Minimally, local graduation policies must include statewide graduation requirements – but LEAs are not required to offer every option identified in legislation (e.g., not all schools offer International Baccalaureate coursework or CTE Concentrator Programs).

Conversely, LEAs may expand upon statewide requirements with local board approval. By way of example, an LEA might require:

• Options beyond those delineated in statute or PDE guidance be met
• More rigorous options be met (such as Proficiency or better on all three Keystone Exams)

However, local requirements may only supplement, not supplant, statewide graduation requirements. 

LEAs are encouraged to work with their solicitors to ensure their local high school graduation policies comply with Section 121 of the Pennsylvania Public School Code (24 P.S. § 1-121) and Title 22, Chapter 4 of the Pennsylvania Code.

No later than the beginning of each school year, every LEA must publish on its publicly accessible website its board-approved high school graduation requirements (including statewide requirements as well as any additional requirements established by the LEA). Education stakeholders, including staff and community partners, should be apprised of expectations regarding their roles in assisting students to graduate prepared for post-secondary success.

No later than the beginning of the school year in which a student may start to satisfy graduation requirements, an LEA should notify the student and their parent(s) or guardian(s) of the requirements and engage them in an ongoing, reciprocal dialog designed to support the student in graduating on time. Communications should allow for student voice when considering which pathway options best exemplify their aspirations and abilities and should identify potential barriers to student participation or circumstances that might suggest other diploma options.

LEAs should have robust systems and processes for ensuring students stay on track and should actively maintain a team, including school leaders as well as educators and counselors, who can support those efforts.

The team should closely monitor progress toward meeting graduation requirements so that interventions or alternative options may be offered before a student is identified as at risk of not graduating. Frequent conferences provide the opportunity to adjust a student’s path based upon not only academic performance but also evolving student interests and goals; parents or guardians should be notified of a student’s off-track status and be engaged in assisting the student to re-orient and graduate on time.

The team should also regularly evaluate whether there are sufficient and appropriate opportunities for the student to graduate and consider how the LEA might enhance or expand offerings to better meet student needs. For example:

• Are currently available pathway options timely and easily accessible, with participation barriers (such as scheduling, transportation, fees, or language) removed?
• Are currently available pathway options aligned to students’ abilities and interests?
• Might additional student experiences or evidence (such as a service-learning project) be embedded within existing curricular or extra-curricular offerings?
• What would be needed to offer new options (such as work-based learning experiences through community partnerships)?

Between October 1 and December 1, each LEA must submit a Grad Report annually via the Future Ready Comprehensive Planning Portal (FRCPP) indicating the aggregate numbers of students graduating by pathway/option and by exception (e.g., waiver, IEP).

The Grad Report should reflect students eligible to graduate during the prior school year: i.e., students completing their academic requirements prior to October 1. Eligible to graduate refers to LEA-enrolled students (including outplaced students) who were on-track to graduate by the end of the prior school year, students in Grade 12, students identified as seniors based upon credits earned, and multi-year seniors. This number should include dropouts – but not students who transferred out of the LEA.

Students with IEPs who will graduate via successful completion of their special education program or who will reach age 21 without having completed their academic requirements should be reported as eligible to graduate only for the year in which they will either be issued a diploma or based on age are no longer eligible to participate in the program (whichever comes first).

For the Proficiency Pathway (numeric and non-numeric), Composite Pathway (2-score and 3-score), or the CTE Concentrator Pathway, LEAs will report the total number of students who graduated via the pathway.

For the Alternative Assessment Pathway or the Evidence-Based Pathway, LEAs will report the total number of students who graduated via the pathway and, by criterion, the number of students who utilized that criterion to satisfy the pathway. Where a student completes more criteria than required for the pathway, the LEA may select which to report for that student.

For the Alternative Assessment Pathway, the subtotals will equal the total number of students satisfying the pathway because students are only required to meet one criterion.

For the Evidence-Based Pathway:

• Section One subtotals must equal or exceed the total number of students reported as graduating via this pathway because students are required to meet at least one of the criteria listed in this section.
• The Sections One and Section Two combined subtotals will never exceed three times the total number of students satisfying the pathway; however, the combined subtotals might equal an amount less than three times the total number of students satisfying the pathway. LEAs report the number of students utilizing the criteria - not the number of artifacts/evidence produced.

For Waivers, LEAs will report by reason the number of waivers granted to students in Grade 12 or who experience an extenuating circumstance: serious illness, death in the student’s immediate family, family emergency, frequent school transfers, transfer from an out-of-state school in Grade 12, or pandemic (for the graduating classes of 2023, 2024, and 2025 only).

For reporting students with disabilities, LEAs will report the number of students who graduated based upon successful completion of their Special Education Program.

For students who experience education instability (Act 1 of 2022 ) and are unable to meet local graduation requirements but meet minimal statewide graduation requirements, LEAs will report the number of students for whom they are requesting Keystone Diplomas. NOTE: Students who graduate via a Keystone Diploma are reported as non-graduates for the LEA.

Most students with disabilities should be able to graduate via one of the five pathways. When a student’s Individualized Education Program (IEP) team determines the pathways are not appropriate, it is their responsibility to determine how successful completion is defined based on completion of IEP goals in accordance with Pa. Code.

It is important to note that Pa. Act 158 of 2018 did not alter the existing provision under Chapter 4.24 (High School Graduation Requirements). That provision was designed to accommodate students whose special education programs, by design, would not meet the statewide graduation requirements:

“Children with disabilities who satisfactorily complete a special education program developed by an Individualized Education Program team under the Individuals with Disabilities Education Act and this part shall be granted and issued a regular high school diploma by the school district of residence, charter school (including cyber charter school) or AVTS, if applicable. This subsection applies if the special education program of a child with a disability does not otherwise meet the requirements of this chapter.” [Title 22 Chapter 4.24(d)]

NOTE: Students who graduate in this manner are not considered to have been granted waivers under Act 158.

EL students who do not participate in one or more Keystone Exams or who do not qualify for non-numeric Proficient scores may meet graduation requirements utilizing pathways other than those reliant on Keystone Exams or may graduate via a waiver. However, students who do not participate in one or more Keystone Exams or who do not qualify for non-numeric Proficient scores must meet locally established grade-based requirements for academic content associated with each Keystone Exam in which they did not have a Proficient or Advanced.

When satisfying the Alternative Assessment or Evidence-Based pathway, ELs may utilize evidence attained in a foreign language or from outside the United States provided it meets both the definition and parameters of the criterion. By way of example:

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

Act 1 of 2022 (Act 1) was enacted to promote timely high school graduation and to facilitate equal access to academics and extracurricular activities and the removal of systemic barriers for students who experience “education instability”, defined by the legislation as one or more LEA changes due to homelessness, foster care, adjudication, or involvement with the juvenile justice system.

If a student identified as experiencing education instability is not eligible to graduate on time, the LEA may collaborate with the chief school administrator of the sending school to determine whether the student meets the local graduation requirements of the prior entity. Regardless of which school entity confers the diploma, the LEA in which the student is enrolled at the time of graduation shall report the student as part of its graduating class (FRCPP Grad Report) and graduation cohort (PIMS).

If the student is unable to meet local graduation requirements at either their current or prior school entities despite the LEA’s exhaustive measures, the LEA may request a PDE-issued Keystone Diploma; however, a student granted a Keystone Diploma will be considered a non-graduate at the local level – reducing the LEA’s Grad Rate in the FRPA Index.

NOTE: A student requesting a Keystone Diploma minimally must meet locally established, grade-based requirements for each Keystone content area in which the student does not have a numeric or non-numeric Proficient or Advanced.

The student must meet or exceed the established score of Silver Level on the ACT WorkKeys NCRC.

The ACT WorkKeys National Career Readiness Certificate (NCRC) is a portable, evidence-based credential earned by completing the following three WorkKeys assessments: Applied Math, Graphic Literacy, and Workplace Documents. Silver Level signifies that an individual has scored at least a Level 4 on each of the three ACT Workplace assessments.

The student must meet or exceed the established score of 630 on any SAT Subject Test.

NOTE: While the College Board no longer offers the SAT Subject Tests, students who have previously taken the test(s) may use the score(s) as evidence, provided that they have met the established score.

The student must score a 3 or higher on any Advanced Placement (AP) Exam consistent with the student’s goals and career plan.

The student must score a 3 or higher on any International Baccalaureate (IB) Programme Exam consistent with the student’s goals and career plan.

The student must earn dual credit (both high school credit and postsecondary credit) on any LEA-approved concurrent enrollment course consistent with the student’s goals and career plan.

A concurrent enrollment course is defined in legislation as “a course in which a secondary student is enrolled and, upon successful completion of which, both high school and postsecondary credit are earned”. The course must be a credit-bearing, non-remedial college-level course.

*NOTE: Where an additional fee may be required for the credit to appear on a postsecondary transcript, the LEA/student does not need to assume the cost in order to meet statewide high school graduation requirements.

The student must earn postsecondary credit on any college-level course consistent with the student’s goals and career plan. The course must be an LEA-approved, credit-bearing, non-remedial college-level course.

A postsecondary course is defined in legislation “as a course in which a secondary student is enrolled and, upon successful completion, postsecondary credit is earned”; therefore, the student may not necessarily be awarded high school credit.

The student must earn an industry-recognized credential, consistent with the student’s goals and career plan, as identified in PDE guidance documents for Career & Technical Education Programs or for non-CTE Career Readiness Programs (see Guidance for Identifying and Reporting Industry-Based Learning Credentials for Non-CTE Students).

NOTE: Per Pa. Act 55 of 2022, IRCs attained by a student shall be included on the student's transcript. An earned credential that has expired may be used to meet a pathway criterion and should be included on the student transcript. Additionally, an earned credential not attained in the school setting may be used to meet a pathway criterion and should be included on the student transcript if certified by the LEA as meeting PDE guidance for minimal non-technical requirements.

The student must demonstrate acceptance into an accredited other-than-4-year non-profit institution of higher education by providing:

- A letter of admittance confirming non-conditional acceptance* into an explicit other-than 4-year program
OR
- Written confirmation of general admittance and evidence of the ability to enroll in college-level coursework through one of the following:

- Placement test results (or equivalent criteria established by the IHE) indicating the student may enroll in college-level coursework in every subject area
or
- College registration confirmation of enrollment in college-level courses (non-remedial) only
or
- A locally-established graduate profile recommended minimally to consist of:

•   GPA of 2.6 (or C average) or higher
•   Attendance rate of 80% in grades 11 and 12
•   Successful completion in an advanced** secondary-level math course other than the course leading to the Algebra I Keystone Exam
•   Successful completion in an advanced** secondary-level English course other than the course leading to the Literature Keystone Exam

* Non-conditional acceptance explicitly waives any pre-requisites for non-college level, non-credit, or remedial coursework.

** Determined by the LEA to be of equal or greater rigor than the Keystone-associated course.

The student must earn either a scaled (numeric) score of 1500 or higher on a Keystone Exam or qualify for a non-numeric score of Proficient (See Numeric & Non-Numeric Proficiency under the Keystone Academic Content section of this document).

The student must successfully complete a service-learning project of sufficient duration and intensity to address identified community needs and meet a specified project learning goal(s). While LEAs may use discretion, a minimum of 10 hours is recommended.

A service-learning project may be embedded within a course, including one that might count as another piece of evidence (e.g., a CHS leadership course), provided the service-learning project is evaluated as a separate artifact and includes a practical (not just theoretical) application resulting in a community benefit. Service-learning projects completed as part of local graduation requirements may be used to meet this criterion.

A project proposal must be submitted to the school official for pre-approval and must be supervised and assessed by an adult with successful completion verified in writing by the adult supervisor. LEAs should enter into written understandings with hosting entities to identify the supervisor and establish the terms of the supervision of the students in the program. Background/clearance checks for those adults responsible for supervising students should comply with board policy as well as state and federal regulations.

Proposals should include a project description, learning goal(s), timeline, number of service hours, the project’s contribution to the community, and the sponsoring organization. 

NOTE: The CCR and Graduation – Student Evidence Comparison (provided in the Resources section of the toolkit site) highlights similarities/differences in student service-learning projects for College & Career Readiness (as reflected in the Future Ready PA Index) and the Pennsylvania Pathways to Graduation.

The student must successfully complete an internship, externship, or cooperative education program, as evidenced by locally established documentation.

• Internships place students at a workplace for a defined period to participate in and observe work within a given industry, with specified learning objectives and assessment of student performance.
• Externships often occur during non-school hours and mainly explore interests as opposed to internships, which act as the bridge from student life to professional life.
• Cooperative Education programs alternate or coordinate high school studies with jobs in fields related to students’ academic or career objectives.

Internship, externship, or cooperative education programs must comply with related federal and state laws and regulations. Additionally, LEAs should enter into written understandings with hosting entities to identify the supervisor and establish the terms of the supervision of the students in the program. Background/clearance checks for those adults responsible for supervising students should comply with board policy as well as state and federal regulations.

NOTE: The CCR and Graduation – Student Evidence Comparison (provided in the Resources section of the toolkit site) highlights similarities/differences in student work-based learning experiences for College & Career Readiness (as reflected in the Future Ready PA Index) and the Pennsylvania Pathways to Graduation.

Regardless of postsecondary intent and for the purpose of meeting this criterion only, the student must comply with NCAA’s Division II core course requirements for college-bound student athletes. Students are not required to register with the NCAA or meet other NCAA eligibility requirements – they are only required to earn the 16 NCAA-approved core-course credits and to attain a core-course GPA of 2.0 or the equivalent on an alternate grading scale in order to satisfy this graduation requirement.

NOTE: If the student is interested in competing at an NCAA Division II or Division I school as a student athlete, the student will be required by the NCAA to meet a higher GPA and additional eligibility standards.

The student must provide documentation guaranteeing sustained full-time employment:
- averaging at least 30 hours per week, or
- 130 hours per month, or
- multiple jobs that, in aggregate, are reasonably commensurate with full-time work.

Work that is timebound or terminates with project completion (such as freelance work) may be considered sustained, providing the LEA deems likely a continuation or recurrence of work in a manner consistent with ongoing employment. It is at the LEA’s discretion as to whether salary is a factor in determining full-time employment status.

Full-time employment should be scheduled to commence no later than 30 calendar days after the date of high school graduation (i.e., date of receipt of diploma or 30 calendar days after student has fulfilled academic requirements for graduation). If cause for a delay in employment is determined to be reasonable by the LEA, full- time employment may commence up to 90 calendar days after graduation.

In lieu of full-time employment, the student may provide verification of military enlistment (to include enrollment in a Delayed Enlistment Program which permits a delay of up to 365 days).