FAQ August 2023

How do we work with students who have not met their academic requirements by the graduation ceremony?

LEAs may choose to permit students to participate in graduation ceremonies and later, after all local and state high school graduation requirements have been met, receive their diplomas; however, students should be encouraged to pursue multiple pathways and/or types of evidence simultaneously in order to avoid these delays or uncertainties. NOTE: Students meeting graduation requirements no later than September 30 are to be considered part of the graduating class of the prior school year.

What options exist for students who cannot meet both local and statewide graduation requirements?

Students with disabilities may graduate if they satisfactorily complete a special education program that does not otherwise meet graduation requirements, per 22 Pa. Code § 4.24(d).

Students who meet local graduation requirements but who are unable to fulfill one of the five pathways to graduation may have the pathway-specific requirements waived and be granted a diploma by the chief school administrator, provided the student meets locally established, grade-based requirements for each Keystone content area in which they do not have a Keystone Exam score ≥1500 or a Non-Numeric Proficient.

Students who meet statewide requirements but who, having experienced education instability, cannot meet local graduation requirements at either the current or prior LEA may seek a Keystone Diploma, per 24 P.S. § 13-1331.1. Education instability is defined in statute as one or more changes in LEA enrollment due to homelessness, foster care, adjudication, or involvement with the juvenile justice system.

Students who do not fall into one of the above categories and who do not satisfy local and statewide graduation requirements are not eligible to graduate.

May students fulmay students fulfill graduation requirements remotely (e.g., online coursework or internship)?

Yes. LEAs may work with outside agencies to offer students the flexibility to participate in a program or learning experience remotely, where appropriate.

What funding sources are available to assist students with associated costs?

Any funding source may be used if the expenditures qualify as allowable under the specific program, including Title I funds for those students receiving Title I services. If a Title I designation is schoolwide, all students qualify for funding.
College Board has a fee waiver program for both the SAT and SAT Subject Tests, as well as the PSAT/NMSQT. ACT also has a fee waiver program for eligible students, and AP Exam offers a fee reduction.

What information needs to be included on student transcripts or diplomas?

There is no requirement to include a student’s performance levels on the Keystone Exams or to delineate the pathway by which a student graduated; however, an LEA may elect to include this information on the transcript or diploma. NOTE: Per Act 55 of 2022, the student transcript must list industry-recognized credentials attained by the student.

Must a student participate in all three keystone exams in order to meet statewide high school graduation requirements?

No. A student meets the Keystone Proficiency Pathway if the student qualifies for a non-numeric score of Proficient or better for each Keystone Exam in which the student does not have a numeric score.

A student who opts out of or otherwise does not participate in one or more Keystone Exams may also meet the statewide graduation requirements under Section 121 of the Pennsylvania Public School Code via the CTE Concentrator, Alternative Assessment, or Evidence-Based Pathway or via a waiver or special education program.

A student who graduates via the CTE Concentrator, Alternative Assessment, or Evidence-Based Pathway or by waiver must meet locally established grade-based requirements for each Keystone content area in which the student did not attain a numeric score of Proficient/Advanced on the related Keystone Exam or qualify for a non-numeric score of Proficient.

Note: Student non-participation in statewide assessments affects the LEA’s participation rate and may affect the LEA’s federal accountability designation.

What is the difference between a “Numeric” and a “Non-numeric” score?

A student who participates in a Keystone Exam receives both a numeric score (e.g., 1500) and a corresponding performance level, the non-numeric score (e.g., Proficient).

Where a student performance level on Keystone academic content is determined without the associated Keystone Exam result (see How May a Student Qualify for a Non-Numeric Score of Proficient without Participation in a Keystone Exam?), only a non-numeric score may be assigned as the determination is without a standardized measure and at the LEA’s discretion.

Note: A student demonstrating proficiency in Keystone academic content for the purposes of meeting locally established, grade-based requirements is not considered to have a non-numeric score of Proficient.

How may a student qualify for a non-numeric score of proficient without participation in a keystone exam?

There are two circumstances under which a student may qualify for a non-numeric score of Proficient without participation in a Keystone Exam:

–The student has demonstrated proficiency through comparable coursework and an equivalent assessment in a prior educational setting, or
–During the 2019-20 school year only, the student* successfully completed a course that was 1) in an academic content area associated with the Keystone Exam and 2) locally established as a grade-based requirement for demonstrating mastery of the Keystone content per Act 136 of 2020.

*Including a student who may have been unsuccessful in demonstrating Proficiency in the associated Keystone Exam prior to the 2019-20 school year. By way of example, a student who attained a numeric score of 1460 (Basic) in the Biology Keystone Exam during the 2018-19 school year would have received a non-numeric Proficient for repeating and successfully completing the trigger course (or an eligible credit recovery course) during the 2019-20 school year. The student may utilize either the numeric score of 1460 or the non-numeric Proficient in order to satisfy statewide graduation requirements.

Note: For the purposes of federal accountability, only a “first-time test-taker” who successfully completed a Keystone content-associated course during the 2019-20 school year is included in required reporting to the United States Department of Education.

How does an lea determine a student has demonstrated keystone proficiency in a prior educational setting for the purpose of awarding a non-numeric proficient?

Students transferring into a Pennsylvania high school from a private school, a home school environment, out-ofstate, or out-of-country may qualify for a non-numeric Keystone Exam score of Proficient if the LEA:

–Determines that the standardized assessment the student has completed aligns with the state academic standards assessed by the Keystone Exam, and
–Evaluates the student’s performance to be commensurate with a Keystone Exam score of Proficient or better, and
–Verifies the transcript shows credit earned in Algebra 1, or an equivalent course; Literature, or an equivalent course; or Biology, or an equivalent course.

If one or more of the above are not met (e.g., the student did not participate in a standardized assessment), the LEA may not award a non-numeric score of Proficient but may consider the student as having meet locally established, grade-based requirements for the Keystone content.

May a transfer student be awarded a non-numeric proficient score per act 136 of 2020?

Yes. The LEA may award the student a non-numeric score of Proficient provided the transfer student successfully completed a Keystone content related course in the prior educational setting during the 2019-20 school year (the only year in which statewide assessments were not required to be administered for federal accountability purposes) regardless of whether they participated in an associated standardized assessment.

Other educational settings impacted by the federal accountability waiver include home education and private schools as well as out-of-state schools.

How may a non-numeric score be used to satisfy statewide high school graduation requirements?

Non-numeric scores may be used to satisfy the Keystone Proficiency Pathway requirements or to fulfill criteria under Section Two of the Evidence-Based Pathway; however, non-numeric scores may not be used to satisfy the Keystone 3-score Composite Pathway as three numeric values are required to calculate the composite score. In order to qualify for the Keystone 2-score Composite Pathway, a student must have earned one non-numeric score of Proficient under Act 136; however, numeric scores earned in the other two Keystone Exams must be used to satisfy pathway requirements.

Also, a student pursuing the CTE, Alternative Assessment, or Evidence-Based Pathway is not required to meet locally established grade-based requirements for Keystone academic content in which the student has a numeric or nonnumeric score of Proficient/Advanced.

Note: A student meeting locally established, grade-based requirements for Keystone academic content is not considered as having attained a non-numeric score of Proficient.

May a student with a non-numeric score of proficient participate in the associated keystone exam?

Yes. A student who was awarded a non-numeric score of Proficient may elect to take the associated Keystone Exam and may utilize whichever score (numeric or non-numeric) is more advantageous in meeting pathway requirements.

Note: If a student earned a non-numeric Proficient in a Keystone Exam and subsequently elected to take the Keystone Exam in that content area, the student remains eligible for the 2-score composite pathway but cannot use that numeric score to calculate the 2-score composite.

Is a student required to retake a keystone exam after an unsuccessful attempt?

There is no state requirement for a student to retake any Keystone Exam. However, locally established policies may require a student to retake a Keystone Exam for purposes of meeting the LEA’s graduation requirements.

Note: A student who scores Basic or Below Basic may request to retake the assessment; a student who achieves a score of Proficient or Advanced may retake the exam if the student or parent/guardian submits a request in writing to the LEA.

To graduate on the keystone proficiency or the keystone composite pathway, must a student pass the keystone exam ‘trigger’ courses?

No. By way of example, an advanced student might earn a score ≥ 1500 on a Keystone Exam without having taken the associated ‘trigger’ course.

Note: The Keystone Proficiency Pathway requirements may be met using one or more non-numeric scores of Proficient - eligibility for which requires the student to have passed an associated course (see What is the Difference between a “Numeric” and a “Non-Numeric” Score).

How were the keystone composite pathway criteria determined?

The Keystone 3-score Composite Pathway criteria were informed by a report to the legislature, Findings and Recommendations Pursuant to Act 1 of 2016, and approved by the State Board of Education. In response to the pandemic and in consultation with PDE’s Technical Advisory Committee, subsequent 2-score criteria were established under Act 55 of 2022.

May scores from standardized assessments other than keystone exams be calculated as part of a keystone composite score?

No. Other standardized assessment scores may not be used to calculate a Keystone composite score; however, they may be used to satisfy pathways other than Keystone Composite, including Keystone Proficiency if the student is awarded a non-numeric Proficient.

May a project based assessment be used in lieu of a keystone exam?

No. However, Project Based Assessments (PBAs) may provide another option for students to meet locally established grade-based requirements for Keystone academic content in which they have not demonstrated proficiency.

LEAs may design their own PBAs or utilize Department-provided PBAs, which offer two modules per Keystone Exam (e.g., for Algebra I, Module 1 addresses Operations and Linear Equations and Inequalities and Module 2 addresses Linear Functions and Data Organization). Assessment Coordinators requiring access to the PBAs on SAS should contact the Help Desk at 877.973.3727.

Regardless of whether LEA-designed or Department-provided PBAs are conducted, administration is the responsibility and at the discretion of the LEA - including the method of delivery, teacher oversight, length of time to complete the work, scoring protocols, etc.

Must a student pass the keystone trigger course in order to demonstrate proficiency when meeting locally established, grade-based requirements?

Minimally, locally established, grade-based requirements (i.e., performance criteria reflected in the local graduation policy as consistent with proficiency in Keystone academic content) should include the successful completion of an associated trigger course - but not necessarily be limited to trigger courses.

Where a student is unable to successfully complete a trigger course, an LEA might consider permitting the student to demonstrate proficiency through the successful completion of either a:

–Project-Based Assessment (PBA), or
–Credit recovery course that covers the same breadth and depth of Keystone eligible content as the original trigger course (as determined by the LEA) with a passing grade/credit reflected on the student transcript.

Alternatively, an LEA may designate an advanced course (for which the Keystone course might be considered a prerequisite) as the grade-based requirement for students who are able to demonstrate proficiency in the Keystone content without participation in the trigger course (e.g., a student who is evaluated and placed directly into Algebra II).

Note: LEAs are not required to code every locally established, grade-based requirement as a ‘trigger’ course; refer to the PIMS Manual for more information.

May a student satisfy locally established grade-based requirements through an advanced placement or concurrent enrollment course?

Yes, if the LEA has adopted a policy to that effect. The LEA is not required to identify the AP or concurrent enrollment course as a Keystone Exam ‘trigger course’; however, the LEA must determine that the course covers the same breadth and depth of the Keystone eligible content.

Note: Where a passing grade in a concurrent enrollment course is used to satisfy locally established grade-based requirements for a student, the same course grade may not be used to also satisfy a pathway criterion for the same student.

May another course be used in lieu of biology when establishing local grade-based requirements?

In accordance with legislation, any science, technology, environment, and ecology course may serve as a grade-based requirement for academic content associated with the Keystone Exam in Biology where the requirements for Keystone Biology cannot be met (e.g., Biology is not offered as a standalone course, the student has opted not to enroll in Biology).

Where the standards are addressed over a series of courses, the LEA may either identify the course that culminates in the Keystone Biology Exam or consider student performance across the course series when determining proficiency in the Keystone academic content for the purposes of meeting locally established, grade-based requirements.

Must a student meet pathway-specific criteria for each keystone content area in which the student did not demonstrate proficiency?

The only pathway-specific criteria based upon Keystone academic content are the AP Exam, IB Exam, and concurrent enrollment course criteria under the Alternative Assessment Pathway, which require an associated exam or course for each Keystone content area in which the student has not demonstrated proficiency (i.e., has not attained a numeric or non-numeric score of Proficient/Advanced).

By way of example, a student who has a score of Proficient only for Keystone Literature would satisfy the following under the AP Exam criterion for the Alternative Assessment Pathway:

Locally Established, Grade-Based Requirement (LEGBR)	Alternative Assessment Pathway: AP Exam Criterion
Meet LEGBR for Algebra I	Must score 3 or higher on AP Exam aligned to Algebra I content
Meet LEGBR for Biology	Must score 3 or higher on AP Exam aligned to Biology content

Alternatively, that same student might choose to successfully complete only one approved pre-apprenticeship program in any discipline in order to satisfy the Alternative Assessment Pathway:

Locally Established, Grade-Based Requirement (LEGBR)	Alternative Assessment Pathway: Pre-Apprenticeship Criterion
Meet LEGBR for Algebra I	Must successfully complete one approved pre-apprenticeship
Meet LEGBR for Biology

Note: Under the Evidence-Based Pathway, the AP Exam, IB Exam, and concurrent enrollment or postsecondary course criteria may be in any content area consistent with the student's goals and career plan.

May a student combine AP exams and concurrent enrollment courses under the alternative assessment pathway?

No, Keystone-associated artifacts (AP Exam, IB Exam, and concurrent enrollment courses) may not be combined in order to satisfy the Alternative Assessment Pathway – however, the same artifacts may be used in combination to satisfy the Evidence-Based Pathway.

By way of example, a student with a non-numeric Proficient in Algebra I who has met locally established, grade-based requirements for Biology and Literature and earned the following artifacts has met statewide requirements:

Sample Student Artifacts	EB Pathway	Statewide Requirements	AA Pathway		Statewide Requirements
			Biology	Literature
AP Exam score ≥3 (Chemistry)	√ Section 1	MET	√	x	NOT MET
Concurrent Enrollment Course (American Literature)	√ Section 1		x	√
Keystone Exam (Algebra I NNP)	√ Section 2

May a psat 10 score satisfy the criterion under the alternative assessment pathway?

Yes. For the purposes of meeting this criterion under the Alternative Assessment Pathway, a score of 970 or better on the PSAT 10 is the same as achieving a score of 970 or better on the PSAT/NMSQT.

Note: A score in the PSAT 8/9 may not be utilized to satisfy this pathway as it has a different scoring scale.

May a student who participates in the ASVAB with accommodations be considered as having met requirements for admittance into the armed services?

No. Only Armed Forces Qualifying Test (AFQT) scores obtained from an ASVAB exam session given under identical (i.e., standardized) conditions may be considered as having met the minimum score to gain admittance to a branch of the armed services, thereby satisfying the criterion under the Alternative Assessment Pathway.

Note: Accommodations are available for the ASVAB Career Exploration Program (CEP) which, if appropriate for the student, may be incorporated into an IEP for the purpose of meeting Pennsylvania’s Career Education and Work (CEW) standards.

Must concurrent enrollment course credit earned appear on both the high school transcript and a postsecondary transcript?

A concurrent enrollment course is one in which both high school and postsecondary credit are earned upon successful completion; therefore, the student must successfully complete a course that offers both high school and college credit (e.g., dual credit, college in the high school).

The student must meet both high school and postsecondary requirements for course credit; however, where an additional fee may be required for the credit to appear on a postsecondary transcript, the LEA/student does not need to assume the cost in order to meet statewide high school graduation requirements.

May a student satisfy a criterion in a language other than English or by using evidence from outside the US?

Provided it meets both the definition and parameters of the criterion, evidence attained in a foreign language or from outside the United States may be accepted.

By way of example:

–Work-based or service-learning experiences occurring in a foreign language setting
–Concurrent enrollment or postsecondary courses conducted in a foreign language
–Exams (such as for an industry-recognized credential) conducted in a foreign language
–Postsecondary acceptance into an accredited nonprofit institution of higher education situated in an independent territory or foreign country
–Offer of employment or enlistment with an entity situated in an independent territory or foreign country

May a chief school administrator waive graduation requirements?

Yes, to an extent. For a student either in grade 12 or experiencing extenuating circumstances who does not meet the Keystone Proficiency or Keystone Composite Pathway requirements, the chief school administrator may waive the student’s obligation to satisfy criteria under other pathways provided the student successfully completes locally established, grade-based requirements for academic content associated with each Keystone Exam for which the student was not deemed Proficient via a numeric or non-numeric score.

Extenuating circumstances include serious illness, death in the student’s immediate family, family emergency, frequent school transfers, and transfer from out-of- state in grade 12. Per State Board of Education resolutions, the pandemic also may be considered an extenuating circumstance for which a waiver may be granted to students in the graduating classes of 2023, 2024, and 2025.

Where the chief school administrator grants waivers to more than five percent of a graduating class for reasons other than extenuating circumstances, the LEA will be required to complete an improvement section within the annual Grad Report. If the LEA is required to complete the improvement section in two consecutive reports, the LEA will be subject to corrective action and an audit.

How can an LEA assist English learners in meeting graduation requirements?

In addition to accommodations to the Algebra and Biology Keystone Exams, the following may prove beneficial when working with ELs:

–Both the SAT and ACT offer testing supports for English Learners.
–Concurrent enrollment or post-secondary courses (i.e., college-level, dual credit courses) may be available online in the student’s native language.
–A pre-apprenticeship or other work-based experience in which the predominant language spoken is not English may be an option.
–Service learning projects may be developed where language is not a barrier.
–A guarantee of full-time employment/military enlistment outside of the US may be accepted as evidence.
–Industry-Recognized Credentials may be earned in the student’s native language. (SkillUp PA, a free online platform, offers preparatory courses for credentialization translated into various languages).
–Admittance into an accredited non-profit IHE outside of the US may be accepted as evidence.

What graduation options exist for students experiencing education instability?

Where a student is identified as having experienced education instability (per §1331.1 of the Pennsylvania School Code) and is at risk of not graduating on time, LEAs should evaluate prior coursework and/or determine mastery of course content in order to award partial or full credit toward meeting local graduation requirements.

If the student is still unable to meet local graduation requirements, the LEA should collaborate with the chief school administrator of the prior school to determine whether the student meets the local graduation requirements of the prior entity. If the student is unable to meet local graduation requirements at either their current or prior school entities, the LEA may request a PDE-issued Keystone diploma; however, a student requesting a Keystone Diploma is considered a nongraduate at the local level – reducing the LEA’s Grad Rate in the FRPA Index.

Note: A student requesting a Keystone Diploma must meet statewide graduation requirements, minimally by qualifying for a chief school administrator waiver.

What graduation options exist for a student with disabilities?

Most students with IEPs will graduate via one of the five pathways; however, students with disabilities who satisfactorily complete a special education program (per the Individuals with Disabilities Education Act and 22 Pa. Code Ch. 14) which, by design, does not meet statewide graduation requirements are issued regular high school diplomas by the LEA. Students who graduate in this manner are not considered as having graduated via a chief school administrator waiver.

A student who continues in their special education program beyond Grade 12 may participate in the graduation ceremonies with their 12th grade peers and receive a certificate; however, the student should not be reported as ‘eligible to graduate’ until the year in which they either receive a diploma or exit the program.

Note: All students, including students with disabilities, are required to participate in the Keystone Exams for the purposes of federal accountability - unless the student participates in the Grade 11 PASA.

Are there limitations when graduating students via special education programs (IEP goals)?

No. The number or percentage of students within a graduating class issued diplomas for the satisfactory completion of a special education program is not limited, and students do not have to qualify for the PASA in order to graduate in this manner.

Must an adult student or a student who is re-engaged in a diploma program meet statewide graduation requirements?

Students who are legally entitled to attend school in the commonwealth (e.g., those students who are 21 years of age or younger or have turned 21 during the school term) and who are re-engaged in the academic program as delineated in Chapter 4 are subject to statewide high school graduation requirements, including students with a GED who are working toward a diploma or students beyond the age of 21 in an extended school program per a hearing officer decision or court order.

Participants in preparation programs for a Commonwealth Secondary School Diploma or High School Equivalency (via a GED, HiSET, or 30 college credit option) are not expressly subject to statewide graduation requirements, nor are adults who do not meet the above conditions but are engaged in an LEA-offered program resulting in the local issuance of a high school diploma.

Which graduation requirements must a student meet if placed in an alternate educational setting or receiving educational services through a host school?

If a student is ≤21 years of age (or participating in an extended school program per hearing decision or court order) and is enrolled at a school entity as defined in Section 121 of the Pennsylvania Public School Code, the student must meet the statewide graduation requirements. Specifically, a school entity is defined as a school district, intermediate unit, area vocational-technical school, charter school, cyber charter school, regional charter school, or multiple charter school organization.

Where a student is placed into another educational setting with the intention of granting that student a diploma from the school entity (as defined above) upon successful completion of the program, the student is subject to the local and state graduation requirements in that school entity’s board-approved policy regardless of whether the student returns to the school entity or completes the program in placement.

Conversely, where a student for whom the school entity (host school) is providing educational services shall receive a diploma from their resident school upon completion of the program, the student is subject to the graduation requirements of their resident school (whether in the US or abroad).

Students participating in a home education program are not subject to §121; however, other home education diploma requirements remain in place.

Note: Entities not included in the definition are not subject to Section 121, but may be subject to other mandates regarding responsibilities to a home/host district for student academic progress and achievement of graduation requirements; see Department guidance delineated in the Basic Education Circulars (BECs) for more information.

How can schools track student pathways?

Schools may elect to use the PDE-provided tracking tool available through MyPDESuite. This optional tool will: - Allow schools to enter and track each student’s progress toward meeting graduation pathways, and - Assist schools in identifying viable alternatives for students not meeting Keystone Proficiency or Composite score requirements.

Note: The tracking tool is not an online repository for individual student artifacts; therefore, schools should establish procedures for the local management of pathway evidence. Though the student artifact itself need not be retained, schools should maintain documentation indicating the manner by which each student graduated or the criteria fulfilled prior to a student exiting the secondary program.

What must LEAs report to the department?

No later than December 1st, each LEA must submit annually via the Future Ready Comprehensive Planning Portal (FRCPP) in MyPDESuite the following data:

–The numbers of students eligible to graduate and graduated during the prior school year
–Of those graduated, the numbers of students graduating by:

− Pathway and, for the Alternative Assessment and Evidence-Based Pathways, option(s) utilized
− Chief school administrator waiver and reason granted
− Satisfactory completion of a special education program

–Of those not graduated, the number of students requesting a Keystone Diploma

The LEA-reported data will be made publicly available via the Future Ready PA Index no later than January 15th.

Note: Students reported as ‘eligible to graduate’ are all students who should have fulfilled graduation requirements during the reported year, regardless of whether they did - including 12th graders, multi-year seniors, and students identified as seniors based on credits.