2Nd Round Written and Oral Public Comment in Response To

2nd Round--Written and Oral Public Comment in Response to

OAR 581-022-1134 and OAR 581-022-1135

Compiled by OSLP

Date / Name / Repre-senting / Role / Comment / Section / Pos-itive / Neg-ative / Neutral / Requires Action
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / There will be a huge gap in services for students who supplement core class credits through modified credit curriculum related to vocational placements, internships and on the job training experiences.
5/1/08 / KC Clark / Ed Support Svc., Eugene / Administrator / I am writing this letter on behalf of the EugeneSchool District 4J Education Support Services Team. As the Modified Diploma public comment window has reopened, we would like to take this opportunity to express our concerns regarding portions of the proposed OARs for the modified diploma and changes suggested in public comment to the Oregon State Board of Education on April 16 and 17, 2008. / 0 / X / Action: No action required
5/1/08 / KC Clark / Ed Support Svc., Eugene / Administrator / The 2007 modified Diploma legislation is a great accomplishment and we would like to extend our appreciation and support to the Oregon Advocacy Council, Oregon Parent Training Institute, Council on Developmental Disabilities and Representative Sara Gesler for championing this bill.
However, we would like to encourage the State Board of Education and Oregon Department of Education to take steps to ensure that the new legislation does not have a negative impact on students who are currently eligible to earn a modified diploma and does not compromise the integrity of the modified diploma or create a ‘special education’ diploma. / 0 / X / X / Action: No action required
5/1/08 / Kathie Oatman / Harney ESD / I would like to express my concern over the recent suggestions in changes in the High School diploma.
Students who have learning disabilities need to be provided equal access to the curriculum, thereby earning a High School Diploma, not a modified diploma or a certificate.
I would think that it would be a Federal concern, if students were not provided the diploma they have earned. / 0 / X / Action: All students who complete the requirements will receive a regular high school Oregon Diploma
4/30/08 / Brian Hilsabeck / Willamette ESD / Asst. Dr.
Special Programs / I want to make a couple of points:
I am currently in favor of the Modified Diploma as it currently stands. It allows enough flexibility and at the same times provides enough structure for school teams in cooperation with parents and students to make decisions as to whether a Modified Diploma will work for a student.
I believe it provides the a balance of academic rigor, but is truthful in that it is a Modified Diploma and some of the credits established for the modified diploma are based on the specific needs of the student. / 0 / X / Action: No action needed
4/24/08 / Kevin Hertel / SouthMedfordHigh School / Resource Teacher / My review of the modified diploma framework ended with positive results. I feel that the proposed framework extensively addresses the current needs of students in the state of Oregon. The criteria and the timeline that are proposed create a situation in which only the students who would benefit from a modified diploma will be allowed to pursue one. The flexibility to move between a typical diploma and a modified diploma allows for districts to adapt to changing needs of individual students. The proposed requirements still hold higher standards for students to meet in the core academic courses, but they also allow flexibility for students to receive an abundance of courses that will better prepare students for a post-secondary education environment that does not involve a 4-year college degree. / 0 / X / Action: No action needed
4/24/08 / Colleen Stover / Sisters SD / Special Education Administrator / I have read the proposal for the State Modified Diploma and believe that this diploma will meet the long-overdue needs of our Learning Disabled, ED and OHI students who are unable to pass the rigorousstate graduation diploma standards. The very nature and definition of their disabilities necessitates a diploma that acknowledges their efforts and their differentiated successes and allows them to move into society as high school graduates. This special population makes up approximately 30% to 40% of our Special Education students. / 0 / X / Action: No action needed
5/1/08 / KC Clark / Ed Support Svc., Eugene / Administrator / The OARs should clearly state that students working to earn a modified diploma are required to complete career related learning standards (CRLS) and the extended application. We believe the CRLS and the extended application are important tools for students in their preparation for post-secondary pursuits. / 12 / X / Action: Section 12 addresses extended application
4/22/08 / Robin Wortman / ORPTI / Parent / There may also need to be a phase in period, so that school districts
can prepare and create policies for implementation. / 14 / X / Action: Section 14 addresses this concern
5/1/08 / KC Clark / Ed Support Svc., Eugene / Administrator / It has been hard work to educate employers, educational institutions and the military about the modified diploma and to get them to acknowledge that the modified diploma is not based only on seat time, but actually requires a student to demonstrate a level of academic achievement. It is important to maintain the integrity of the modified diploma. / 6 / X / Action: Section 6 adequately addresses substantial academic content.
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / The mandate from IDEIA 2004 to address functional performance suggests that students need more time in school sponsored academic and community based experiences.
Students could conceivably be finished with high school by the middle of their second year with a 12 credit diploma.
How, where, and what services should be offered to 15 year old high school graduates? / Credits / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / We want to challenge every student by setting the bar as high as possible.A 24 credit modified diploma allows each student to have an individually crafted education plan to help students reach their potential / Credits / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / Despite the intent of the 12 credit modified diploma to provide the most severely impaired students with academic offerings, all students should take as many enrichment electives and academic courses as possible in high school.
Instead of trying to be inclusive of the most severely disabled, the standards might create a culture that excludes those students from experiences because they are “done” with their credits.
If students are allowed or expected to stay in high school after completing of the 12 credits, then we should certainly increase the minimum number of units. / Credits / X / Action: Maintain the language of draft dated 4/7/08
4/18/08 / Clayton Rees / Department of Human Services / Vocational Rehabilitation Admin. / As to reducing the credits to 12, why not six? Why have credits at all? Confirm the student attended class, listened to the teacher, and 12 years, or more, later, give them a modified diploma and call it good. / Credits / X / Action: Maintain the language of draft dated 4/7/08
4/23/08 / Zachary S. Ross / CenturyHigh School
Hillsboro / Special Education Teacher / My name is Zachary S. Ross, and I am a Resource Teacher at CenturyHigh School in Hillsboro, Oregon. We had a colleague report to us at a department meeting today that there is a proposal to make the modified diploma a 12 credit diploma instead of the 24 credit plan it is now. While the current modified diploma needs clarification and refinement, it is still a viable and vital option for many students. The ramifications for pushing this plan through would be severe. I would personally advise all of the parents that have students on my caseload to write their State Representatives and District Administrators to express their concerns over the proposal. Taking away opportunities and options from kids is criminal. This proposal aims to do just that. Leaving high school with a certificate of completion is not only irresponsible, but short – sighted. We should not expect less so students can get less.
The current plan calls for the same number of credits, but builds in the flexibility for students to get the Transition course work that will be so important for them in their lives. Core classes are just that, a foundation upon which all other life lessons and life skills are built. Also, not grandfathering in current modified diploma kids would leave them in the lurch, and unable to finish what they had planned to start. Another issue with this proposal would be that current modified diploma students would lose a great deal of motivation to stay in school if they know that they are working towards a certificate instead of a diploma. I strongly urge the State Legislature to dismiss this ridiculous proposal. / Credits / X / Action: Maintain the language of draft dated 4/7/08
4/24/08 / Vikki Mahaffy / DaytonSD / Learning Specialist - DaytonHigh School / These changes reduce the number of credits required by a modified diploma (significantly reducing the level of competence a student must demonstrate) and eliminate it’s availability to those students it was intended for by limiting it’s use to only those students who took the Extended Assessment in junior high. / Credits / X / Action: Maintain the language of draft dated 4/7/08
4/30/08 / Lu Ann Anderson / Special Education Administrator / Reducing the number of credits does nothing to address the criteria and content intended to be learned and demonstrated by the student to earn a "modified credit" regardless of the total number of credits to be earned. I think districts will develop criteria for earning credit that will be as different from district to district as the current system where, until recently, a district couldchoose to offer a modified diploma. This is likely to causefrustration to students and parents who move during the high school years as they will need to learn different criteria for earningmodified credit to earn a modified diploma that is based on the local school districts criteria. / Credits / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / KC Clark / Ed Support Svc., Eugene / Administrator / Limiting access to modified diplomas to those students who qualify for extended assessment is the same as saying that the modified diploma is only available to students with significant cognitive delays. This limitation would establish the modified diploma as a ‘special education’ diploma as only students with disabilities would be eligible. Creating a diploma perceived as a ‘special education’ diploma would be illegal because it violates student rights as they would clearly be identified as being disabled. / Extended Assessment / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / I’ve taken point on responding to the Representative Gelser’s bill for a 12 credit modified diploma with the following arguments:
12 credits is too few and identifying modified candidates by extended assessments in middle school is too narrow a tracking tool for granting modified diplomas. / Extended Assessment / X / Action: Maintain the language of draft dated 4/7/08
4/30/08 / Lu Ann Anderson / Special Education Administrator / I have strong concerns about the intent to award a modified diploma to students who are taking the extended assessment. It implies that the student is only capable of achieving that exit document when in reality; the student may only take the extended assessment in one content area. I think that by equating the achievement of the modified diploma with passing the extended assessment it discredits the student taking the assessment. The extendedassessment is based on grade level standards. I realize that the student is not performing at grade level and not demonstrating proficiency of content and skills at grade level but they are taking assessments based on grade level standards. / Extended Assessment / X / Action: Maintain the language of draft dated 4/7/08
4/30/08 / Charlene Baker / Morrow SD / Irrigon Junior/Senior High School Special Education Teacher / From the way this proposal reads it seems to leave a large portion of the special education population out. Many of the students that are in special education are able to take the regular assessment, but cannot do well in the grade level classes because they need to move at a slower pace or need additional help. The way I understand this diploma to read is that they only receive the modified diploma if they take the extended assessment. I feel there needs to be an additional diploma or middle ground for the learning disabled students.
Also when students are asked for a copy of their diploma from employers the employer automatically assumes they are MR even if they are only learning disabled and it makes it very hard for them to get a job. / Extended Assessment / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / Lisa Eisiminger / Parent / I think the proposed changes concerning the modified diploma would promote discouragement among our student population that struggles with learning. Many of these students are going to be productive, tax paying citizens of this state. If many of them don't qualify for a regular diploma, and they don't fall into the category of a modified then what will they really earn? I think this legislation sounds exclusive and may very well increase the drop out rate. Is that really the goal of our education system? / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / How do we honor the efforts of our learning disabled students who have a documented history failing to measure up to academic standards? / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / Dropout rates will increase.Graduation rates will decrease. / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
5/1/08 / David Shapiro / Bend-La Pine Schools / Transition Coord. / Psycho-social ramifications will be devastating for many of our students if they are not granted a modified diploma because they don’t meet the disability criteria. / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
4/30/08 / Brian Hilsabeck / Willamette ESD / Asst. Dr.
Special Programs / My understanding is that a certain legislator would like the Modified Diploma to be relevant to a small group of students who have limited cognitive abilities and in turn also would like to also limit the number of credits to obtain a Modified Diploma to 12 credits. If this is indeed the case, I am not in favor of the Legislator’s proposal. It would not stand up to the rigor and basically would be a certificate of attainment or attendance which is already available in most Oregon Public School Districts. This proposal would impact such a small population.
The Modified Diploma OAR, as is stands will be a viable option for a large population of students who have no other options right now. / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
4/18/08 / Clayton Rees / Department of Human Services / Vocational Rehabilitation administrator / Youth who are developmentally delayed, or have a history of such condition, certainly need some document to confirm their academic performance and a document that would help them in their transition to post secondary activities. However, in my opinion, to restrict the "modified diploma" to just one group would be tantamount to saying ADA is just for people in wheel chairs. I cannot imagine the political fall out from parents and school staff around the state if they are told that their child, who has struggled through high school with autism or SLD, will not be getting a standard or modified diploma - just "something else". / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
4/22/08 / Robin Wortman / ORPTI / Parent / Input from Representative Gelser regarding having the modified diploma only available for students on IEP's who take the extended assessment in
middle school is not only discriminatory against students who do not take extended assessments, it could be a violation of FERPA. The modified diploma would, in effect become a special education diploma for students with mental retardation. Please do not put this limitation on modified diploma.
Taking the option of a modified diploma away from students who are not able to earn a "regular diploma" will limit the opportunity for attendance at community college and enlistment into the military from those students as well. / Intended Population / X / Action: Maintain the language of draft dated 4/7/08
4/23/08 / Martha Ahern / MadrasSD / Special Education Teacher / I have been teaching special needs students since the 70s and this proposal is not reasonable. This senator it seemsis not familiar with the variety of students that we serve and the IEP team process that is necessary for determining the need for a student to go for the 'modified diploma'. To put restrictions on this is restricting our students’ possibilities. I have taught severe and moderately disabled students at the high school level for 13 years. It has been important for many students to begin the high school years with the possibility of a regular diploma. It would be very demoralizing for them not to be given the chance at a regular diploma. But at the same time it would be unconscionable to lock them into a regular diploma track and force failure when they cannot make the grade. Students are still developing mentally, emotionally and cognitively at the junior and high school levels it would not serve our students to pigeon hole them at such an early stage. We have the IEP process to insure that each student is considered personallywith their strengths and weaknesses explored by a team of people, it should be this team who decides when the modified or regular track should be followed not a state law that doesn't know the particular student. / Intended Population / X / Action: Maintain the language of draft dated 4/7/08