Emergency Graduation Rules, Waivers FAQs

House Bills 1121 and 1131 (Laws of 2021) authorized the State Board of Education to adopt rules to implement an emergency waiver program to authorize school districts and private schools to waive certain graduation requirements because of disruptions in learning as a result of the COVID-19 pandemic.

In May 2022, the Board adopted permanent rules for an emergency waiver program for students in the Classes of 2022 and 2024. These rules are necessary to allow for students and educators to plan for students to be able to use the waiver, and, if appropriate, to graduate.

Download a one pager on the Emergency Waiver Program. Find additional information and resources on SBE's Emergency Waiver Program page.

The emergency waiver program is intended to help prevent students from being unduly impacted by unforeseen disruptions to coursework and assessments resulting from an emergency or disaster. The waiver program will give districts authority to waive certain credit and graduation pathway option requirements for individual students who were unable to complete graduation requirements despite a good faith effort on the part of the district to help the student meet the requirements.

The waiver allows LEAs (school districts, charters schools, and tribal compact schools) and private schools to waive certain credit and graduation pathway option requirements for graduating students on a case-by-case basis.

  • The waiver does not apply to local graduation requirements. Districts have the authority to waive their local requirements.
  • Students awarded the waiver must have demonstrated preparation for their postsecondary plan according to their High School and Beyond Plan.

The program is designed so that students expecting to graduate this year are not negatively impacted by pandemic-related disruptions to their learning and their ability to meet the graduation pathway requirement or earn credits needed for a diploma. The waivers are applied on an individual student-basis so the impact of the rules may be a little different for each student.

The rules require that LEAs explore options to provide students the opportunity to meet all graduation requirements, since it is the first and preferred option that students meet the requirements they need to graduate. However, if students cannot earn graduation requirement credits or meet the graduation pathway requirement because of school disruptions due to the novel coronavirus, these emergency rules will permit the waiver of some graduation requirements so that eligible students can graduate.

The rules for graduation allow for a fair amount of flexibility in terms of how students meet state graduation requirements, but they don't provide enough flexibility in terms of waiving or reducing requirements in a situation such as the COVID-19 pandemic, with substantial disruption to the traditional education model. Legislation, emergency rules and permanent rules were required to create increased flexibility, specifically focused on seniors, so that students could earn their diploma and move on to their next steps after high school.

The State Board of Education (SBE) will approve applications from Local Education Agencies (LEAs) (school districts, charter schools, and tribal compact schools). Once approved, the LEA is authorized to waive certain credit and graduation pathway requirements for individual students in the Classes of 2020 through 2024 who were reasonably expected to graduate this school year and who have demonstrated post-secondary preparation.

The LEA is responsible for making waiver decisions on an individual basis at the local level, in accordance with WAC 180-111. The Board will not review individual student waivers (although some reporting will be required).

There is a place for high school students among Washington’s 50 public and private baccalaureate and community colleges. Students who intend to, or are considering enrolling in, a college or university are strongly encouraged to contact the higher education institution regarding potential impacts. Potential considerations may include:

  • Minimum admission standards for Washington college and universities
  • Preparation for intended majors (e.g. nursing, engineering, and other STEM fields)
  • College course placement
  • Employment eligibility
  • Admission and transfer to out-of-state institutions

Washington’s college and universities want Washington high school students! At the same time, it is important to ensure students are appropriately prepared for college, including college-level mathematics and writing, and can be adequately supported within our campus capacities. Many institutions have adopted flexibility in the admissions process during the pandemic, so if a student is interested in attending college after high school, they should connect with that institution to discuss a path forward:

The emergency waiver may be granted to students graduating in 2020-21 through 2023-24. The waiver is administered by year, and not by graduating cohort. However, students in the graduating cohorts prior to the Class of 2020 are not eligible for the waiver.

Yes. In fact, that would be preferred. The emergency waiver is an extra tool districts can use to make sure students graduate after the COVID-19 educational disruptions.

Schools should be working with students to earn the credit and meet their graduation pathway requirement through the strategies outlined in the good faith effort section of WAC 180-111-020 and their existing local authority (which includes mastery-based credit). After all appropriate options for receiving credit and meeting their pathway requirement have been exhausted, then an individual student may be granted a waiver.

“Demonstration of postsecondary preparation” means the student has demonstrated skills and knowledge indicating preparation for the next steps identified in their High School and Beyond Plan and for success in postsecondary education, gainful employment, and civic engagement. “Demonstration of postsecondary preparation” may be determined locally, however, the rules include the following examples:

  • The student has completed a graduation pathway option in accordance with RCW 28A.655.250 and WAC 180-51-230.
  • The student has completed activities consistent with the criteria for “Career Prep” or has participated in an approved “Career Launch” program through Career Connect Washington.
  • The student has completed a preparatory career and technical education course or a course that meets the preparatory standards as defined in RCW 28A.700.030.
  • The student has developed and practiced leadership and employability skills through a job, volunteer position, or a Career and Technical Student Organization that would enable them to advance in their chosen career field and has obtained external validation from an employer, tribal elder, CTE business or industry advisory committee member, or other community member that can attest to the student’s preparation for their next steps.
  • The student is a participant in a recognized apprenticeship preparation program or registered apprenticeship program or has signed an apprenticeship agreement with an employer.
  • The student has earned college credit in a core subject area.
  • The student has earned an industry recognized credential.
  • The student has completed minimum college admission standards for four-year institutions of higher education, in accordance with RCW 28B.77.020(7)(a).
  • The student placed into a college-level math or English course at an institution of higher education.
  • The student completed a summer bridge program or a senior transition course (Bridge to College).
  • The student has been awarded a scholarship for higher education.
  • The student has enlisted in a branch of the military.

In 2023-24, only up to one credit may be waived. The waived graduation requirement credit may be either core or flexible credit graduation requirements, as defined in WAC 180-51-210. The student must earn no fewer than a total of 21 credits to graduate.

In the 2023-2024 school year, the graduation pathway requirement may be waived, with some limitations, namely, students may not receive a waiver of credit and a waiver of the graduation pathway requirement in the same subject. For example:

  • If a student is granted a waiver of up to one math credit, then the student may have an English graduation pathway requirement waived, but not a math pathway requirement.
  • If a student is granted a waiver of up to one English credit, then the student may have a math graduation pathway requirement waived, but not an English pathway requirement.
  • If a student has no credits waived, or if a credit is waived in a subject other than English or math, then the student may have the pathway requirement waived in both English and math.
  • Note: the ASVAB and CTE graduation pathways address both English and math, so a student completing either of these pathways would not need a waiver of the pathway requirement. A student granted a credit waiver in English or math may not receive a waiver of the ASVAB or CTE pathway.

Other waivers may be used with this waiver program, including waiver of local graduation requirements and the two-credit wavier for student circumstances, provided a student earns at least 21 total credits. The limit on number of credits waived is based on what a student was planning to reasonably complete by the end of the school year.

Yes. The waiver must be granted in the school year the student expected to graduate, which extends through August 31 (RCW 28A.150.203).

A possible student example is:

A student who planned to graduate in summer and receives the waiver for 1.5 credits attempted during the fall semester that was impacted by the novel coronavirus disruption. The district performed a good faith effort to help the student meet the requirement, but the student was unable to meet the requirement due to having to work to support their family. The student then comes back for summer school to finish a required course important to their postsecondary plan and graduates in summer.

Yes, in Q2023-24, the emergency waiver of one credit may be used with the waiver of two flexible credits for student circumstances provided the student earns at least 21 total credits.

Yes. A student with this waiver may graduate with fewer than the state minimum requirements. For example, a possible scenario is students graduating with 3.5 credits of English because they were unable to earn credit for the second semester. However, this must be applied on an individual student basis and the first priority is to try to help the student earn the credit. Also, credits in subjects most related to the student’s High School and Beyond Plan should not be waived.

In their application for authority to be able to grant individual student waivers, the LEA must certify the following:

  1. The local education agency will adopt by resolution* a written plan, under WAC 180-111-040, that describes the district’s process for granting and declining emergency waiver for students, and provide for a panel with at least one counselor and educators with expertise in trauma-informed instruction and culturally responsive education, and if appropriate, special education, instruction for multilingual/English Language learners, and a migrant graduation specialist or migrant student advocate to review and make recommendations to the district concerning any decision to decline a waiver. The resolution will also include a process for students to appeal within the school district a decision to not grant an emergency waiver. The plan must include culturally responsive ways, based on the school district’s local community, to communicate with students and families about the waiver and the process to request, appeal, or decline the waiver.
  2. The LEA will consider equity when administering the waiver. The LEA shall disaggregate administrative waiver data by student subgroups as referenced in RCW 28A.300.042(3) and will conduct further disaggregation of subgroups if data is available to do so. If disproportionality is found, the local education agency will take appropriate actions to ensure equitable administration.
  3. The LEA will demonstrate a good faith effort, as defined in WAC 180-111-020, to help the individual student address credit deficiencies and meet core course and graduation pathway requirements prior to granting a waiver.
  4. The LEA will grant waivers to eligible students in accordance with program rules (WAC 180-111)—on an individual, case-by-case student basis—after a good faith effort has first been made to help students earn the credit.
  5. The LEA will maintain records on the use of the waiver, and report administration data to the SBE in the annual basic education compliance survey, and report student-level data to OSPI as determined by OSPI.

*The Washington State School Directors' Association has developed a model resolution to assist school districts with implementing the Emergency Waiver Program.

“Good faith effort” means the local education agency or private school considered and implemented options, determined appropriate by the local education agency or private school, to support individual students in meeting credit and graduation pathway requirements. This includes consideration of awarding and waiving of credits through the existing authority of local education agencies and private schools (e.g. providing mastery credit where appropriate). LEAs should consider all the options, determine which ones the LEA can provide, then examine individual circumstances and determine which of the available options are appropriate to implement with the student.

This emergency waiver program does not allow for the waiver of the High School and Beyond Plan. Also, this emergency waiver program does not extend to local graduation requirements.

Civics, taught as a stand-alone course for credit, may be waived under this emergency waiver program.

Under existing law, districts may waive Washington State History for juniors or seniors who took a state history course in another state, or who missed taking Washington State History because of residing outside of Washington, or other circumstance due to an emergency (WAC 180-51-210 for districts that are implementing the 24-credit graduation requirements).

Current middle school students who miss completing Washington State History because of school closures cannot use the current emergency waiver. Addressing the needs of students in the classes beyond the current year’s graduating class is ongoing work of the State Board of Education, the Office of the Superintendent of Public Instruction, and local districts.

Document in the individual student record (in cumulative file, HSBP or in student management system):

  • Steps taken to demonstrate good faith effort to help the student meet graduation requirements
  • Courses, term, and amount of credit waived
  • Whether the graduation pathway option was waived
  • How the student demonstrated postsecondary preparation

Report on the student transcript:

  • Any waived credit(s)
  • Graduation pathway waiver

Collect data on:

  • The number of waivers requested and not granted.
  • Student demographics on waivers granted and not granted by student group to:
    • Disaggregate waiver data by student group for use by the district in evaluating equitable administration of the waiver
    • Report student-level data to OSPI

Note: This data should be used locally to assess if there is disproportionality in the use of the waiver. If disproportionality is found, the district must take appropriate actions to ensure equitable administration of the waiver.

Report to SBE on:

  • Districtwide good faith efforts
  • Actions taken to ensure equity in administration of the waiver

No, the legislation that authorized the emergency waiver program limited the application of the emergency waiver to students starting with the Class of 2020.

We encourage working with students in earlier classes to consider existing flexibilities and ways of awarding credit for demonstrated knowledge and skills. Options could include:

  • mastery- or competency-based learning*
  • the Expedited Assessment Appeals (EAA) Waiver (students in the Class of 2018 need to have attempted another assessment before accessing the EAA)
  • the two-credit waiver for individual student circumstances for schools implementing the 24-credit diploma requirements
  • work-based learning credit
  • waiver of local graduation requirements
  • Special, Unavoidable Circumstance Appeal (SUCA) to waive SBA
  • WA-AIM Engagement Rubric for an “Awareness Waiver” or the CIA options (Certificate of Individual Achievement) for students receiving special education services
  • flexibility for PE and WA State History
  • summer school or online credit recovery
  • extended and expanded learning opportunities

*Additional Considerations around Mastery-based Learning

  • Through mastery- or competency crediting you may be able to award credit for languages, including a student’s native language if the student is bilingual or learning English.
  • Students who are successful in a higher level course in a sequence of courses, but who were unsuccessful in the lower level courses, may be awarded competency credit for the lower level courses. Success in the higher level course is a demonstration of mastery of the learning standards addressed in the lower level courses.
  • Course equivalency—one course that meets two graduation requirements, allows greater flexibility in student schedules, and accelerates students meeting graduation requirements. For courses that address learning standards in more than one subject, are the standards addressed sufficiently in two subjects that you could consider awarding two credits through mastery-based learning? Or, with an additional demonstration of skills and knowledge by the student, would it be possible to award additional credit?
  • See additional information in the mastery-based learning FAQ.

The emergency waiver is intended as a last resort for students to be able to graduate in the year the waiver is granted. If a student was granted an emergency waiver in 2022 but then was unable to complete requirements by August 31, 2022* and was not able to graduate, then the student and the school should review the student’s High School and Beyond Plan and make a plan for completing all graduation requirements in 2022-23. This plan should include a review of all options for earning credit (including mastery-based credit, online learning, and options at community and technical colleges) as well as options for waiving credit, if appropriate (including up to 2.0 flexible credits that may be waived due to student circumstances and up to 2.0 credits waived for COVID-related impacts through the emergency waiver).

Consideration should be given to providing all students, including 5th and 6th year seniors, the opportunity to maximize their access to free education and preparation for their postsecondary goals. If needed, as a last resort, and after a good faith effort to help the student meet all graduation requirements, the emergency waiver is available in 2022-23, and there will be an emergency waiver available in 2023-24. The waiver in 2023-24 will allow for a waiver of one credit in any subject, and the graduation pathway requirement may be waived with certain limitations.

If the review with the student results in a plan for the student to earn the credits they need before the end of the school year the waiver may be granted before the end of the school year.

*Per WAC 392-700-155: A school year begins September 1st and ends August 31st.

In the 2023-24 school year, students in the Classes 2025 (or later) who have met all other graduation requirements may have their graduation pathway requirement waived. These students may not receive an emergency waiver of credit requirements.

Last updated: April 2024

The emergency waiver is intended as a last resort for students to be able to graduate in the year the waiver is granted. If a student was granted an emergency waiver in 2022 but then was unable to complete requirements by August 31, 2022* and was not able to graduate, then the student and the school should review the student’s High School and Beyond Plan and make a plan for completing all graduation requirements in 2022-23. This plan should include a review of all options for earning credit (including mastery-based credit, online learning, and options at community and technical colleges) as well as options for waiving credit, if appropriate (including up to 2.0 flexible credits that may be waived due to student circumstances and up to 2.0 credits waived for COVID-related impacts through the emergency waiver).

Consideration should be given to providing all students, including 5th and 6th year seniors, the opportunity to maximize their access to free education and preparation for their postsecondary goals. If needed, as a last resort, and after a good faith effort to help the student meet all graduation requirements, the emergency waiver is available in 2022-23, and there will be an emergency waiver available in 2023-24. The waiver in 2023-24 will allow for a waiver of one credit in any subject, and the graduation pathway requirement may be waived with certain limitations.

If the review with the student results in a plan for the student to earn the credits they need before the end of the school year the waiver may be granted before the end of the school year. 

*Per WAC 392-700-155: A school year begins September 1st and ends August 31st.