Graduation and Special Education Frequently Asked Questions (FAQ)

1.1 Which students are eligible to graduate under 19 TAC §89.1070? 

These rules apply to any student who is receiving special education services and enrolled in a public school district or open-enrollment charter school. 

1.2 When was the most recent revision to this rule? 

Amendments to this rule were adopted with an effective date of April 5, 2026. The adopted amendment adds new subsection (d) to align with House Bill (HB) 2 and Senate Bill (SB) 568 of the 89th Legislature by clarifying the qualifications a student receiving special education and related services must meet to receive the distinguished level of achievement with modified curriculum. This rule was also modified to update cross references to the state standards in the TAC.

While the revised rules applied to students in all cohort years, there was no requirement to update the individualized education program (IEP) for students who entered grade 9 prior to the 2025-26 school year.  

1.3 What is the difference between subsections 19 TAC §89.1070(b)(1) and (b)(2)? 

TAC §89.1070(b)(1) states that a student who receives special education services may graduate and be awarded a diploma if the student meets the same expectations for graduation as students without disabilities.  

Subsection (b)(2) clarifies that an admission, review, and dismissal (ARD) committee has determined that satisfactory performance, beyond what would otherwise be required in subsections (b)(1) and (e) of this section, on the required end-of-course (EOC) assessment instruments is not required for graduation.  

Subsection (e) states that a student in Grade 11 or 12 who has failed to achieve satisfactory performance on no more than two state assessments would be eligible to graduate under the first condition described in 19 TAC §89.1070(b)(1).  

Note that a student’s ARD committee determines whether a student is required to achieve satisfactory performance on an EOC assessment. As specified by 19 TAC §101.3022(f)(1), a student receiving special education services is not subject to the requirements for Individual Graduation Committee (IGC). 

1.4 Can the student’s graduation plan be adjusted during high school? 

Yes. Students’ needs and eligibility may change during high school. At any time, an ARD committee meeting may be held to admit or dismiss a student from special education and related services or to update the types of services they receive. A student’s graduation plan, including courses of study aligned to the student’s postsecondary goals, must be reviewed each year and updated, as appropriate. 

1.5 What are the requirements for the IEP to include information about graduation? 

In accordance with 34 Code of Federal Regulations (CFR) §300.320(b)(2) and 19 TAC §89.1055 (l)(2), beginning with the first IEP that is in effect when the student turns 14, or younger if determined appropriate by the ARD committee, the IEP must include the transition services (including courses of study), needed to assist the student in reaching their postsecondary goals.  Guidance for courses of study can be found in Item 5 of the Data Collection Guidance for Secondary Transition.  

ARD committee decisions related to 19 TAC §89.1070 should be documented in the IEP and updated annually.  

In addition, graduation-related information documented in the IEP should align with the student’s official academic records. The Minimum Standards for the Academic Achievement Record (AAR) specify that:

“The AAR is an official and permanent record of a student's academic performance during high school and, in some cases, of high school courses completed prior to high school. Entries on this official record of actual courses taken, grades earned, credit awarded, and codes denoting special explanations must be consistent with teachers’ records and the student’s individualized education program (IEP), when applicable.”

1.6 Must an LEA require a separate ARD committee meeting specifically to address graduation? 

No. Graduation may be discussed during any ARD meeting, including the annual ARD meeting, with decisions documented in the IEP.  

During the year in which the student graduates, the ARD committee is not required to hold a separate meeting to discuss graduation unless it was not addressed during the annual ARD meeting or if there were subsequent changes to the graduation plan that conflict with IEP documentation. Since graduation is a change in placement, if an additional ARD meeting is required to address graduation, an amendment to agree without a meeting may not be used to make changes to the IEP. Additionally, prior written notice must be provided at least five days before the LEA proposes a change in placement.  

For example, an annual ARD meeting is held in October for a student who is expected to graduate in May. Ten days before the annual ARD meeting, the prior written notice was sent to the parent and adult student. This notice contained a summary of the proposed actions, which included the student’s annual IEP review and a discussion of a change in placement due to graduation.  

During the annual ARD meeting in October, the ARD committee members agreed to the change in placement due to graduation (after the last school day in May). In this example, the “reasonable timeframe” of at least five school days before proposing the change in placement was met because the ARD notice was sent 10 school days prior to discussing graduation. 

2.1 Under what conditions can a student receiving special education services be awarded a diploma through modified content? 

Subsection (b)(3) specifies the requirements for students with modified content and curriculum expectations established in the student's IEP. See section 4 to learn more about ARD committee considerations for 19 TAC §89.1070(b)(3). 

2.2 What are the options for students with disabilities to earn an endorsement under this rule? 

In accordance with 19 TAC §89.1070(c), a student receiving special education services may earn an endorsement if the student:  

(1) satisfactorily completes the requirements for graduation under the Foundation High School Program specified in §74.12 of this title as well as the additional credit requirements in mathematics, science, and elective courses as specified in §74.13(e) of this title with or without modified curriculum;  

(2) satisfactorily completes the courses required for the endorsement under §74.13(f) of this title without any modified curriculum or with modification of the curriculum, provided that the curriculum, as modified, is sufficiently rigorous as determined by the student's ARD committee; and  

(3) performs satisfactorily as established in Texas Education Code (TEC), Chapter 39, on the required EOC instruments unless the student's ARD committee determines that satisfactory performance is not required.  

2.3 Can a student receiving special education and related services earn a distinguished level of achievement? 

Yes. TEC §28.025(c-7) authorizes students receiving special education services to earn a distinguished level of achievement under the Foundation High School Program with or without modified curriculum. The requirements to earn a distinguished level of achievement are specified by the April 2026 amendments to 19 TAC §89.1070.  

Subsection (d) of the amended rule specifies that the student’s ARD committee will determine if the curriculum required for the distinguished level of achievement, if modified, is sufficiently rigorous as modified to earn the distinguished level of achievement and whether the student is required to achieve satisfactory performance on an EOC assessment to earn the distinguished level of achievement. 

2.4 What should the ARD committee consider when determining whether “the curriculum, as modified, is sufficiently rigorous” for a student to earn an endorsement or distinguished level of achievement?  

While the interpretation of “sufficiently rigorous” curriculum is outside the scope of rulemaking and guidance, ARD committee members may find it helpful to consider the following questions when determining whether to award an endorsement for a student who received modified content in one or more courses:  

• In which content areas or courses did the student require modified curriculum?
• What types of modifications were needed for the student to access the curriculum standards, the Texas Essential Knowledge and Skills (TEKS), for the course? For example, was the student able to make progress toward the student expectations in the TEKS for the course, or were the student’s academic goals aligned to prerequisite skills significantly below the TEKS for the course?
• What other information is available about the student’s academic access, including their participation and progress in courses that satisfy the endorsement requirement? 

2.5 Does a student need to complete an Endorsement Opt‑Out form if their ARD committee determined the curriculum was not sufficiently rigorous to earn an endorsement? 

No. In this situation, the student is not considered to have declined or opted out of an endorsement. If the IEP includes documentation of the ARD committee determination that the student’s curriculum, as modified, does not meet the level of rigor required to earn an endorsement, the Endorsement Opt‑Out form is not required.  

LEAs should establish methods to ensure that ARD committee decisions related to graduation are communicated to the appropriate staff, such as the school counselor or administrator designated to review high school personal graduation plan options with each student, as outlined in TEC §28.02121. 

2.6 Can the ARD committee substitute required courses for students with disabilities? 

Section 2.1(c) of the 2024 Minimum Standards for the AAR specifies that “For students receiving special education and related services, no substitutions are allowed for courses required for high school graduation, except as indicated in the graduation requirements under 19 TAC Chapter 74. Students enrolled in a high school course required for graduation must access the curriculum for that course as specified in the TEKS (19 TAC Chapters 110 – 128) or state-approved innovative courses, with specially designed instruction in the appropriate settings as determined by the student’s ARD committee.”  

Additional information is available on the TEA website, including responses to FAQs about substitutions for languages other than English (LOTE) and physical education (PE). See question 9.6 for information about coding for courses for high school graduation credit.  

2.7 Can the ARD committee exempt a student from meeting additional graduation requirements, such as demonstrating proficiency in the major components of speech (19 TAC §74.11(a)(3))? 

Unless specifically addressed in TEC or TAC, all graduation requirements and other provisions must be met, with adaptations as described in the IEP.

For example, 19 TAC §74.38(f) includes the option for schools to waive the requirement for instruction in cardiopulmonary resuscitation (CPR) and use of an automated external defibrillator (AED) for a student who, due to a disability, is unable to complete the requirement. Another example is the ability for any student to opt out of the financial aid application that must be completed before graduating from high school. Students who meet the criteria described in rule and guidance will be able to pursue a diploma without meeting the specified requirement or provision.  

If there are no options for a student to opt-out of (or for the school to waive) a requirement or other provision, the ARD committee will consider the disability-related needs of the student and define the specially designed instruction needed for the student to complete the requirement. This is also true for any local graduation requirements specified by districts and open-enrollment charter schools (unless options for students with disabilities are addressed by local board policy).  

For example, neither the instruction on proper interaction with peace officers required by 19 TAC §74.39 nor the demonstration of proficiency in major components of speech required by 19 TAC §74.11(a)(3) include options for schools to waive the requirement. The IEP will describe the adaptations for any student whose disability will impact their access to content or mastery of the required skills. 

2.8 If a student takes a course designed to meet their disability-related needs, is that considered “modified” for the purposes of graduation? 

When determining how specially designed instruction is documented, the ARD committee should carefully consider whether the services provided truly require the curriculum to be modified.

For example, consider interventions for students with dyslexia. Reading I, Reading II, and Reading III are eligible for state high school credit and are built upon TEKS that can be met through appropriately designed, evidence-based dyslexia instruction as outlined in the Dyslexia Handbook. If a student is receiving dyslexia instruction within one of these courses, the instruction should still support mastery of the TEKS for the course with accommodations. 

If a student can master the TEKS in all other courses with accommodations but is determined to need modified content only in the Reading course, it is important to clarify why the student could not demonstrate mastery of the Reading TEKS using allowable supports. This distinction helps ensure that dyslexia instruction is accurately represented and does not unintentionally mischaracterize the student’s disability-related needs.

Another example to consider is Braille Reading and Writing. This innovative course is available for state elective credit toward graduation requirements and must be taught by a certified teacher of students with visual impairments (TVI). For a student who can master the TEKS in all other courses with accommodations, it is reasonable to expect that the student can master the essential knowledge and skills for Braille Reading and Writing with accommodations, as appropriate.

For additional information about specially designed instruction, including how to determine if a support should be considered an accommodation or a modification, see the technical assistance resources for Individualized Education Program Development and Understanding Accommodations and Modifications or reach out to the ARD/IEP Supports contact for your region.  

2.9 What are the considerations for calculating grade point average (GPA) and determining class rank in relation to students receiving special education services?   

Section 2.5(a) in the 2024 Minimum Standards for the AAR includes the following guidance related to class rank:

• Calculation and reporting of class rank is according to local board policy. However, if class rank is not calculated or reported, the AAR should indicate that and may do so using the letters “DNR” for Does Not Rank. Failure to report rank or DNR may result in a delay in the student’s college-acceptance consideration.  
• Class rank, course weights, grade point scale, and related topics are determined by local board policy.

New 19 TAC §74.3001 was proposed in April 2026 to reflect the requirements of SB 1191, 89th Texas Legislature, Regular Session, 2025, and identify minimum requirements for school districts when computing a student's high school GPA. The proposed new section would implement TEC §28.0252.  

For additional information related to these issues, see the FAQs on Report Cards and Transcripts For Students with Disabilities published by the Office for Civil Rights in the United States Department of Education.  

3.1 Are there any options for students to be exempt from taking the required EOC assessments? 

No. There are no exemptions to the testing requirements. While there is a State of Texas Assessments of Academic Readiness (STAAR) Medical Exclusion policy, this process is for district and campus accountability purposes and does not impact or eliminate a student’s testing requirements or graduation requirements. See the information available on the TEA website for more resources related to testing requirements, including options for students to take a substitute assessment for a required STAAR EOC assessment.  

For a student who meets the participation requirements for STAAR Alternate 2, the ARD committee may determine that the student meets the eligibility criteria for "No Authentic Academic Response (NAAR)” or a "Medical Exception,” and the student will not participate in the assessment. See question 3.3 for additional information about participation in the required EOC assessments through STAAR Alternate 2. 

3.2 During 10th grade, a student’s ARD committee determined that passing the STAAR EOC assessments for English I and English II was not required for graduation. The student is now in 12th grade and would like to retake the EOC assessments to attempt a passing score. May they be allowed to retake the EOC assessments? 

Yes. Required participation in academic content area assessments is outlined in 19 TAC §101.3021. Subsection (f) indicates that a student “may retake an EOC assessment under the TEC, §39.023(c), only if the student previously failed the EOC assessment. A student is not required to retake a course in order to be administered a retest of an EOC assessment.”  

The ARD committee will consider the options for assessment decisions included in 19 TAC §89.1070 and current information about the student to determine appropriate actions, including retaking any assessments as permitted under 19 TAC §101.3021. 

3.3 What are the unique graduation considerations for students who take STAAR Alternate 2? 

For a student who meets participation requirements for STAAR Alternate 2 (including eligibility for No Authentic Academic Response or Medical Exception), the ARD committee may consider the questions included in section 4 of this FAQ to establish an individualized graduation plan.  

A student who has taken the required EOC assessments through STAAR Alternate 2 or who was determined by their ARD committee to meet eligibility for No Authentic Academic Response or Medical Exception is considered to have met the assessment requirements for graduation. 

3.4 Can the ARD committee determine that passing an EOC assessment is not required for graduation before the student takes the assessment for the first time?

Yes. To determine whether satisfactory performance on the required EOC assessment instruments is required for graduation, the ARD committee will use relevant information about the student, such as evaluation reports, progress monitoring, results of previous STAAR assessments or benchmark testing, the impact of the student’s disability on curriculum access and test-taking, and skill gains in response to Accelerated Instruction or an Intensive Program of Instruction.  

For most students, these discussions will likely occur after attempting the EOC assessment. However, there are no specific requirements for the timing of this determination by the ARD committee.

3.5 What does “Participated in the Assessment Instrument” mean, as referenced in certain Diploma Type codes in the Texas Student Data System (TSDS) and Public Education Information Management System (PEIMS)?

To earn a diploma through the requirements specified by 19 TAC §89.1070(b)(2) or (b)(3), students must attempt the required STAAR EOC assessments at least one time. Absence on the day of the test administration would not qualify as participation in this context. At a minimum, a test instrument for each required STAAR EOC assessment must be submitted and a score received for the student to have “participated” in the assessment.  

Students who would not otherwise be required to take a STAAR EOC assessment are not eligible to attempt the assessment for the sake of meeting participation guidelines as specified for special education. For example, a student who moved into a Texas public school from another state or country and the credit previously earned for a course with a corresponding STAAR EOC assessment was accepted by the receiving district would not be required to take the STAAR EOC assessment. See the information available on the TEA website for more resources related to STAAR testing requirements. 

4.1 A student exited special education through dismissal or revocation of consent before graduating. Will they need to retake courses for credits they completed through modified curriculum? 

No. A student does not have to retake courses when the parent or adult student revokes consent. Students who have revoked consent for services are the same as students whose ARD committees dismissed them from special education. The curriculum requirements that were completed while they were receiving special education services, with supports as determined by an ARD committee, are not required to be completed again without special education services in place. 

4.2 After participating in the required EOC assessments, a student exited special education through dismissal or revocation of consent before graduating. Previously, an ARD committee determined that passing one or more EOC assessments was not required for graduation. After exiting special education, would this student need to pass the failed EOC assessment(s) in order to graduate? 

No. 19 TAC §101.3022(f)(2) reads, “A student dismissed from a special education program who achieved satisfactory performance on an alternate EOC assessment while enrolled in a special education program is not required to take and achieve satisfactory performance on the general EOC assessment to graduate. A student who took an EOC assessment while enrolled in a special education program is not required to retake and achieve satisfactory performance on the EOC assessment if the student's ARD committee determined that the student was not required to achieve satisfactory performance on the EOC assessment to graduate. A student dismissed from a special education program must achieve satisfactory performance on any remaining EOC assessments that the student is required to take. If the student fails to achieve satisfactory performance on no more than two of the remaining EOC assessments, the student is eligible for IGC review under TEC §28.0258, and is subject to the provisions of subsection (e) of this section.” 

4.3 For a student who met EOC assessment requirements through STAAR Alternate 2, must they take the STAAR EOC assessments if they are dismissed from (or consent is revoked for) special education services prior to graduating? 

No. In this circumstance, the student is not required to take the STAAR assessment or to retake the failed STAAR Alternate 2 EOC assessments if the student’s ARD committee previously determined the student was not required to achieve satisfactory performance to graduate. See the response to question 4.2 for additional information. 

5.1 What should the ARD committee consider when determining which condition under 19 TAC §89.1070(b)(3) is most applicable for a student who accessed the required TEKS through modified content? 

After meeting curriculum and assessment requirements for the Foundation High School Program with modified content and curriculum expectations as established in the IEP (with or without endorsements or distinguished level of achievement), the ARD committee must also consider which condition specified in subsection (b)(3) the student has met to award a diploma.  

The following recommendations may be used by ARD committees to consider which of the three conditions is most appropriate for the student. This list is intended as a starting point for ARD committee discussion and is not to be used as regulatory guidance.  

Pursuant to subsection (b)(3)(A) and “consistent with the IEP, the student has obtained full-time employment, based on the student's abilities and local employment opportunities, in addition to mastering sufficient self-help skills to enable the student to maintain the employment without direct and ongoing educational support of the local school district”  

• Is the student currently employed? If so, where and for how long?
• Is the student successful in their job(s)? How do you know?  
• Did the student require any support from special education to obtain or retain the job? If yes,  
  • Who will the student contact once they graduate from high school to access the same type of support to retain their job or obtain a new job?  
  • Is the student already in contact with this person/agency?
• “Full-time” is not clearly defined in this rule. The ARD committee can determine what this means “based on the student’s abilities and local employment opportunities.”

Pursuant to subsection (b)(3)(B) and “consistent with the IEP, the student has demonstrated mastery of specific employability skills and self-help skills that do not require direct ongoing educational support of the local school district”  

• What job experiences did the student have during high school?  
• If the student has never held a job or been competitively employed, what courses has the student taken that prepared them to obtain or retain a job (as identified in their postsecondary employment goal), including courses that provided instruction for self-help skills the student would need to be successful in that job (based on their individual disability-related needs in the present levels of academic achievement and functional performance)?  
• Was the student successful in these courses? How do you know (e.g., an IEP goal was developed, and the student mastered the goal)?  
• What job skills and self-help skills were addressed in the student’s IEP, such as the coordinated set of activities or annual IEP goals aligned to the student’s disability-related needs?  
• Do the results of transition assessments (including a functional vocational evaluation, as appropriate) show evidence of job skills and self-help skills?

Pursuant to subsection (b)(3)(C), “the student has access to services or other supports that are not within the legal responsibility of public education, including employment or postsecondary education established through transition planning”  

• What activities have been established for the student’s daily schedule after graduation, including opportunities for continued learning or employment?  
• Did the student require any support from special education to participate in learning, community, or daily activities?  
• If yes, who will provide the same type of support to obtain or maintain a new job, or participate in continued learning and daily activities after exit from public school?
• Is the student already receiving support from this person/agency? If not, how will supports be established prior to exit from public school? 

5.2 After a student has completed the required curriculum and assessments, must they graduate when they have met their IEP and one of the three conditions listed in 19 TAC §89.1070(b)(3)? 

For students who are eligible to continue enrollment to receive special education services beyond meeting curriculum and assessment requirements, the ARD committee will consider the student’s unique situation to determine next steps and document these decisions in the IEP. The recommendation for the student to graduate must not be made based solely on meeting one of the conditions listed in 19 TAC §89.1070(b)(3) or the availability of services through public agencies outside of the LEA. 

5.3 After completing curriculum and assessment requirements for graduation through 19 TAC §89.1070(b)(2) or (b)(3), the student wants to receive their diploma and exit public school. Can the school withhold their diploma until the student can show proof of readiness for meeting postsecondary goals? 

No. A student who has met the curriculum and assessment requirements for graduation is entitled to receive a diploma and exit public school. For students who are eligible to continue enrollment, the ARD committee will consider transition services, including courses of study, as specified by 19 TAC §89.1055(l)(2).  

If continued enrollment is recommended and the parent or adult student prefers to exit, the diploma must not be withheld. In such cases, it is recommended that the IEP include a statement describing the option to request additional services after receiving a diploma, as specified by 19 TAC §89.1070(j).  

See question 5.1 for ARD committee considerations to select the appropriate condition for students pursuing a diploma through subsection (b)(3) and consult with local legal counsel for questions about the appropriate provision of a free and appropriate education (FAPE) for individual students. 

5.4 What happens when a student reaches maximum age eligibility, and their ARD committee does not agree they have completed their IEP and/or met one of the three conditions in subsection 19 TAC §89.1070(b)(3)? 

After meeting curriculum and assessment requirements for graduation, a student is entitled to receive a diploma and exit public school. Careful consideration should be given to situations where there is disagreement about a student’s readiness to exit. See question 5.1 for considerations to select the appropriate condition in subsection 19 TAC §89.1070(b)(3).

In rare cases, it may be necessary for the ARD committee to consider the following questions to determine whether compensatory services are needed to ensure adequate provision of services. It is recommended that LEAs consult with local legal counsel, as appropriate.

• What transition services have been provided since the first IEP to be in effect by the student’s 14th birthday?
• What strengths, preferences, interests, and skills were identified through transition assessments? Did the selected assessments provide adequate information to establish appropriate transition services? If not, was a functional vocational evaluation as specified by 19 TAC §89.1055(k)(4) considered?  
• What are the student’s postsecondary goals related to education, employment, and independent living? What special education services were provided to support the student in reaching those goals?  
• What career planning was completed, such as participation in Career and Technical Education (CTE) and other work-based learning opportunities?  
• What connections to governmental agencies did the school facilitate, as specified by 19 TAC §89.1055(k)(5)?  
• What supplementary aids, services, curricula, and other opportunities to assist the student in developing decision-making skills were provided, as specified by 19 TAC §89.1055(k)(6)?  
• What supports and services to foster the student's independence and self-determination were provided, as specified by 19 TAC §89.1055(k)(6)?  
• What age-appropriate instructional environments, including community settings or environments that prepare the student for postsecondary education or training, competitive integrated employment, or independent living, in coordination with the student's transition goals and objectives, were considered as specified by 19 TAC §89.1055(n)(2)? What age-appropriate environments were accessed by the student as part of their schedule of services after meeting curriculum and assessment requirements for graduation? 

5.5 Do students who meet graduation requirements described in 19 TAC §89.1070(b)(2) need to meet one of the three conditions specified by subsection (b)(3) of this rule? 

No. While students who are awarded a diploma through meeting the requirements specified by subsection (b)(2) are eligible to continue enrollment in public school to receive special education services aligned to their unique situation, no additional conditions are included in this subsection. The ARD committee will consider information about the student, such as the results of transition assessments, their postsecondary goals, skills or supports needed to be successful in postsecondary environments, and disability-related needs for postsecondary assessments (such as college entrance exams) to determine appropriate services in the least restrictive environment. 

5.6 What is the expectation for the student to “complete their IEP” as described in 19 TAC §89.1070(b)(3)? 

When a student pursuing graduation through subsection (b)(3) has completed the curriculum and assessment requirements for graduation, the ARD committee will review their IEP to confirm that annual IEP goals have been met and services have been provided.  

See questions 5.1 and 5.4 for ARD committee considerations related to awarding a diploma through subsection (b)(3). 

6.1 What are the options for students to participate in commencement ceremonies if they will be continuing enrollment rather than exiting public school? 

As described in TEC §28.025(d), a school district may issue a “certificate of coursework completion” to a student who completes the curriculum requirements for graduation, but who does not meet EOC assessment requirements.  

Subsection (f) of this statute specifies that a school district shall issue a “certificate of attendance” to a student who receives special education services and has completed four years of high school but will continue enrollment to complete their IEP. Students receiving a certificate of attendance may participate in only one graduation ceremony and may receive a diploma upon meeting the requirements specified in 19 TAC §89.1070.  

Note that 19 TAC §89.1070(e) specifies that a student who reaches maximum age eligibility but has not met the requirements for graduation may receive a certificate of attendance. See question 5.4 in this FAQ for recommended ARD considerations for a student who has reached maximum age eligibility and completed curriculum and assessment requirements through 19 TAC §89.1070(b)(3). See question 9.3 in this FAQ for use of the IEP Continuer indicator for students who receive a certificate of attendance. 

6.2 If a student violated the code of conduct that would otherwise restrict them from participating in commencement ceremonies, must they be allowed to attend if they will be receiving a certificate of attendance? 

Disciplinary decisions, including restriction from commencement ceremonies for students receiving either a certificate or a diploma, will consider local LEA policy related to TEC §37.001. See subsection (b-1) of this statute for provisions related to students receiving special education services.  

In cases where a student with a disability will be restricted from participating in commencement ceremonies due to conduct violations, it is recommended that school administrators consider the unique circumstances and the student’s disability-related needs. See the Behavior Supports and Guidance for Students with Disabilities to learn more about state guidance related to this topic. 

6.3 Can a student receiving special education services participate in commencement ceremonies with their cohort if they are pursuing a diploma through 19 TAC §89.1070(b)(1) and have not completed credit requirements? 

When a student pursuing graduation through 19 TAC §89.1070(b)(1) reaches the end of their 4th year of high school without completing the curriculum requirements for a diploma, the LEA should consider the unique circumstances to determine whether it is appropriate for the student to participate in commencement ceremonies. It may be helpful for school teams to review local board policy related to commencement ceremonies and consult with legal counsel for specific situations. Further, as noted above in 6.1, per TEC 28.025(f),  

• “A school district shall issue a certificate of attendance to a student who receives special education services under Subchapter A, Chapter 29, and who has completed four years of high school but has not completed the student's individualized education program. A school district shall allow a student who receives a certificate to participate in a graduation ceremony with students receiving high school diplomas. A student may participate in only one graduation ceremony under this subsection. This subsection does not preclude a student from receiving a diploma under Subsection (c)(2).” 

7.1 Can a student return to request additional services after graduating and receiving a diploma? 

As specified in 19 TAC §89.1070(j), students who graduate and receive a diploma according to subsections (b)(2) or (b)(3)(A), (B), or (C) of this section are entitled to an ARD committee meeting to determine needed special education services upon the request of the student or parent to resume services, as long as the student meets the age eligibility requirements.  

Technical assistance related to Child Find and Evaluation may be helpful for ARD committees and school teams. Additionally, the lists of considerations in questions 5.1 and 5.4 of this FAQ may be helpful for ARD committees to focus on the transition planning needs of a student who returns to request additional services. 

7.2 If a student is determined eligible and re-enrolls after receiving a diploma, will funding for the services provided to the student be the same as if they had continued enrollment (without graduating and exiting public school)? 

Yes. The table in section 3.2.3 in the Student Attendance Accounting Handbook (SAAH) lists “a student with a disability who graduated by meeting the requirements of 19 TAC §89.1070(b)(2) or (3)(A), (B), or (C) as determined by an admission, review, and dismissal (ARD) committee and who is still in need of special education services” as eligible for Foundation School Program benefits.  

Additionally, section 3.2.2.4 of the SAAH clarifies that “students who are continuing enrollment to receive special education services; or students who have returned to school to receive special education services after receiving a diploma” are exceptions to the rule for funding eligibility of students who have met all graduation requirements and thus are eligible to continue to generate Average Daily Attendance (ADA) for funding purposes. 

7.3 A student who was home-schooled (or attended private school) until age 18 enrolled in our district to request special education services in our 18+ program. Can the ARD committee award a diploma? 

Coursework completed from an accredited private school recognized by Texas Private School Accreditation Commission (TEPSAC) or International Association for Learner Driven Schools (IALDS) may be transferred to Texas public schools. A student who graduated from an accredited private school and is determined by an ARD committee to meet eligibility to resume services in accordance with 19 TAC §89.1070(k) may be reenrolled the same as a student who graduated from public schools through 19 TAC §89.1070(b)(2) or (b)(3).  

Coursework completed through an unaccredited private school or through homeschooling should be evaluated by the LEA to assess the mastery level of courses that students have taken. It is recommended that ARD committees start by exploring local policies and procedures related to evaluating courses/curriculum completed through home schooling or unaccredited private schools. The following state guidance should be followed, as appropriate:

• Home Schooling: This page indicates that “The State of Texas does not award a diploma to students that are home schooled. Home-schooled students can enter public school at any time but should be aware that most districts have policies and procedures in place to assess the mastery level of courses that students in home schools have taken. The results of the assessment may be used for grade placement or award of credit or both. Students transferring from home schools should be afforded the same treatment as students transferring from unaccredited private schools.”  
• Additionally, section 1.7(d) of the 2024 Minimum Standards for the AAR includes guidance for evaluating transferred credit from other Texas public schools and from non-Texas public schools.  
• The rules for students to earn Credit by Exam (CBE) are outlined in 19 TAC §74.24. For students who need modifications to content or an alternate assessment, there is no specific guidance. 

7.4 A student received a diploma outside of Texas before reaching age 22. They enrolled in our district, and the ARD committee agrees that our 18+ program is the least restrictive environment for the student. Does the student need to meet Texas graduation requirements to receive special education services in an 18+ setting? 

Section 3.2.2.7 of the SAAH clarifies funding eligibility for students who received special education services and were awarded a diploma in another state or outside of the United States.  

“A student may be entitled to receive special education services through age 21 if the student has a disability and the district determines the student would have met the Texas criteria to continue the receipt of special education services after having been awarded a diploma in another state or outside of the United States. The district must evaluate the transcript carefully, and the student must still meet eligibility requirements for funding.”

Section 4.3.3 of the handbook describes enrollment procedures for a student who transfers, including verification that the student had an IEP in effect in the previous district. School teams may consider using the Students with Disabilities Who Transfer In-State and Out-of-State Quick Guide for support to understand the federal and state requirements.

8.1 Is the SOP required for all students receiving special education services? 

Yes. Any student who will be exiting public school through meeting the graduation requirements specified by 19 TAC §89.1070(b)(1)-(3) or exceeding maximum age eligibility must be provided an SOP. 

8.2 What must be included in the SOP? 

As specified under IDEA through 34 CFR §300.305(e), the SOP must include:  

• A summary of the child’s academic achievement and functional performance; and
• Recommendations on how to assist the student in meeting their postsecondary goals.  

As specified by 19 TAC §89.1070(g), the SOP must also consider, as appropriate:  

• The views of the parent and student; and  
• Written recommendations from adult service agencies on how to assist the student in meeting postsecondary goals.  

See question 8.3 for additional SOP requirements for certain students 

8.3 When is the reevaluation process required as part of the SOP? 

There are two answers to this question. While all students receiving special education services who exit public school through graduation or exceeding age eligibility must receive an SOP, not all SOPs must include an evaluation.  

1. 1. The reevaluation process is not required for students who have met graduation requirements specified by 19 TAC 89.1070(b)(1). The reevaluation process is also not required for students who have exceeded maximum age eligibility without meeting graduation requirements.  
2. 2. The reevaluation process is required for students who have met graduation requirements specified by 19 TAC 89.1070(b)(2) or (b)(3). These students are entitled to an evaluation as described by 34 CFR §300.305(e):  
   • (1) Except as provided in paragraph (e)(2) of this section, a public agency must evaluate a child with a disability in accordance with §§300.304 through 300.311 before determining that the child is no longer a child with a disability.  
   • (2) The evaluation described in paragraph (e)(1) of this section is not required before the termination of a child’s eligibility under this part due to graduation from secondary school with a regular diploma, or due to exceeding the age eligibility for FAPE under State law.  
   • (3) For a child whose eligibility terminates under circumstances described in paragraph (e)(2) of this section, a public agency must provide the child with a summary of the child’s academic achievement and functional performance, which shall include recommendations on how to assist the child in meeting the child’s postsecondary goals.  

The requirements for the SOP are described in 19 TAC 89.1070(f) and (g). For additional information and guidance related to the reevaluation process, see the Review of Existing Evaluation Data and Reevaluation: Question and Answer Document. 

8.4 For a student who is “entitled to an evaluation” as part of their SOP, may the REED process be used if the FIE is current? 

Yes. If the student is not due for a three-year (triennial) reevaluation, the guidance for Review of Existing Evaluation Data (REED) and Reevaluation may be used to determine appropriate evaluation for the student’s SOP.  

It is worth noting that while students who will be exiting public school through meeting the graduation requirements specified by 19 TAC §89.1070(b)(1) or exceeding maximum age eligibility are not entitled to an evaluation, it is recommended that appropriate reevaluation is considered for each student. 

8.5 Can the SOP be created and reviewed outside of an ARD meeting and provided to the student in the year in which they graduate, either before or after their annual ARD meeting?

There are no requirements related to reviewing the SOP in an ARD meeting. As a matter of practice, it likely makes sense in most cases to review it as part of the annual ARD for a student who is on track to graduate or reach maximum age eligibility within the IEP year, but there are no specific requirements surrounding this issue.  

It is left to the LEA to develop practices that meet the needs of each student to receive the information in ways that allow them to utilize their SOP beyond exit from public school. The LEA should also ensure the results of decisions related to the SOP are documented in the IEP.

8.6 Is there a standard template or format for the SOP?

No. While there is not a standardized format required for the SOP, there are model forms that LEAs may consider when developing their local resources for SOP. For LEAs that use the SOP form(s) included in their IEP software, the LEA should contact the software vendor, as appropriate, if it is determined that changes are needed.  

The following examples of SOP templates may be helpful for LEAs in reviewing their local resources for SOP. Note that these examples do not include the additional Texas requirements for SOP specified by 19 TAC §89.1070(g). See questions 8.2 and 8.3 for the federal and state-required elements to be included in the SOP.  

• Transition Tennessee  
• National Technical Assistance Center for Transition: The Collaborative (NTACT:C)  

9.1 What is TSDS? 

The Texas Student Data System (TSDS) is a statewide system for collecting and reporting education data for publicly funded schools in the state of Texas. The Texas Education Data Standards (TEDS) is a collection of data standards for transferring data to TSDS. The Texas Web-Enabled Data Standards (TWEDS) is a web-based version of TEDS. The TWEDS describe the data reporting requirements, responsibilities, and specifications.  

For questions about local procedures related to TSDS PEIMS data submissions, connect with the PEIMS Coordinator for your LEA. For support to submit accurate and valid data, contact the ESC TSDS PEIMS Champion for your region.   

9.2 What references in the TWEDS are directly related to submitting graduation data for students receiving special education services? 

The following list includes a highlighted selection of TWEDS references.  

Note: When accessing the TWEDS, select the correct school year in the upper right corner of the page. The links in the following list point to the School Year 2025-26 TWEDS.

• CourseCode (Data Element ID E3071) refers to a unique alphanumeric code assigned to a course. The list of CourseCodes (including courses eligible for state high school credit, local credit, and CTE) can be found on the References tab in TWEDS. The Course Code Table is available at the Course Codes link under the “References” tab.
• DiplomaType (Data Element ID 0806) identifies how a student met graduation requirements, including students receiving special education services who were awarded a diploma by meeting requirements specified by 19 TAC §89.1070. Descriptor codes are defined in TWEDS Table C062.  
  • Descriptor code 34 is used for all students who meet the description, including students who meet requirements specified by 19 TAC §89.1070(b)(1)  
  • Descriptor code 35 should be used for students receiving special education services at the time of graduation who meet requirements specified by 19 TAC §89.1070(b)(2)  
  • Descriptor code 54 should be used for students receiving special education services at the time of graduation who meet requirements specified by 19 TAC §89.1070(b)(3)(A)  
  • Descriptor code 55 should be used for students receiving special education services at the time of graduation who meet requirements specified by 19 TAC §89.1070(b)(3)(B)  
  • Descriptor code 56 should be used for students receiving special education services at the time of graduation who meet requirements specified by 19 TAC §89.1070(b)(3)(C)  
• DistinguishedLevelAchivementGraduate (Data Element ID E3089) indicates the student has successfully completed the distinguished level of achievement as provided by TEC §28.025 (b-15) or TEC §28.0253, including students who meet requirements specified by 19 TAC §89.1070. This data element is available under the Data Components tab.
• EndorsementCompleted (Data Element ID E3021) indicates the student has successfully completed a Foundation High School Program to earn a STEM, Business and Industry, Public Services, Arts and Humanities, or Multi-Disciplinary Studies endorsement. The list of EndorsementCompleted descriptors can be found in Table C332.
• ExitWithdrawType (Data Element ID E1001) identifies the reason a student (1) exited from the local education agency (LEA), or (2) did not exit the LEA but had a CalendarCode, ADAEligibility, StudentAttribution, or EntryGradeLevel change during one school year. The list of ExitWithdrawType descriptors can be found in Table C162.
• IEP Continuer is a student characteristic that indicates whether a student meets eligibility to continue enrollment beyond completion of graduation requirements. Additional information can be found in DR27 of the StudentEducationalOrganizationAssociation Entity. 

9.3 What are the unique considerations for reporting students who will continue enrollment to receive special education services after completing graduation requirements? 

For purposes of understanding data reporting, students who are eligible to continue enrollment after meeting graduation requirements (in accordance with 19 TAC §89.1035 and §89.1070) will match one of the following descriptions at the end of the school year:

• Graduate: The student will exit public school with a diploma awarded through 19 TAC §89.1070(b)(2) or (b)(3). An IEP has not been developed for the following school year.  
• IEP Continuer: The student has completed graduation requirements, has not graduated with a diploma previously, and will continue enrollment to receive special education services. An IEP has been developed for the following school year.
• Returner: The student graduated previously and an ARD committee determined needed services in accordance with 19 TAC §89.1070(k).
• Not enrolled: The student graduated or dropped out in a prior year, has not met maximum age eligibility, and has not resumed services.

Beginning in the 2025-2026 school year, Leaver and graduate data for the 2025-2026 school year will be reported in the PEIMS Summer and Extended Year Submissions. The change to the leaver and graduate collection will allow TEA to meet the federal reporting deadlines for certain submissions.

A student who meets the description for IEP Continuer will be reported with the “IEP Continuer” student characteristic in the PEIMS Summer submission. TEA will confirm the student’s enrollment the following school year through the PEIMS Fall snapshot, and the student will again be reported with the “IEP Continuer” student characteristic in PEIMS Fall submission. Other data will be submitted as appropriate for a student in any grade (for example, instructional setting).  

A student who meets the description for Returner has already been reported as a graduate in a prior year. The LEA should follow procedures described in section 4.3.3 of the SAAH: Enrollment Procedures for a Student Who Is New to Your District but Was Previously Receiving Special Education Services. The IEP that was in place when the student graduated, including evaluation data, may be reviewed by the ARD committee to determine the appropriate next steps. An ExitWithdrawType descriptor will not be submitted when this student exits again after re-enrolling. The student can be considered a “mover” in terms of data submissions upon exit after re-enrolling. During the TEA leaver reconciliation process, this student will be identified as a previous graduate and will not be classified as a dropout or underreported. Additionally, the IEP Continuer indicator will not be submitted. Otherwise, all data will be submitted as appropriate for a student in any grade (for example, instructional setting).

A student who meets the description for Graduate will be reported in PEIMS Summer submission with ExitWithdrawType 01 (Graduated From a Campus In This District Or Charter) and the appropriate DiplomaType. This includes students who were reported as IEP Continuers in previous years and are graduating with a diploma in the current school year. Other descriptors will also be reported based on the student’s academic achievement.  

A student who was reported in the PEIMS Summer submission as an IEP Continuer or as a graduate but changed their mind before the end of the School Start Window may be reported in the PEIMS Extended Year submission with their updated status. For example, a student was reported as an IEP Continuer in the summer submission and they do not show up for school in August. The school contacts the student, and it is determined appropriate to hold an ARD committee meeting to finalize graduation. In this case, the student can be reported with an ExitWithdrawType of 01 – Graduated in the PEIMS Extended Year submission or resubmission.  

To ensure accurate and valid data is submitted, special education staff are encouraged to contact the PEIMS staff for their LEA or the TSDS Champion for their ESC.  

9.4 Should the IEP Continuer indicator be submitted for each school year a student is enrolled beyond the 4th year? For example, a student completed graduation requirements and continued enrollment to receive 18+ services. They remained enrolled for 3 more years before receiving a diploma and exiting. Should the IEP Continuer student characteristic be submitted for the 2nd and 3rd year of 18+ services? 

Yes. See question 9.3 for additional information about reporting students as IEP Continuers.  

9.5 What Diploma Type code may be used for a student who revoked consent or was dismissed from special education after earning credits through modified content and curriculum, meeting state assessment requirements through alternate assessments, or an ARD committee determination that passing was not required for more than would otherwise be allowable? 

Code 34 may be used for students who are not receiving special education services at the time of graduation, including for students who revoked consent or were dismissed from special education, as well as for students receiving special education services who are awarded a diploma through 19 TAC §89.1070(b)(1).  

Codes 35, 54, 55, and 56 may be used only for students who are receiving special education services at the time of graduation. It is important to note that DiplomaType codes for students receiving special education services are selected based on which condition described by 19 TAC §89.1070(b) was met, as determined by their ARD committee. These codes do not reflect the location of services, such as self-contained settings, where the student received instruction. 

9.6 What CourseCode should be used for a student who received modified content to access the curriculum? 

With the exception of course codes aligned to STAAR Alternate-2 EOC assessments, the standard course code should be used for all students, regardless of the adaptations to course content. Codes related to course completion should be selected based on the student’s access to content, not the location of instruction.  

For example, a student who meets participation requirements for STAAR Alternate 2 attends classes in a general education setting for English I, receiving modifications and supports as described in their IEP (including prerequisite skills aligned to the TEKS for English I). In this case, the unique code 03220107 would be entered for the course code. This same student also takes World Geography in a self-contained special education setting. The course code used for their World Geography class will be the standard code 03320100 because no EOC assessment exists for that course.  

For additional guidance, see section 2.1(c) of the Minimum Standards for the AAR:

• “For students receiving special education and related services, no substitutions are allowed for courses required for high school graduation, except as indicated in the graduation requirements under 19 TAC Chapter 74. Students enrolled in a high school course required for graduation must access the curriculum for that course as specified in TEKS (19 TAC §§110– 128) or state-approved innovative courses, with specially designed instruction in the appropriate settings as determined by the student’s ARD committee. See Appendix B, Part B, for detailed instructions for reporting TSDS PEIMS course codes and titles in TSDS PEIMS for students receiving special education and related services. See subsection 2.1(h) for information about local-credit courses.”

See question 2.6 for additional information about course substitutions.  

It is important to note that the Course Entity represents the organization of subject matter and related learning experiences provided for the instruction of students on a regular or systematic basis. This is the course catalog of all courses offered at each school. The CourseIdentificationCode common type represents a standard code that identifies the organization of subject matter and related learning experiences provided for the instruction of students. 

9.7 What should be entered on the AAR for a student whose ARD committee determined that passing the EOC assessment was not required for graduation?

For students whose ARD committees determined that passing one or more EOC assessments is not required for graduation, the assessment performance level entered on the AAR should align with the table described in section 2.6(a)(5) of the 2024 Minimum Standards for the Academic Achievement Record.  

For example, if a student did not meet performance standards for the Biology EOC assessment and their ARD committee determined passing was not required for graduation, the AAR would reflect a “DidNotMeet” performance for that assessment. If applicable, the transcript may also include a date in a “date met” field to indicate that the assessment requirement was met through ARD committee determination. Additionally, the indication of a graduation date and inclusion of an appropriate graduation program seal indicate whether a student has completed the assessment requirements (and curriculum requirements) for graduation.

As specified by 19 TAC 101.3022(f)(1), a student receiving special education services is not subject to the requirements for IGC. Therefore, the guidance in section 2.6(c) of the 2024 Minimum Standards for the AAR does not apply to a student whose ARD committee determined passing was not required for one or more EOC assessments. 

• Academic Achievement Record (Minimum Standards for the AAR)  
• Career and Technical Education (CTE) and Special Education FAQ  
• Curriculum Standards  
• Graduation Toolkit (available on the TEA Brochures page)
• State Graduation Requirements  
• Student Assessment (including Assessments for Special Populations)  
• Student Attendance Accounting Handbook (SAAH)
• Texas Transition and Employment Guide