Dual Credit Quality Act: Our Public Comment on Draft Administrative Rules

While legislation can set the course for policy, administrative rule-making profoundly shapes the implementation of policy priorities for those laws. In March, the Illinois Community College Board (ICCB) issued proposed rules for dual credit (Subpart C, Section 1501.313) for public comment. These rules reflect the 2025 Dual Credit Quality Act (DCQA) amendment (Public Act 104-0012), which made substantial changes to the partnership agreement process.

EdSystems has contributed a public comment to applaud the work ICCB has put into these draft rules and identify areas for further refinement in order to ensure they are the most helpful for district and college leaders as they collaborate to develop and scale robust, equitable, and strategic dual credit opportunities for learners in their regions. 

Our public comment highlights a few key areas of feedback:

  • Utilize data from appeals processes for courses and Professional Development Plans to understand patterns in partnership development challenges and inform future policy discussions through the Dual Credit committee.
  • Provide resources and guidance on navigating new expectations, such as the partner data review.
  • Consider ways to ensure the appeals process is clear and effective, including regions with existing partnership agreements.
  • Clarify timeline guidance to help partners navigate “calendar” vs. “working” days and ensure negotiations are conducted in a timely manner, so neither colleges nor high schools feel their counterpart is “running out the clock.”

We encourage our partners to review the draft rules and consider offering public comment to help ensure the finalized rules reflect the real-world challenges and best practices of leaders across the state.

Public comment is due May 11 and may be directed to Illinois Community College Board, Attn: Matt Berry, 401 East Capitol Avenue, Springfield, IL 62701-1711 or Matt.Berry@illinois.gov.

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