Agencies | Governor
Virginia Regulatory Town Hall
Department of Education
State Board of Education
Regulations Establishing Standards for Accrediting Public Schools in Virginia [8 VAC 20 ‑ 131]
Action 2007-2008 revisions
Stage Proposed
Comment Period Ends 11/5/2008
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10/27/08  11:46 am
Commenter: Melissa C. Goemann, Juvenile Law and Policy Clinic, UR Law

Hold schools to high graduation standards

The Juvenile Law and Policy Clinic at the University of Richmond’s T.C. Williams School of Law advocates for youth from a variety of backgrounds, including those involved in the juvenile justice system.  We commend your efforts to set a statewide graduation accreditation rate.   However, the current target of 80 points is too low.  We ask that you (1) increase the target to 90 points to promote diploma graduates and eliminate graduation gaps among student subgroups; (2) provide a small “extra credit” value to Advanced diploma-earners; (3) weight Special and Modified diplomas at 100 points; and (4) lower the value of all non-diploma options such as GEDs and of Certificates of Completion to reflect the diminished opportunities that they offer to students.

A high school degree is vital to a youth’s ability to pursue higher education or secure a job that will ensure self-sufficiency.  High school graduation rates are particularly important to those of us working with delinquent youth because many of our clients fall through the cracks in their school when they become involved in the justice system.  One study estimates that75% of all prisoners are high school dropouts.[1]  This is particularly concerning because between 38% and 42% of youth admitted to the juvenile justice system in Virginia were previously identified as special education eligible.[2]  These students, in particular, need high graduation standards in order to help them achieve their highest potential before it is too late.

We congratulate the Board of Education for the On Time Graduation Rates published in October, 2008.[1]  While the overall graduation rate of 81% is commendable, the data reflected that graduation rates vary greatly by race.  There is a nearly 13 percentage point gap between white and black students and a 15.3 percentage point gap between white and latino students.  White students are twice as likely as black students to earn an Advanced Diploma in 4 years.  Students labeled as “disadvantaged” are graduating at a rate of only 69.8%.  In 15 school divisions, less than 70% of the Class of 2008 made it graduation day in 4 years.  All students should have an equal opportunity to be workforce and college ready.  By raising the target to 90 points, you will ensure that students from all racial and socioeconomic groups have a chance to reach their highest potential. 

Additionally, the proposed plan places too much weight on alternative credentials, including General Education Development (GEDs) and Certificates of Completion.  Under the proposed standards, a GED is worth 75 points and the target is set at 80 points.   Thus, a school could become fully accredited by awarding 80 GEDs and only 20 diplomas.  A Certificate of Completion is worth 60 points, but there is no statewide standard for when a school may award this credential.[1]

Setting the target so close to the value of the GED may have the unintended consequence of tracking students, who could earn a Standard diploma with the right supports and services, into a GED program.  A GED should be available as a last resort because it offers a significant decrease in earning potential.  GED holders are not eligible for army recruiting bonuses that can reach up to $40,000.[1]   GED earners earn 18% less than high school graduates.[2]  They are also less likely than graduates complete higher education.  Only 10% of GED holders graduate from a two or four year college.[3]  Although GEDs are intended for adult dropouts, over one-third (37%) of all GED candidates in Virginia are between the ages of 16 and 18.[4]

There are times when it is realistic to encourage a likely dropout to pursue a GED and students who work hard to earn one deserve our respect.  Given what is at stake for our students, however, we must ensure that GEDs are used as a last resort and that schools are encouraged to track students towards diplomas.  Thus, the target should be increased to 90 or the value of these alternative credentials should be reduced. 

           In summary, please raise the target to 90 points so schools can be held to a high graduation standard for students of all races and socioeconomic backgrounds.  Please also award more credit for Advanced and Standard diplomas than GEDs to reflect the increased economic and educational opportunities that these diplomas afford.  Educational success translates to greater life chances for youth, reduces their rate of re-entry into the juvenile justice system, and promotes a safer and more economically vibrant Virginia.  Thank you for your consideration.

Melissa Coretz Goemann

 Director, Juvenile Law and Policy Clinic, University of Richmond School of Law



[1] “Army offers $40K Recruiting Bonus of HS grads,” NPR (Feb. 5, 2008). 

[2] “GED Battery. No Substitute for Diploma,” Education Week (June 22, 2006).

[3] Id.

[4] Id.

[1] Va. Code Ann. § 22.1-253.13:4

[1] Class of 2008 On-Time Graduation Rate.  Data is available at

[1] Harlow, C.W., “Education and Correctional Populations. Bureau of Justice Statistics Special Report,” US Department of Justice (October, 2003).

[2] Virginia Juvenile Justice Summit on Children and Youth with Disabilities: Executive Summary. (October 16, 2001).

CommentID: 2888