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New York State (NYS) Career Development
and Occupational Studies (CDOS)
Commencement Credential
Frequently Asked Questions
Updated June 15, 2023
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TABLE OF CONTENTS
Overview .................................................................................................................... 3
Eligibility ..................................................................................................................... 4
Instruction Towards the CDOS Learning Standards And Opportunities To Earn a
Diploma...................................................................................................................... 7
Work-Based Learning ................................................................................................ 9
Career and Technical Education Coursework .......................................................... 15
Career Plan .............................................................................................................. 17
Employability Profile ................................................................................................ 18
Documentation ......................................................................................................... 20
Work Readiness Credentials ................................................................................... 22
Transfer Students .................................................................................................... 23
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OVERVIEW
The following document addresses frequently asked questions from the
field regarding the NYS CDOS Commencement Credential. The answers
are organized by topics with the questions that apply to students with
disabilities at the end of each section. This document supersedes any
previously issued FAQ on this topic. This document will be periodically
updated.
If after reading this guidance document, there are additional questions,
please contact the appropriate office below:
• Questions regarding graduation requirements, Office of Standards and
Instruction, [email protected]
• Questions regarding Career and Technical Education (CTE)
coursework or work-based learning, Office of Career and Technical
Education, emsccte@nysed.gov
• Questions regarding students with disabilities, Office of Special
Education, [email protected]
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A. ELIGIBILITY
All Students
A1. 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.
A2. Can a student receive the CDOS Commencement Credential if they continue in
high school beyond four years?
Yes.
A3. 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.
A4. 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.
A5. 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
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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.
A6. 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.
A7. 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.
A8. 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?
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• Is the student graduating with a regular high school diploma or has the
student attended school for at least 12 years, excluding kindergarten?
A9. 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 Office of Information and Reporting Services.
A10. 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
A11. Can a student who takes the New York State Alternate Assessment (NYSAA) for
some subject areas and Regents exams for other subject areas be eligible for the
CDOS Commencement Credential?
Yes. A student with a disability, who meets the definition of a student with a
severe disability in section 100.1(t)(2)
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of the Regulations of the Commissioner of
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Students with severe disabilities means students who have limited cognitive abilities combined with
behavioral and/or physical limitations and who require highly specialized education, social, psychological
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Education, may be recommended by the committee on special education (CSE)
to participate in the State’s alternate assessment only for selected subject areas.
State data identifies few instances when this has occurred; however, in the
exceptional instances when this may occur, such student may be eligible for the
CDOS Commencement Credential if the student meets the credential
requirements, including achievement at the commencement level of the State’s
CDOS Learning Standards.
B. INSTRUCTION TOWARDS THE CDOS LEARNING STANDARDS
AND OPPORTUNITIES TO EARN A DIPLOMA
All Students
B1. If a student does not meet all standards (i.e., 1, 2 and 3a) at the commencement
level, are they eligible for an award of the CDOS Commencement Credential?
No. The school district must have evidence that a student has demonstrated
commencement level knowledge and skills relating to the CDOS learning
standards 1, 2 and 3a (i.e., career development, integrated learning, and the
universal foundation skills) to award this credential to the student. However, it is
not necessary for the student to complete all the sample tasks to demonstrate
attainment of that standard.
B2. May a student work only towards attainment of the CDOS Commencement
Credential without participating in coursework and the assessments that would
lead to a high school diploma?
No. Students should not be placed on a “separate track” to receive the CDOS
Commencement Credential as their only exiting credential, and at no point should
a decision be made that a student stop working toward a high school diploma in
order to concentrate only on earning this credential.
B3. How will students have time to work toward both the CDOS Commencement
Credential and a high school diploma?
Over a four (or more) year period of time (grades 9-12), it is reasonably expected
that schools can provide students with work-based learning activities such as job
shadowing, community service, volunteering, service learning, senior/career-
focused research project(s) and/or school-based enterprise(s) to meet the work-
based learning requirements to earn the CDOS Commencement Credential.
Although work-based learning experiences must be provided consistent with
and medical services in order to maximize their full potential for useful and meaningful participation in
society and for self-fulfillment. Students with severe disabilities may experience severe speech, language,
and/or perceptual-cognitive impairments, and evidence challenging behaviors that interfere with learning
and socialization opportunities. These students may also have extremely fragile physiological conditions
and may require personal care, physical/verbal supports and/or prompts and assistive technology devices.
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NYSED guidelines and under the supervision of the district, participation in these
activities may occur outside of regular school hours.
All students beginning in grade 9 should have access to CTE coursework.
NYSED’s Resource Guide with Core Curriculum includes examples of how the
CDOS standards can be presented in the classroom. Some activities are short,
one-day events that focus on a single topic or concept. Others are multi-day
instructional units that lead students through inquiry processes that increase their
understanding. While there are specific CDOS standards, there are unlimited
ways to teach those standards.
In addition, under Option 2, a student has the opportunity to earn the CDOS
Commencement Credential if they have met the requirements for one of the
nationally recognized work readiness credentials
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in lieu of completing the 216
hours of CTE coursework, of which 54 hours must be work-based learning, or
utilizing the full 216 hours of work-based learning option instead of two units of
CTE coursework..
Students with Disabilities
B4. If a student with a disability has completed the CTE coursework and work-based
learning requirements to earn a CDOS Commencement Credential and remains
in or returns to school, must districts continue to provide transition planning and
services?
Yes. A student with a disability is entitled to transition planning and activities until
they exit high school. In addition, the hours of instruction and work-based
learning requirements to earn the CDOS Commencement Credential are the
minimum standard. All students should be encouraged to evolve their work
readiness skills beyond the minimum requirements, and all districts should
provide students with additional coursework and work-based learning
experiences beyond the 216-hour (2 unit) requirement while the student
continues in school to earn a local or Regents diploma.
B5. The regulations indicate that a school district that awards the credential to more
than 20 percent of students with disabilities in the cohort, where the credential is
not a supplement to a regular diploma, may be subject to redirection of a portion
of their IDEA funds. What portion of these funds will be reallocated? How is the
20 percent ceiling being calculated?
To clarify, there is no cap on the percentage number of students with disabilities
that can receive the CDOS Commencement Credential where the credential is
not a supplement to a regular diploma. However, when the credential is awarded
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Pursuant to section 100.6(b)(4)(ii) of the Regulations of the Commissioner of Education on or after
April 3, 2017, students who seek to use Option 2 to meet the requirements for the CDOS
Commencement Credential must pass a
work-readiness assessment approved by the Commissioner.
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to more than 20 percent of the students with disabilities in the district cohort as
the student’s only exiting credential, NYSED may, at its discretion, determine that
the reason for these numbers is that the district failed to provide such students
with disabilities with appropriate access to participate and progress in the general
education curriculum necessary to earn a regular high school diploma. The
amount of funds to be redirected would be determined on a case-by-case basis,
depending on the findings of the State.
C. WORK-BASED LEARNING
All Students
C1. 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.
C2. Does a student automatically earn the required 54 WBL hours when they are
enrolled in a CTE course? What about a NYSED-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 NYSED-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,
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skills development activities, and modeling safety in the classroom cannot be
counted as WBL hours.
C3. 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 NYSED 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 NYSED-registered program are available on the Work-Based Learning
Programs webpage.
C4. 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 NYSED-
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 Coordinator of Work
Based Learning Programs extension.
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C5. 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 National Institute for Occupational Safety and Health 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.
C6. 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
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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.
C7. 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 NYSED 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.
C8. 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.
C9. 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.
C10. 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
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• 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.
C11. 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 NYSED guidelines, under the supervision of the district, and
documented in a student’s transcript.
C12. 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
C13. 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
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• Help to acquire a sense of belonging at the work site and encouraging an
understanding of and a participation in employee programs which involves
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 fulfill 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.
C14. 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 NYSED or
another State agency to provide such services. Education Law section
4401(2)(n) authorizes school districts to enter into formalized agreements for the
provision of transition services [as defined in Education Law section 4401(9)] with
programs such as vocational training programs that are approved by NYSED 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 contracts
for instruction 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.
C15. 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.
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D. CAREER AND TECHNICAL EDUCATION COURSEWORK
All Students
D1. Does the requirement to use CTE coursework towards the 216 required hours
mean that a student must be enrolled in CTE courses or programs of study?
To earn the CDOS Credential under Option 1, a student must be enrolled and
successfully complete the equivalent of two units of study (or 216 hours)
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of CTE
course(s) and/or CTE programs of study taught by a teacher certified in a CTE
content area. The CTE coursework (grade 9-12) can be courses that are
approved by the local board of education or are approved by NYSED through the
CTE program approval process. Students must have a minimum of 54 hours of
the total 216 hours in documented, school-supervised work-based learning
experiences related to career awareness, exploration and/or development which
may, but are not required to, be completed in conjunction with the student’s CTE
course(s).
D2. If a school district develops a locally approved CTE course, what must the
coursework/curriculum include?
The majority of all courses that districts offer is locally developed and locally
approved. For purposes of this credential, the CTE coursework (grade 9-12) can
be courses that are approved by the local board of education or are approved by
NYSED through the CTE program approval process. Such courses must:
• Be aligned to the State learning standards (in this case, the CDOS learning
standards);
• Be taught by a certified teacher in a CTE content area as defined in section
100.1(l) of the Regulations of the Commissioner of Education appropriate
to the course description;
• Meet the unit of study requirement consistent with section 100.1(a) of the
Regulations of the Commissioner of Education (at least 180 minutes of
instruction per week throughout the school year or the equivalent); and
• Meet the unit of credit requirements established in section 100.1(b) of the
Regulations of the Commissioner of Education. A unit of credit is earned
by:
o The mastery of the learning outcomes set forth in a NYS-developed
or locally developed syllabus for a given high school subject, after
a student has had the opportunity to complete a unit of study in the
given subject matter area; or
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Students may complete all of the 216 hours through participation in work-based learning. The 216
hours, whether achieved through completion of CTE coursework and/or work-based learning, may begin
accumulating in 9th grade.
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CTE course offerings and programs of study approved at the local level or through
the NYSED program approval process include the following content areas:
• Agricultural Education
• Business and Marketing
• Computer Science
• Family and Consumer Sciences
• Health Sciences
• Technology Education
• Trade and Technical Education
Coursework in which a student participates should also be consistent with his/her
strengths, preferences, and interests.
D3. Can a school district’s general education courses that integrate CDOS learning
standards (e.g., English language arts (ELA) where an activity is creating a
resume) count toward 216 hours (2 units of study) in CTE coursework?
No. General education courses (e.g., ELA) do not count toward the 216 hours (2
units of study) required for this credential. The equivalent units of study must be
earned through coursework in CTE taught by a certified CTE teacher and/or
through work-based learning experiences. CTE coursework (grade 9-12) can be
courses that are approved by the local board of education or by NYSED through
the CTE program approval process.
D4. If a student is enrolled in a course(s) that would provide them with 216 hours of
work-based learning, but the student is absent several times, does the student
need to make up lost hours to meet the requirement for award of the credential?
In order to satisfactorily complete the course, students must meet class
attendance requirements established by the district.
D5. If a student takes a high school CTE course in eighth grade and it is recorded on
the high school transcript, will this credit count towards the CDOS
Commencement Credential?
Yes. Successful completion of an accelerated CTE course by an eighth-grade
student, pursuant to section 100.4(d) of the Regulations of the Commissioner of
Education, is a high school credit bearing course and as such could count toward
the required hours for the CDOS Commencement Credential. However, CTE
instruction required at the middle level as part of the unit of study requirements
for grades 7-8 pursuant to section 100.4(c) of the Regulations of the
Commissioner of Education to meet the State intermediate learning standards
does not count as CTE coursework to meet the requirement for the credential.
D6. Can coursework delivered through a distance learning network count as CTE
coursework to meet CDOS Commencement Credential requirements?
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For CTE coursework to count towards CDOS Commencement Credential
requirements, it must be taught by a certified teacher of a CTE content area as
defined in section 100.1(l) of the Regulations of the Commissioner of Education.
With the exception of operationally approved programs in appearance
enhancement, barbering, and the health sciences, the development of CTE
curriculum is left to local control. Schools have the option to use distance learning
so long as the instructor of record is a certified teacher of the applicable CTE
content area who is employed by the school district or BOCES and not the
vendor.
D7. Can online coursework provided through a third-party vendor be counted
as CTE coursework to meet CDOS Commencement Credential Requirements?
For CTE coursework to count towards CDOS Commencement Credential
requirements, it must be taught by a certified teacher of a CTE content area as
defined in section 100.1(l) of the Regulations of the Commissioner of Education.
With the exception of operationally approved programs in appearance
enhancement, barbering, and the health sciences, the development of CTE
curriculum is left to local control. Schools have the option to use the curriculum
from a third party vendor so long as the instructor of record is a certified teacher
of the applicable CTE content area who is employed by the school district or
BOCES and not the vendor.
E. CAREER PLAN
All Students
E1. 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. Section 100.2(j)(ii) of the Regulations of the Commissioner of Education
requires that a student’s guidance program in grades 7-12 shall include an annual
review of each student's educational progress and career plans. 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 New York State Department of Labor's
CareerZone.
E2. How often should the Career Plan be completed or reviewed during a student’s
high school career?
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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.
E3. 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 CareerZone, 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.
E4. Does NYSED provide a model career plan?
Yes. The NYSED 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.
F. EMPLOYABILITY PROFILE
All Students
F1. Who is responsible for completing the employability profile?
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The employability profile is completed by the school or others personally
knowledgeable about the student’s skills (e.g., general education teacher, special
education teacher, CTE teacher, work-based learning coordinator, employer, job
coach, or extracurricular club advisor, etc.).
F2. What documentation should districts collect to substantiate the information on a
student’s employability profile?
The work skills employability profile is intended to document student attainment
of technical knowledge and work-related skills. Documents to validate skills
reported on the profile could include, but are not limited to, an employer/teacher
review of student work based on learning standards and expectations in the
workplace, performance evaluations, and observations.
Commissioner’s regulations require that at least one employability profile be
completed within one year of a student’s exit from high school. As such, nothing
would preclude a school from providing the student with more than one profile.
Schools are encouraged to complete an employability profile for each of the work-
based learning experiences in which the student participates to capture skills
across a variety of settings and use the employability profile annually as a tool to
identify areas of need for student-specific instruction.
F3. May the employability profile be modified?
Yes. Districts may develop their own form or modify the model form as long as it
includes the required components. These include documentation of the
student’s:
• Employability skills and experiences
• Attainment of each of the commencement level CDOS learning standards
1,2, and 3a; 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.
F4. May the employability profile be considered documentation of student’s
attainment of CDOS Learning Standards?
Yes, if the employability profile addresses all of the CDOS Learning Standards
(1, 2, and 3a). Additional evidence may be used in conjunction with the
employability profile as well.
F5. If a student earns 1s (unsatisfactory) and 2s (needs improvement) on the
employability profile, will they receive the credential?
In order to award the CDOS credential, a school must have evidence that the
student has satisfactorily completed the requirements for the credential (i.e.,
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career plan, achievement of the CDOS learning standards at the commencement
level, and satisfactory completion of the 216 hours (2 units) of career and
technical education and/or work-based learning). The employability profile
documents the student’s satisfactory completion of work-based learning and must
be signed by the individual completing the form to assure authenticity and
validation. The principal is responsible for determining if, based on all the
documentation, the student has demonstrated work-readiness skills at the entry
level to appropriately award the credential. No single rating or score should be
used to make this determination.
Students with Disabilities
F6. Will the employability profile for the CDOS Commencement Credential serve as
the Student Exit Summary?
No. The employability profile does not meet all of the requirements for the
Student Exit Summary under section 200.4(c)(4) of the Regulations of the
Commissioner of Education. The Student Exit Summary must include a summary
of the student’s academic achievement and functional performance as well as
recommendations to assist the student in meeting their post-secondary goals.
The information in the employability profile(s) should be considered when
completing the Student Exit Summary. Both documents should help the student
better understand the impact of their disability and articulate individual strengths
and needs as well as supports that would be helpful in post-school life.
G. DOCUMENTATION
All Students
G1. 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.
G2. 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. NYSED has developed a “Model Certificate for CDOS
Commencement Credential” for award of the NYS CDOS Commencement
Credential that districts may opt to use.
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G3. 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.
G4. Does the SED 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. SED’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.
G5. 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
Records Retention and Disposition Schedule.
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
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• 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
G6. 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.
G7. 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.
H. WORK READINESS CREDENTIALS
All Students
H1. Can a district offer coursework and training to prepare a student to take one of
the nationally recognized work readiness assessments?
Yes. Districts can offer coursework and/or work-based learning experiences that
will prepare a student for any of the Department-approved, nationally recognized
work readiness assessments under Option 2.
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Each of these assessments measures slightly different skills and has a fee
associated with it. Each also provides instructional materials and resources to
assist in preparing a student for the assessment.
Although a school district may provide individual students the option of earning
the NYS CDOS Commencement Credential by meeting the requirements under
Option 2, this should not be the only option available to students in the district to
earn the credential.
H2. Must students participate in work-based learning experiences if they are earning
the credential through successful completion of one of the Department-approved,
nationally recognized work readiness assessments?
No. Students would not be required to participate in work-based learning
experiences unless otherwise required for successful completion of the work
readiness assessment.
H3. Can parents pursue attainment of a CDOS Commencement Credential through
Option 2 on their own with their child, outside of the school day?
To award the CDOS Commencement Credential through Option 2, the district
must have documentation that the student passed a Department-approved,
nationally recognized work readiness assessment. Public school districts must
offer students the option to earn a CDOS Commencement Credential. As such,
parents may opt to pursue attainment of a credential under Option 2 for their child
on their own.
I. TRANSFER STUDENTS
All Students
I1. 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
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• 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.
