September 2015 Dear Board of Regents, The current New York State Education Department graduation requirements for Special Education students are unrealistic and have created a cycle of test and punish for those children who require the most support. Despite the objections of parents and educators across NYS, the Board of Regents and NYSED discontinued the RCT option for students with learning disabilities as of the 9 th grade cohort of 2011. SPED students have been put into the position of retaking Regents exams over and over again in an attempt to earn a local diploma. Students have had to give up study in areas that may be a strength, such as art, music, practical mechanics, to spend hours in review sessions to get through five Regents exams. The Board of Regents and NYSED have further compounded the problem with the Common Core Algebra and ELA exams. The language on the Algebra 1 exam is overly confusing with “gotcha” questions, and is a vocabulary test on top of a math test. The ELA regents now include passages with very complex language, for example, Chekov, or excerpts from Stephen Hawking on physics and string theory. It is certainly fair to teach students with these types of passages, but it is unrealistic to expect a child with a reading disability to process such complex information on an exam where their entire future rests. According to NYSED’s own report on graduation statistics through 2014, 3% to 5% of all demographics graduated with a local diploma. These students would have had access to the RCTs as a backup strategy. Now, this same group is on a test and be punished cycle beginning in June of their 9 th grade year. Students who may excel in mechanics but who are not good test takers cannot graduate. Students with dyslexia who may be very strong in math have no further options. The response that these students should “try harder” is unacceptable. We ask that the Board of Regents and NYSED implement the following changes to the pathway to a local diploma as a short term solution to the special education student cycle of test and punish: •
Allow all SPED students the option to take the RCTs though 2017, while they are still available to the 2010 cohort.
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SPED students should have access to a waiver process that is similar to the process that currently exists for General Education students. SPED students who earn a 50 to 54 on two Regents exams in one subject may apply for a waiver provided that they have good attendance and have successfully completed their coursework.
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Schedule Regents exams in each category on separate days so that SPED students do not end up taking exams for up to 12 hours in one day. (All Math Regents to be scheduled on the same day, All Science Regents to be scheduled on the same day, and ELA, USH and GHG each schedule on a day that does not conflict with other required Regents exams)
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Approve the CDOS as a valid diploma option and open it up to all students. A credential that demands rigorous work and is only available to SPED students is a violation of FERPA. Students on the CDOS track are still required to take Regents level courses (but have a waiver for passing Regent exams) in addition to the 216 hours required to complete the CDOS qualification, and it should be treated as a meaningful path to graduation.
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Make these changes retroactive for the students in the 2011 9 th grade cohort.
As a longer term solution, we ask that the Board of Regents and the NYSED form a working committee to define multiple measures to meaningful assessments of skills so that students truly graduate with the skills they will need in the future. This working committee should consist of representatives of the Coalition for Multiple Pathways for a Diploma, special education and ELL specialists and true career educators. The Regents exams, in their current form, do not objectively meet the goal of college and career readiness. Thank you.