State to require more reporting on dual enrollment programs |
On Board Online • September 22, 2025
By Sara Foss
Special Correspondent
The state budget passed last spring directed Education Commissioner Betty Rosa to adopt a statewide policy on dual enrollment. As a result, the State Education Department (SED) plans to increase reporting requirements for participating school districts and colleges. The proposal was discussed at a joint meeting of the Board of Regents' Higher Education and P-12 committees in September.
Dual enrollment programs enable high school students to earn college credits, potentially saving them time and money in college. Currently, the state has no way to regulate the quality of these programs or track student outcomes.
The proposed regulations would change that by providing a clear definition of dual enrollment programs and what is required of them. Also, it would require school districts to share demographic data on who is taking these courses.
One goal is to expand participation in dual enrollment programs by low-income students and students from groups that are typically underrepresented in such programs, according to state officials.
The proposed regulations, which were developed in coordination with the office of Gov. Kathy Hochul, would require school districts, charter schools and BOCES with dual enrollment programs to submit a partnership agreement with participating colleges and universities on a form provided by SED by Sept. 1, 2026. These agreements would detail the scope and terms of the dual enrollment program and would have to be updated at least every five years.
Both P-12 institutions and their higher education partners would be required to submit participation and outcome data to SED annually. This data would be published on the SED's website each year to ensure transparency.
Currently, three state-funded dual enrollment programs enable students to take college courses for free, as well as receive academic support:
- New York State Pathways in Technology.
- Smart Scholars Early College High School.
- Smart Transfer ECHS.
Students can earn an associate's degree in these programs.
In addition, individual school districts and BOCES have many dual enrollment programs beyond the three state programs, according to Laura Glass, assistant commissioner in SED's Office of Education Policy. "However, we don't know what those programs look like. We don't know what the outcomes of those programs are, and we don't know the standards for the college courses those students are taking."
Under the proposal, SED would define a dual enrollment program as "any program that is a partnership between at least one school and at least one institution of higher education that provides high school students with the opportunity to enroll in college courses and earn transferable college credit from the institution or institutions while completing high school graduation and diploma requirements."
Glass focused on the phrase "transferable college credit." If course credits earned through dual enrollment programs do not transfer to institutions of higher learning, "students are not going to be realizing the cost and time savings for college, and it could discourage other students from pursuing dual enrollment," she said.
Courses that allow students to earn transferable college credits would have to be listed in the course catalog of the college or university and have the same or comparable learning outcomes, content and rigor as other sections of the course, regardless of how or where they are taught.
"Dual enrollment has a significant amount of research behind it" as a way to prime students to become successful college graduates, said Alex Perry, an SED consultant and senior policy adviser at Washington, D.C.-based Foresight Law + Policy. "Students who have access to college courses in high school are more likely to access college by virtue of having taken that course, and they're more likely to complete college."
Less than 2% of New York's public schools participate in the three state-funded dual enrollment programs, but the state has the third-largest dual enrollment population in the nation. "That's tens of thousands, if not hundreds of thousands, of New York high school students who are taking college courses in high school," Perry said.
Perry said that certain groups of students - those who are Black, Hispanic, disabled, English Language Learners, male or come from rural or urban backgrounds - are typically underrepresented in dual enrollment programs.
"The state should think about its role in how to expand access so more students can gain access to those experiences," Perry said. "For the students who don't have access right now, it could be life-changing. So how do we think about expanding access and opportunity?"
The state budget passed last spring created a new "College in High School Opportunity Fund" that provides funding for all dual enrollment programs in the state, including a new "College in High School Programs" as well as P-TECH, Smart Scholars Early College High School (ECHS) and Smart Transfer ECHS.
The Legislature allocated $9.1 million for the new College in High School Programs, and the SED is developing an RFP for it.
Regent Susan Mittler cautioned against setting students up for failure by expanding access to students who aren't ready to take college courses. "If I take the class and I fail the class, I still will have learned, but it's a very negative experience," she said.
Glass said that academic advising and counseling for students in dual enrollment programs is critical. "It can help students figure out what makes sense," she said.
Regent Roger Tilles asked whether the paperwork requirements might backfire by reducing the number of schools and colleges with dual enrollment programs. "I worry every time we set something up [with reporting requirements] and it becomes too much for a district or a college to have the program," he said.
Glass described the paperwork requirements as minimal. "We really want to promote local, flexible, innovative ideas that best meet the needs of districts," she said.
There are three formats for taking dual enrollment courses: online from a college professor, in-person from a college professor and from a high school teacher credentialed as an adjunct professor. According to Glass, students tend to take general education courses such as English 101 and career and technical education courses.
A notice of proposed rule-making is scheduled to be published in the state register on Sept. 24 for a 60-day public comment period.