As with secondary, we are strong supporters of establishing a national minimum standard by which states can define a concentrating student at the postsecondary level and we support the proposed threshold; however, it is our recommendation that the terminology of Concentrator remain as the name of the students that achieve the dosage required to be considered committed or what is being called ‘accountably enrolled’. We feel that the term is well known and understood. It is a part of the fabric and understanding of CTE and the designed and guided progression of a student. Additionally, as this term is in the mindset of stakeholders, it is also in publications and literature.

• Will the 12 credit threshold include 50% of all courses students take as part of their program of study, including general study courses, or just the CTE courses? Since CTE courses are the distinguishing elements of a CTE program, Massachusetts supports enrollment in 50% of CTE courses to be used as the threshold.
• A CTE program of study could be defined as the entire program of study sequence the student takes from high school through postsecondary education. If we use a cohort model for enrollments (only students in CTE cohorts in high school would be allowed into CTE courses in college), how would the CTE program of study be defined for postsecondary students (based on CTE core courses only; general studies plus CTE core courses; pre-college courses (remediation plus General Studies plus core CTE courses).
• If we adopt a cohort model, can dislocated workers be enrolled in CTE courses at all? Maybe there needs to be different model cohorts?
• If a student changes concentration from CTE to Non CTE or other CTE programs after meeting the 12 credits threshold, how will the student be counted?
• As stated above, what if the high school and postsecondary coursework are unrelated? Should the student be counted as a postsecondary students even if there is no link between the high school and postsecondary programs?

I would also suggest that these 12 credits be in CTE coursework as we are looking at CTE programs that, in California, often don't require gen ed for the certificate as we have integrated academic rigor into our CTE and vice versa.

We agree with the 12 credits, however, it should include both academic and technical. Our population could be extremely small if we only counted technical courses and excluded the academic. Academics have a very strong impact on how well some students actually do in technical courses. It could also take some students a year or two to even take the technical courses.

A comprise might be 12 credits with at least 1 technical course being taken.

"Career and technical programs of study" that incorporate secondary and postsecondary elements; include coherent and rigorous content aligned with challenging academic standards and relevant career and technical contents in a coordinated, non-duplicative progression of courses that align secondary to postsecondary education; may include opportunity for secondary education students to gain postsecondary education credits through dual or concurrent enrollment programs or other means; and lead to an industry-recognized credential or certificate at the postsecondary level or an associate or baccalaureate degree.