Alternate Assessment: Who Qualifies, the 1% Cap and the Tests

Estimated reading time: 20 minutes

Alternate assessment is the version of a state’s annual test taken by students with the most significant cognitive disabilities who cannot take the general test even with accommodations. It covers the content of the student’s enrolled grade, reports results against alternate academic achievement standards, and the IEP team decides who takes it. This guide covers the federal rules, who participates, the 1% cap, diploma effects, the main tests in use in 2026-27 (Dynamic Learning Maps, MSAA and state-developed tests), the alternate English proficiency tests and a decision checklist. It describes rules, not legal advice: check your state’s guidelines and involve district counsel when a decision is disputed.

Executive Summary

Federal rules cap alternate assessment participation at 1.0% of students assessed in each subject statewide, and several large states remain above it. In 2024-25, Florida reported 1.39% to 1.49% by subject and New York 1.56% to 1.58%. The U.S. Department of Education (ED) declined Florida’s and California’s waiver requests for 2025-26, though its September 2025 memo notes that the number of states above 1.3% in mathematics fell from 16 to 9 since 2017-18.

The cap is a state number built from individual IEP meetings. Districts that get it right apply the state definition to real evidence, explain diploma effects to families and revisit the decision every year.

What Is an Alternate Assessment?

An alternate assessment aligned with alternate academic achievement standards (AA-AAAS) is a state test that covers the academic content standards for the grade in which a student is enrolled and reports results against alternate achievement standards set for students with the most significant cognitive disabilities.

Under ESEA section 1111(b)(1)(E), alternate standards must be aligned with the state’s content standards, promote access to the general curriculum, reflect the highest possible standards achievable by these students, be designated in each student’s IEP, and keep a student who meets them on track for postsecondary education or employment. States name them differently: Essential Elements (Dynamic Learning Maps), Core Content Connectors (MSAA, California) or Access Points (Florida). No other “modified” standards are allowed (34 CFR 200.6(c)(6)).

Alternate Assessment vs Accommodations

ED’s September 2025 memo states the default: “Nearly all students with disabilities should be expected to make academic progress measured against grade-level achievement standards.” See IEP accommodations and accommodations vs modifications.

The Federal Rules for Alternate Assessments

• Everyone is assessed: all children with disabilities take state and districtwide assessments, with accommodations and alternate assessments if necessary, as their IEPs indicate (34 CFR 300.160(a)).
• Grade-level alignment: the alternate covers the content standards for the enrolled grade (34 CFR 200.6(c)(1)).
• A written reason: the IEP states why the student cannot take the regular assessment and why the particular alternate is appropriate (34 CFR 300.320(a)(6)(ii)).
• Short-term objectives: the IEP includes benchmarks or short-term objectives (34 CFR 300.320(a)(2)(ii)); see our complete guide to IEP goals.
• Trained staff: states must ensure that teachers, paraprofessionals and other staff know how to administer alternate assessments (34 CFR 200.6(b)(2)(ii)).
• Separate reporting: states report how many students with disabilities take each kind of assessment (200.6(c)(5)).

Who Takes an Alternate Assessment

Each state must give IEP teams guidelines for deciding case by case, including a definition of “students with the most significant cognitive disabilities” that addresses cognitive functioning and adaptive behavior (34 CFR 200.6(d)(1)):

• A disability category or English learner status does not determine it.
• Past low achievement is not enough, nor is a past need for test accommodations.
• The test is the level of support: extensive, direct individualized instruction and substantial supports to make measurable gains on grade-level content.

How Three States Define the Group

Details are in our guides to STAAR Alt 2, the Florida alternate assessment and NYSAA. Florida and New York both treat the decision as annual.

Reasons That Cannot Drive the Decision

New York’s guidelines rule out decisions based solely on disability category, educational environment, instructional setting, language differences, absences, cultural or environmental factors, past low achievement or past need for accommodations. Its FAQ adds that a student whose behavior escalates on difficult tasks but who does not meet every criterion takes the general test with accommodations.

The 1% Cap on Alternate Assessment Participation

In each subject, alternate assessment takers may not exceed 1.0% of all students assessed in the state (34 CFR 200.6(c)(2)).

• Districts: a state may not prohibit a district from exceeding 1.0%, but must require a justification, provide oversight and publish the justifications (200.6(c)(3)).
• States: a state may request a one-year waiver at least 90 days before its window, with subgroup data, proof that it assessed at least 95% of all students and of students with disabilities, and an improvement plan (200.6(c)(4)).

ED’s September 25, 2025 memo adds that any 2025-26 request, new or extension, must show lower participation in each subject. Recent figures, as each state reports them:

Sources: ED response to Florida; ED response to California; NYSED Updated 2026 Plan. In both letters, ED found that rates had increased. New York flagged 452 districts above 1.0% on 2024-25 data and required state training for their CSE members.

Alternate Assessment and the High School Diploma

The diploma is where a test decision becomes a life decision. Federal rules require states to:

• Explain the effects to IEP teams, including how the alternate may delay or affect a regular high school diploma (34 CFR 200.6(d)(2), 300.160(d)).
• Inform parents that achievement will be measured on alternate standards and how that may affect the diploma (200.6(d)(3), 300.160(e)).
• Keep the door open: the student may not be precluded from attempting the regular diploma requirements (200.6(d)(4)).

A regular diploma cannot be aligned to alternate standards (20 U.S.C. 7801(43)), but a state may count in its graduation rate students on the alternate who earn a standards-based, state-defined alternate diploma (20 U.S.C. 7801(25)). Florida offers a standard diploma through access courses, with a score of 3 on the alternate in Access ELA II, Access Algebra I or Access Geometry unless results are waived with parental approval (Rule 6A-1.09963, F.A.C.). New York awards the Skills and Achievement Commencement Credential, which NYSED says is not a regular diploma. Plan the conversation with transition IEP goals.

The State-Defined Alternate Diploma

A state-defined alternate diploma is a diploma a state may create for students with the most significant cognitive disabilities who take the alternate assessment, and ESSA lets the state count those students as graduates if the diploma meets three conditions. Under the graduation rate definitions in ESEA section 8101(23) and (25), the diploma must be:

• Standards-based;
• Aligned with the state requirements for the regular high school diploma;
• Obtained within the period for which the state ensures FAPE under IDEA.

A general equivalency diploma, certificate of completion or certificate of attendance never counts. An alternate diploma is not a regular high school diploma, so it does not end the right to FAPE: under 34 CFR 300.102(a)(3), graduation ends it only with a regular diploma, and a regular diploma may not be aligned to alternate standards. Two state examples, as of October 2026:

Sources: Indiana Department of Education, Alternate Diploma FAQ (updated July 11, 2023); Georgia State Board of Education Rule 160-4-2-.48 (effective March 11, 2020). Other states award credentials that are not diplomas, as New York does with its commencement credential, so read your state’s graduation rule before the IEP team talks about diploma options.

Alternate Assessment Families in 2026-27

Lists come from DLM and the MSAA 2026 score report guide. The District of Columbia and the Department of War Education Activity appear on both, and DLM states may use it for some subjects only, so confirm subjects on your state’s page.

Dynamic Learning Maps (DLM)

Year-End model: Alaska, Colorado, Illinois, Maryland, New Hampshire, New Jersey, New Mexico, New York, Oklahoma, Pennsylvania, Rhode Island, Utah, West Virginia and Wisconsin. Instructionally Embedded model: Arkansas, Delaware, Idaho (joined October 2026), Iowa, Kansas, Missouri, Montana, North Dakota and Tennessee.

• Essential Elements: grade-specific expectations, each tested at linkage levels from Initial Precursor to Successor in ELA and mathematics (four levels in science).
• Testlets: short item groups sharing a context; in spring 2027, Year-End students take 9 in ELA, 6 to 8 in mathematics and 8 or 9 in science, by grade.
• Two models: Year-End states test in spring, with an optional earlier window whose results do not count toward end-of-year reports; Instructionally Embedded states assess through the year.
• Training: teachers pass each required module with 80% or higher on its post-test before testing.

Sources: DLM pages and its 2026-27 Year-End Test Administration Manual. Results use four levels: Emerging, Approaching the Target, At Target and Advanced.

MSAA: The Multi-State Alternate Assessment

The MSAA assesses ELA (reading and writing) and mathematics in grades 3-8 and high school, aligned with the MSAA Core Content Connectors. According to its 2026 score report guide:

• Format: computer-based and stage-adaptive, mostly selected-response items written at three levels of complexity, given one-on-one, on paper when needed.
• Length: 45 to 55 items per content area across two sessions, including a scaffolded writing prompt in ELA.
• Science: eight partners, including Arizona, Maine and Vermont, also test science in grades 5, 8 and high school.
• Results: scale scores from 1200 to 1290 and four performance levels.

State-Developed Alternate Assessments

• Texas, STAAR Alternate 2: a paper test in mathematics, RLA, science and social studies, grades 3-8 and high school, replaced in 2027-28 by what TEA calls “the SST Alternate assessment, previously STAAR Alternate 2.” See STAAR Alt 2 and the ARD meeting guide.
• Florida, FAA: a Performance Task and a Datafolio aligned to Access Points; see the Florida alternate assessment guide.
• California, CAAs: computer-based, one-on-one and stage-adaptive, in grades 3-8 and 11 for ELA and mathematics, with three performance levels (CDE fact sheet); the CAA for Science uses three embedded performance tasks, with a window that opened on September 15, 2026.
• Ohio, AASCD: aligned to Ohio’s extended standards, ELA and mathematics in grades 3-8, science in grades 5 and 8, and a high school test that adds social studies (Ohio Department of Education and Workforce).
• New York, NYSAA: delivered through DLM; see NYSAA.

Alternate English Language Proficiency Assessments

States must provide an alternate English proficiency test for English learners with the most significant cognitive disabilities who cannot take the regular one even with accommodations (34 CFR 200.6(h)(5)):

Make the content and language decisions at the same meeting; the legal frame is in our guide to dually identified students.

Alternate ELPA21: The Alt ELPA

The Alt ELPA, sometimes called Alternate ELPA21, is ELPA21’s English language proficiency test for English learners with the most significant cognitive disabilities, with a screener to identify English learners and a summative test to measure yearly progress. According to ELPA21:

• Design: the summative test was developed through a 4-year U.S. Department of Education grant by the Collaborative for the Alternate Assessment of English Language Proficiency (CAAELP), an Iowa-led project, with researchers at UCLA CRESST; it was first administered in 2022-23.
• Results: scores for receptive skills (listening, reading) and productive communication (speaking, writing), domain scores and an overall proficiency determination; a student can be proficient with several domain exemptions.
• Screener: the Alt ELPA Screener is given one-to-one, year-round, and typically takes 6 to 22 minutes depending on grade band.

In January 2025, UCLA CRESST, which has housed ELPA21 since 2016, listed the member states as Arkansas, Iowa, Louisiana, Mississippi, Nebraska, Ohio, Oregon, Tennessee and West Virginia, with Arizona and Connecticut administering only the Alt ELPA (CRESST, ELPA21 at a Glance, updated March 2026). States may rename the test: Ohio gives it as the Alt-OELPA, in a window that typically falls in February and March. California uses its own alternate instead; see our guide to the Alternate ELPAC.

Alternate Assessment Decision Checklist

The checklist below is an original example to adapt to your state’s form; it does not replace the state’s own decision tool.

1. Start with the general test: document the accommodations tried and their results.
2. Check the state’s stop rules, such as a specific learning disability or a speech impairment alone.
3. Gather evidence across domains: cognition, adaptive behavior, communication and classroom data.
4. Test each excluded reason: would the answer change without the label, setting, absences or behavior?
5. Apply every criterion of the state definition and record the evidence.
6. Write the IEP statement and add short-term objectives to each annual goal.
7. Explain diploma effects and obtain written consent where the state requires it.
8. Decide the language test for English learners at the same meeting.
9. Calendar the review for next year.

Our IEP meeting guide covers how to run the meeting itself.

Funding and Staffing

IDEA Part B, state and local funds pay for the instruction behind the test; the cost districts feel most is staff time. DLM, the FAA, the MSAA and the CAAs are all given one student at a time, and states must ensure that staff are trained to administer them (34 CFR 200.6(b)(2)(ii)). With 45 states reporting special education teacher shortages in 2024-25 (Learning Policy Institute, 2026), certify more test administrators than the roster strictly needs.

Common Mistakes District Leaders Make

1. Deciding by label or classroom. A self-contained placement or an intellectual disability category does not decide eligibility.
2. Using the alternate to manage behavior or test stress. New York’s FAQ points those students to accommodations instead.
3. Carrying the decision forward. Florida and New York both expect a fresh decision each year.
4. Leaving out the IEP statement or short-term objectives. Both are federal requirements for these students.
5. Skipping the diploma conversation. Families should hear it before the first alternate test, not at age 17.
6. Ignoring the district rate. A district above 1.0% owes the state a justification, and the trend matters as much as the number.
7. Forgetting the language test. English learners on the alternate content test usually need an alternate English proficiency test too.

Questions District Leaders Should Ask

• What share of our assessed students take the alternate in each subject, and how has it moved over three years?
• Are some schools, disability categories or student groups overrepresented?
• How many alternate assessment decisions were reversed at the next annual review, and why?
• What do families of these students know about diploma options by middle school?
• Do our English learners on the alternate also take the alternate language test?

Frequently Asked Questions

What is alternate assessment for students with disabilities?

It is the state test for students with the most significant cognitive disabilities who cannot take the general assessment, even with accommodations. It covers the content of the enrolled grade at reduced depth, breadth and complexity and reports results against alternate achievement standards. ESSA and IDEA require it, and each state chooses its test: DLM, the MSAA or its own.

Who qualifies for alternate assessment?

A student with an IEP who meets the state’s definition of the most significant cognitive disabilities and needs extensive, direct individualized instruction and substantial supports to make measurable gains on grade-level content. A disability category, English learner status, past low achievement or past accommodations cannot by themselves qualify a student.

What does alternate assessment mean on an IEP?

It means the IEP team decided the student will take the state’s alternate test instead of the regular one. The IEP must explain why the student cannot take the regular assessment and why the alternate is appropriate, and the IEP must include benchmarks or short-term objectives. Florida also requires written parental consent.

When should alternate assessments be used?

Only when the IEP team, applying state guidelines to current evidence, finds that the student has a most significant cognitive disability and cannot show learning on the general test even with accommodations. A label, a placement, test anxiety or an expected low score is not a reason. Review the decision every year.

What is the difference between an alternate assessment and an accommodation?

An accommodation changes how a student takes the general test, such as a read-aloud or extra time, and results are still measured against grade-level standards. An alternate assessment is a different test measured against alternate standards. Many students with IEPs use accommodations; only a small group, capped at 1.0% statewide per subject, takes the alternate.

What is the MSAA assessment?

The Multi-State Alternate Assessment is an alternate test in ELA and mathematics for grades 3-8 and high school, used in 2026 by Arizona, Maine, South Dakota, Vermont, the District of Columbia, the Bureau of Indian Education, the Department of War Education Activity and four territories. It is computer-based, stage-adaptive and given one-on-one; some partners add science.

Can AI tools support instruction for students who take alternate assessments?

An AI tool can help a teacher draft simplified texts or picture-supported practice linked to an alternate standard, which the teacher then checks. It should never receive secure test items or identifiable student information, and it cannot make the participation decision. See the ChatGPT for teachers guide.

Related Resources

• STAAR Alt 2: Participation Requirements and Released Tests
• Florida Alternate Assessment (FAA)
• NYSAA: New York State Alternate Assessment
• WIDA Alternate ACCESS
• TELPAS Alternate
• Dually Identified Students

Conclusion

Alternate assessment exists so that every student counts in the state’s results, including the small group for whom the general test cannot measure learning. Its value depends on the decision behind it: a state definition applied to real evidence, a written rationale, short-term objectives, an honest diploma conversation with the family and a review every year. Districts that hold to those steps keep the alternate for the students it was built for.

Sources: 34 CFR 200.6, Inclusion of all students; 34 CFR 300.160, Participation in assessments; 34 CFR 300.320, Definition of individualized education program; 20 U.S.C. 6311 (ESEA section 1111), State plans; U.S. Department of Education, Requirements to Request a Waiver or Waiver Extension for the 2025-26 School Year from the 1.0 Percent Cap (September 25, 2025); Dynamic Learning Maps, State Resources; DLM, Test Administration Manual 2026-2027, Year-End Model States; MSAA, 2026 Guide for Score Report Interpretation (Maine Department of Education); California Department of Education, California Alternate Assessments for ELA and Math; ELPA21, Alt ELPA Summative; NYSED, Updated 2026 Plan for Compliance with NYSAA 1.0 Percent Cap (August 2026). State documents and waiver letters are linked where they are cited.

Join the 2027 Special Education Pilot

Students who take an alternate assessment build each skill through many supported repetitions across the year, and the adult time to give them one student at a time rarely stretches that far. Telo AI is being adapted for students with IEPs: patient, 1-on-1 practice aligned to each student’s IEP goals, including daily living skills and speaking practice. We are inviting districts to shape it with us in a 2027 pilot.

Apply to pilot Telo AI in your Special Education program