Policy/Program Memorandum No. 127

Issued under the authority of the Deputy Minister of Education

Introduction

This memorandum sets out policy with respect to the secondary school literacy graduation requirement.

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 Ontario Secondary Schools, Grades 9 to 12: Program and Diploma Requirements, 1999 (OSS) in order to earn an Ontario Secondary School Diploma (OSSD). Most students will meet the 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.

The following students are not required to meet the secondary school literacy graduation requirement:

• 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
• 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)
• students who are working towards an earlier diploma, such as the Secondary School Graduation Diploma

Ways of Meeting the Secondary School Literacy Graduation Requirement

Ontario Secondary School Literacy Test

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.

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 in 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. Once students have successfully completed the literacy test, they may not retake it.

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 boards¹ should ensure that this policy is made known to students and to the parents² 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.

For more detailed information on the OSSLT, see OSS, section 3.1.4.

Ontario Secondary School Literacy Course

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, 2003.³ 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. However, 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.

Accommodations specified in a 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 modifications of the expectations are permitted.

Adjudication Process

In June 2004, the ministry introduced an adjudication process. School boards may now establish adjudication panels at the end of the school year to provide certain students with an additional opportunity to meet the literacy graduation requirement. These students include those who would otherwise be eligible to graduate in June but, 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. Also eligible for the adjudication process are students who were receiving special education programs or services, and who had an IEP documenting required accommodations, but, owing to unforeseen circumstances, did not have access to these accommodations when they were taking the OSSLT.

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 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" box on the OST, in accordance with the policy stated on page 2 of this memorandum and with the Guide for Administering the Ontario Secondary School Literacy Test - October 2001 of the Education Quality and Accountability Office (EQAO). 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" box on the student's OST.

Accommodations for Students With Special Needs Who Are Taking the Test

Legislation and Ministry of Education Policy

The obligation of school boards and schools to provide accommodations for students with special needs is reinforced both by legislation and Ministry of Education policy. Under the Ontario Human Rights Code, 1981, which sets out provisions on the "duty to accommodate" all persons with disabilities, school boards have the responsibility to 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 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, 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 Identification, Placement, and Review Committee (IPRC) in order to have an IEP.

Use of Terms

For the purposes of this memorandum, the following terms have the meanings outlined below.

"Students with special needs" are students with an IEP who may or may not have been identified as "exceptional pupils" through the IPRC process, and who are receiving special education programs and services. An IEP must be developed for students who have been identified as exceptional by an IPRC. An IEP may be developed for students who have not been identified as exceptional by an IPRC, but who are receiving special education programs and/or services. ⁴

"Modifications" are changes to content and to performance criteria. Modifications to the OSSLT are not permitted because they would affect the validity and reliability of the test.

"Accommodations" are forms of support and services that enable students with special needs to demonstrate their competencies in the skills being measured by the test. Accommodations change only the way in which the test is administered or the way in which the person tested responds to the components of the test. They do not alter the content of the test or affect the validity or reliability of the test.

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, and appropriate staff (including special education and professional support services staff, where appropriate);
• be made prior to the taking of the OSSLT;
• 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 section below);
• be clearly communicated in writing to the parents or adult student in advance of the writing of the test;
• be recorded, with all pertinent details, on the Student Information Form provided by the EQAO.

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 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 and the process for seeking accommodations are outlined in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions. This document can be accessed by visiting the EQAO website, at www.eqao.com, or obtained by writing to the following address:

Education Quality and Accountability Office
2 Carlton Street
Suite 1200
Toronto ON M5B 2M9

Accommodations that will be permitted include the following:

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

For example, reading aloud of the questions in the writing component of the test is a permitted accommodation for students who have this specified as an accommodation in their IEP. However, reading aloud of the questions in the reading component of the test is not permitted as an accommodation, because the ability to read questions unassisted is an integral part of what is being measured in the reading component.

Such forms of support as the following are also not permitted as accommodations, since they would affect the validity of the test: clarifying test questions for students by rewording or explaining them; answering students' questions during the test or providing additional information; and allowing discussion prior to the performance of writing tasks.

Note that clarification of instructions for both the reading and the writing components of the test 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 this memorandum and 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 test.

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 section below.

See the appendix for more information on the human resources required for the implementation of accommodations for students with special needs.

Requests for Special Consideration of Accommodations

1. Accommodations that are listed in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions

When a parent, adult student, or principal identifies the need for an accommodation that is listed in the EQAO guide, one of the following procedures applies, as appropriate:

1. If the accommodation is not described in the student's IEP, the parent, adult student, or principal may submit a request for consideration to the appropriate supervisory officer. The decision of the supervisory officer is final.
2. 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.
3. If, owing to temporary circumstances, a student who would not normally require accommodations requires one or more in order to take the test, 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, 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.

2. Accommodations that are not listed in the EQAO Guide for Accommodations, Special Provisions, Deferrals, and Exemptions

When a parent, adult student, or principal identifies a need for an accommodation that is not listed in the EQAO guide or involves more than double the time allowed for the test, that conforms to the definition of accommodations in the guide, and that is described in the student's IEP, the parent, adult student, or principal must submit the request for consideration to the Chief Assessment Officer of the EQAO. The decision of the Chief Assessment Officer is final.

Deferrals of the Test

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 Test

To be eligible for an exemption, a student must have an IEP. The IEP must include documentation to support an exemption from the OSSLT 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 16 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 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 but the parent or adult student disagrees with this decision, the student must be allowed to write the test. Where the principal decides that the student should write the test 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 services is to take the test, the principal must ensure that the student has a fair and equal opportunity to successfully complete the test. 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 must be kept in the student's Ontario Student Record (OSR).

Appendix - Human resources required for the implementation of accommodations for students with special needs who take the Ontario Secondary School Literacy Test

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 Ontario Secondary School Literacy Test 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.

1. In this document, school board(s) and board(s) refer to district school boards and school authorities.
2. In this document, parent(s) refers to parent(s) and guardian(s).
3. This document is available in print and on the ministry's website, at http://www.edu.gov.on.ca.
4. See OSS, section 5.4, and Individual Education Plans: Standards for Development, Program Planning, and Implementation, 2000, p. 5.