Charter Public Schools are Reminded to Adopt Competency Determination Policies and Review Local Graduation Requirements by End of Year
Massachusetts public school students are required to meet a state standard, known as the Competency Determination (“CD”), as well as local graduation requirements in order to graduate from high school. In accordance with regulatory language approved by the Board of Elementary and Secondary Education in May 2025, Massachusetts school districts – including charter public schools – are each required to adopt a CD policy and submit that policy to the Department of Elementary and Secondary Education (“DESE”) by December 31, 2025.1
A CD policy must include the following:
- The coursework to be satisfactorily completed in each of the required subject areas2, including the specific courses the charter school considers applicable for the purposes of the CD;
- The measure(s) the charter school will use to determine whether the student has demonstrated mastery of skills, competencies, and knowledge in each of the named subject areas;
- Considerations for students with disabilities and English learners;
- Considerations for late-enrolling students;
- A description of the limited instances in which the charter school may use MCAS scores to determine competency;
- The process by which a student can appeal the charter school’s decision to award or deny a CD; and
- The process by which a current or former student may request a transcript review.
To demonstrate mastery, a student must successfully complete in accordance with the charter school’s grading policy: (1) the final assessment for a course; or (2) a capstone or portfolio project; or (3) an equivalent measure identified in the charter school’s CD policy.
To satisfactorily complete coursework, a student must earn full credit in accordance with the charter school’s grading policy in the courses listed in the table below3:
Content Area |
Coursework Requirements |
Notes |
English Language Arts |
The equivalent of two years of high school English Language Arts courses. |
To satisfy this course requirement, the English Language Arts courses must be taken in grades 9-12. |
Mathematics |
The equivalent of one year of both Algebra I and Geometry courses, or the equivalent of one year of both Integrated Math I and Integrated Math II. Whether to follow an Algebra/Geometry or Integrated Math I/II course sequence is determined by the district, but the equivalent length of the courses must still be met. |
Middle school math courses may be certified by the charter school as meeting the coursework requirement for the mathematics component of the CD. Charter schools must confirm that the course aligns to the high school Algebra I/Geometry/Integrated Math I/Integrated Math II standards as listed in the 2017 Massachusetts Mathematics Curriculum Framework. |
Science |
The equivalent of one year of any one of the following disciplines: Biology, Physics, Chemistry, or Technology/Engineering. |
To satisfy this course requirement, the science course must be taken in grades 9-12. |
U.S. History (beginning with the graduating class of 2027) |
The equivalent of a one-year United States history course. |
To satisfy this course requirement, the U.S. History course must be taken in grades 9-12. |
A charter school’s CD policy must be approved by its Board of Trustees. Upon approval by the Board of Trustees, the CD policy must be publicly posted on the school’s website in English as well as translated versions to ensure meaningful access for all parents and families, consistent with other school-wide communications.
Local graduation requirements, distinct from the CD, are at the sole discretion of a charter school’s Board of Trustees and may go beyond the requirements of the CD policy to include requirements related to credit-earning, attendance, participation in extracurricular activities, community service, etc. Local graduation requirements, as well as the requirements outlined in the charter school’s CD policy, must be met by students in order to graduate high school.
Following Board of Trustees approval of the CD policy, each charter school must submit both its CD policy and its local graduation requirements to DESE via GEM$. Through its submission, the charter school will be required to certify the following:
- The CD policy has been approved by the charter school’s Board of Trustees;
- The CD policy has been shared with all students, families/guardians, and charter school stakeholders; and
- The CD policy has been made publicly available in multiple languages.
DESE will publish each charter school’s and each district’s CD policy and local graduation requirements, based on the information provided in GEM$.4
Please reach out to attorneys Elka Sachs (esachs@kb-law.com), Bettina Toner (btoner@kb-law.com), or Eric Jordan (ejordan@kb-law.com) in K&B’s Education Practice Area with any questions or requests you may have regarding the CD policy or local graduation requirements. We are available to support your charter school in the development and adoption of those policies and graduation requirements in advance of the December 31, 2025, submission deadline.
Krokidas & Bluestein LLP's Education Law Practice provides a full array of advice and guidance to charter schools and other education entities on a wide range of legal matters including student discipline, special education, employment, governance, tax, regulatory and compliance matters, real estate, financing, and litigation.
[1] 603 CMR 30.04(5).
[2] The required subject areas, identified in the table below, are English Language Arts, Mathematics, and Science, and, beginning with the graduating class of 2027, U.S. History. (603 CMR 30.03).
[3] This table can be found in DESE’s “Competency Determination Guidance and Policy Submission Process” document, published in July 2025.
[4] https://mass.egrantsmanagement.com/
