CSign
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Do you mean that they did not meet the graduation requirements or that they couldn't do it in a standard school setting?
Typically, it's for student's who have been in self-contained placements which turn into life-skills classes etc. as they get older. Generally speaking, it's for individual students who don't have the cognitive ability to benefit from and progress in the general Ed setting. They only determine that after time has passed and the student has demonstrated their capacity for learning. In other words, a student being deaf is not going to qualify them for a special ed diploma as they are fully capable of obtaining a regular high school diploma.
Students who attend schools for the deaf are still eligible for regular diplomas. It's a question if whether or not the student meets standards set by the educational agency.