Summary

• Students with IEPs in D.C. can be routed toward certificate tracks due to systemic barriers rather than individual needs.

• Certificates of IEP completion are not equivalent to diplomas and can limit postsecondary and employment opportunities.

• Graduation outcomes vary across schools due to inconsistent implementation, unclear requirements, and limited guidance for families.

• Being tracked for a certificate can result in long-term consequences, including placement in sub-minimum wage jobs under outdated federal provisions.

• The State Board calls for more transparent, inclusive graduation pathways that uphold the dignity and potential of all students with disabilities.

In Washington, D.C., students with disabilities are often tracked toward certificates of Individualized Education Program (IEP) completion – not out of need but because of systemic limitations in support, communication gaps, and unclear pathways. The result is a pattern of lowered opportunity that starts early and lasts a lifetime.

The D.C. State Board of Education (State Board) is examining the current state of equitable access to high school diplomas for students with learning disabilities in the District. At its June 18 monthly public meeting, the State Board convened community leaders and education experts to understand what barriers currently exist, how other states and school districts are advancing more inclusive graduation pathways, and what D.C. can learn from those efforts. Panelists included Maria Blaeuer of Advocates for Justice and Education, Chelsea Kovacs of SchoolTalk D.C., and Hannah Blumenfeld-Love of D.C. SPED Hub.

What’s the difference between a certificate and diploma?

There are slight distinctions between various secondary-level credentials.

• A Standard Diploma is what most students earn. It offers full recognition and access to college, employment, and career training programs.
• A Certificate of IEP Completion is a recognition of attendance or participation, but it doesn’t carry the weight a standard diploma does. For example, college admissions, most job training programs, and employers may not recognize such certificates as qualifying.
• An Alternate Diploma is a credential specifically designated in many states for students with the most significant cognitive disabilities. This diploma type is typically based on modified academic standards and is not equivalent to a standard high school diploma.

(In this piece, ‘students with disabilities’ refers primarily to those served under the Individuals with Disabilities Education Act (IDEA) through IEPs. While not all students with disabilities have IEPs, those who do represent the subset most directly affected by diploma pathway decisions.)

How prevalent is certificate tracking for D.C. students with learning disabilities?

That question is at present difficult to answer.

We simply don’t know.Students on the certificate track are able to remain in school until the end of the academic year in which they turn 22 – well beyond standard reporting timelines. That means their outcomes often aren’t captured. Even when the outcomes are captured, they are typically grouped together with GEDs or other “alternative” awarded credentials. That makes it nearly impossible to parse out how many received a certificate of completion versus a diploma.

As Blumenfeld-Love explained in her testimony, this “lack of clarity isn’t just frustrating”; it’s a serious obstacle to informed policymaking. Without disaggregated data, we can’t answer even the most basic equity questions: Are certain schools disproportionately placing students with IEPs on non-diploma tracks? Are multilingual students or students of color more likely to be affected? Are outcomes improving—or getting worse?

Until D.C. commits to collecting and publishing disaggregated data for students with disabilities, families and city leaders will remain in the dark. And without that transparency, there’s no real way to hold schools accountable, improve education policy and practices, or ensure every student is getting a fair chance.

How do special education students get pushed onto certificate tracks?

The State Board’s June public meeting panelists pointed to multiple reasons.

Communication breakdowns.

Many families of students with learning disabilities, particularly those who face language barriers or have limited resources, are not fully informed by the D.C. education system about the full range of certificate or diploma pathways available to their child, nor the long-term academic and career consequences of each option.

The use of the term “track” itself can also be misleading. DC technically has one diploma, but the way students are guided through that system creates de facto tracks with very different outcomes. For example, while D.C. formally offered only one type of diploma, now students may be slotted into coursework that does not meet the full requirements, resulting in a certificate of completion. This routing can happen unintentionally, with little family awareness, and it can produce dramatically different postsecondary options for students.

Inconsistencies across Local Education Agencies (LEAs).

There are inconsistencies across LEAs, including D.C. Public Schools and public charter schools in how graduation pathways are implemented for students with disabilities. This includes differences in how IEPs align with graduation requirements, how course sequences are structured, and whether students and families receive clear guidance on diploma eligibility. 

In some schools, students on IEPs might have a transparent and standards-aligned path to a diploma. In others, particularly certain charter settings, their path forward might be opaque or underdeveloped. As Kovacs from SchoolTalk D.C. pointed out in her testimony, this can “result in students, families, and even educators being unclear about whether a student is on track to earn a diploma” or simply participating in general instruction that leads to a certificate of completion without the necessary credit accumulation for a diploma. As Kovacs emphasized, resource gaps across LEAs create drastically different experiences for students.  Students who transfer schools midstream may suddenly find themselves off track for a diploma, even after fulfilling every requirement asked of them.

If anecdotes from the public are taken as representative of the treatment of schools’ indoor air quality, though, it does appear that the District has a problem on its hands.

Weak accountability within IEP teams.

School staffing capacity, funding limitations, and administrative constraints can become the primary drivers of placement decisions, rather than placing student needs first. As the National Council on Disability (2018) found, despite federal mandates requiring inclusive placements based on a student’s IEP, many students with disabilities, especially students of color in urban schools, are still placed in separate classrooms, specialized programs, or entirely different campuses away from their general education peers. These “segregated settings” can limit access to rigorous academic content and reduce opportunities for social inclusion, undermining the core intent of federal protections.

What can be the consequences of being tracked for a certificate unnecessarily?

Blaeuer noted in her testimony that certificates are essentially “legally insignificant documents.” They carry no entitlement under federal education law and provide far fewer protections or pathways. Thus, graduating with a certificate of completion instead of a diploma can have serious long-term impacts.

A recent Bloomberg feature illustrates just how serious this is. It reports that tens of thousands of adults with disabilities in the U.S. are paid less than minimum wage – sometimes as little as 25 cents an hour. Such miniscule wages are authorized by Section 14(c) of the Fair Labor Standards Act, which allows employers to pay subminimum wages to individuals with disabilities under special wage certificates issued by the U.S. Department of Labor. 

As of July 2025, over 682 employers held active 14(c) certificates, including some in D.C. (Department of Labor, 2025). Students tracked to certificates can find themselves pipelined into 14(c) roles postgraduation due to less-than-robust transition planning and job-readiness training.

The realities of where they land render in high resolution the injustice done to them. One worker profiled in the Bloomberg report, Michele Jardine, reported an hourly wage between just one dollar and three. Another — a man with autism, Brady Bartley, made just three dollars per hour before eventually securing a job with more dignified pay.Their experiences reveal a system that too often steers disabled individuals toward lesser credentials without first offering clear guidance or supports to ensure their success, locking them out of important life opportunities. That’s not just a gap in policy. It’s a failure to deliver on the full promise of access, dignity, and opportunity that students with disabilities are entitled to under federal law. 

We must better support diploma attainment for students with disabilities.

Though some students with disabilities are better fit for a certificate track – given it can help them a valuable opportunity to learn a life skill – it is still worth the investment to pave ways for those students who are suitable for the diploma track to more easily access it.  As Kovacs put it: we need multiple ways for students to reach the same finish line, rather than creating multiple finish lines. D.C. has the capability to build that kind of graduation system which upholds the potential of students with disabilities.

The State Board’s June 18 public meeting panel produced some ideas on how to proceed:

• Ensure transparency in decision-making. IEP teams should be required to capture and report data, while documenting their rationale for certificate pathway decisions.
• Clarify credit requirements. There is widespread confusion, especially among families of students with disabilities, about what a diploma truly requires, how credits are earned, and how learning is assessed. This lack of clarity can lead to students being diverted from the standard diploma without informed consent.
• Expand flexible pathways to a standard diploma. This includes developing occupational diploma tracks that maintain academic rigor and result in a standard credential.
• Highlight student skills through endorsements. Micro-credentials and endorsements can recognize students’ strengths and interests without defaulting to lower-tier certificates.

The D.C. State Board of Education is committed to working alongside its partners in the District’s community and Education Cluster to secure diploma pathways for our students with disabilities.