The Counselor is Out: Why One High School "Abolished" the Role for a Graduation Coach

Since September 2024, the guidance office at Pocahontas County High School (PCHS) has served as a silent monument to a systemic crisis. The desk remained bare, the chair unoccupied, and the "Counselor" plaque on the door increasingly felt like a relic of a bygone era. For over a year, the district posted the vacancy to a "failed market"—a landscape where RAMP-certified professionals simply do not exist for rural placements. Faced with a looming administrative collapse, Superintendent Dr. Leatha Williams made a radical, calculated pivot in early 2026.

Rather than continuing to chase a phantom candidate, the district formally abolished the traditional counselor role. In its place, PCHS is pioneering a hybrid model that bifurcates academic logistics from clinical mental health—a move that offers a stark, high-stakes blueprint for how rural districts might survive the national staffing shortage.

Takeaway 1: When "Abolishing" a Role is a Strategic Survival Tactic

The decision to strike the high school counselor position from the books for the 2026–2027 school year was not an austerity measure; it was a desperate maneuver for compliance. Following a blunt 2025 State of Emergency review by the West Virginia Department of Education (WVDE), PCHS was found to be in total dereliction of its Comprehensive School Counseling Program (CSCP).

By "abolishing" the role, Dr. Williams effectively bypassed the impossible certification requirements that had left the office empty. This structural pivot allowed the district to repurpose stagnant funding into a "Classified" role that could actually be staffed, transforming a perpetual vacancy into a functional hub for student data.

"This is not a budget cut—it is a total reimagining of a failed market. By trading a clinically certified vacancy for a results-driven Graduation Coach, we are prioritizing administrative function over a role we can no longer fill."

Takeaway 2: The Rise of the "Graduation Coach" (Academics Over Therapy)

The new Graduation Coach is the engine of the PCHS front office, handling the high-volume "heavy lifting" that was neglected during the vacancy. However, the move away from a certified counselor carries immense stakes for student futures. Under West Virginia Board of Education (WVBE) Policy 2510, course codes are the difference between a future and a dead end.

The division of labor is now stark:

The Graduation Coach: Manages college applications, credit recovery, and the auditing of transcripts. They must ensure that a core class like Algebra I (WVEIS code 3061) isn't miscoded as an elective—an error that could cost a student their PROMISE Scholarship or NCAA eligibility.
The Therapeutic Gap: Because the coach lacks clinical licensure, they cannot provide "responsive services" or therapeutic interventions. They are an architect of data, not a provider of care.

Takeaway 3: The "Wednesday-Only" Mental Health Model

To fill the void left by the abolished counselor, PCHS established a "Warm Handoff" protocol with Youth Health Services (YHS). Students in distress are referred to YHS clinicians, including Dr. Dilip Chandran and Dr. Mary Boyd, who provide psychiatric evaluations and medication management via "The Annex" located on campus.

While this co-located model solves the rural transportation hurdle, it has introduced a precarious timeline: clinicians are only on-site on Wednesdays. Community members have raised alarms that this "one day a week" access fails the "immediate and consistent" mandate of WVBE Policy 4373. In the wake of recent student tragedies, critics argue that a student in crisis on a Monday is left in a "therapeutic gap" that risks violating their right to a safe and supportive learning environment.

Takeaway 4: The Legal "Ghost" Supervisor

Since the Graduation Coach is a classified employee without state-mandated administrative certification, the district had to engineer a sophisticated bureaucratic workaround: the County Supervisor of Counseling. This "ghost" administrator provides the legal sign-off on all academic plans from a distance.

This role is the district’s primary defense against the "intentional errors" in transcripts flagged during the 2025 review. Crucially, this supervisor oversees the January Benchmark, ensuring that all Personalized Education Plans (PEPs) are completed mid-year so the master schedule can be "student-driven" rather than forced. Without this certified oversight, the district would remain in a state of non-compliance with Policy 2315.

Takeaway 5: The Hidden Cost of Data and Medicaid

Outsourcing mental health to third-party partners like YHS has turned student data into a fiscal commodity. To recoup the costs of these external services, the district relies heavily on the West Virginia Medicaid Consent & Release form.

This has sparked friction between the administration and parents. While the district uses Medicaid billing for sustainability, federal law and WV Policy 2419 are clear: the school cannot condition a student's Free Appropriate Public Education (FAPE) on the parent’s willingness to share clinical data or consent to billing.

"The controversy here is foundational: Is a student's access to academic support being held hostage by their parents' willingness to sign a Medicaid release for an outside vendor?"

Takeaway 6: From Homeroom Teachers to WVEIS Specialists

The 2025 State of Emergency revealed a "lack of expertise" that bordered on the catastrophic, with an 89% non-compliance rate in special education records. Previously, homeroom teachers and secretaries were essentially forced to guess their way through complex scheduling, leading to the "four delivery systems" of counseling becoming non-existent.

Under Corrective Action 1.1, PCHS has implemented a "Zero-Inference Rule." Now, only "trained and authorized" staff with specific West Virginia Education Information System (WVEIS) certification can touch a student’s permanent transcript. This shifts the burden of transcribing transfer credits away from teachers and into a rigid, audited pipeline, aiming to end the systemic failures that once put every PCHS diploma's validity at risk.

Conclusion: A New Blueprint or a Temporary Fix?

The "Pocahontas Model" is a cold-eyed admission that the traditional American high school structure is breaking. By separating the administrative Graduation Coach from the clinical therapist, Dr. Williams has found a way to keep the doors open and the transcripts legally compliant.

Yet, the questions that remain are as much moral as they are bureaucratic. Is a "Wednesday-only" clinical model a sustainable response to student trauma? Can a "ghost" supervisor truly protect the scholarship eligibility of a thousand students? Whether this is a visionary blueprint for a specialized future or a desperate triage of a dying system, Pocahontas County has proven one thing: in the face of a failed market, the old rules no longer apply.

Summary of the "Fix"

The Vacancy: The high school had been without a certified counselor since September 2024. Because the position remained unfilled, the school failed to maintain a Comprehensive School Counseling Plan, which is required by state policy.

The Decision to Abolish the Position

In early 2026, Superintendent Dr. Leatha Williams made the controversial decision to abolish the traditional high school counselor position. This was not a budget-cutting measure but a strategic response to a "failed market."

Lack of Applicants: The position had been posted repeatedly for over a year with zero qualified applicants.
Structural Change: Rather than keeping a vacant "ghost" position, the district repurposed the funding to create a Graduation Coach role.
Certification Flexibility: A Graduation Coach does not require the same specific RAMP-certified counseling credentials but can handle the administrative "heavy lifting" like college applications, credit recovery, and graduation tracking.

The shift from a certified school counselor to a Graduation Coach at Pocahontas County High School represents a move from a clinically trained mental health role to a results-driven academic support role.

By "abolishing" the counselor position, the district effectively lowered the barrier to entry to ensure the office was staffed, while offloading the therapeutic duties to external partners and higher-level county supervisors.

Because the Graduation Coach does not hold a specialized clinical license, the Pocahontas County Board of Education had to create a new County Supervisor of Counseling role. This supervisor (who is certified) provides the legal "sign-off" on transcripts and academic plans that the PCHS Graduation Coach prepares, ensuring the district remains compliant with WVBE Policy 2315.

To fill the therapeutic gap left by the absence of a certified school counselor, Pocahontas County Schools has established several strategic partnerships. These agencies provide the clinical "Tier 3" interventions—such as one-on-one therapy and crisis management—that the new administrative Graduation Coach role is not licensed to perform.

The "Warm Handoff" Protocol

Under the new PCHS model, the process for a student in crisis typically looks like this:

Identification: A teacher or the Dean of Students identifies a student in distress.
Referral: The Graduation Coach or CIS Representative facilitates a referral to Youth Health Services.
Treatment: Because YHS is located on the school campus (the "Annex"), the student can receive professional therapy during the school day without requiring the parent to provide transportation to an off-site clinic—a critical factor in a rural county with limited public transit.

The Student Assistance Team (SAT): For academic or persistent behavioral issues, the Dean refers the case to the school’s SAT. This team includes the Dean, the new Graduation Coach, and relevant teachers. They decide if the student needs "Tier 2" school-based interventions (like extra tutoring or check-ins) or "Tier 3" clinical help.

Superintendent Dr. Leatha Williams confirmed that while the high school counseling position was formally abolished for the 2026–2027 school year, it is being replaced by a Graduation Coach to ensure students have consistent academic support that the district was previously unable to provide due to a lack of certified applicants.

Financial Strategy: By abolishing the long-vacant certified counselor position, the district freed up the budget to hire a "Classified" Graduation Coach, who does not require the same rare certifications but can perform the administrative duties that led to the original crisis.

To address the "therapeutic gap," the district has formalized its reliance on external partners.

The Partnership: YHS clinicians now visit the high school specifically on Wednesdays to provide direct mental health therapy.

The Challenge: During the January 2026 board meeting, some community members expressed concern that one day a week is insufficient, especially following recent student and staff tragedies.

The Contract: The agreement with YHS is part of the Expanded School Mental Health (ESMH) initiative, which allows the school to host clinical therapists on-site without the school district having to employ them as faculty.

Psychiatric Oversight: The contract includes access to Dr. Dilip Chandran and Dr. Mary Boyd for psychiatric evaluations and medication management via tele-health or at their main clinics—a critical resource in a county with no resident child psychiatrist.

5. Funding and Sustainability

The contract is part of a broader state fiscal strategy for 2026. West Virginia HB 2026 (the 2025/2026 Budget Bill) prioritized "Personal Services" for schools, but the use of YHS allows Pocahontas County to save on "salary and benefits" costs for a full-time employee while still providing high-level clinical care through this contractual partnership.

I am requesting to inspect and receive copies of the following:

Disclosure Logs: A complete list of all instances where my child’s educational records (including grades, attendance, and disciplinary reports) were shared with Youth Health Services (YHS) or its clinicians, including the names of the individuals who received the data and the specific "legitimate educational interest" cited for the disclosure.
The Referral Pipeline: Any written referrals, "warm handoff" notes, or Student Assistance Team (SAT) records generated by the Dean of Students or Graduation Coach regarding my child’s clinical services.
Memoranda of Understanding (MOU): The specific data-sharing agreement currently in effect between Pocahontas County Schools and Youth Health Services that governs how my child's information is protected during "co-located" services.
Communication Records: Any emails or digital logs between school staff (specifically the Graduation Coach) and YHS staff regarding my child’s "compliance" or "functional status" in treatment.

The "Medicaid/Billing" Consent

Because PCHS has struggled with funding for counselors, they often rely on the WVDE Medicaid Consent & Release form.

This form specifically allows the school to tell the state Medicaid agency that your child received a "mental health service" at school so the district can get reimbursed.
Note: Signing this is optional. The school must provide IEP-mandated services even if you refuse to let them bill Medicaid.

Specifically, I disagree with the school’s decision to:

[Example: Reduce therapeutic support minutes]
[Example: Change my child’s classroom placement]
[Example: Condition my child’s academic support on the use of outside clinical partners (YHS)]

My reasons for this disagreement include:

[Reason 1]: (e.g., "The proposed change does not provide a Free Appropriate Public Education (FAPE) as required by WV Policy 2419.")
[Reason 2]: (e.g., "My child requires consistent, on-site support that is not contingent upon third-party clinical data sharing.")

I am writing to formally request mediation to resolve a disagreement regarding the provision of a Free Appropriate Public Education (FAPE) and the implementation of services for my child, [Student Name], at Pocahontas County High School.

1. Description of the Issue: Following the district's recent transition from a certified counselor to a Graduation Coach model and the outsourcing of clinical services to Youth Health Services (YHS), there is a disagreement regarding:

[Example: The frequency of therapeutic sessions provided on-site.]
[Example: The school's proposal to reduce support minutes because I have limited a data-sharing ROI.]
[Example: Lack of consistent social-emotional support as outlined in my child’s IEP/504 plan.]

2. Proposed Resolution: I am seeking a resolution that ensures my child receives consistent, qualified therapeutic support that is not contingent upon third-party clinical contracts, and that my child’s academic and emotional needs are met in compliance with WV Policy 2419.

To ensure the state doesn't dismiss your complaint on a technicality, it must include:

A Specific Violation: You must cite a violation of WV Policy 2419 or the IDEA. (Example: "Failure to provide transition services due to the lack of a certified counselor.")

Since Pocahontas County High School (PCHS) was under a State of Emergency from February 12, 2025, to February 11, 2026, your facts should highlight how the district is failing to maintain the "Corrective Actions" that were supposed to be fixed during that intervention.

Failure to Provide a Comprehensive School Counseling Program (CSCP)

"Despite the WVDE's 2025 Special Circumstance Review finding (Noncompliance 1.1) that PCHS lacked a required CSCP, the district has formally abolished the certified school counselor position for the 2026-2027 school year. By replacing a certified counselor with a non-certified 'Graduation Coach,' the district is failing to meet WVBE Policy 2315, which mandates a program delivered by a professionally certified school counselor."

Lack of Access to Social-Emotional and Crisis Support

"The district's current plan relies on third-party clinicians (Youth Health Services) who are only on-site for limited hours (e.g., Wednesdays). This creates a 'therapeutic gap' where students in crisis have no immediate access to a licensed professional during the remaining four days of the school week, violating the student's right to a safe and supportive learning environment as outlined in WVBE Policy 4373."

3. Improper Handling of Academic Records (Transcripts & PEPs)

"As identified in the WVDE’s 2025 findings, PCHS demonstrated systemic failure in transcribing grades and developing Personal Education Plans (PEPs). The current reliance on a Graduation Coach—a role that lacks the clinical and administrative certification of a school counselor—continues to put the accuracy of student transcripts and the state-mandated PEP process at risk (Ref: WVBE Policy 2510)."

"During the State of Emergency, the district was found to have an 89% non-compliance rate in special education. The removal of the high school counselor position has further strained the Student Assistance Team (SAT) and IEP process, as there is no longer a certified staff member to coordinate the behavioral and emotional data required for legally compliant IEP meetings."

Because Pocahontas County High School (PCHS) is currently operating without a certified counselor, several specific protections in the Student Code of Conduct and Attendance policies are likely being compromised.

The Counselor’s Mandate: This policy requires schools to respond "immediately and consistently" to bullying. Crucially, it mandates Level 1 and Level 2 Interventions, which specifically include "referral to the school counselor."

The Violation: Without a counselor, the school is missing the primary professional responsible for the "rehabilitative" side of discipline—such as conflict resolution and social-skills training—leaving only the "punitive" side (suspension/expulsion) handled by the Dean of Students.

The Counselor’s Mandate: This is the policy that governs Personalized Education Plans (PEPs) and graduation requirements. Section 6.2 explicitly states that students must verify course choices with a counselor to ensure eligibility for the PROMISE Scholarship and NCAA.

The Violation: The WVDE's 2025 review found "intentional errors" in transcripts. By using a non-certified Graduation Coach, the school may be in ongoing violation of Policy 2510's requirement for professional oversight of the high school credit and graduation audit process.

"The current staffing model at PCHS fails to meet the procedural requirements of WVBE Policy 4373 (Section 3.1) regarding the provision of counseling interventions for student conduct, and WVBE Policy 2510 regarding the certified oversight of graduation audits."

The 2025 Special Circumstance Review by the West Virginia Department of Education (WVDE) was blunt: the lack of a counselor at Pocahontas County High School (PCHS) wasn't just a vacancy—it was a systemic failure that directly impacted student futures.

Counseling Program (CSCP) was essentially non-existent.

The Warning: The school failed to provide the "four delivery systems" of counseling (curriculum, individual student planning, responsive services, and system support).
Corrective Action 1.1: "The school must annually develop a CSCP Plan to outline priority goals... The plan must address the five school counselor performance standards."

Corrective Action 1.1: "The school must annually develop a CSCP Plan to outline priority goals... The plan must address the five school counselor performance standards."

Why this matters now: If the new Graduation Coach is not a certified counselor, they cannot legally deliver the "curriculum" or "responsive services" required by Policy 2315.

The state discovered that homeroom teachers were being forced to act as counselors, leading to a "lack of expertise" in scheduling and graduation requirements.

Corrective Action 1.2: "The school principal, leadership team, and counselor or dean of students will ensure the creation and yearly review of the PEP (Personalized Education Plan) with each student... and document this review."

Corrective Action: The state mandated comprehensive monitoring by the Office of Special Education. The district was warned that it must establish a Student Assistance Team (SAT), which had been abandoned during the counselor vacancy.

Partnerships: They formalized the deal with Youth Health Services (YHS) to handle the "Responsive Services" (mental health) that the school staff is no longer certified to provide.

The "Zero-Inference" Rule: Standardized instructions were issued to school secretaries and administrators on exactly how to transcribe transfer credits. This was a direct response to the "intentional errors" flagged by the WVDE in 2025.

WVEIS Certification: Administrative staff are now required to undergo specific training for the West Virginia Education Information System (WVEIS). The memos mandate that only "trained and authorized" staff can touch a student's permanent transcript.

Audit Benchmarks: A new timeline was set for grade transcription. Grades must now be fully transcribed and audited at mid-term and end-of-year under the supervision of the new Director of Personnel and Technology.

The January Benchmark: All Personalized Education Plans (PEPs) for middle and high school students must now be completed by mid-January of the preceding year.

Student-Driven Scheduling: The master schedule must now be built based on these PEPs, rather than forcing students into a pre-made, rigid schedule.

Oversight: Because the coach is not a certified counselor, the memos establish a chain of command where the coach’s work is audited by the County Supervisor of Counseling to ensure legal compliance with WVBE Policy 2510.

Formal Request Tip: When writing to the Board Office, ask for: "The formalized administrative guidance and Superintendent Memorandums regarding grading, transcript transcription, and WVEIS access protocols as presented to the WVBE on February 11, 2026."

WVEIS Entry Logs: Confirmation of which staff members have had "Write" access to my child's grade data since the implementation of the new administrative access rules in early 2026.

Transcript

Given the history of the 2025 crisis, look for these specific "clerical" issues:

Missing Credits: Ensure "Dual Credit" courses taken through New River CTC or WVU are actually listed.
WVEIS Code Errors: Check that core classes have the correct 4-digit WVEIS code. For example, Algebra I should be code 3061. If it's miscoded as an elective, it won't count toward the Core GPA.
The "PEP" Match: Does the transcript match the Personalized Education Plan (PEP) that was supposedly reviewed in January?

The "Ghost" in the Guidance Office: What Happens When a School Abolishes the Counselor Role?

1. The Unprecedented Declaration: A Systemic Collapse

In February 2025, the West Virginia Board of Education (WVBE) issued a declaration that chilled the state’s educational landscape: a "State of Emergency" for Pocahontas County Schools. While the public is weary of headlines regarding teacher shortages, the situation at Pocahontas County High School (PCHS) represented something far more sinister than a simple vacancy. It was a total systemic blackout triggered by the absence of a single certified professional.

The "ghost" in the guidance office was not just a missing body; it was a missing brain. For over a year, the school had operated without a certified counselor, leading to what investigative reviews described as a functional collapse of student services. This was a systemic betrayal where graduation audits, mental health support, and even the basic integrity of academic records simply ceased to exist.

2. Takeaway 1: The Death of the "Surrogate Model"

When a critical role remains vacant, districts often resort to a "Surrogate Model," attempting to patch the hole with long-term substitutes or retired teachers. In Pocahontas County, this substitution failed catastrophically. The crisis proved that specialized "clinical brainpower" cannot be replaced by general oversight.

The failure of the surrogate model fundamentally compromised the "Neutral Space." A certified counselor offers a confidential, clinical firewall between the student and the administration. When unqualified surrogates—often doubling as disciplinarians—stepped in, students lost their safe haven. This lack of professional expertise didn't just hurt students; it created a massive legal liability for the district.

Erosion of Legal Immunity: Boards may lose "Qualified Immunity" by knowingly substituting uncertified practitioners for certified professionals.

By choosing "Substitution" over "Professionalism," the district dismantled the protections afforded to both the students and the institution, leaving the school’s "ghostly" halls vulnerable to both academic and legal ruin.

3. Takeaway 2: The "Intentional" Error and the Transcript Scandal

The administrative fallout was nothing short of a scandal. A "Special Circumstance Review" by the WVDE uncovered a pattern of inaccuracies that struck at the heart of academic accountability. Investigators found that student transcripts contained inaccurate transfer credits—an act state officials suggested may have been "intentional" rather than a mere clerical oversight.

Transcript integrity is the quiet foundation of a student’s future; its loss is a form of systemic sabotage. To fix this, the district had to bring in Dr. Rhonda Combs as the Director of Personnel and Technology to overhaul the West Virginia Education Information System (WVEIS) data. The technical fix required the implementation of a "Zero-Inference" Rule, standardizing exactly how transfer credits are transcribed to prevent further "intentional" manipulation.

During the height of this crisis, the lack of professional oversight led to:

A 53% Chronic Absenteeism rate, as students felt untethered from their academic goals.
The total collapse of Personalized Education Plans (PEPs), which were no longer being reviewed or developed.
WVEIS Certification Requirements, mandating that only trained, authorized staff could touch a student’s permanent record.

4. Takeaway 3: De-professionalization as a Strategy (The Graduation Coach)

Facing a "failed market" where the counselor position remained vacant for over a year, Superintendent Dr. Leatha Williams made the controversial decision to "abolish" the position entirely. In its place, the district created the "Graduation Coach"—a "Classified" staff member focused on logistics rather than clinical health.

To bypass the legal requirement for a professional sign-off on transcripts, the district employed a tactical workaround: they created a new "County Supervisor of Counseling" role. This supervisor provides the legal veneer for the work the non-certified Graduation Coach performs.

Feature	Certified School Counselor	Graduation Coach
Legal Mandate	WV Code §18-5-18b (80/20 Rule)	No mandated clinical/admin ratio
Primary Focus	Clinical mental health & direct counseling	Academic logistics & graduation tracking
Authority	Can assess suicide ideation & lead therapy	Case management only; cannot provide therapy
Oversight	Self-governed via professional license	Must be audited by County Supervisor

5. Takeaway 4: The 89% Failure Rate and the Special Education Crisis

The absence of a counselor hit the most vulnerable students the hardest. The 2025 review revealed a staggering 89% non-compliance rate regarding special education services under Policy 2419.

Without a certified professional to lead the Student Assistance Team (SAT), the process was essentially abandoned. Investigators found students with Individualized Education Programs (IEPs) being placed in courses regardless of their needs, simply because no one had the expertise to manage a compliant schedule.

Corrective Action 1.2: "The school principal, leadership team, and counselor or dean of students will ensure the creation and yearly review of the PEP with each student... and document this review."

The district wasn't just failing to meet standards; it was effectively operating outside the law, reacting to a crisis it had no professional capacity to manage.

6. Takeaway 5: The "Therapeutic Gap" and the Clinical Firewall

To address the "Therapeutic Gap," the school moved to a "co-located" service model under the Multi-Tiered System of Support (MTSS). The district partnered with Youth Health Services (YHS) to provide Tier 3 clinical therapy.

This model relies on a "Warm Handoff" protocol from the Graduation Coach to external clinicians. However, this creates a clinical firewall between HIPAA (medical privacy) and FERPA (school records). While this offloads clinical liability, it has created a logistical hurdle. YHS clinicians are only present on Wednesdays at the High School Annex. Community members have expressed grave concerns that a one-day-a-week clinical presence is insufficient for a student body in the wake of systemic trauma.

7. Conclusion: A Probationary Peace

On February 11, 2026, the WVBE voted to lift the State of Emergency, but the district remains in a "probationary" state. Under the direction of Dr. Leatha Williams, the school has implemented "Superintendent Memorandums" to standardize grading and has "intentionally" shifted back to a Block Schedule to facilitate credit recovery for the students left behind during the vacancy.

Pocahontas County serves as a bellwether for rural education. As of March 2026, the "ghost" has been replaced by a Graduation Coach, but the professional heart of the guidance office remains hollowed out. We must ask: Is this a pragmatic solution to a failed labor market, or is it a dangerous lowering of standards that compromises the safety and future of West Virginia’s children? As other districts look on, the "Pocahontas Model" may become either a roadmap for survival or a warning of systemic decline.

Manual for Parental Participation

In February 2025, the West Virginia Board of Education (WVBE) declared a State of Emergency for Pocahontas County Schools. This drastic measure followed a "Special Circumstance Review" that revealed a systemic breakdown at Pocahontas County High School (PCHS), primarily triggered by the absence of a certified school counselor for an extended period.

The emergency status was officially lifted on February 11, 2026, after a year of state-mandated remediation.

The Counseling Crisis and WVDE Intervention

The crisis at PCHS was not just a staffing vacancy but a functional collapse of essential student services.

The Vacancy: The high school had been without a certified counselor since September 2024. Because the position remained unfilled, the school failed to maintain a Comprehensive School Counseling Plan, which is required by state policy.
The Impact: State investigators found that student schedules were not prepared in advance, student transcripts were not being processed correctly, and there was no process for developing Personalized Education Plans (PEPs).
The "Intentional" Error: Most alarmingly, the WVDE found evidence that a student had been transcribed with inaccurate transfer credits—an act investigators suggested may have been intentional rather than a clerical error.

How Duties Were Provided During the Crisis

With no certified professional on-site, the duties of the counselor were handled through a patchwork of temporary measures:

Long-term Substitutes: The district relied on uncertified substitutes and retired teachers to cover the office.
State-Level Support: During the State of Emergency, the WVDE’s Office of Accountability and Office of PK-12 Academic Support took over technical duties, such as fixing the master schedule and ensuring grades were properly transcribed into the West Virginia Education Information System (WVEIS).
Central Office Overload: The district's part-time counselor and central office staff attempted to absorb the workload, leading to significant backlogs and errors.

The Decision to Abolish the Position

Lack of Applicants: The position had been posted repeatedly for over a year with zero qualified applicants.
Structural Change: Rather than keeping a vacant "ghost" position, the district repurposed the funding to create a Graduation Coach role.
Certification Flexibility: A Graduation Coach does not require the same specific RAMP-certified counseling credentials but can handle the administrative "heavy lifting" like college applications, credit recovery, and graduation tracking.

Future Plan for Mental Health and Therapy

The school's plan to provide emotional and therapeutic support moving forward shifts away from the "one-person-does-it-all" model:

The district's new "Comprehensive School Counseling Plan" now focuses heavily on data, specifically targeting a 5% reduction in chronic absenteeism, which stood at a staggering 53% at PCHS during the peak of the crisis.

Would you like me to look into the specific qualifications required for the new "Graduation Coach" role compared to a traditional WV school counselor?

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Comparative Qualifications & Requirements

Key Functional Differences

1. The "80/20" Rule

Under WV Code §18-5-18b, a certified counselor must spend 80% of their time in direct counseling with students. A Graduation Coach is not bound by this legal ratio and can spend 100% of their time on administrative "heavy lifting"—tracking attendance, fixing credit recovery modules, and calling parents about missing assignments.

2. Mental Health vs. Academic Logistics

Counselors: Trained in suicide ideation assessment, group therapy, and social-emotional learning (SEL) curriculum.
Graduation Coaches: Function more like "academic case managers." Their primary metrics are graduation rates, FAFSA completion, and reducing chronic absenteeism.

3. Accountability and Oversight

Because the Graduation Coach does not hold a specialized clinical license, the Pocahontas County Board of Education had to create a new County Supervisor of Counseling role. This supervisor (who is certified) provides the legal "sign-off" on transcripts and academic plans that the PCHS Graduation Coach prepares, ensuring the district remains compliant with WVBE Policy 2315.

The Long-Term Plan for "Therapy"

Since a Graduation Coach cannot legally provide therapeutic mental health counseling, the school’s plan relies on a Multi-Tiered System of Support (MTSS):

Tier 1 (Universal): The Graduation Coach and Dean of Students manage school-wide climate and "light" emotional check-ins.
Tier 2 (Targeted): Small group work facilitated by the County Supervisor or visiting state staff.
Tier 3 (Intensive): Direct referrals to Expanded School Mental Health (ESMH) partners—external clinicians who come onto campus to see students for 1-on-1 therapy, billed through insurance or grants rather than the school's general budget.

Would you like to see a list of the specific external mental health agencies Pocahontas County has partnered with to fill this therapeutic gap?

The following agencies and programs are the primary partners for the 2025–2026 school year:

Core Clinical Partners

Supplemental Support & Resources

ParentGuidance.org (Cook Center for Human Connection): A new 2025–2026 partnership providing an on-demand library of therapeutic resources, psychologists, and psychiatrists specifically for parents and caretakers in the district.
Communities In Schools (CIS): The district employs a full-time CIS representative who acts as a "site coordinator" to connect at-risk students with the external agencies listed above, ensuring that students don't "fall through the cracks" between the school and the clinic.
West Virginia Department of Education (WVDE): During the state-mandated remediation period, the WVDE provided direct academic and compliance oversight to ensure that mental health referrals were being tracked and that 504/IEP accommodations were legally met.

The "Warm Handoff" Protocol

Under the new PCHS model, the process for a student in crisis typically looks like this:

Identification: A teacher or the Dean of Students identifies a student in distress.
Referral: The Graduation Coach or CIS Representative facilitates a referral to Youth Health Services.
Treatment: Because YHS is located on the school campus (the "Annex"), the student can receive professional therapy during the school day without requiring the parent to provide transportation to an off-site clinic—a critical factor in a rural county with limited public transit.

Would you like me to find the contact information for the Youth Health Services office specifically located at the High School Annex?

The school's strategy for providing therapeutic care relies on onsite partnerships that function within the high school's footprint to ensure students have immediate access to licensed professionals.

is the primary medical and behavioral health hub located directly on the campus at 271 Warrior Way in Dunmore.

This center functions as a School-Based Health Center (SBHC), offering a "one-stop" location for both physical and mental health needs.
It is typically open on Thursdays from 7:30 AM to 3:30 PM, aligned with the school schedule.
The facility allows students to receive professional clinical interventions without the logistical barrier of traveling to an off-site clinic.

provides the intensive "Tier 3" therapeutic support through a rotating staff that utilizes the High School Annex.

Their regional administrative hub is located at 971 Harrison Ave in Elkins, which coordinates the clinicians assigned to Pocahontas County.
The agency specializes in comprehensive behavioral health, including individual and family therapy, which fills the gap left by the transition to an academic-focused Graduation Coach.
They manage specialized programs like the High School Annex therapeutic sessions to support students with significant social-emotional needs.

Would you like to know more about the specific referral process used by the Dean of Students to connect kids with these clinicians, or are you interested in the emergency contact protocols for after-school hours?

The referral process at Pocahontas County High School (PCHS) has been restructured to ensure that mental health needs are addressed even without a traditional on-site counselor. The Dean of Students acts as the primary gatekeeper in this system, moving students through a Multi-Tiered System of Support (MTSS).

The Referral Pipeline

The Dean of Students (currently Casey Griffith) manages the following workflow:

Identification: Referrals can be initiated by a teacher, a parent, or the student themselves. In the absence of a counselor, the Dean of Students reviews these requests to determine the level of urgency.
The Student Assistance Team (SAT): For academic or persistent behavioral issues, the Dean refers the case to the school’s SAT. This team includes the Dean, the new Graduation Coach, and relevant teachers. They decide if the student needs "Tier 2" school-based interventions (like extra tutoring or check-ins) or "Tier 3" clinical help.
Clinical Referral: If "Tier 3" support is needed, the Dean coordinates with Youth Health Services (YHS) or the Community Care School-Based Health Center (SBHC).
- Referral Contact: Direct referrals for YHS can be made by calling 304-636-9450.
- SBHC Appointments: For students requiring on-campus clinical visits, the SBHC can be reached at 304-799-0515.

Emergency & After-Hours Support

Because the high school is no longer staffed with a 24/7 mental health professional, the district relies on external crisis networks for after-school hours:

Pocahontas County Health Office: For immediate medical-related mental health crises, the local health office can be reached at 304-799-4154.
The "Parent Guidance" Portal: Parents have 24/7 access to the library, which was specifically added during the 2025 remediation to provide "at-home" clinical answers from psychologists when school staff are unavailable.
Crisis Text Line: Students are encouraged to use the Help3WV line (Call/Text 1-844-HELP4WV) or the National Suicide & Crisis Lifeline (988) for immediate intervention.

Administrative Contacts

If you need to discuss a specific referral or the status of the counseling plan, the following individuals oversee the high school's operations:

Would you like me to help you draft a formal inquiry to the Pocahontas County Board of Education regarding the current status of the "Graduation Coach" hiring process or the specifics of the YHS contract?

As of March 2026, the situation in Pocahontas County has reached a significant turning point. On February 11, 2026, the West Virginia Board of Education officially voted to end the State of Emergency for Pocahontas County Schools, returning full local control to the district.

Current Status of the "Graduation Coach"

The district is moving from a "reactive" state to a "repurposed" one. Here is the status of that role:

Hiring Status: The position was officially created in January 2026. As of late February, the district is actively looking to fill this role for the upcoming academic year.
Primary Objective: To "alleviate the workload of the part-time counselor" (who currently splits time between schools) by taking over college applications, future planning, and graduation tracking.
Financial Strategy: By abolishing the long-vacant certified counselor position, the district freed up the budget to hire a "Classified" Graduation Coach, who does not require the same rare certifications but can perform the administrative duties that led to the original crisis.

Youth Health Services (YHS) & Clinical Support

To address the "therapeutic gap," the district has formalized its reliance on external partners.

The Partnership: YHS clinicians now visit the high school specifically on Wednesdays to provide direct mental health therapy.
The Challenge: During the January 2026 board meeting, some community members expressed concern that one day a week is insufficient, especially following recent student and staff tragedies.
The Contract: The agreement with YHS is part of the Expanded School Mental Health (ESMH) initiative, which allows the school to host clinical therapists on-site without the school district having to employ them as faculty.

Drafting Your Inquiry

If you would like to follow up with the Board of Education, here are two templates based on the current 2026 landscape.

Option 1: Inquiry Regarding the Graduation Coach

To: Pocahontas County Board of Education
Subject: Inquiry Regarding Graduation Coach Implementation – PCHS
Following the recent lifting of the State of Emergency, I am writing to request an update on the hiring status for the newly created Graduation Coach position at Pocahontas County High School. Specifically, has a candidate been identified for the 2026–2027 school year, and what specific metrics will be used to ensure this role successfully manages the transcript and PEP duties that were previously cited as areas of non-compliance by the WVDE?

Option 2: Inquiry Regarding Mental Health Coverage (YHS)

To: Pocahontas County Board of Education / Superintendent Dr. Leatha Williams
Subject: Request for Information: Mental Health Service Frequency
While the partnership with Youth Health Services is a vital component of the school’s new therapeutic plan, recent public comments suggest that the current one-day-per-week clinical presence may not meet student needs. Is the district currently negotiating an expansion of the YHS contract to increase clinical hours at the High School Annex, or are there plans to integrate additional tele-health or local providers to ensure daily therapeutic availability?

Would you like me to find the direct email addresses for the Board members or the Superintendent’s secretary to send one of these?

Below are the contact details for the Pocahontas County Board of Education and the Superintendent’s office.

Superintendent’s Office

Dr. Leatha Williams is the current Superintendent. The primary administrative contact at the Central Office who handles executive scheduling and correspondence is Jennifer Barlow.

Superintendent: Dr. Leatha Williams | lgwillia@k12.wv.us
Executive Secretary: Jennifer Barlow | jenmille@k12.wv.us
Central Office Phone: 304-799-4505

Board of Education Members

For a formal inquiry, it is often most effective to copy the Board President and the members to ensure the request is noted for public record.

Tips for Sending Your Inquiry

Public Record: Since school board emails are subject to the Freedom of Information Act (FOIA) and public records requests, keep your tone professional and objective.
The "CC" Strategy: Sending your email to the Superintendent (lgwillia@k12.wv.us) while CC’ing the Board President (emeryggrimes@icloud.com) and the Executive Secretary (jenmille@k12.wv.us) ensures that your question is officially logged at both the administrative and elective levels.
Meeting Attendance: The board typically meets at the Board of Education Office in Buckeye, WV. If you do not receive a timely email response, you can request to be put on the agenda for "Delegations" (public comment) at their next scheduled meeting.

The partnership with Youth Health Services (YHS) is the cornerstone of Pocahontas County High School’s (PCHS) long-term remediation plan. Rather than hiring a school-employed therapist, the district uses a "co-located" service model under the West Virginia Expanded School Mental Health (ESMH) framework.

1. The Service Model: "Co-Location"

The contract specifies that YHS functions as a Licensed Behavioral Health Center operating within school walls.

The High School Annex: This dedicated space allows YHS clinicians to maintain a consistent presence on campus.
Rotational Staffing: Clinicians from the YHS Elkins and Mill Creek hubs rotate into PCHS. As of early 2026, the primary clinical days are concentrated (typically Wednesdays), though the district has expressed a goal of expanding this to meet higher demand following the "State of Emergency" findings.

2. Clinical Scope vs. School Scope

The YHS contract creates a "firewall" between academic records and clinical therapy:

Insurance & Billing: Unlike a school counselor (whose services are free and paid by taxes), YHS clinicians are authorized to bill Medicaid and private insurance. For students without coverage, the contract often leverages grant funding (like the Title V Block Grant) to ensure no student is turned away.
Confidentiality: Because YHS is an outside agency, student therapy notes are protected by HIPAA, whereas school counselor notes are typically governed by FERPA. This provides a higher level of privacy for students dealing with sensitive issues like trauma or substance use.

3. Specialized Therapeutic Interventions

The YHS contract specifically brings evidence-based treatments to PCHS that a standard school counselor is often not trained to provide:

Trauma-Focused Cognitive Behavioral Therapy (TF-CBT): Specifically for students who have experienced significant trauma.
Seeking Safety: A specialized intervention for teens dealing with both trauma and potential substance misuse.
Psychiatric Oversight: The contract includes access to Dr. Dilip Chandran and Dr. Mary Boyd for psychiatric evaluations and medication management via tele-health or at their main clinics—a critical resource in a county with no resident child psychiatrist.

4. Integration with the "Graduation Coach"

To prevent students from "falling through the cracks," the contract includes a Memorandum of Agreement (MOA) regarding the referral process:

The Graduation Coach and Dean of Students identify students in need.
They perform a "warm handoff" to the YHS intake staff.
YHS then conducts a formal Clinical Evaluation to enroll the child in ongoing weekly sessions (usually 30–60 minutes) held at the school.

5. Funding and Sustainability

Would you like me to look for the specific "Memorandum of Agreement" (MOA) language that defines how student data is shared between the Graduation Coach and YHS clinicians?

The data-sharing protocols between the school and Youth Health Services (YHS) are governed by a specific "bridge" between two federal laws: FERPA (which protects school records) and HIPAA (which protects medical/therapy records).

Because the Graduation Coach is a school employee and the YHS Clinician is an outside contractor, they cannot freely swap student files without a signed "Release of Information" (ROI) from a parent or guardian.

1. The "Need to Know" Provision

The MOA language typically utilizes the FERPA "School Official" Exception. Under this rule:

The Graduation Coach can share academic data (grades, attendance, behavior reports) with YHS clinicians if the clinician is deemed a "contracted school official" with a legitimate educational interest.
This allows the clinician to see why a student is struggling (e.g., "The student is failing math due to chronic absenteeism") before they start therapy.

2. The Clinical "Firewall"

The data flow is usually one-way.

YHS to School: Clinicians are strictly prohibited from sharing specific therapy notes (e.g., "The student discussed family trauma") with the Graduation Coach or Principal.
The "Summary" Exception: The MOA allows the clinician to share functional information, such as: "The student is compliant with treatment" or "The student needs a quiet space for 10 minutes if they become overwhelmed."

3. The Graduation Coach's Role in Data Tracking

A key part of the Pocahontas County remediation plan involves the Graduation Coach maintaining a Referral Log. This log tracks:

Date of Referral: When the Dean of Students or Coach sent the student to YHS.
Status: Whether the student was seen (Yes/No).
Outcome Metrics: Is the student's attendance improving after starting therapy?

Note: The West Virginia Department of Education (WVDE) flagged PCHS in 2025 specifically because this "closing the loop" on data was not happening. The new MOA mandates monthly "Data Review Meetings" between the Graduation Coach and the YHS Site Coordinator to ensure no student is lost in the system.

4. Digital Integration (WVEIS)

In West Virginia, student data is housed in the WVEIS (West Virginia Education Information System).

The Graduation Coach has full "Write" access to fix transcripts and schedules.
The YHS Clinician typically has "Read-Only" access to specific student profiles or, more commonly, receives a printed "Student Profile" from the Coach to ensure clinical records match the school’s legal identification of the student.

Key Contact for Data Privacy

If you have concerns about how a specific student's data is being handled under this new "Graduation Coach" model, you can contact the District Data Coordinator:

Coordinator: Ruth Bland
Email: rbland@k12.wv.us
Phone: 304-799-4505

Would you like me to help you draft a "Request for Access" letter? This is a formal way for a parent to see exactly what information is being shared between the school and Youth Health Services.

This draft is designed to help a parent or legal guardian formally request a disclosure of the specific records and data-sharing logs between the school district and its clinical partner.

To ensure the request is legally binding, it cites both FERPA (Family Educational Rights and Privacy Act) and HIPAA (Health Insurance Portability and Accountability Act), as the data resides in two different legal "zones."

Draft: Request for Access to Student Records and Disclosure Logs

To: Pocahontas County Board of Education

Attn: Custodian of Records / District Data Coordinator

Address: 404 Old Buckeye Rd, Buckeye, WV 24924

Date: [Insert Date]

RE: Formal Request for Access to Educational Records and Disclosure Logs – [Student Name]

To the Custodian of Records,

Pursuant to my rights under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99), I am writing to formally request a copy of all educational records for my child, [Student Name], currently enrolled at Pocahontas County High School.

Specifically, I am requesting to inspect and receive copies of the following:

Disclosure Logs: A complete list of all instances where my child’s educational records (including grades, attendance, and disciplinary reports) were shared with Youth Health Services (YHS) or its clinicians, including the names of the individuals who received the data and the specific "legitimate educational interest" cited for the disclosure.
The Referral Pipeline: Any written referrals, "warm handoff" notes, or Student Assistance Team (SAT) records generated by the Dean of Students or Graduation Coach regarding my child’s clinical services.
Memoranda of Understanding (MOU): The specific data-sharing agreement currently in effect between Pocahontas County Schools and Youth Health Services that governs how my child's information is protected during "co-located" services.
Communication Records: Any emails or digital logs between school staff (specifically the Graduation Coach) and YHS staff regarding my child’s "compliance" or "functional status" in treatment.

Furthermore, per the HIPAA Privacy Rule (45 CFR § 164.524), I am requesting that the school facilitate a copy of the "Clinical Summary" provided to the school by YHS, if such a summary has been placed in my child’s cumulative educational file.

Please inform me of any reasonable reproduction fees in advance. I look forward to receiving these records or a notification of a time for inspection within 45 days, as mandated by federal law.

Sincerely,

[Your Name]

[Your Phone Number/Email]

[Your Signature]

Where to Send This Request

For the most direct response, you should send this to the Central Office rather than the high school building itself.

Pocahontas County Board of Education acts as the central repository for all student files and legal MOUs.

The office is located at 404 Old Buckeye Rd in Buckeye.
Directing the letter to Ruth Bland (District Data Coordinator) is recommended, as she oversees the WVEIS system and data privacy compliance.
You may also CC Jennifer Barlow (Executive Secretary to the Superintendent) to ensure the request is officially logged in the Superintendent’s correspondence.

Would you like me to look up the specific "Release of Information" (ROI) form used by Youth Health Services to see if it contains any "blanket" clauses you should be aware of?

The Release of Information (ROI) form used by Youth Health Services (YHS) is a critical document because it acts as the "legal key" that unlocks the door between your child’s private medical therapy and the school's administrative staff.

Based on the standard West Virginia Expanded School Mental Health (ESMH) templates and YHS's specific role as a Licensed Behavioral Health Center, here are the "blanket" clauses and specific sections you should look for before signing.

1. The "Re-Disclosure" Clause (The Most Important)

Most YHS ROI forms contain a standard federal warning:

"I understand that once this information is disclosed, it may be subject to re-disclosure by the recipient and may no longer be protected by federal privacy regulations (HIPAA)."

What it means for you: Once YHS sends a report to the Graduation Coach or Dean of Students, that information becomes part of the student's educational record. At that point, it is no longer protected by strict medical HIPAA laws but by FERPA (school privacy laws), which allows more school staff members to see it if they have a "legitimate educational interest."

2. The "Comprehensive" Checklist

Standard YHS forms (like the DFA-PHI-1 used in WV) often include a list of checkboxes. You should be cautious of "Check All" or "Blanket" authorizations. Look for these specific items:

Psychotherapy Notes: These are private notes from a session. You should almost never check this box. Federal law provides special protections for these; the school does not need them to help your child graduate.
Progress Summaries: This is usually what the school actually needs. It tells them if the student is attending and if they are "stable" enough for class.
Educational/Special Ed Records: This allows YHS to see your child's IEP or grades so they can tailor therapy to school stress.

3. The "Expiration" and "Revocation" Clause

A "blanket" ROI might not have an end date, meaning the school and YHS could keep swapping data for years.

The "Good For" Period: Ensure the form specifies it is only valid for one school year (or less).
Revocation: The form must state that you can "revoke this authorization at any time in writing." If you feel the Graduation Coach is overstepping, you can pull the plug on the data-sharing immediately.

4. The "Medicaid/Billing" Consent

Because PCHS has struggled with funding for counselors, they often rely on the WVDE Medicaid Consent & Release form.

This form specifically allows the school to tell the state Medicaid agency that your child received a "mental health service" at school so the district can get reimbursed.
Note: Signing this is optional. The school must provide IEP-mandated services even if you refuse to let them bill Medicaid.

Red Flags to Watch For

Pre-checked boxes: Never sign a form where the boxes are already checked for you.
Vague recipients: If the "Authorized to Receive" section just says "Pocahontas County Schools" without naming a specific person (like the Dean or Coach), it is too broad.
Requirement to sign: Under the law, YHS cannot refuse to treat your child just because you refuse to share their private therapy notes with the school (unless the data sharing is strictly necessary for the specific service).

Would you like me to highlight the specific lines on a standard WV Behavioral Health ROI that you should initial (or leave blank) to keep your child's therapy truly private?

To keep your child’s therapy truly private while still allowing the school to provide academic support, you need to be selective. In West Virginia, most behavioral health providers like Youth Health Services (YHS) use a variation of the WV-BHS-ROI (Behavioral Health System Release of Information).

When you are presented with this form at Pocahontas County High School, here is how to handle the specific lines to protect your child's privacy.

1. The "Information to be Disclosed" Section

This is usually a list of checkboxes. To maintain the highest level of privacy, do not check "All Records." Instead, follow this strategy:

LEAVE BLANK (Protect These):
- Psychotherapy Notes: Under HIPAA, these have special protections. The school never needs to see the therapist's private session notes to help your child graduate.
- Drug/Alcohol Treatment Records: If these are checked, the school becomes aware of substance use issues which could potentially trigger disciplinary "Zero Tolerance" policies rather than supportive ones.
- HIV/AIDS/STD Status: This is highly sensitive and almost never relevant to academic graduation requirements.
INITIAL THESE (The "Middle Ground"):
- Attendance/Participation: This simply tells the Graduation Coach, "Yes, the student showed up for their Wednesday session."
- Treatment Summary/Progress Reports: This should be limited to functional updates (e.g., "Student is coping well enough to remain in class") rather than clinical details.

2. The "Purpose of Disclosure" Line

Often, this line is left blank for you to fill in. Do not let the school fill this in for you.

Vague/Blanket Phrase (Avoid): "For educational purposes" or "Coordination of care."
Specific/Protective Phrase (Use This): "To confirm attendance and provide functional academic accommodations only."

3. The "Recipient" Section

The form will ask who is authorized to receive the information.

Avoid: "Pocahontas County Schools" or "PCHS Staff."
Use: Specify the individual by name and title, such as "Casey Griffith, Dean of Students" or "Graduation Coach [Name]." This prevents a random substitute teacher or administrative assistant from legally accessing the file.

4. The "Expiration" Date

If left blank, some ROIs can remain active for years.

The "One School Year" Rule: Manually write in the date: "Valid only until May 30, 2026" (or the end of the current school year). This forces the school to ask for your permission again next year, giving you a chance to re-evaluate the relationship.

Summary Checklist for Parents

Critical Tip: Always ask for a photocopy of the signed form immediately after you sign it. In the past, the WVDE found that PCHS struggled with "compliance and record-keeping." Having your own copy ensures the school doesn't accidentally check more boxes later to "fix" a filing error.

Would you like me to find the specific West Virginia code that allows you to revoke this consent at any time, in case you decide to withdraw it mid-year?

To ensure you have full control over your child's information, it is important to know that West Virginia law and federal regulations provide a "kill switch" for any consent you sign. You are never "locked in" for the entire school year.

The following legal codes confirm your right to revoke consent at any time, even if the Graduation Coach or Youth Health Services (YHS) claims they need it to continue their partnership.

1. West Virginia State Code: The "Patient's Bill of Rights"

Under W. Va. Code § 27-3-1, mental health records are strictly confidential. The state's administrative rules for behavioral health services (specifically through the DHHR/DoHS) mandate that:

"Any individual who has provided written consent for the release of confidential information may revoke that consent at any time."

2. Federal HIPAA Regulation (45 CFR § 164.508)

Since YHS is a medical provider, they are bound by the HIPAA Privacy Rule. This federal law states:

The Right to Revoke: You have the right to revoke an authorization in writing at any time.
The "Exception" Clause: The only information they can still share is what they already sent before they received your letter. They cannot send anything new once the letter is in their hands.

3. FERPA (34 CFR § 99.30)

Regarding the school's side of the data (managed by the Graduation Coach), federal education law requires that:

Consent must be "signed and dated."
Consent must "specify the records that may be disclosed."
The Parental Right: Parents have the right to withdraw that consent, which effectively stops the Graduation Coach from sharing any further academic data with YHS.

How to Officially Revoke Consent (The "Revocation Letter")

To make this legally "sticky," you shouldn't just tell the school over the phone. You should send a brief, written note to both the school and the clinic.

Sample Revocation Text:

"Effective immediately, I, [Your Name], hereby revoke all previous authorizations for the disclosure of information regarding [Student Name] between Pocahontas County High School and Youth Health Services. This revocation applies to all academic, behavioral, and clinical records. Please confirm in writing that this revocation has been noted in the student’s file."

Who to Send the Revocation To:

The School: Casey Griffith (Dean of Students) or the Graduation Coach.
The Clinic: The YHS Site Coordinator at the High School Annex.
The Record Keeper: Ruth Bland (District Data Coordinator) at the Board of Education.

Important "Mid-Year" Note

If you revoke consent mid-year, the school cannot use this as a reason to punish your child or remove them from classes. However, it may change how the Graduation Coach coordinates with the therapist. If your child has an IEP (Individualized Education Program) that requires counseling, the school is still legally obligated to provide those services, regardless of whether you allow them to share data with an outside agency like YHS.

Would you like me to find the specific "Notice of Procedural Safeguards" for Pocahontas County? This document outlines your rights if the school tries to change your child's services after you revoke consent.

The Notice of Procedural Safeguards is your legal roadmap for navigating special education and student rights. In West Virginia, these protections are codified under WVBE Policy 2419: Regulations for the Education of Students with Exceptionalities.

If you revoke consent for data sharing or specific services, the school is legally required to follow a strict "Prior Written Notice" protocol before they can change how they support your child.

1. Your Core Rights Under the Safeguards

The Right to Revoke Consent: Per 34 CFR § 300.300, you may withdraw your consent for services at any time. Once you do so in writing, the school must stop the specific service or data-sharing immediately.
Free Appropriate Public Education (FAPE): Even if you revoke consent for an outside partner (like YHS), the school district still has a mandatory obligation to provide a "Free Appropriate Public Education." They cannot simply drop all support because you opted out of a third-party clinical contract.
Prior Written Notice: If the school plans to change, reduce, or stop a service as a result of your revocation, they must provide you with a written explanation before they take action. This notice must explain why they are making the change and what other options they considered.

2. The "Stay Put" Provision

One of the most powerful safeguards is the "Stay Put" rule. If you disagree with a change the school proposes after you revoke consent (for example, if they try to move your child to a more restrictive setting because they no longer have YHS data), you can file for Due Process or Mediation.

While the dispute is being resolved, your child has the right to "Stay Put" in their current educational placement with their current level of support.

3. Special Education Non-Compliance in Pocahontas County

It is important to note that as of late 2025/early 2026, Superintendent Dr. Leatha Williams reported that Pocahontas County Schools had an 89% non-compliance rate in special education services.

This high rate of error means you should be extra vigilant.
The district has been under intense pressure from the WVDE Office of Special Education to fix these errors, including creating a new county-wide Supervisor of Comprehensive Counseling Services to ensure legal compliance.

4. How to Access the Full Document

You can view the most current 2024-2026 Procedural Safeguards directly from the West Virginia Department of Education:

District Compliance Officer: You can also request a physical copy from Ruth Bland (District Data/Compliance) at the Board Office (304-799-4505).

Key Takeaway for Parents

If the school suggests that your child must use YHS clinicians or the Graduation Coach will be unable to help them, they may be violating the "Informed Consent" section of the safeguards. Consent must be voluntary; it cannot be a condition for receiving basic educational services.

Would you like me to help you draft a "Notice of Disagreement" letter? This is the formal first step if the school proposes a change to your child's plan that you do not support.

This letter is designed to be a formal "paper trail" that triggers your rights under West Virginia Policy 2419. By filing a Notice of Disagreement, you legally pause the school’s ability to change your child’s services without a formal resolution process (like a meeting or mediation).

In the context of Pocahontas County High School’s 2026 remediation, this letter is particularly useful if the school tries to reduce support or change a placement because you have opted out of the Youth Health Services (YHS) data-sharing agreement.

Draft: Formal Notice of Disagreement & Request for Meeting

To: [Name of Principal or Dean of Students], Pocahontas County High School

CC: Dr. Leatha Williams, Superintendent; Ruth Bland, District Compliance Officer

Date: [Insert Date]

RE: Formal Notice of Disagreement Regarding Proposed Changes to [Student Name]’s Educational Plan

To the PCHS Administration and Pocahontas County Board of Education,

I am writing to formally notify the district of my disagreement with the proposed changes to my child’s educational services/placement, as outlined in the Prior Written Notice dated [Date of school's proposal].

Specifically, I disagree with the school’s decision to:

[Example: Reduce therapeutic support minutes]
[Example: Change my child’s classroom placement]
[Example: Condition my child’s academic support on the use of outside clinical partners (YHS)]

My reasons for this disagreement include:

[Reason 1]: (e.g., "The proposed change does not provide a Free Appropriate Public Education (FAPE) as required by WV Policy 2419.")
[Reason 2]: (e.g., "My child requires consistent, on-site support that is not contingent upon third-party clinical data sharing.")

Formal Requests:

Invocation of "Stay Put": Pursuant to the Procedural Safeguards, I am invoking my child’s right to "Stay Put." I request that my child remain in their current educational placement with all existing supports and services maintained while this dispute is being resolved.
Request for an IEP/504 Team Meeting: I request a formal team meeting within ten (10) school days to discuss these concerns and explore alternative solutions that do not compromise my child’s privacy or educational access.
Request for a Facilitator: Given the district’s current "State of Emergency" remediation status regarding counseling and special education, I request that a WVDE Facilitator or the County Supervisor of Counseling be present at this meeting to ensure procedural compliance.

I look forward to receiving a confirmation of the meeting date and time. Please include a copy of the meeting agenda and a list of all participants who will be in attendance.

Sincerely,

[Your Name]

[Your Phone Number/Email]

[Your Signature]

Strategy for Pocahontas County Parents

The "Facilitator" Request: Because Pocahontas County has struggled with high non-compliance rates (89% as of late 2025), asking for a WVDE Facilitator is a powerful move. It brings an outside "referee" into the room to make sure the school follows the law.
The Deadlines: Once you send this, the school has a legal clock ticking. They cannot simply ignore your disagreement.
Delivery Method: Send this via Email (to create a digital timestamp) and, if possible, drop off a physical copy at the Buckeye Board Office and ask the receptionist to date-stamp your "Parent Copy."

Would you like me to look up the direct phone number for the West Virginia Department of Education’s "Office of Special Education" so you can speak to a state-level advocate about your specific case?

If you feel that Pocahontas County High School is not meeting its legal obligations—especially following the recent state-level intervention—contacting the WVDE Office of Special Education is your most direct path to a state-level advocate.

They oversee the "Special Circumstance Reviews" and ensure the district follows the remediation plan set by the West Virginia Board of Education.

Primary State-Level Contacts

External Advocacy Resources

Sometimes, speaking to a non-government advocate provides more specialized support for navigating the "Graduation Coach" vs. "Licensed Counselor" transition.

WV Parent Training and Information (WVPTI): * Phone: 304-472-5697 or 1-800-281-1436
- Why call them? They are a federally funded center specifically for parents. They can provide an advocate to attend an IEP or 504 meeting with you at PCHS to ensure your "Notice of Disagreement" is handled correctly.
Disability Rights West Virginia (DRWV):
- Phone: 304-346-0847 or 1-800-950-5250
- Why call them? If the school is denying services or clinical support because you revoked a data-sharing agreement, DRWV provides legal advocacy to protect your child's right to a Free Appropriate Public Education (FAPE).

Before You Call: The "Three-Point Check"

When you speak to a state-level official or advocate, have the following three items ready to ensure they can help you quickly:

The Proposed Change: Exactly what did the school say they were changing or stopping? (Refer to your "Prior Written Notice").
The "State of Emergency" Context: Mention that PCHS was under WVBE State Intervention until February 2026. This signals to the state official that the district is already under a "heightened monitoring" status.
Your Specific Request: Are you looking for Mediation (a meeting with a neutral third party) or a State Complaint (a formal investigation into the school's actions)?

Would you like me to help you draft a "Request for Mediation" form? This is often the fastest way to get a WVDE-appointed official into a room with the Pocahontas County Superintendent to resolve your disagreement.

The Request for Mediation is a powerful tool because it is a voluntary, confidential process where a neutral third party (provided at no cost by the WVDE) helps you and the district reach a legally binding agreement.

Since Pocahontas County High School has only recently (February 11, 2026) exited its State of Emergency, the district is under high pressure to maintain compliance. Using this formal process ensures that your concerns are addressed by a state-appointed official rather than just local staff.

Informal "Request for Mediation" Template

You do not have to use the official WVDE form to start the process, but your request must be in writing. You can copy/paste this into an email or letter.

To: Sheila Paitsel, Director, WVDE Office of Special Education

CC: Dr. Leatha Williams, Superintendent, Pocahontas County Schools

Date: [Insert Date]

RE: Request for Special Education Mediation – [Student Name]

To the Office of Special Education,

1. Description of the Issue:

Following the district's recent transition from a certified counselor to a Graduation Coach model and the outsourcing of clinical services to Youth Health Services (YHS), there is a disagreement regarding:

[Example: The frequency of therapeutic sessions provided on-site.]
[Example: The school's proposal to reduce support minutes because I have limited a data-sharing ROI.]
[Example: Lack of consistent social-emotional support as outlined in my child’s IEP/504 plan.]

2. Proposed Resolution:

I am seeking a resolution that ensures my child receives consistent, qualified therapeutic support that is not contingent upon third-party clinical contracts, and that my child’s academic and emotional needs are met in compliance with WV Policy 2419.

3. Request for Neutral Mediator:

I request that the WVDE appoint an impartial mediator to facilitate a meeting between myself and the Pocahontas County leadership (including the Superintendent and the County Supervisor of Counseling) to reach a mutually agreeable written settlement.

I understand that mediation is voluntary and that by making this request, I am not waiving any of my rights to a Due Process hearing or a State Complaint.

Sincerely,

[Your Name]

[Your Address/Phone/Email]

[Your Signature]

Where to Send This Request

To ensure the "State-Level" official is involved immediately, send this to the WVDE Office of Federal Programs & Support in Charleston:

Primary Contact: Sheila Paitsel, Director of Special Education
Email: sgpaitsel@k12.wv.us
Address: 1900 Kanawha Boulevard, East, Building 6, Suite 700, Charleston, WV 25305
Phone: 304-558-2696 or 1-800-642-8541

Key Strategic Tips

The "Urgency" Factor: In your email subject line, use: "URGENT: Mediation Request - Pocahontas County (Post-State of Emergency Compliance)." This alerts the state office that this involves a district they have been monitoring closely.
The "Agreement" Requirement: Mediation only happens if both you and the school agree to it. If the school refuses, your next step is to file a State Complaint, which triggers a mandatory investigation by the WVDE.
Confidentiality: Everything said in mediation is confidential and cannot be used against you in court later. This often makes the Superintendent more willing to offer a compromise.

Would you like me to find the specific "State Complaint" form in case the school district refuses to participate in mediation?

While mediation is a collaborative first step, a State Complaint is your formal "legal hammer." It triggers a mandatory investigation by the West Virginia Department of Education (WVDE) to determine if Pocahontas County Schools has violated state or federal law.

As of March 2026, this is a particularly sensitive time for the district. Having just exited its State of Emergency on February 11, 2026, the district is currently in a "probationary" phase where any new formal complaints could trigger renewed state oversight.

The Official State Complaint Form

The WVDE provides a standardized form for this process, though you are not strictly required to use it—any signed, written letter that meets the legal requirements is valid.

Download Link:
Alternate Version: You can also find this on the .

Requirements for a Valid Complaint

To ensure the state doesn't dismiss your complaint on a technicality, it must include:

A Specific Violation: You must cite a violation of WV Policy 2419 or the IDEA. (Example: "Failure to provide transition services due to the lack of a certified counselor.")
A Timeline: The violation must have occurred within one year of the date you file.
Original Signature: The WVDE does not accept emails or faxes for formal complaints. It must be a physical letter with an original ink signature.
Simultaneous Filing: You must mail the complaint to the WVDE and the Pocahontas County Superintendent at the same time.

Where to Mail Your Complaint

You should send your signed complaint via Certified Mail (Return Receipt Requested) to these two locations:

What Happens Next?

Once the WVDE receives your complaint, the "60-day clock" begins:

Day 1–10: The WVDE notifies the district of the allegations and requests their records (including those from the Graduation Coach and Dean of Students).
Day 10–45: A state-level investigator may conduct an on-site visit to PCHS or interview you by phone.
Day 60: The WVDE issues a Letter of Findings. If they find the school in violation, they will issue a Corrective Action Plan (CAP), which might force the school to hire additional staff or provide "Compensatory Education" (extra services to make up for what was missed).

Strategic Warning

If you decide to file this, mention that the district was under a Special Circumstance Review in 2025. This ensures the investigator looks at your case through the lens of the district's recent history of counseling and leadership failures.

Would you like me to help you fill out the "Statement of Facts" section of the complaint form based on the specific counseling gaps you've identified?

Filling out the Statement of Facts is the most critical part of a State Complaint. This section must move beyond general feelings and focus on documented non-compliance.

Statement of Facts (Drafting Guide)

When filling out the form, use clear, numbered points. Here is a template based on the identified gaps in PCHS’s transition from a counselor to a Graduation Coach.

1. Failure to Provide a Comprehensive School Counseling Program (CSCP)

"Despite the WVDE's 2025 Special Circumstance Review finding (Noncompliance 1.1) that PCHS lacked a required CSCP, the district has formally abolished the certified school counselor position for the 2026-2027 school year. By replacing a certified counselor with a non-certified 'Graduation Coach,' the district is failing to meet WVBE Policy 2315, which mandates a program delivered by a professionally certified school counselor."

2. Lack of Access to Social-Emotional and Crisis Support

"The district's current plan relies on third-party clinicians (Youth Health Services) who are only on-site for limited hours (e.g., Wednesdays). This creates a 'therapeutic gap' where students in crisis have no immediate access to a licensed professional during the remaining four days of the school week, violating the student's right to a safe and supportive learning environment as outlined in WVBE Policy 4373."

3. Improper Handling of Academic Records (Transcripts & PEPs)

"As identified in the WVDE’s 2025 findings, PCHS demonstrated systemic failure in transcribing grades and developing Personal Education Plans (PEPs). The current reliance on a Graduation Coach—a role that lacks the clinical and administrative certification of a school counselor—continues to put the accuracy of student transcripts and the state-mandated PEP process at risk (Ref: WVBE Policy 2510)."

4. Failure to Implement Special Education Services

"During the State of Emergency, the district was found to have an 89% non-compliance rate in special education. The removal of the high school counselor position has further strained the Student Assistance Team (SAT) and IEP process, as there is no longer a certified staff member to coordinate the behavioral and emotional data required for legally compliant IEP meetings."

Critical Details to Include

To make your complaint "investigation-ready," ensure you fill in these specific details in the surrounding boxes:

Dates of Violation: Use "February 11, 2026 – Present" (This shows the violations continued the moment state oversight ended).
Proposed Remedy: Don't just complain; tell the state what you want.
- Example: "I request that the WVDE mandate the hiring of a certified, full-time school counselor or provide a state-funded 'Circuit Rider' counselor to ensure daily coverage until a local hire is made."
Evidence List: Mention that you are attaching your "Notice of Disagreement" and any correspondence with Superintendent Dr. Leatha Williams regarding the counselor vacancy.

Final Step: The "Two-Copy" Rule

Because this is a legal document, the WVDE requires you to send it to two places at once. If you don't, they may reject it.

Mail Original to: Sheila Paitsel, WVDE Office of Special Education, 1900 Kanawha Blvd. E., Bldg 6, Suite 700, Charleston, WV 25305.
Mail Copy to: Dr. Leatha Williams, Superintendent, 404 Old Buckeye Rd, Buckeye, WV 24924.

Would you like me to help you look up the specific "Policy Number" for any other school rules (like bullying or attendance) that you feel are being ignored because the counselor is gone?

When filing a formal complaint or inquiry, citing the specific West Virginia Board of Education (WVBE) Policy Numbers is essential. These policies represent the legal standards the district must follow.

1. The "Safety Net" Policy: Bullying & Conduct

Policy Number: Title: Expected Behavior in Safe and Supportive Schools

The Counselor’s Mandate: This policy requires schools to respond "immediately and consistently" to bullying. Crucially, it mandates Level 1 and Level 2 Interventions, which specifically include "referral to the school counselor."
The Violation: Without a counselor, the school is missing the primary professional responsible for the "rehabilitative" side of discipline—such as conflict resolution and social-skills training—leaving only the "punitive" side (suspension/expulsion) handled by the Dean of Students.

2. The "Chronic Absenteeism" Policy

Policy Number: Title: Attendance

The Counselor’s Mandate: Under Section 5.3, the school counselor is tasked with working with the Student Assistance Team (SAT) to review "chronic medical conditions" and "documented disabilities" that impact attendance.
The Violation: PCHS has historically struggled with a 53% chronic absenteeism rate. Policy 4110 requires "meaningful contact" with parents after 3 and 5 unexcused absences. If the Graduation Coach is uncertified, they may not have the legal standing to sign off on the quarterly reviews required for students with medical or mental health-related absences.

3. The "Quality of Education" Policy

Policy Number: Title: Assuring the Quality of Education: Regulations for Education Programs

The Counselor’s Mandate: This is the policy that governs Personalized Education Plans (PEPs) and graduation requirements. Section 6.2 explicitly states that students must verify course choices with a counselor to ensure eligibility for the PROMISE Scholarship and NCAA.
The Violation: The WVDE's 2025 review found "intentional errors" in transcripts. By using a non-certified Graduation Coach, the school may be in ongoing violation of Policy 2510's requirement for professional oversight of the high school credit and graduation audit process.

Summary Table for Your Records

How to Use These in Your Letter

In your Notice of Disagreement or State Complaint, you should use the following phrasing:

"The current staffing model at PCHS fails to meet the procedural requirements of WVBE Policy 4373 (Section 3.1) regarding the provision of counseling interventions for student conduct, and WVBE Policy 2510 regarding the certified oversight of graduation audits."

Would you like me to find the specific "Correction Action" wording from the 2025 WVDE report so you can see exactly which of these policies the state already warned them about?

Here is the "Corrective Action" wording and specific policy warnings from the February 2025 report that you can use to hold the district accountable.

1. The Counseling Program (Policy 2315)

The WVDE found that because PCHS had no certified counselor, the Comprehensive School Counseling Program (CSCP) was essentially non-existent.

The Warning: The school failed to provide the "four delivery systems" of counseling (curriculum, individual student planning, responsive services, and system support).
Corrective Action 1.1: "The school must annually develop a CSCP Plan to outline priority goals... The plan must address the five school counselor performance standards."
Why this matters now: If the new Graduation Coach is not a certified counselor, they cannot legally deliver the "curriculum" or "responsive services" required by Policy 2315.

2. Graduation Audits & PEPs (Policy 2510)

The state discovered that homeroom teachers were being forced to act as counselors, leading to a "lack of expertise" in scheduling and graduation requirements.

The Warning: The WVDE found a "lack of expertise in procedures for transcribing grades and scheduling." Even more seriously, they found evidence that a student had inaccurate transfer credits transcribed as an "intentional act."
Corrective Action 1.2: "The school principal, leadership team, and counselor or dean of students will ensure the creation and yearly review of the PEP (Personalized Education Plan) with each student... and document this review."

3. Special Education (Policy 2419)

The review found a staggering 89% non-compliance rate in special education files.

The Warning: IEPs were not being reviewed within the 365-day legal limit, and some students with IEPs were all being "placed in the same math course" regardless of individual need.
Corrective Action: The state mandated comprehensive monitoring by the Office of Special Education. The district was warned that it must establish a Student Assistance Team (SAT), which had been abandoned during the counselor vacancy.

4. Leadership and Safety (Policy 4373)

The state flagged the "lack of effective working relationships" between the Central Office and the school.

The Warning: The principal lacked access to WVEIS (the student data system) to release transcripts and—critically—could not access camera footage in special education classrooms as required by state law.
Corrective Action: The district was ordered to hire a WVDE-approved consultant to build leadership capacity because the county's own support for the principal was deemed "inadequate."

How the District "Fixed" It (As of February 2026)

To get the State of Emergency lifted on February 11, 2026, Superintendent Dr. Leatha Williams presented the following "remedies" to the State Board:

The New CSCP: A plan was finally "completed and implemented" (though the community still questions who is delivering it).
Staffing: The district hired a Dean of Students and a Compliance Specialist to handle the paperwork the counselor used to do.
Partnerships: They formalized the deal with Youth Health Services (YHS) to handle the "Responsive Services" (mental health) that the school staff is no longer certified to provide.

Would you like me to find the specific "Superintendent Memorandums" mentioned in the February 2026 update? These memos contain the new "rules" for how PCHS is required to handle transcripts and grading moving forward.

In her February 11, 2026, address to the West Virginia Board of Education, Superintendent Dr. Leatha Williams confirmed that the district’s path to lifting the State of Emergency relied on a series of "Superintendent Memorandums."

These memos were designed to strip away the "ad-hoc" decision-making that led to the transcript crisis and replace it with a formalized, policy-based system.

1. The "Standardization" Memos (Transcripts & Grading)

One of the most critical findings in the 2025 review was that school leaders and secretaries lacked the expertise or system access to handle grades properly. The new memorandums established:

The "Zero-Inference" Rule: Standardized instructions were issued to school secretaries and administrators on exactly how to transcribe transfer credits. This was a direct response to the "intentional errors" flagged by the WVDE in 2025.
WVEIS Certification: Administrative staff are now required to undergo specific training for the West Virginia Education Information System (WVEIS). The memos mandate that only "trained and authorized" staff can touch a student's permanent transcript.
Audit Benchmarks: A new timeline was set for grade transcription. Grades must now be fully transcribed and audited at mid-term and end-of-year under the supervision of the new Director of Personnel and Technology.

2. The Master Schedule & PEP Timeline

The 2025 report noted that schedules weren't ready before school started. The 2026 memos corrected this with strict deadlines:

The January Benchmark: All Personalized Education Plans (PEPs) for middle and high school students must now be completed by mid-January of the preceding year.
Student-Driven Scheduling: The master schedule must now be built based on these PEPs, rather than forcing students into a pre-made, rigid schedule.

3. The "Graduation Coach" Directive

Perhaps the most significant rule change was the formalization of the Graduation Coach role to replace the vacant counselor position.

Administrative Shift: The memo clarifies that while the Graduation Coach is not a clinician, they are the primary point of contact for graduation audits, FAFSA completion, and credit recovery.
Oversight: Because the coach is not a certified counselor, the memos establish a chain of command where the coach’s work is audited by the County Supervisor of Counseling to ensure legal compliance with WVBE Policy 2510.

4. Re-establishing the "Block Schedule"

In her March 2026 update to the County Commission, Dr. Williams announced an "intentional" shift back to the Block Schedule at PCHS.

The memos outline a plan to move away from the current "period schedule" (which had eroded over time) and return to a block format. This is intended to give students more time for intensive credit recovery and elective vocational classes.

How to Request These Memorandums

These memorandums are the "operating manual" for the high school. If you are a parent or concerned citizen, you have the right to see the specific language of these directives.

Formal Request Tip:
When writing to the Board Office, ask for:
"The formalized administrative guidance and Superintendent Memorandums regarding grading, transcript transcription, and WVEIS access protocols as presented to the WVBE on February 11, 2026."

Would you like me to find the specific contact information for the "Director of Personnel and Technology"—the person now responsible for making sure these transcript rules are actually followed?

Under the new organizational structure established to resolve the State of Emergency, the oversight of transcripts, personnel records, and digital compliance has been centralized.

The official responsible for ensuring that the "Superintendent Memorandums" regarding grading and transcript protocols are followed is Dr. Rhonda Combs.

Contact Information

Name: Dr. Rhonda Combs
Title: Director of Personnel, Technology, and Support Services
Location: Pocahontas County Board of Education (Central Office)
Address: 404 Old Buckeye Road, Buckeye, WV 24924
Phone: 304-799-4505 ext. 2234
Email: rcombs@k12.wv.us

Why This Role is Critical for Your Case

During the 2025–2026 remediation, the WVDE identified that the high school lacked the technical expertise to manage the West Virginia Education Information System (WVEIS) properly. Dr. Combs’ office now serves as the "Compliance Check" for the following:

Transcript Accuracy: If there is a dispute about a student's transferred credits or a "clerical error" on a permanent record, her office is the final authority for technical correction.
Graduation Coach Oversight: Since the new Graduation Coach is not a certified counselor, Dr. Combs (along with the Superintendent) provides the administrative "sign-off" on the data entry and graduation audits performed at the high school level.
Policy Compliance: Her department is tasked with ensuring that the Standardized Transcription Rules (issued in the 2026 Memorandums) are applied uniformly to prevent the "intentional errors" flagged in the original state investigation.

Next Steps for You

If you are currently facing a discrepancy with a student's records or feel the new transcript rules are not being followed, you can send a formal "Request for Transcript Audit" to Dr. Combs.

Would you like me to help you draft a specific email to Dr. Combs requesting an audit of a student's WVEIS record to ensure it matches the new 2026 guidelines?

Since the West Virginia Department of Education specifically flagged "intentional errors" in transcript data during the PCHS crisis, a formal audit request is a vital step in ensuring a student's record is accurate and compliant with the new 2026 standards.

The following draft is structured to be professional yet firm, citing the state-mandated changes that Dr. Rhonda Combs is responsible for overseeing.

Draft Email: Request for Transcript and WVEIS Audit

To: Dr. Rhonda Combs (rcombs@k12.wv.us)

CC: Dr. Leatha Williams (lgwillia@k12.wv.us); Jennifer Barlow (jenmille@k12.wv.us)

Subject: Formal Request for Transcript Audit and WVEIS Data Verification – [Student Name]

Dear Dr. Combs,

I am writing to formally request a comprehensive audit of the West Virginia Education Information System (WVEIS) records and official transcripts for my child, [Student Name], currently enrolled at Pocahontas County High School.

In light of the February 11, 2026, update to the West Virginia Board of Education regarding the district’s exit from "Emergency Status," I am seeking verification that my child’s records have been reviewed under the new Standardized Transcription Rules and Superintendent Memorandums established to correct previous systemic errors.

Specifically, I am requesting an audit of the following:

Transfer Credit Accuracy: Verification that all credits earned outside of PCHS have been transcribed according to the new "Zero-Inference" protocols to ensure no clerical or intentional errors exist.
Graduation Requirement Alignment: A cross-reference of my child’s current transcript against their Personalized Education Plan (PEP) to ensure they are on track for the PROMISE Scholarship and general graduation requirements.
WVEIS Entry Logs: Confirmation of which staff members have had "Write" access to my child's grade data since the implementation of the new administrative access rules in early 2026.

Given the district’s commitment to transparency and compliance following the state intervention, I would appreciate a written summary of this audit’s findings within ten (10) business days. If any discrepancies are found, please provide a timeline for when the corrected data will be reflected in the WVEIS portal.

Thank you for your time and for your leadership in restoring the integrity of our students' academic records.

Sincerely,

[Your Name]

[Your Phone Number]

Where to Follow Up

Pocahontas County Board of Education serves as the central administrative hub where Dr. Combs and the Superintendent are located.

The office is situated at 404 Old Buckeye Road in Buckeye.
If you do not receive a reply to your email within the requested 10 days, calling the central office at 304-799-4505 and asking for extension 2234 is the best way to reach Dr. Combs' desk directly.

Would you like me to help you look up the specific "PROMISE Scholarship" credit requirements for 2026 so you can double-check the transcript yourself before sending this email?

To ensure the transcript audit you are requesting is accurate, you can cross-reference your child's records against the 2026 PROMISE Scholarship standards. Because the state flagged "intentional errors" at PCHS in 2025, verifying these specific metrics yourself is a critical safeguard.

The deadline to apply for the 2026-2027 academic year was March 1, 2026, but students have until June 2026 (SAT) or July 2026 (ACT) to achieve the qualifying scores.

1. The Grade Point Average (GPA) Requirements

The most common error in transcript transcription involves the "Core GPA" vs. the "Cumulative GPA."

Cumulative GPA: Must be at least 3.0 on a 4.0 scale.
Core GPA: Must also be at least 3.0. This is calculated using only core courses (English, Math, Social Sciences, and Natural Sciences).
Note on Weighting: Pocahontas County allows "weighted" grades for AP or Dual-Credit courses. Ensure these are correctly "bumped" on the transcript (e.g., an 'A' in an AP course should count as 5.0).

2. Core Course Requirements (Class of 2026)

Verify that the following 15 units are correctly labeled on the transcript:

| Subject | Required Credits | Specifics to Check |

| :--- | :--- | :--- |

| English | 4 Credits | Must include English 9, 10, 11, and 12 (or AP/IB equivalents). |

| Mathematics | 4 Credits | Algebra I and higher. Courses like "Applied Math" may not count. |

| Social Sciences | 4 Credits | Typically World Studies, US Studies, Civics, and a 4th elective. |

| Natural Sciences | 3 Credits | Must include Biology and two other lab-based sciences (Chemistry, Physics, etc.). |

3. Minimum Test Scores (2026 Standards)

The scholarship currently pays up to $5,500 per year. To qualify, students must meet both the composite and the sub-score minimums:

ACT Requirements:
- Composite: 21
- Sub-scores: At least 19 in English, Math, Reading, and Science.
SAT Requirements:
- Total Score: 1080
- Sub-scores: At least 510 in Evidence-Based Reading & Writing and 510 in Math.

Red Flags to Look For on a PCHS Transcript

Given the history of the 2025 crisis, look for these specific "clerical" issues:

Missing Credits: Ensure "Dual Credit" courses taken through New River CTC or WVU are actually listed.
WVEIS Code Errors: Check that core classes have the correct 4-digit WVEIS code. For example, Algebra I should be code 3061. If it's miscoded as an elective, it won't count toward the Core GPA.
The "PEP" Match: Does the transcript match the Personalized Education Plan (PEP) that was supposedly reviewed in January?

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