Credential in the absence of a high school diploma?

Pursuant to section 100.6(c) of the Regulations of the Commissioner of Education, ��when a student’s only exiting credential is the CDOS Commencement Credential (i.e., the student has not yet earned a diploma) and ��the student is less than 21 years of age, the credential must be accompanied by a written statement of assurance that the student named as its recipient shall continue to be eligible to attend the public schools of the school district in which the student resides without the payment of tuition until the student has earned a Regents or local high school diploma or until the end of the school year in which such student turns age 21, whichever occurs first.

Additionally, for a student with a disability, pursuant to section 200.5(a)(5)(iii) of the Regulations of the Commissioner of Education, prior to the student exiting with a CDOS Commencement Credential, the parent or guardian must be given prior written notice indicating that the student continues to be eligible for a free appropriate public education until the end of the school year in which the student turns age 21 or until the receipt of a Regents or local high school diploma.

Students with Disabilities

11. Can a student who takes the New York State Alternate Assessment (NYSAA) be eligible for the CDOS Commencement Credential?

Students that are eligible for NYSAA have severe cognitive disabilities and typically take the NYSAA in all content areas, making them eligible for the Skills and Commencement Credential. However, in rare instances, the committee on special education (CSE) may determine that a student receives grade-level instruction and participate in grade-level assessment in one or more content areas but receive instruction under alternate standards and take an alternate assessment in another content area.

According to federal regulations, local education agencies (i.e., school districts) must not preclude a student with the most significant cognitive disabilities who takes an alternate assessment aligned with alternate academic achievement standards from attempting to complete the requirements for a regular high school diploma. If a student eligible for NYSAA is able to complete the requirements for a regular high school diploma and/or the CDOS Commencement Credential, then the CSE should review the student’s eligibility for NYSAA to determine if they are truly a student with a severe cognitive disability.

All Students

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

No. A student must complete a minimum of 54 hours of work-based learning and cannot “opt out” of this requirement if they are earning the credential through Option 1.��

2. Does a student automatically earn the required 54 WBL hours when they are enrolled in a CTE course? What about a 51����-approved CTE program?

No. A CTE course or program of study in and of itself does not count as work-based learning. However, students participating in a CTE course or program of study should have work-based learning opportunities made available to them. Work-based learning can include an array of different activities along a continuum, from short-term, introductory types of experiences to longer-term, more intensive ones, including paid work experiences and formal training. Ultimately it is the responsibility of the school to provide the opportunities and verify, document, and maintain student hours for the CDOS credential work experience requirement.�� Information regarding work-based learning requirements is available on the CTE website.

Students in a 51����-Approved CTE program are required to have work-based learning opportunities available to them and for schools/BOCES receiving Perkins funding, student attainment of a minimum of 54 hours of work-based learning is a program quality indicator. Only the hours that the student independently demonstrates mastery of skills that meets industry standards and produces a product and/or provides a service, even when working with other students in a team project, can count toward the required WBL hours (e.g., a culinary student following a recipe and using proper measuring techniques and precise/consistent vegetable cuts to produce a soup for teacher luncheon or outside consumer).�� If working on a team project, the student must actively participate in the project by demonstrating various skills as mentioned above and not just bring the supplies, tools, and materials to the job site or assist other students to be credited with the work-based learning hours. Practice of skills, skills development activities, and modeling safety in the classroom cannot be counted as WBL hours.

3. Do students need to participate in registered work-based learning programs to complete the 54 minimum hours required for the CDOS Commencement Credential?

No. Students may participate in locally approved work-based learning experiences that do not require a certified work-based learning coordinator to meet the work-based learning requirement for the CDOS Commencement Credential such as:

• Job Shadowing
• Community Based Work Program
• School Based Enterprises
• Community Service/volunteering
• Industry-Based Projects (that produce a product or provide a service)

Schools must ensure that the students placed in local work-based learning experiences are provided with proper safety and health training.

The following work-based learning programs must be registered with 51���� and must be supervised by a certified work-based learning coordinator:

• Career Exploration Internship Program (CEIP)
• General Education Work Experience Program (GEWEP)
• Career and Technical Education Cooperative Work Experience Program (CO-OP)

Information regarding work-based learning requirements and the application for a 51����-registered program are available on the Work-Based Learning Programs webpage.

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

Teachers providing work-based learning experiences associated with 51����-registered programs must, depending upon the type of program, be certified as a work-based learning coordinator completing the extension of Coordinator of Work-Based Learning Programs.�� CO-OP experiences must be supervised in coordination with the CTE teacher from the content area from which the CO-OP experience is concentrated.

For teachers supervising locally approved work-based learning experiences, it is highly recommended but not required that they obtain the extension.��

5. Is safety training a required component for the CDOS Commencement Credential?

While not mandated, safety training is highly encouraged.�� Prior to arranging for a work-based learning activity for a student, the district must ensure that the site has been approved for safety and that it has arranged for appropriate supervision of the student. While there is no required number of hours or amount of safety instruction students should receive, health and safety instruction appropriate for the work-based learning experience should be provided by the school before a student’s participation in the experience with additional training provided as appropriate at the worksite. The NYS Work-based Learning Manual recommends that students receive, as appropriate, instruction in general health and safety topics including:

• Hazardous/prohibitive occupations for minors
• Identifying occupational hazards
• Child Labor Laws
• Common sense health and safety precautions
• Slips and falls – injury prevention
• Hazardous materials and chemicals
• Threats – terrorists, criminal acts
• Violence in the workplace
• Safety training specifically related to the occupation or work-based learning experience; and
• Sexual harassment and bullying.

The provides information about teaching young workers about job safety and health.����

While not specific to participation in work-based learning experiences, the curriculum for all students must include instruction in highway safety and traffic regulation as outlined in section 100.2(c)(5) of the Regulations of the Commissioner of Education ��and fire drills and fire and arson prevention, injury prevention and life safety education as outlined in section 100.2(c)(6) of the Regulations of the Commissioner of Education.

6. What components of a career-focused research project (senior project) can be used to meet the required work-based learning hours for the CDOS Commencement Credential?

Students may be granted work-based learning hours for participating in job shadowing, conducting interviews with professionals currently working in a career; and the student’s final presentation for his/her senior project. The number of hours associated with each of these activities must be outlined, monitored, supervised and documented at the district level. The career-focused (senior project) may be completed anytime in grades 9-12. The research project (senior project) should not be a student’s only means of obtaining work-based learning experiences necessary for award of the CDOS Commencement Credential. Additional information regarding the career-focused research project (senior project) can be found in the NYS Work-Based Learning Manual.

7. Can a student use part time employment outside of school to fulfill the work-based learning requirement for the CDOS Credential?

A student cannot use their independent employment outside of school to count toward the number of hours of work-based learning that is required for the credential unless the school district enters into an agreement with the business that ensures the employer is complying with the Laws Governing the Employment of Minors document from the NYS Department of Labor, defines the educational aspects of student’s work experience, and outlines the school, student, and employer’s responsibilities. ��This relationship would need to be part of a Registered GEWEP program that is overseen by an instructional staff member with the Coordinator of Work-Based Learning Programs extension.�� All work-based learning experiences must be provided consistent with 51���� 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 the Work-Based Learning Programs webpage.

8. Can experiences/hours that were completed prior to the start of grade 9 count towards the credential?����

Work-based learning completed in middle school cannot be counted towards the CDOS Commencement Credential unless these hours are associated with a credit bearing high school CTE course.

9. Can coursework taken in the summer prior to entering grade nine that provides work-based learning experiences count toward the 216 hours of required coursework and work-based learning?

A student may begin accumulating the 216 hours of coursework and/or work-based learning during the summer session between eighth and ninth grades only if they have completed the requirements for eighth grade by June and have been promoted to ninth grade.

10. What are the benefits or incentives for employers to host students for work- based learning opportunities?

Work-based learning programs benefit employers by:

• Providing a source of skilled and motivated future employees who understand workforce expectations
• Reducing their future recruitment and training costs
• Strengthening the labor supply
• Establishing connections between industry professionals and education providers
• Providing an opportunity to communicate job-specific proficiencies and general workforce expectations to educational personnel so students are better prepared for the workforce
• Developing and/or strengthening their relationship with the community through their connection to public education
• Promoting a positive public image of their business.

11. Can work-based learning experiences provided as part of a summer youth employment program (e.g., Summer Youth Employment programs (DOL)); or for students with disabilities, summer youth work experiences (ACCES-VR) or Pathways to Employment (OPWDD) count towards the work-based learning requirements for the CDOS Commencement Credential?

Yes. Paid or unpaid employment in a summer youth work program may be considered a community-based work program if such experiences are provided consistent with 51���� guidelines, under the supervision of the district, and documented in a student’s transcript.��

12. Where can I find answers to other questions that I have about work-based learning?

The Office of Career and Technical Education has developed a Frequently Asked Questions page for work-based learning. ��Additional information may also be found in the work-based learning manual.

Students with Disabilities

13. Are students with a disability required to have a job coach for work-based learning experiences?

Not necessarily.�� Whether a student requires supports or on the job training (e.g., a job coach) must be determined on an individual basis and documented in the student’s Individualized Education Program (IEP).�� A job coach is a person who provides on the job training and helps students that have more intense needs and require more direct supervision to work at a job site.��

In determining a student’s need for a job coach, the CSE should consider if the student needs:

• 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
• Help to acquire a sense of belonging at the work site and an understanding of participation in employee programs which involve socialization with coworkers.

Teaching assistants may accompany and/or monitor students during community-based work experiences under the supervision of a teacher who may or may not be present at the work site and often fulfills the role of job coach.�� It is recommended that an individual serving as a job coach complete a job coach training program.�� 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 have such individuals perform such duties.

14. Can a district arrange for students with disabilities to participate in transition services, specifically work-based learning experiences, during or outside of the school day that are provided by a community organization?�� If so, can that experience be counted toward the work-based learning requirement for the CDOS Commencement Credential?

Yes, provided the community organization has been approved by 51���� or another State agency to provide such services.�� authorizes school districts to enter into formalized agreements for the provision of transition services [as defined in ] with programs such as vocational training programs that are approved by 51���� 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 must be consistent with State requirements. If the community agency programs are not an approved program pursuant to Education Law section 4401(9), the district may not submit a STAC for tuition reimbursement of such programs and services.

15. Should school districts disclose information about a student’s disability when developing a Memorandum of Agreement (MOA) or Memorandum of Understanding (MOU) with an employer for a student’s participation in a work-based learning experience?

A “Memorandum of Agreement” or “Memorandum of Understanding” outlines the responsibilities of the student, employer, parent/guardian, and school/coordinator, all of whom should sign to confirm their support of the agreement.�� Information regarding the student’s disability should be disclosed only to the extent necessary to ensure the student receives the appropriate accommodations, supports, and services.��

16. Can the hours from a Pre-Employment Transition Services (Pre-ETS) work-based learning experience (WBLE) provided by an approved Adult Career and Continuing Education Services-Vocational Rehabilitation (ACCESS-VR) Pre-ETS vendor count toward the required 54 hours of WBL to earn the credential through Option 1?

Yes, hours earned from a Pre-ETS WBLE can count toward the required WBL hours if the following criteria have been met:

1. ACCES-VR has authorized a WBLE for a student with a disability who is eligible or potentially eligible for vocational rehabilitation services; and
2. WBLE are provided consistent with the guidance in the 51���� WBL manual specific to the WBLE type.

It is recommended that the designated school district staff, ACESS-VR staff and, as appropriate, the approved Pre-ETS vendor collaborate to ensure that all guidelines for their respective programs are met. For guidance on Pre-ETS, districts should contact the in their region of the state.

All Students

1. When should a student begin a Career Plan?

Students working toward this credential should begin commencement level career planning in grade nine.�� Districts are encouraged to engage all students in career planning early on in the student’s education as it is an important mechanism to add relevance and meaning to learning experiences across subject areas. Per , as part of a district’s comprehensive developmental school counseling/guidance program, for students in grades 6-12, school counselors must provide an annual individual progress review plan, which reflects each student's educational progress and career plans. For students with disabilities, the plan must be consistent with the student’s IEP. New York State provides model Career Plans beginning in kindergarten which districts may opt to use. Beginning in grade six, students may also create individual Career Plans with the "My Portfolio" tool found at the .

2. How often should the Career Plan be completed or reviewed during a student’s high school career?����

To ensure the student is actively engaged in career planning, the school district must have evidence that the student has developed, annually reviewed, and, as appropriate, revised their career plan.�� Additionally, a student’s preferences and interests as identified in their career plan should be reviewed annually to assist in planning courses of study, work-based learning experiences, and graduation pathways.�� For students with disabilities, the career plan must be considered in the annual review of their IEP.�� While the career plan is a student-developed document, some students may require assistance in completing their career plan, and districts must provide appropriate assistance to students.�� How frequently a student works on their career plan will depend upon the individual student and their unique needs.

3. How does the career plan encourage students to develop “realistic” career goals?

It is very important that educators and parents encourage students to develop and maintain high expectations related to career goals.�� As students move through the stages of career awareness, exploration, and career development, their goals are expected to change over time based upon their experiences and what they have learned about specific careers.�� District personnel, parents, guardians, and others working with students should assist them in shaping and refining their career decisions based upon their strengths, needs, preferences, and interests.�� Using tools such as , students will begin to identify their career interests, explore a variety of career options, learn about the educational and skill requirements for specific careers, identify what it is about a specific career that interests them, and learn about other career options.

Through the process of annually reviewing and revising the career plans, students will be better able to articulate their own strengths and begin to identify tentative career choices based upon the level of education they intend to pursue and their specific skills and interests.

4. Does 51���� provide a model career plan?

Yes. The 51���� Commencement Level Career Plan template may be used to document ����students’ academic coursework, career exploration activities, and personal experiences. It provides a structured format for the student to reflect upon their skill development and post-secondary readiness throughout high school. The Commencement Level Career Plan template can be used to show evidence of the attainment of CDOS Learning Standard 3a.

All Students

1. What documentation should be included in the transcript of the student earning the CDOS Commencement Credential?

The transcript must identify that the student earned the NYS CDOS Commencement Credential and document the CTE coursework and number of hours of work-based learning experiences the student completed.

2. Will the State issue a model certificate for the CDOS Commencement Credential?

Each school is responsible for developing a certificate at the local level that is similar in form to the district diploma.�� The certificate cannot use the term “diploma” and must indicate that the NYS CDOS Commencement Credential is endorsed by the NYS Board of Regents as a certificate of readiness for entry-level employment. 51���� has developed a “Model Certificate for CDOS Commencement Credential” for award of the NYS CDOS Commencement Credential that districts may opt to use.

3. If a student does not meet the requirements to earn a NYS CDOS Commencement Credential and does not receive a diploma, does the student receive any other type of document upon exiting school (i.e., certificate of attendance or other recognition)? ��

Nothing in State law, regulation, or guidance prevents a school from issuing certificates of attendance or recognition.�� This is a local decision that must be made by the school district.

4. Does the 51���� model form “Evidence of Attainment of the Commencement Level Career Development and Occupational Studies (CDOS) Learning Standards” or similar document need to be completed and placed in the student's record to document their attainment of the CDOS Learning Standards?

The school district must have evidence that the student has attained the commencement level knowledge and skills related to the CDOS learning standards.�� It is up to local discretion how this evidence is documented. 51����’s model form “Evidence of Attainment of the Commencement Level Career Development and Occupational Studies (CDOS) Learning Standards” is provided as a tool to assist districts in tracking student attainment of the commencement-level CDOS learning standards as demonstrated in coursework and work-based learning experiences in which the student participated over the course of high school.

5. How long does documentation need to be kept showing the student has met the requirements for the CDOS Commencement Credential?

Pursuant to section 100.6(b) of the Regulations of the Commissioner of Education, a copy of the career plan in effect during the school year in which the student exits high school and at least one employability profile completed within one year prior to high school exit must be maintained in the student’s permanent file. ����Award of the CDOS Commencement Credential must be documented in the student’s transcript which also must be maintained in the student’s permanent file. Additional information regarding student records retention can be found in the .

Consistent with the Records Retention and Disposition Schedule: documents related to participation in work-based learning experiences should be retained as follows:

• Memorandums of agreement, training plans, parent/guardian permission forms, student’s time sheets and work summaries, and similar work-based learning records: six (6) years from when the student graduates or would have normally graduated from school
• Student journals: one (1) year after the end of the school year
• Copy of Employment Certificates (working papers): zero (0) years after student attains age 21.�� Additional information specific to retention of records related to work-based learning experiences is in the New York State Work-Based Learning Manual

Students with Disabilities

6. Where in the IEP should it indicate that a student is working towards the CDOS Commencement credential?

Documentation that the student is working toward the CDOS Commencement Credential should not be documented in the student’s IEP.�� School districts should provide all students with appropriate career planning, coursework instruction, and work-based learning activities that would provide all students with disabilities the opportunity to exit with the credential.�� Indicating in the IEP that a particular student is working toward the credential may have the unintended consequence of ‘tracking’ the student to exit with the credential in lieu of a regular high school diploma.

7. For a student with a disability exiting high school with the CDOS Commencement Credential in the absence of a regular high school diploma, is there an official NYS letter of written notice that states that the student remains eligible for a free appropriate public education (FAPE) until he/she earns a Regents or local high school diploma or until the end of the school year in which the student turns age 21?

Yes. Prior to a student’s exit with a CDOS Commencement Credential, parents the student’s parents must be given prior written notice indicating that the student continues to be eligible for FAPE until the end of the school year in which the student turns age 21 or until the receipt of a Regents or local diploma as outlined in section 200.5(b)(5)(iii) of Commissioner’s Regulations.

All Students

1. How does a principal determine whether a student who transfers from another school district meets the requirements of the CDOS Commencement Credential?

For students who transfer from another school district within the State or another state, the principal must, after consultation with relevant faculty, evaluate the work-based learning experiences and coursework on the student’s transcript or other records to determine if the student meets the requirements of the CDOS Commencement Credential. When making the determination as to whether the student meets the requirements of the CDOS Commencement Credential in these situations, the principal, in consultation with relevant faculty should consider the following:

• Documentation that the student has engaged in career planning and exploration.�� Minimally, all students should have a career plan
• Evidence that the student has attained each of the commencement level CDOS learning standards
• The extent to which the student has successfully completed instruction, courses of study and transition activities at the secondary level related to the student’s post-secondary employment goals
• An evaluation of the student’s employability skills as documented in the employability profile of the student.

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