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Standards/Content Areas

COVID-19 Resources for Minimum High School Graduation Requirements

Published: 5/11/2020 9:02 AM

NTI Program Guidance Documents

The following non-traditional instruction (NTI) program guidance includes information and essential questions concerning the senior class of 2020 and the assigning and reporting of grades that can guide thinking as districts leaders, administrators and teachers address the needs of students.

Considerations for Senior Class of 2020

Considerations for Assigning and Reporting of Grades

Prom and Graduation Ceremonies

Due to the COVID-19 emergency, holding events such as proms and graduations in their traditional formats will not be possible during the 2019-2020 academic year even if Kentucky reaches the seven benchmarks discussed April 17 for reaching the first phase of reopening the state spelled out in federal guidelines, because gatherings would be restricted to groups of no more than 10 people during phase one.

“When we look at our benchmarks … we’re not going to be able to have an in-person prom or graduation in a building, or even an outdoor graduation,” Governor Andy Beshear said in an April 20 teleconference call with superintendents .

Instead, he recommended two options for graduation ceremonies: a virtual ceremony, which he said is the safest option, and a drive-in ceremony similar to the services being held by many churches.

“If we got people together outside of that for a graduation right now, this virus would spread,” Beshear said. “While it’s a special moment, we want to make sure it’s done in a way that is truly safe and doesn’t put people in harm’s way.”

Many schools have expressed a desire to have an in-person graduation at a later date, but the governor said there is no way to know when that might be possible.

The Kentucky Department of Education (KDE) released two new guidance documents on April 30 to help districts work through how to safely handle graduation alternatives and other end-of- school procedures during the novel coronavirus (COVID-19) outbreak.

The documents – COVID-19 Emergency Guidelines for End-of-School Procedures and COVID-19 Emergency Guidelines for Graduation Ceremonies and Related Year-End Activities – provide guidance and options and offer questions districts should consider when making decisions about what kind of alternative graduation ceremony to have and letting students back into buildings to retrieve belongings and return school property.

Since Kentucky is a local-control state, many of the decisions on how to move forward in this challenging time will be decided by local boards of education and school-based decision-making councils, in consultation with local health departments.

Promotion and Retention

Promotion and retention is a matter of local school district and school-based decision making (SBDM) policy. 

The following Kentucky Revised Statutes (KRSs) and Kentucky Administrative Regulation (KAR) establish that the local school or district is responsible for proper placement and awarding of credits to students.

  • KRS 158.140 establishes that any promotions or credits earned in attendance in any approved public school are valid in any other public school to which a pupil may go, but the superintendent or principal of a school, as the case may be, may assign the pupil to the class or grade to which the pupil is best suited. This statute also ensures that upon successful completion of all state and local board requirements students shall receive a diploma indicating graduation from high school.
  • 704 KAR 3:305 places the responsibility on the school district to determine the standards for awarding credit toward a high school diploma from that district/board of education.

    • Section 3. (1) For students entering grade nine (9) on or before the first day of the 20182019 academic year, each student in a public school shall have a total of at least twenty-two (22) credits for high school graduation.  (2) Those credits shall include the content standards as provided in the Kentucky academic standards, established in 704 KAR 3:303 and KAR Chapter 8.

    • Section 7. (1) A local board of education may award credit toward high school graduation for satisfactory demonstration of learning based on content standards described in the Kentucky academic standards, established in 704 KAR 3:303 and 704 KAR Chapter 8, and a rigorous performance standards policy established by the local board of education.

    • Section 7. (2) A local board of education shall award credit toward high school graduation based on:  (a) A standards-based Carnegie unit credit that shall consist of at least 120 hours of instructional time in one (1) subject; or  (b) A performance-based credit based on standards, regardless of the number of instructional hours in one (1) subject.

  • KRS 160.345(3)(b) indicates local school boards shall adopt policies related to school-based decision making, including “assessment of individual student progress, including testing and reporting of student progress to students, parents, the school district, the community, and the state.” 

Therefore, the number of awarded credits, based on the local assessment of student progress as seen in the assignment and reporting of grades, determines proper student placement. Final decisions as to promotion or retention rests with school authorities as set forth in KRS 158.140; however, no student may be retained without prior consultation with the parents. Individual placement decisions for children who are eligible for special education and related services shall be determined by the appropriate admissions and release committee, pursuant to 707 KAR 1:051.

The Council on Postsecondary Education (CPE) shared a transition support resource with the KDE Education Continuation Task Force on April 21 to detail what some higher education institutions are doing to prepare for this cohort of seniors who may need remediation or who are now anxious about going to college in the fall and feeling unprepared.


Q: Are students still required to complete the Individual Learning Plan during the 2019-2020 school year?

A: Below is a general statement about the expectations for the Individual Learning Plan during Covid-19:

Remember that districts have the autonomy to create/implement their own Individual Learning Plans. As such, the KDE does not deem an ILP complete or incomplete as long as the district is following their plan and adhering to the ILP Self-Implementation Rubric. Districts should see how much of the ILP process has been implemented thus far, continue having students working on the ILP as necessary/productive/possible and adjust accordingly for next year. This is an ideal time to have students take a deeper dive with the ILP and lean into its possibilities for their own personal development and career exploration if obstacles like a lack of technology and/or connectivity do not exist.  Seniors who have not completed the ILP according to district implementation policies should not be prohibited from graduating. For general information on the ILP process, check out this video from Dr. Sweeney.

Civics Test

Q: Do seniors need to pass the civics test in order to graduate?

A: No. Interim Commissioner of Education, Kevin C. Brown, issued a waiver on April 3, 2020, in response to the COVID-19 emergency. Pursuant to the authority granted in EO 2020-243 and with the approval of Lt. Gov. Jacqueline Coleman, Secretary of the Education and Workforce Development Cabinet, the waiver suspends KRS 158.141, which requires students to pass a 100-question civics test to graduate from a Kentucky public high school, for the 2019-2020 school year.

While most students scheduled to graduate at the end of the current school year have already completed this requirement, a small number of students had not done so prior to Gov. Beshear's recommendation to suspend in-person classes beginning March 16. There is an online option that will satisfy the requirement, but the KDE recognizes that not all students have a computer and internet access. The suspension of this statute removes a barrier to graduation for students who would otherwise graduate this spring.

Performance-based Competency in Technology

Q: Are students required to demonstrate performance-based competency in technology as part of the state minimum required 22 credits for graduation in the 2019-2020 academic year? 

A: Yes. 704 KAR 3:305(3) establishes that for students entering grade 9 on or before the first day of the 2018-2019 academic year, the minimum required credits and demonstrated competencies include “demonstrated performance-based competency in technology” (i).  

Section 7 of KAR 3:305 also establishes that “the local board of education may award credit toward high school graduation based on a rigorous performance standards policy established by the local board of education. A school shall establish performance descriptors and evaluation procedures to determine if the content and performance standards have been met.”

Therefore, student demonstration of  performance-based competency in technology is determined and evaluated at the local level. 

Early Graduation

Waiver Suspends Requirement for Early Graduation End-of-Course (EOC) Examinations

Interim Commissioner of Education, Kevin C. Brown, issued a waiver on Friday, April 3, 2020, in response to the COVID-19 emergency. Pursuant to the authority granted in EO 2020-243 and with the approval of Lt. Gov. Jacqueline Coleman, Secretary of the Education and Workforce Development Cabinet, the waiver suspends the requirement that current high school juniors participating in the KRS 158.142 Early High School Graduation Program take and pass end-of-course (EOC) examinations in order to complete the early high school graduation program and graduate at the conclusion of the 2019-20 school year.

The waiver suspends KRS 158.142 (3)(a), which dictates the requirements for completing an early high school graduation program and receiving an Early Graduation Scholarship Certificate. The suspension excludes current high school juniors who declared their intent to participate in the early high school graduation program prior to Jan. 1 from end-of-course (EOC) examinations. Therefore, juniors who obtain a qualifying benchmark score on the ACT and who meet all other requirements set forth in KRS 158.142 will remain eligible for early graduation.

The EOC exams are provided to school districts by KDE and are paper-based tests administered in schools. During the suspension of in-person classes due to the need for social distancing, it is not practical to require early high school graduation program students to report to school for these exams.

The emergency school closures should not prevent juniors participating in the early high school graduation program from completing the program and qualifying for an Early Graduation Scholarship Certificate.

The EOC requirement remains in effect for high school freshmen and sophomores, who will have the opportunity to take EOC exams in future school years.

Dr. ​Damien Sweeney
Office of Career and Technical Education and Student Transition
300 Sower Blvd., 5th Floor
Frankfort, KY 40601
(502) 892-6639 Ext.4545 
Fax (502) 564-6470
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