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Policy/Program Memorandum No. 127

Date of Issue: August 7, 2009
Effective: September 1, 2008, until revoked or modified

Subject: THE SECONDARY SCHOOL LITERACY GRADUATION REQUIREMENT

Application: Directors of Education
Secretaries of School Authorities
Principals of Secondary Schools
Principals of Elementary Schools
Principals of Provincial and Demonstration Schools
Principals of Inspected Private Schools

Reference: This memorandum replaces Policy/Program Memorandum No. 127, “The Secondary School Literacy Graduation Requirement”, October 13, 2004.

Introduction

This memorandum sets out policy with respect to the secondary school literacy graduation requirement. This memorandum also provides a revised definition of the term mature student, which now applies to all ministry documents in which reference is made to mature students (see page 4).

All students who entered Grade 9 in the 2000–2001 school year, or in subsequent years, are required to meet the literacy graduation requirement outlined in section 3.1.4 of Ontario Secondary Schools, Grades 9 to 12: Program and Diploma Requirements, 1999 (OSS) in order to earn an Ontario Secondary School Diploma (OSSD). The only exceptions are students who have an Individual Education Plan (IEP) that indicates that they are not working towards the OSSD, and who are granted an exemption in accordance with section 3.1.4.1 of OSS and this memorandum.

Most students who are working towards an OSSD under OSS will meet the literacy graduation requirement by successfully completing the Ontario Secondary School Literacy Test (OSSLT) or the Ontario Secondary School Literacy Course (OSSLC). Some students may be allowed to meet the requirement by successfully completing a special adjudication process.

The secondary school literacy graduation requirement is based on the expectations for reading and writing throughout the Ontario curriculum up to and including Grade 9. Its purpose is to determine whether students have the skills in reading and writing that they will need to succeed at school, at work, and in daily life.

Students who are working towards the OSSD under Ontario Schools, Intermediate and Senior Divisions (Grades 7–12/OACs): Program and Diploma Requirements, rev. ed., 1989 (OSIS) and students who are working towards an earlier diploma, such as the Secondary School Graduation Diploma, are not required to meet the secondary school literacy graduation requirement.

Ways Of Meeting The Secondary School Literacy Graduation Requirement

The Ontario Secondary School Literacy Test (OSSLT)

The OSSLT is the standard method for assessing the literacy skills of students in Ontario for the purpose of determining whether students meet the provincial secondary school literacy requirement for graduation. The test thus identifies students who have demonstrated the required skills in literacy as well as those who have not demonstrated the required skills and will need to do further work. The test identifies the specific areas in which these students need remediation.

The test is administered through the Education Quality and Accountability Office (EQAO) once each year, usually in the spring.

Students who are working towards the OSSD under OSS will normally take the OSSLT when they are in Grade 10. Those who do not take the test in the year following the year in which they enter Grade 9 will require a deferral. Deferrals must be granted in accordance with the policies on deferrals in section 3.1.4.1 of OSS and on page 10 of this memorandum.

For students who entered Grade 9 in 1999–2000, successful completion of the test is not a graduation requirement. However, for those students who took the field test of the OSSLT in 2000–2001, failed the test, and chose to retake the OSSLT in October 2001, successful completion of the provincial literacy graduation requirement became a diploma requirement.

Students who are working towards an OSSD under OSS and who do not successfully complete the OSSLT will have opportunities to retake the test in subsequent years on dates scheduled by the EQAO. Once students have successfully completed the literacy test, they may not retake it.

For students with special education needs,1 accommodations2 specified in the student's IEP must be available (see pages 6–10 of this memorandum). For students for whom required accommodations were not available on the day the OSSLT was administered, see also under “Students With Special Education Needs” on pages 4 and 5.

A student will take the OSSLT in the language of instruction of the school in which he or she is enrolled at the time of test administration. School boards3 should ensure that this policy is made known to students and to the parents4 of students who are planning to transfer from the English-language system to the French-language system, or vice versa, and have not yet fulfilled the literacy graduation requirement. A student who has successfully completed the OSSLT in either English or French is considered to have met the literacy graduation requirement, and will not have to retake the test in the other language after transferring to the receiving school.

As stated in section 3.1.4 of OSS, school boards are required to provide remedial assistance for students who do not complete the test successfully. This remedial assistance should be designed to help students improve their skills so that they are better prepared to retake the literacy test. For example, a board could offer a credit course on learning strategies or one on literacy skills for these students.

The Ontario Secondary School Literacy Course (OSSLC)

In 2003, the ministry developed the Ontario Secondary School Literacy Course (OSSLC). Policy requirements for taking the OSSLC are contained in the curriculum policy document The Ontario Curriculum: English, the Ontario Secondary School Literacy Course (OSSLC), Grade 12, 2003.5 Students who pass the course are considered to have met the literacy graduation requirement.

The reading and writing competencies required by the OSSLT form the instructional and assessment core of the course. The course differs from other courses in that it outlines specific requirements for evaluation in order to ensure alignment with the requirements of the OSSLT.

For the 2003–04 school year, students who had had two opportunities to take the OSSLT and had failed it at least once were eligible to enrol in the OSSLC. In June 2004, policy was changed to grant principals the discretion to allow a student to enrol in the OSSLC before he or she has had a second opportunity to take the OSSLT, if the principal determines that it is in the best educational interests of the student.

The credit earned for successfully completing the OSSLC may be used to meet the Grade 11 or the Grade 12 compulsory credit requirement in English. If used to meet the Grade 11 requirement, the course is coded OLC3O. If used to meet the Grade 12 requirement, the course is coded OLC4O. The credit may also be used to meet the group 1 compulsory credit requirement for the Ontario Secondary School Diploma. Students should check admission requirements for postsecondary institutions, since the OSSLC may not be accepted as the Grade 12 English entrance requirement for college or university programs.

The OSSLC may be used as a substitution to meet the requirements for compulsory credits.

A student cannot be granted credit for the OSSLC through the challenge process described in the Prior Learning Assessment and Recognition (PLAR) policy outlined in either Policy/Program Memorandum No. 129, “Prior Learning Assessment and Recognition (PLAR): Implementation in Ontario Secondary Schools,” July 6, 2001, or Policy/Program Memorandum No. 132, “Prior Learning Assessment and Recognition (PLAR) for Mature Students: Implementation in Ontario Secondary Schools,” May 7, 2003.

Students With Special Education Needs
For students with special education needs, accommodations specified in the student's IEP must be available to the student throughout the course. However, because achievement of the expectations in this course represents fulfilment of the literacy requirement for graduation, no modifications6 of the expectations are permitted.

Students who were receiving special education programs or services, and had an IEP documenting required accommodations when taking the OSSLT, may be eligible to enrol directly in the OSSLC without having failed the OSSLT at least once if, owing to unforeseen circumstances, these accommodations were not available on the day the OSSLT was administered. (The accommodations must be in accordance with those outlined under “Permitted Accommodations” on pages 7–8 of this memorandum.) In such cases, the student must have been present to take the test, but the required accommodations, or a reasonable alternative to them, were unavailable to the student during the whole test or part of the test. For students in these circumstances in June of their graduating year, see “Adjudication Process” on page 5.

Mature Students
As of September 1, 2008, mature students may enrol directly in the OSSLC without first attempting the OSSLT. Successful completion of the OSSLC provides mature students an alternative means of demonstrating the required reading and writing competencies measured by the OSSLT. A mature student may still elect to meet the literacy graduation requirement by successfully completing the OSSLT.

A “mature student” is a student who:

• is at least eighteen years of age on or before December 31 of the school year in which he or she registers in an Ontario secondary school program;
• was not enrolled as a regular day school student7 for a period of at least one school year8 immediately preceding his or her registration in a secondary program;
• is enrolled in a secondary program for the purpose of obtaining an OSSD.

As stated on page 1, this revised definition now applies to all ministry documents in which reference is made to mature students.

Adjudication Process

In June 2004, the ministry introduced an adjudication process. School boards may establish adjudication panels at the end of the school year to provide certain students with an additional opportunity to meet the literacy graduation requirement. The process is designed for students who, through no fault of their own, have not been able to take advantage of the normal opportunities to write the OSSLT and/or have not been able to enrol in or complete the OSSLC, owing to unforeseen circumstances. Every spring, the ministry sends boards the procedures, application forms, and timelines for the adjudication process for that school year.

Students who are otherwise eligible to graduate in June of a given school year are eligible for adjudication to obtain their graduation literacy requirement if they meet one or more of the
following criteria:

• The student was never able to write the test because of illness, injury, or other extenuating circumstances.
• The student was eligible to enrol in the OSSLC, but the student's school did not offer the OSSLC or make arrangements for the student to take the OSSLC in another school./li>
• The student was enrolled in the OSSLC, but owing to illness, injury, or other extenuating circumstances, was not able to complete the OSSLC.

Students With Special Education Needs
Students with special education needs who are otherwise eligible to graduate in June of a given school year are eligible for adjudication to obtain their graduation literacy requirement if they meet one or more of the following criteria:

• The student was receiving special education programs or services, and had an IEP documenting required accommodations when taking the OSSLT. (The accommodations must be in accordance with those outlined under “Permitted Accommodations” on pages 7–8 of this memorandum.) In that school year or in a previous school year, the student was present to take the test, but owing to unforeseen circumstances, the required accommodations, or a reasonable alternative to them, were not available to the student on the day the OSSLT was administered during the whole test or part of the test.
• The student was eligible to enrol in the OSSLC, but the student's school did not offer the OSSLC or make arrangements for the student to take the OSSLC in another school.
• The student was enrolled in the OSSLC, but owing to illness, injury, or other extenuating circumstances, was not able to complete the OSSLC.

Recording Of Results On The Ontario Student Transcript

A student's results on the OSSLT, in the OSSLC, or in the adjudication process will be recorded on the Ontario Student Transcript (OST). An “X” will be entered in the “Successfully Completed in English” box (or the “Réussi en français” box) if the student has successfully completed the test, the course, or the adjudication process. “N/A” applies to students whose IEP indicates that they are not

working towards the OSSD; to students who are working towards the OSSD under OSIS; and to students who are working towards an earlier diploma, such as the Secondary School Graduation Diploma.

“N/A” will also normally apply to students who are working towards an OSSD under OSS and who entered Grade 9 in 1999–2000, whether or not they completed the test successfully in 2000–2001, since successful completion of the test is not a graduation requirement for them. However, for students who chose to retake the test in October 2001 and successfully completed the test, an “X” will be entered in the “Successfully Completed in English” (or “Réussi en français”) box on the OST, in accordance with the policy stated on page 2 of this memorandum and with the EQAO Guide for Administering the Ontario Secondary School Literacy Test – October 2001. If these students did not complete the test successfully in October 2001, they were required to retake and successfully complete the OSSLT in order to be eligible to earn an OSSD. (Alternatively, if they have not yet successfully completed the OSSLT, they may meet the literacy graduation requirement by successfully completing the OSSLC or successfully completing the adjudication process.) Upon successful completion of the literacy graduation requirement, an “X” will be entered in the “Successfully Completed in English” (or “Réussi en français”) box on the student's OST.

Accommodations For Students With Special Education Needs

Legislation and Ministry of Education Policy

The Education Act requires that school boards provide special education programs and services for students with special education needs, including students who have been identified as exceptional by an IPRC. The Ontario Human Rights Code, 1981, prohibits discrimination in the provision of services with respect to specific grounds that are set out in the code.  For the purposes of the code, education is considered to be a service. The code also requires that persons identified under the specified grounds in the code must be accommodated up to the point of “undue hardship” on the person providing the accommodation. Therefore, school boards must provide appropriate accommodations that will enable students with special needs to participate in the educational setting. OSS states: “The necessary accommodations must be made to ensure that students who are receiving special education programs and services and who have an Individual Education Plan (IEP) have a fair and equal opportunity to successfully complete the secondary school literacy test.” Accommodations needed for the literacy test or the literacy course may be challenging to implement, and consequently careful planning will be required on the part of the principal.

To qualify for accommodations for taking the test or the course, a student must normally have an IEP that describes the required accommodations. The student may be, but does not have to be, formally identified as an “exceptional pupil” by an IPRC in order to have an IEP.

Procedures for Making Accommodations

It is important that certain basic procedures be followed in planning and making accommodations so that these may be of maximum benefit to the student. Decisions about accommodations must:

• always be made on an individual student basis;
• be made by the principal in consultation with the student, parents (if the student is under the age of eighteen), and appropriate staff (including special education and professional support services staff, where appropriate)
• be made prior to the taking of the OSSLT or enrolling in the OSSLC;
• take into consideration all accommodations included in the student's IEP that are also permitted in accordance with this memorandum and with the EQAO document entitled Guide for Accommodations, Special Provisions, Deferrals, and Exemptions (see next section);
• be clearly communicated in writing to the parents, or directly to the adult student,9 in advance of the writing of the test or enrolment in the course;
• be recorded, with all pertinent details, on the Student Data Collection System provided by the EQAO for students writing the OSSLT.

Permitted Accommodations

The accommodations that may be necessary in order to give students with special needs the best possible opportunity to successfully complete the OSSLT or the OSSLC may take several forms. In each case, the accommodation used must normally be specified in the student's IEP. Details about the accommodations that may be provided for the OSSLT and the process for seeking accommodations are outlined in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions. This guide can be accessed through the EQAO website, at www.eqao.com under “Educator Resources”, or obtained by writing to the following address:
Education Quality and Accountability Office
2 Carlton Street, Suite 1200
Toronto ON  M5B 2M9

Accommodations that are permitted by the EQAO for the OSSLT include the following:

• adjustments to the environment in which the test is administered
• adjustments in the time allowed for the test
• changes/adjustments to the format of the test (e.g., alternative forms of print)
• changes/adjustments to the format of responses

Note that clarification of instructions for both the reading and the writing components of the OSSLT is permitted for all students before the commencement of the test. Such clarification is not considered to be an accommodation.

If an accommodation that is described in a student's IEP is also one that is permitted in accordance with the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions, the principal must ensure that the accommodation is available to the student during the OSSLT.

Accommodations other than those listed in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions will be given consideration by the EQAO upon receipt of a request, as outlined in the following section.

See pages 9–10 of this memorandum for more information on the human resources required for the implementation of accommodations for students with special needs.

Requests for Special Consideration of Accommodations

Accommodations That Are Listed in the EQAO Guide

When a parent, adult student, or principal identifies the need for an accommodation that is listed in theEQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions, one of the following procedures applies, as appropriate:

• If the accommodation is not described in the student's IEP, the parent, adult student, or principalmay submit a request for consideration to the appropriate supervisory officer. The decision of thesupervisory officer is final.
• If the student does not have an IEP because he or she recently transferred into the school from another jurisdiction, the parent, adult student, or principal may make a request for accommodations to the appropriate supervisory officer. The decision of the supervisory officer is final.
• If, owing to temporary circumstances, a student who would not normally require accommodations requires one or more in order to take the test or the course, the principal may grant permission for the use of any appropriate accommodations that are permitted in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions. If the principal determines that it is not possible to provide an accommodation that will allow the student to take the test, a deferral should be considered. Where the parent or adult student disagrees with the decision of the principal, he or she may make an appeal to the appropriate supervisory officer. The decision of the supervisory officer is final.

For students in Provincial and Demonstration Schools, the request must be made to the appropriate superintendent. The decision of the superintendent is final.

For students in approved education programs in care and/or treatment, custody, and correctional facilities, the request must be made to the appropriate supervisory officer. The decision of the supervisory officer is final.

For students in independent schools and Native schools, the request must be made to the Chief Assessment Officer of the EQAO. The decision of the Chief Assessment Officer is final.

Accommodations That Are Not Listed in the EQAO Guide
When a parent, adult student, or principal identifies a need for an accommodation that is not listed in theEQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions or involves more than double the time allowed for the test, that conforms to the definitionof accommodations in the guide, and that is described in the student's IEP, the parent, adult student, orprincipal must submit the request for consideration to the Chief Assessment Officer of the EQAO. Thedecision of the Chief Assessment Officer is final.

Human Resources Required for the Implementation of Accommodations During Administration of the OSSLT

Any person who is engaged to assist with the accommodations of one or more students and who is not a teacher must work under the direct supervision of a teacher. Only adult persons who are not relatives of students writing the test may provide assistance in these circumstances. It is important that such individuals be given training and that the following guidelines be followed.

• The role of individuals who assist with the implementation of accommodations for students with special needs is to ensure that the student is properly supervised during the administration of the test and that the accommodations are appropriately implemented.

• These individuals shall not provide students with any assistance that would compromise the validity of the test; that is, they shall not provide assistance that helps students to understand the questions or to formulate their answers, or give any instructions or suggestions (for example, suggestions about pacing their work) not given to all students writing the test.

• It is generally an advantage if the student knows the person who assists with the implementation of accommodations. However, as noted above, the person must not be a relative.

• All non-teaching personnel providing assistance with the implementation of accommodations will be required to adhere to the same security provisions and other guidelines for the administration of the OSSLT as the teachers and principals involved in its administration.

• The role of the scribe is to write – by hand or using a typewriter or computer – the student's dictated answers to questions. The scribe must not in any way help the student to formulate answers to the questions. In the course of the test, the scribe:
• must not give any assistance or suggestions relating to the content of the test;
• must not give advice related to the order of the questions or the time to be spent on them;
• must write, by hand or using a typewriter or computer, the student's answers exactly as they are dictated by the student;
• may read back what has been recorded at the student's request;
• may enter student responses to multiple-choice questions on the Student Answer Sheet;
• must adhere to the EQAO policy on the duty to report child abuse, as provided in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions.

• Prompters are allowed for students with severe attention difficulties. Since the sole purpose of the prompts is to draw the attention of a student who has been distracted back to the test, prompts are considered process-related aids that do not affect the integrity or validity of the student's performance on the test. Additional details will be provided by the EQAO.

For complete instructions refer to the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions.

Deferrals of The OSSLT

Deferrals are intended for students who have not yet acquired a level of proficiency in English to successfully complete the test. Such students could include some students who have been identified as exceptional; students who are registered in English as a second language/English literacy development (ESL/ELD) courses; and students who were not successful in acquiring the reading and writing skills appropriate to Grade 9. Deferrals may also be granted to students who are unable to write the test at the scheduled time owing to illness, injury, or other extenuating circumstances. Documentation must be submitted to the principal of the school in such cases.

Deferrals are to be granted to students on an individual basis. The following procedures should be applied:

• A request for a deferral may be made by a parent or an adult student. Such requests are made in writing to the principal. The principal may grant the deferral.
• A principal may also initiate consideration of a deferral with the parent or adult student.
• The principal will make his or her decision in consultation with the parent or adult student and appropriate school staff. In cases of disagreement, the parent or adult student may ask the appropriate supervisory officer to review the matter. The decision of the supervisory officer is final.
• The writing of the test may be deferred only to the time of the next scheduled test. Students who are granted a deferral will write the test at the next scheduled sitting as prescribed by the EQAO.
• If an additional deferral is required, the principal must review the request again with the parent or adult student and appropriate school staff. While there is no limit on the number of deferrals that may be granted, the parent or adult student must be advised that a deferral will result in fewer opportunities to retake the test and that successful completion of the test, successful completion of the OSSLC, or successful completion of the adjudication process is a diploma requirement. Students should be encouraged to write the test so that the school may have an indication of their strengths and needs and be able to develop an appropriate program and/or appropriate forms of support to prepare them for their next attempt.
• All documentation related to the decision to grant a deferral must be kept in the student's Ontario Student Record (OSR).

Exemptions From The Literacy Requirement

To be eligible for an exemption, a student must have an IEP. The IEP must include documentation to support an exemption from the literacy graduation requirement and clear indication that the student is not working towards an OSSD. Both parental consent and the approval of the principal are required for an exemption.

• If a student does not successfully complete the OSSLT, the OSSLC, or the adjudication process, he or she will not be eligible to receive the OSSD.

Exemptions are to be provided to students on an individual basis. The following procedures should be applied:

• The principal of the school will ensure that an IEP is developed for the student in consultation with the parents and the student, if the student is sixteen years of age or older, in accordance with Regulation 181/98.
• The IEP will identify the student's learning expectations, which will indicate whether the student is working towards the OSSD.
• Where the IEP indicates that the student is not working towards the OSSD, the student may be granted an exemption from writing the OSSLT or taking the OSSLC by the school principal.
• The principal will make his or her decision in consultation with the parent or adult student, and the final decision must be communicated in writing to the parent or adult student as part of the IEP development process.
• In cases of disagreement, where the principal decides that the student should be exempted from writing the test or taking the course but the parent or adult student disagrees with this decision, the student must be allowed to write the test or take the course. Where the principal decides that the student should write the test or take the course but the parent or adult student disagrees with this decision, the matter will be referred to the appropriate supervisory officer. The supervisory officer's decision is final.
• Where it is determined that an exemption does not apply and that the student who has an IEP and who is receiving a special education program and special education services is to take the test or the course, the principal must ensure that the student has a fair and equal opportunity to successfully complete the test or the course. The necessary accommodations will be provided in accordance with this memorandum, section 3.1.4.1 of OSS, and the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions.
• If the learning expectations contained in the student's IEP are revised at some point and the student begins to work towards the OSSD, he or she must successfully complete the OSSLT, the OSSLC, or the adjudication process in order to be eligible to receive the diploma.
• All documentation related to the decision to grant an exemption from taking the test or the course must be kept in the student's Ontario Student Record (OSR).

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