BOSTON — School districts could soon be required to make new coursework and postsecondary planning available as Massachusetts reimagines high school graduation requirements, but some education overseers bristled Tuesday over the timetable for change and other logistical hurdles.

Department of Elementary and Secondary Education staff previewed regulatory proposals for a new graduation framework, including two major components: Schools must offer MassCore, a state-recommended program of study, and MyCAP, a college and career readiness program. A 2024 voter law scrapped MCAS exams as a graduation requirement and the proposals echo June recommendations from the K-12 Statewide Graduation Council that look to redefine the value of a diploma.

“We want to begin preparing for the proposed regulations that we anticipate bringing to you in November for discussion,” DESE Deputy Commissioner Lauren Woo told the Board of Elementary and Secondary Education Tuesday in Williamsburg.

“I do want to emphasize an important distinction here: The regulations that we will contemplate this year will establish expectations for what high schools must offer,” Woo continued. “They are not to impose new graduation requirements on individual students. Any student-level graduation requirements aligned with the broader recommended framework will require legislative action.”

DESE recently released a “readiness workbook” that schools and districts can use as they gauge how they currently stack up against the state’s proposed graduation framework, which incorporates other components such as end-of-course assessments, financial literacy, AI and digital literacy, civic readiness and work-based learning, said Adam Seidel, senior associate commissioner of secondary schools and beyond.

MassCore, designed to align with admissions requirements at public four-year colleges and universities in Massachusetts, outlines a sequence of classes to take across English language arts, math, lab-based science, history and social science, world language, physical education, arts and other subjects. The board adopted MassCore in 2007 and updated it in 2018.

“Our current guidance recommends that schools leverage DESE’s curriculum frameworks to ensure each course meets our standards, and we know this is one of the areas that we want to focus on as we move towards regulations and implementation,” Seidel said. “I will also note that, as part of this, we anticipate preserving the current flexibilities and substitutions that are part of our guidance to help make sure that students in different circumstances can access the curriculum.”

Seidel said that about 70% of high schools that submitted their local graduation requirements for state review either already require MassCore “in its totality” or are “just one core subject away.” In 2025, 82% of public high school graduates completed MassCore, he said.

The K-12 Statewide Graduation Council proposed requiring the Class of 2031 to complete MassCore in order to graduate high school, according to a memo to the BESE Board. 

“The idea that you could start implementing this for the Class of 2031, which means for students beginning next year, on top of everything else going on — like literacy, on top of MyCAP, on top of the work you have to do — I think as a board, it’s useful to say to an organization, you got to be a little bit realistic,” BESE Board Vice Chair Matt Hills said. “Under the best of circumstances, the bandwidth isn’t there.”

School districts are also navigating the new literacy reform law, which establishes standards for evidenced-based reading instruction for kindergarten through third grade, requires universal literacy screenings, expands teacher training requirements and installs new accountability measures. The board on Tuesday approved opening up regulations for public comment, with input due by Dec. 28 and a vote expected on Jan. 19.

Invoking equity and access concerns around MassCore, Hills questioned how the state will support smaller districts who can’t hire additional math or foreign language teachers — and asked whether officials would grant waivers that may only deepen educational disparities. Hills, speaking to DESE staffers about the proposed 2031 implementation timeline said, “I don’t see it happening.”

“And I see a lot of cleanup and a lot of improvising to get districts to where you need to be if you move too fast, which is what’s happening, I think, when you start requiring some of these things beginning in the Class of 2031,” Hills said.

Raising another financial concern, board Chair Katherine Craven warned, “The false footing on this could be that the districts say, ‘Hey this is an unfunded mandate. We’re already under so much stress.'”

Education Secretary Stephen Zrike Jr. countered there’s “urgency” around the issue, as he pointed to “too many kids” securing high school diplomas without being ready for college or careers. DESE Commissioner Pedro Martinez pointed to support for the MassCore and MyCAP recommendations, saying he hasn’t heard pushback from superintendents.

“It is important to keep understanding that the majority of the lift, for at least MassCore, is going to be in the later grades,” Martinez said. “It will be in the 11th and 12th grade, so there’s already a runway built in and the superintendents know that.”

John Papay, a Brown University education policy professor, discussed research that found students in schools with high MassCore completion rates were more likely to graduate college. But he said there were “large differences” when accounting for student characteristics, with only 55% of Hispanic students and 59% of Black students completing MassCore — compared to 80% of white students, according to 2025 data. MassCore completion was also low among immigrant newcomers and students with disabilities.

Papay voiced uncertainty over whether MassCore would continue to be a predictor of long-term outcomes, such as college, if the coursework became a requirement.

“Implementation of any requirement will matter,” Papay said. “I think there are important questions about data coverage and quality, about access to courses, about course equivalency and passing standards across schools, about certain populations of students, particularly as we’ve discussed these immigrant newcomers and some students with disabilities. And then some questions about whether there will be unintended district and school responses.”