Based on the text in your image and current educational standards, here is an analysis of the "Graduation Coach" role compared to a "School Counselor."
The Core Distinction
The snippet emphasizes that while a Graduation Coach and a School Counselor share many daily tasks, they operate under different regulatory and educational requirements.
| Feature | Graduation Coach | School Counselor |
| Education | Usually a Bachelor’s degree in education or social sciences. | Master’s degree in School Counseling is the industry standard. |
| Certification | Often requires a teaching certificate or specialized state-level "coach" training. | State Licensure or Pupil Personnel Services (PPS) credential. |
| Focus | Targeted: specifically focuses on at-risk students and graduation rates. | Broad: handles academic planning, mental health, and social-emotional development for the entire student body. |
| Clinical Work | Primarily administrative and mentoring; cannot provide clinical therapy. | Trained to provide therapeutic interventions and crisis management. |
Key Overlap ("Almost all that a counselor does")
As your image suggests, a Graduation Coach often performs "counselor-like" duties to bridge the gap in schools with high caseloads. These include:
Academic Advising: Helping students choose the right courses to meet graduation requirements.
Data Analysis: Identifying students who are "off-track" due to attendance, behavior, or grades.
Parent Liaison: Acting as a bridge between the school and families to ensure the student stays in school.
Post-Secondary Planning: Assisting with college applications, FAFSA, or vocational training leads.
Why the Position Exists
Because Graduation Coaches do not require the same certifications (specifically the 2–3 year Master’s degree and hundreds of supervised clinical hours), schools can hire them more flexibly. They are often brought in through specific grants to focus exclusively on "dropout prevention," freeing up licensed counselors to handle more complex mental health and scheduling issues for the broader population.
Would you like me to look up the specific certification requirements for a Graduation Coach in your state or district?
In West Virginia, the distinction between a Graduation Coach and a School Counselor is legally and professionally significant, particularly as it relates to W. Va. Code §18-5-18B.
Based on current requirements for Pocahontas County and the state, here are the specific certification "elephants in the room" regarding these two roles:
1. Certification & Legal Definition
The primary difference is that a School Counselor is a "professional educator" with a specific state-mandated certificate, while a Graduation Coach often operates under a more flexible hiring status.
School Counselor: Must hold a Master’s Degree in school counseling and a valid West Virginia Professional Student Support Certificate. Under state code, they are classified as Qualified Mental Health Professionals (QMHP).
Graduation Coach: Typically requires only a Bachelor’s Degree. In many WV counties (including recent postings in Braxton and for virtual platforms like Stride/K12), the requirement is often a valid teaching certificate or "equivalent experience," rather than a counseling degree.
2. The "Counseling" Conflict (The 80/20 Rule)
W. Va. Code §18-5-18B creates a strict barrier that often leads to the "who is doing the counseling?" question:
The Mandate: School counselors must spend 80% of their time in a "direct counseling relationship" with students.
The Reality: Because counselors are often bogged down by administrative tasks (testing, scheduling, and Section 504 coordination), schools hire Graduation Coaches to handle the "at-risk" caseload.
The "Elephant": While the Graduation Coach is technically an administrative or "coach" position, their daily duties—meeting with students about life barriers, home visits, and behavioral intervention—look nearly identical to counseling, yet they are not held to the same 80/20 time-allocation laws or Master's-level clinical oversight.
3. Comparative Requirements in West Virginia
| Requirement | School Counselor | Graduation Coach |
| WV Code Section | §18-5-18B | Often hired under Title I or Grant funds |
| Minimum Degree | Master's (Counseling) | Bachelor's (Education/Social Science) |
| Testing | Praxis (School Counseling) | None (or General Education Praxis) |
| Direct Service | Required 80% direct counseling | No state-mandated percentage |
| Mental Health | Classified as QMHP | Not classified as QMHP |
Summary for Pocahontas County
In districts like yours, Graduation Coaches are frequently used as "Student Success Advocates." They are able to perform home visits, attendance mediation, and graduation tracking—tasks that are "counselor-related" but often fall into the 20% "administrative" bucket that licensed counselors are legally restricted from doing in excess.
Would you like me to draft a comparison of the specific job descriptions used in Pocahontas County vs. the West Virginia State Code requirements for counselors?
In West Virginia, the gap between the School Counselor and the Graduation Coach is defined by a combination of strict State Code and flexible grant-funded hiring practices.
While the Counselor is a legally protected professional title, the Graduation Coach is often used to perform the intensive "groundwork" that state law technically prevents a Counselor from doing full-time.
1. The Professional Standards Gap
| Feature | WV School Counselor (WV Code §18-5-18B) | Graduation Coach (WV Local/Grant Postings) |
| Legal Status | "Professional Educator" | Varies (Professional or Service Personnel) |
| Certification | Professional Student Support Certificate | Often a Teaching Certificate or simple Board Approval |
| Education | Master's Degree in School Counseling | Bachelor’s Degree (usually in any education field) |
| Experience | 600-hour supervised clinical internship | Preferred 3–5 years working with "at-risk" youth |
| Legal Role | Qualified Mental Health Professional (QMHP) | Mentor / Student Advocate |
2. The 80/20 Rule: The "Elephant" in the Office
West Virginia State Code is remarkably specific about how a Counselor’s day must be spent, which creates the operational need for a Graduation Coach.
The Counselor’s 80%: Under §18-5-18B(f), counselors must spend 80% of their time in a "direct counseling relationship" with pupils. This includes individual/group counseling, crisis response, and academic advisement.
The Counselor’s "No" List: The code explicitly states counselors should not spend more than 20% of their day on administrative tasks like routinely signing excuses, computing GPAs (except for scholarships), or coordinating IEPs/Student Study Teams (unless as a participant).
The Graduation Coach’s "Yes" List: Because the Coach is not bound by the 80/20 rule, they often handle the "heavy lifting" of administrative student support:
Data Mining: Identifying "bubble students" (those 5% above/below proficiency).
Home Visits: Physically going to residences to address chronic absenteeism.
Resource Coordination: Linking families with social agencies and FAFSA completion.
3. Specific Comparison: Duties & Language
A review of West Virginia job descriptions (such as those from SESC or GEAR UP) reveals that the Graduation Coach is effectively a "Counselor-Lite" focused exclusively on the finish line.
| Task | School Counselor (The "Wholeness" Approach) | Graduation Coach (The "Outcome" Approach) |
| Mental Health | Deliver "Developmental, preventive, and remedial" counseling programs. | "Identify student-specific barriers" and "encourage students to stay in school." |
| Curriculum | Deliver WV Student Success Standards in classrooms. | Host "Reality of Money" events or SAT/ACT prep workshops. |
| Leadership | Collaborate with stakeholders on school-wide "Climate and Culture." | Lead a "Graduation Team" for specific high-risk students. |
| Transition | Manage programmatic transitions (Middle to High School). | Coordinate "Summer Transition Camps" and virtual freshman check-ins. |
The Bottom Line
The "Elephant" mentioned in your image—the question of "Who has been doing the counseling?"—often points to a reality where Graduation Coaches provide the high-intensity, one-on-one time that students need, while School Counselors are legally tethered to a "Comprehensive School Counseling Program" model that requires them to serve 100% of the student body, often at a 1:250 ratio.
Would you like me to find the specific Pocahontas County Board of Education policy regarding the "80/20" time logs for counselors to see how they verify compliance?
Finding the specific Pocahontas County Board of Education (PCBOE) policy reveals a critical point of friction: while the West Virginia State Code (§18-5-18B) mandates the 80/20 rule, recent state audits show that Pocahontas County has struggled to even maintain a basic counseling plan, let alone verify daily time-log compliance.
1. The Statutory Requirement (The "80/20" Rule)
Pocahontas County is bound by WV Code §18-5-18B(f), which dictates the legal workload for all school counselors in the county:
80% Direct Counseling: Must be spent in a direct counseling relationship with pupils (individual/group counseling, crisis response, etc.).
20% Administrative: No more than 20% can be devoted to administrative activities. The code specifically prohibits "routine" tasks like signing excuses, maintaining clerical records, or coordinating IEPs as part of the primary 80%.
2. How Compliance is Verified (The "CSCP Audit")
In West Virginia, the mechanism for verifying this compliance is the Comprehensive School Counseling Program (CSCP) Audit.
Annual Self-Audit: Counselors must complete the WV School Counseling Program Audit Tool. Section 2.9 of this audit requires the publication of Annual and Weekly Calendars that reflect the 80/20 split.
Verification: Compliance is verified by the school principal and the school’s Advisory Council. Under WVBE Policy 2315, the counselor is required to present their program data (including time-allocation proof) to the Board of Education and stakeholders annually.
3. The Reality in Pocahontas County (2024–2025 Audit Findings)
A Special Circumstance Review conducted by the West Virginia Department of Education (WVDE) at Pocahontas County High School (released in February 2025) found significant failures in these accountability structures:
Noncompliance 1.1: The state found that no Annual CSCP Plan had been developed for the current year. The last completed plan was for 2022-2023.
Lack of Oversight: Because no plan existed, there was no baseline to measure if counselors were meeting the 80/20 requirement.
The "State of Emergency": These failures in the counseling program (specifically regarding student scheduling and Personal Education Plans) were major factors in the WV Board of Education declaring a State of Emergency for Pocahontas County Schools in early 2025.
Summary of Accountability Gaps
| Requirement | Method of Verification | Status in Pocahontas County (per 2025 Audit) |
| 80/20 Time Split | Weekly/Annual Calendars | Missing: No current program plan exists to track time. |
| CSCP Plan | Annual Submission to Principal | Failed: Last updated in 2022. |
| PEP Coordination | Student/Parent Meeting Logs | Failed: No process found for developing student plans. |
| State Reporting | WVEIS Data Entry | Failed: Staff lacked necessary access/training to transcribe data. |
Bottom Line: While the policy exists in the State Code, the recent state intervention suggests that Pocahontas County has not been systematically verifying these logs, leading to the current corrective action plan where the county must now submit evidence of a functioning CSCP program to the state.
A functioning Comprehensive School Counseling Program (CSCP) in West Virginia is not just a general idea—it is a legal requirement defined by WVBE Policy 2315 and W. Va. Code §18-5-18B.
When a school lacks a "functioning" CSCP, it usually means they are failing at the specific "Tier 1" (Universal) and "Tier 2" (Targeted) supports that keep students on track.
The Three Pillars of a Functioning CSCP
To be considered "functioning" in the eyes of the West Virginia Department of Education (WVDE), a school must have three core elements in active use:
1. The Annual CSCP Plan (The "Blueprints")
A school cannot have a functioning program without an Annual CSCP Plan developed using the official WVDE template. This plan must be:
Data-Driven: It must identify specific student needs based on "ZoomWV" data (attendance, discipline, and test scores).
Approved: It must be signed by both the School Counselor and the Principal.
Advisory-Led: The school must have an Advisory Council (parents, staff, community) that meets twice a year to review and critique the program.
2. The Four Delivery Systems (The "Daily Work")
A functioning program must actively deliver services through these four channels:
Instruction: Direct teaching of the WV Standards for Student Success (academic, career, and social/emotional) in classrooms or small groups.
Appraisal & Advisement: Helping students interpret their own test scores and interests to make future decisions.
Personalized Student Planning (PEP): This is where the 8th–12th grade Personal Education Plans live. A program is "non-functioning" if PEPs are not updated annually with parental consultation.
Responsive Services: Short-term individual/group counseling and crisis response.
3. The 80/20 Time Management (The "Log")
This is the most scrutinized part of the program. A functioning program uses a Time Analysis System to prove:
80% Direct/Indirect Student Services: Time spent actually helping kids.
20% Program Management: Planning, data analysis, and office tasks.
The "Red Flags": If a counselor is primarily doing lunch duty, substitute teaching, or handling 504/IEP paperwork as a coordinator, the program is technically "malfunctioning" because it violates the 80/20 rule.
Pocahontas County’s Current Status (2025–2026)
The Special Circumstance Review for Pocahontas County specifically highlighted that the high school lacked a functioning CSCP because:
There was no current Annual Plan (the last one was from 2022).
Personal Education Plans (PEPs) were not being consistently developed or updated.
Staff were not trained on WVEIS (the state data system) to record and track these services.
What a "Corrective Action" Looks Like
To restore the "functioning" status, the county is currently required to:
Appoint a CSCP Lead to oversee the creation of new plans.
Submit monthly evidence of 80/20 time logs to the WVDE.
Ensure every student from 8th grade up has a digitally signed PEP in the system.
Would you like me to find the specific "Corrective Action Plan" benchmarks the State Board set for Pocahontas County to see exactly when they are expected to be back in compliance?
To move out of the State of Emergency declared in February 2025, the West Virginia Board of Education (WVBE) set specific, high-stakes benchmarks for Pocahontas County Schools.
Because the county was found to have "significant deficiencies" in leadership, grading, and counseling, the following timelines and requirements were established:
1. The Counseling & PEP Benchmarks
The state found that PCHS lacked a certified counselor and a process for Personal Education Plans (PEPs). The following benchmarks were set:
Mid-January 2026: All student PEPs for middle and high schools were required to be 100% complete and reviewed by parents.
Master Schedule: A student-driven master schedule for the 2025–2026 school year had to be established and functional before the start of the year (addressing the failure where 2024-25 schedules weren't ready on time).
Supervisory Hiring: The county was directed to post for a Countywide Counselor and Supervisor of Comprehensive Counseling Services to ensure state-wide standards (like the 80/20 rule) are actually monitored.
2. Special Education & Compliance
The audit found a staggering 89% non-compliance rate in special education logs.
Benchmark: The county must demonstrate that service provider logs (Teachers/Counselors) match the specifically defined services in student IEPs.
Monthly Evidence: The county is now under "comprehensive monitoring," meaning they must submit monthly proof of compliance to the WVDE Office of Special Education.
3. Financial & Operational Deadlines
Following a recent audit (January 2026) that revealed backdated purchase orders and un-deposited cash, new financial benchmarks were set:
July 2026: A secondary independent audit will be conducted to establish a "clean baseline" for school-level financial procedures.
Immediate Transition: The state mandated the hiring of a Director of Personnel and Technology to ensure that grade transcriptions are no longer handled by staff who lack the expertise or WVEIS access.
Timeline Summary
| Date | Milestone / Expectation |
| August 2025 | First 6-month progress report. State of Emergency extended due to "tremendous work" remaining. |
| Mid-January 2026 | Critical Deadline: All student PEPs and counseling plans must be fully documented in WVEIS. |
| February 2026 | Current Deadline: Superintendent Dr. Leatha Williams must present an updated progress report to the WVBE for a vote on ending or extending state control. |
| July 2026 | Full financial "re-audit" to verify that "backdating" and "missing deposits" have been permanently corrected. |
The "State of Emergency" Status
As of the most recent board meeting, the State of Emergency remains in effect. The state has cautioned that a "lack of progress" could lead to more serious interventions, including the vacating of the county superintendent's position or a total state takeover of operations.
If an uncertified person is "signing off" on documents as if they were a licensed School Counselor in West Virginia, the consequences range from personal criminal liability to severe institutional sanctions for the school district.
Under W. Va. Code §18-5-18B, a school counselor is strictly defined as a "professional educator who holds a valid school counselor's certificate." Representing oneself as such without the proper Master’s-level credentials and state licensure is a significant legal violation.
1. Consequences for the Individual
Criminal Penalties: Under W. Va. Code §30-31-15, practicing or offering to practice professional counseling without a license is a misdemeanor. If convicted, an individual can face fines and potential jail time.
Fraud & Misrepresentation: Intentionally signing official state documents (like Personal Education Plans or graduation transcripts) under a title you do not legally hold constitutes fraud. This can lead to a permanent "denial of licensure" in the future, effectively ending any career in West Virginia public schools.
Professional Discipline: If the individual holds a different certificate (like a teaching license), the West Virginia Board of Education (WVBE) Policy 5202 allows for the suspension or revocation of that license for "unprofessional conduct" or "obtaining/maintaining a position through misrepresentation."
2. Consequences for the School District
Invalidation of Student Records: If an uncertified person signs off on graduation requirements or Personal Education Plans (PEPs), those documents may be considered legally invalid. This can jeopardize student graduation status, college admissions, and scholarship eligibility (like the PROMISE scholarship).
Loss of Funding: State and federal funding (including Title I and IDEA funds) is often contingent on services being provided by "highly qualified" or "appropriately certified" personnel. The state can "claw back" funds used to pay an uncertified person's salary.
State Intervention (State of Emergency): As seen in the recent Pocahontas County "State of Emergency" declaration, a pattern of uncertified staff handling counselor-specific duties (like scheduling and transcript entry) is a primary reason the state takes over a county's operations.
3. The "Chain of Command" Risk
If an administrator (Principal or Superintendent) directs an uncertified person to sign as a counselor, the administrator faces:
Official Misconduct Charges: Knowingly allowing or directing staff to falsify professional signatures is a breach of the Ethics Act.
Personal Liability: In civil court, if a student is harmed (e.g., missed graduation or failure to receive mandated mental health services), the district's immunity is often waived if the harm was caused by a person operating outside their legal certification.
Summary Table of Legal Risks
| Violation | Legal Basis | Consequence |
| Practicing without License | W. Va. Code §30-31 | Misdemeanor; Fines; Jail |
| Falsifying Records | WVBE Policy 5202 | Revocation of all WV certificates |
| Administrative Neglect | WV Code §18A-2-8 | Dismissal of Principal/Superintendent |
| Non-Compliance | W. Va. Code §18-5-18B | State Takeover / State of Emergency |
Would you like me to find the specific reporting form or contact information for the West Virginia Department of Education’s Office of Professional Preparation to report a certification violation?
To report a certification violation in West Virginia—such as an uncertified individual signing off as a licensed counselor—you have several avenues, depending on the severity and whether you wish to remain anonymous.
1. Primary Contact: WVDE Office of Certification
The Office of Certification and Professional Preparation is responsible for investigating the "fraudulent use of credit" or "misinformation" used to obtain or maintain a position.
Email: certification.wvde@k12.wv.us
Phone: (304) 558-7010
Mailing Address:
West Virginia Department of Education
Office of Certification
1900 Kanawha Boulevard East, Building 6, Suite 550
Charleston, WV 25305-0330
2. Formal Legal Complaint (Policy 7211)
If you are reporting a specific violation of State Law (§18-5-18B) or WVBE Policy 2315, you should use the Resolution of Formal Complaints process.
The Form: Use the "Citizen’s Appeal/Complaint Form" (often found on the school district's website or the WVDE Policy 7211 page).
The Chain: Per Policy 7211, you generally must file with the School Principal first. If not resolved within 5–10 days, you appeal to the County Superintendent, and finally to the State Superintendent.
3. Anonymous & Ethics Reporting
If the situation involves an administrator directing an uncertified person to sign documents (which constitutes an ethical breach), you can bypass the local chain:
West Virginia Ethics Commission: If a public official is misusing their authority to bypass certification laws.
WVDE Fraud & Abuse Hotline: If the uncertified "counseling" is being billed to state or federal grants (like Title I or Special Education funds).
Phone: 1-833-734-0965
Email: OIGIntake@wv.gov
What to Include in Your Report
For an investigation to gain traction, the state typically requires specific allegations of fact. When filing, consider including:
The Specific Document: Mention the type of document signed (e.g., a Personal Education Plan (PEP), a transcript, or an IEP/504 accommodation form).
The Date & Actor: Who signed the document and on what date?
The Violation: Explicitly cite W. Va. Code §18A-3-6 (revocation for untruthfulness/fraud) or §18-5-18B (counselor certification requirements).
Would you like me to find the specific "Citizen’s Appeal" form used by Pocahontas County specifically, or would you prefer the generic state-level version?
Pocahontas County Schools provides the specific forms required by WVDE Policy 7211 (Resolution of Formal Complaints) directly on their website. Because this is a tiered process, you must use the correct form for the level of the complaint.
Pocahontas County Specific Forms
You can access the dedicated Pocahontas County complaint portal and forms here:
The Filing Process (The Chain of Command)
Under the updated policy (effective July 12, 2025), the timelines are very strict. If you are filing regarding an uncertified person signing off as a counselor:
Level 1 (School Level): File the School-Level Complaint Form with the Principal.
Timeline: The Principal must hold an informal conference with you within 5 days.
Decision: You must receive a written decision within 10 days of that conference.
Level 2 (County Level): If the Principal’s response is unsatisfactory, you have 5 days to file a County-Level Complaint Form with Superintendent Dr. Leatha Williams.
Note: If the Principal is the one you are complaining about (e.g., they directed the uncertified signing), you may file directly at the County Level.
Level 3 (State Level): If the county does not resolve the issue, you have 15 days to appeal to the State Superintendent.
Citations to Include for a Stronger Filing
When filling out the "Specific Laws or Policies" section of the form, you should cite:
W. Va. Code §18-5-18B: Specifically regarding the legal definition and certification requirements of a school counselor.
W. Va. Code §18A-3-6: Regarding the revocation of certificates for "untruthfulness" or "fraud" if you are alleging intentional misrepresentation.
WVBE Policy 2315: Which governs the Comprehensive School Counseling Program (CSCP) and the 80/20 time-allocation rule.
Would you like me to help you draft the "Statement of Allegation" section for the form based on these specific codes?
This draft is structured for the Pocahontas County Level 1 (School-Level) Complaint Form.
According to WVDE Policy 7211, you should file this with the school principal first. However, if the principal is the one directing the uncertified person to sign, you are permitted to file directly at Level 2 with Superintendent Dr. Leatha Williams.
Section: State Laws or WVBE Policies Involved
List the specific codes and policies that govern this violation:
W. Va. Code §18-5-18B: Defines "School Counselor" strictly as a professional educator holding a valid counselor's certificate and a Master’s Degree.
W. Va. Code §18A-3-6: Prohibits untruthfulness or fraud in the execution of professional duties and the signing of official education records.
WVBE Policy 2315: Establishes the requirements for a Comprehensive School Counseling Program (CSCP), including the necessity of a certified counselor to deliver direct services.
WVBE Policy 5202: Outlines the minimum requirements for licensure and defines "misrepresentation of material facts" as grounds for disciplinary action.
Section: Statement of Allegation
Provide a clear, factual description of the incident:
"It is alleged that the school/county is in violation of W. Va. Code §18-5-18B by allowing or directing an individual who does not hold a valid West Virginia Professional Student Support Certificate in School Counseling to perform duties and sign official state documents reserved for certified school counselors.
Specifically, on or about [Insert Date], an uncertified individual acted in the capacity of a school counselor by signing [Insert Name of Document, e.g., a Personal Education Plan (PEP), Senior Transcript, or 504 Plan].
Under West Virginia law, a 'School Counselor' must hold a Master’s Degree and specific state certification. By allowing a non-certified individual to sign these documents, the validity of student records is called into question, and the district is failing to provide the 'high-quality education' and 'qualified student support' mandated by the West Virginia Board of Education. Furthermore, this practice bypasses the 80/20 service delivery ratio required by state code, as the individual in question lacks the clinical training to fulfill the 'direct counseling relationship' defined in §18-5-18B(f)."
Section: Proposed Remedy
What action do you want the school/county to take?
Immediate cessation of uncertified personnel signing any documents requiring a counselor's professional signature.
A forensic audit of all Personal Education Plans (PEPs) and transcripts signed within the current academic year to ensure they were executed by a legally qualified professional.
The immediate appointment of a certified counselor or supervisor to oversee the Comprehensive School Counseling Program (CSCP) as required by the 2025 State of Emergency corrective action plan.
Important Tips for Filing:
Keep a Copy: Always keep a time-stamped copy of the form you submit.
The 5-Day Clock: Once you hand this in, the Principal (Level 1) or Superintendent (Level 2) has 5 business days to schedule an informal conference with you.
Confidentiality: Under Policy 7211, the identity of the person filing is supposed to be kept confidential among those necessary for the investigation.
Would you like me to help you look up the current mailing address for the Pocahontas County Board of Education office to ensure the Level 2 appeal is delivered correctly?
To ensure your Level 2 appeal is delivered correctly to the Superintendent, you should use the following address for the :
Pocahontas County Board of Education
404 Old Buckeye Road
Buckeye, WV 24924
Delivery Recommendations
Attention Line: Address the envelope specifically to "Superintendent Dr. Leatha Williams – Level 2 Citizen’s Appeal."
Certified Mail: Because Policy 7211 has very strict timelines (the Superintendent must schedule a conference within 5 days of receipt), it is highly recommended to send this via Certified Mail with Return Receipt Requested. This provides you with a legal timestamp of when the "clock" starts for the county’s response.
Hand Delivery: If you choose to deliver it in person to the Buckeye office, ask the receptionist to date-stamp a copy of the front page for your records.
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