• POG: Portrait of a Graduate (NYS framework)

• CBA: Competency-Based Assessment (focuses on skill "mastery" via checklists/frameworks)

• PBA: Performance-Based Assessment (focuses on high-quality student work/artifacts)

by Nadav Zeimer

As New York State phases out Regents exams by 2028 and implements its Portrait of a Graduate (POG) framework, policymakers face a crucial choice that will shape the future of assessment for a generation of students. This choice isn't about whether to reform assessment—that decision has already been made. Rather, it's about how we reform it, and the path we choose will determine whether we truly transform learning or simply replace one top-down system with another.

The question at hand: Should Portrait of a Graduate be implemented in school buildings through competency-based assessment (CBA) or performance-based assessment (PBA)? While these approaches may sound similar, and the difference a bit edu-wonky, the distinction between them also reveals fundamentally different visions for student learning, teacher autonomy, and even educational equity. 

To understand what's at stake, we must first acknowledge what we're moving away from. Traditional grading—with its hodgepodge of multiple-choice exam scores, participation points, homework completion, and often subjective assessments averaged into a single letter grade. All the system cared about was “seat time” like factory work and the grade a teacher extracted from their gradebook without any chance for a second opinion. It was mostly an exchange of time and good behavior for credit and had little to do with learning difficult things. 

This created academics as a game. Students could pass without actually learning by racking up empty points on a private teacher spreadsheet. Savvy students learned to boost their numbers through participation or by copying homework, mastering the art of point accumulation while genuine learning remained optional. The primary skill being evaluated, in truth, was how well students learned to game the system while doing as little work as possible.

Competency-Based Assessment

Competency-based assessment represents a substantial improvement over the industrial “Carnegie Unit of Learning” (seat-time) approach. The downside is that it requires a tremendous amount of overhead like teacher paperwork and administrative mandates.

Under CBA, educators identify specific academic skills and evaluate students' “mastery” of these so-called “competencies.” Instead of a private gradebook, teachers look for evidence that students can consistently demonstrate proficiency based on a common framework of academic skills. This focus on skills allows each student to grow and develop in the ways that align with their learning journey, breaking up the assembly line model of industrialized, standardized, conveyor-belt learning. 

This approach offers massive benefits. Students who struggle with particular competencies receive targeted support rather than being shuffled forward with gaps in their knowledge. Conversations bridge individual classrooms to help students build their learning in a variety of contexts. The "not yet" mindset replaces the permanent stigma of failure or a student focus on earning just a 65 - passing, but barely. Schools and districts that have adopted common competency frameworks—from individual schools to entire states—serve students far better than traditional grading systems. Check out mastery.org for a quality collection of Competency Based Records.

PBA: Reduction in Paperwork for Educators

CBA is overly complicated because it tries to offer a holistic assessment of the learner but does so by imposing on them a restricted list of chosen academic skills. Students are rewarded for demonstrating only these specific skills. Any skills not on the list are collateral damage and any learner that doesn’t naturally fit the “portrait” designed by administrators is at a disadvantage. 

The simpler version, PBA, achieves the educational reform goal of project-based, student-centered learning with less systemic complexity. Performance-based assessment focuses on evaluating individual artifacts of student work using a rubric. 

In fact, CBA is built using PBA. It’s as if CBA forms a second layer above PBA. PBA is used to evaluate student work and then CBA is meant to extrapolate an evaluation of a human being as a learner using the PBA evidence. Competency-based practitioners grade work with rubrics just like Performance-based assessment requires. They then organize the graded work as evidence of a larger picture they are painting of the student. In a sense, PBA aims to evaluate student work while CBA then goes on to make claims about the learner as an individual relative to an ideal learner the school has defined.

While CBA can use PBA as the first layer assessment, it can also use common industrial methods as evidence of student learning. A school can claim to be "competency-based" while students still spend their time filling in multiple-choice answers and writing formulaic five-paragraph essays under time pressure and never demanding students work collaboratively or present to a real audience (unless these specific skills were chosen to be part of the framework). PBA, by contrast, demands a laser-like focus on project-based learning. By definition, PBA requires students to create substantial work products. You cannot do performance-based assessment without engaging students in meaningful projects. The assessment method itself demands the pedagogical practice we seek. 

The concept of "mastery" itself, central to CBA implementation, deserves scrutiny. It suggests arrival at some destination rather than an expectation of a lifetime of learning. It requires that educators evaluate more than a piece of student work, but go on to evaluate the inferred abilities of the human learner. This is a massive leap of inference which adds inadvertent bias clouding academic assessment. Any competency framework offers little more than a distorted lens through which these inferences are to be made. 

We could simply call it “proficiency-based learning” showing that we expect basic proficiency of key academic skills instead of mastery. The problem remains that we must extrapolate from the student work product to make a judgment of the student themselves as a learner. While that is the entire point of academic data, PBA leaves the student learner as an emergent quality of a collection of carefully validated work products. In a sense CBA is a top-down framework for determining student readiness while PBA is a bottom-up approach where the nature of the student emerges from a collection of hard-to-earn credits. 

PBA-focused practice removes the second layer from the workload of school buildings. Certainly someone must take the collection of student work and make some determination about what this work, in aggregate, says about the learner. High schools focused on PBA leave that work to state officials, universities, and others outside their walls. While the inferences are left for others, pedagogues focus on guiding students to a portfolio of quality academic work. The expectation that students must pass a variety of subject area classes to graduate high school ensures a diversity of skill sets in a graduate portfolio, making a top-down competencies framework just a limiting factor without added pedagogical value. CBA is necessary work, but ends up delivering little more than excessive paperwork when implemented within the high school setting. CBA is best handled by university admissions officers based on PBA evidence provided by the student and their school.

Rather than creating elaborate competency frameworks, tracking student progress across dozens of skills, and building assessment systems to gather evidence for each competency, PBA asks simply: can the student produce high-quality academic work in a variety of subject areas? By simplifying our approach and focusing exclusively on the rigorous assessment of individual student work products, we allow for these work products to be individually complex. A myriad of unimaginable skills interacting organically to produce a solid product. That is much more like college and what the real world: you aren’t going to have a university administrator or a boss give you a list of skills that you can master and be done, once and for all, with learning. 

As an example of PBA implemented at scale, HS Cred includes multiple independent evaluators of any approved student recording. These evaluators are outside of the school where the student creates their work and thus help to lessen the assessment burden on individual teachers who must focus their efforts on time spent guiding young adults. CBA platforms like mastery.org leave all the grading as well as the second layer narrative to the pedagogues who are distracted from the students they serve by a burden of mastery determination and documentation. 

The larger narrative about the student as a learner is presented first by the student themselves. On the HS Cred platform, they have an OVERVIEW section they author on the top of each transcript. Mastery.org has something similar. But at HS Cred, this is the only opportunity to tell a story from the data. On mastery.org the primary story being told is that of the school through their top-down competency framework. 

The institution of higher learning either receives a transcript like that shown here, pure PBA . Or they get a complex story about the student from the lens of a set of chosen skills and the administrator has to dig through that to find the actual data provided by PBA to make their own determination about the students capabilities. 

Why should teachers and school administrators get involved in this complex process of inference and judgement calls if it just muddies the view admissions officers get of the student. The school’s job is to instill in each student their own history of achieving difficult outcomes. Less paperwork for educators, more responsibility left for students to present themselves for post-secondary opportunities directly to the university admissions team. 

With a gold standard CBA platform like mastery.org, educators spend their time collecting artifacts as evidence of student mastery within a school's competency framework. In this model, the school administration defines a "one size fits all" picture of the ideal scholar, then collects evidence showing where each student fits within that predetermined template of ultimate success. Colleges are forced to navigate a number of such frameworks since each high school defines their own. By doing the CBA for the colleges, schools muddy the water and make the use of PBA directly by admissions officers too complex and opaque. 

PBA keeps things simple by focusing on the “layer 1,” the “proof-of-work,” the evidence of a student practicing academic skills. Colleges get 20 independently validated student achievements so that they can do the work of CBA to make their best evaluation of the learner as a scholar within the context of their own competency framework. The admissions team no longer has to read admissions essays since they have pre-vetted academic work at their fingertips. The individual scholar chooses how to present themselves; no administrative decree defines what an ideal candidate should look like so that the university themselves can define their own vision of the ideal candidate. 

Schools that successfully implement CBA should certainly not stop. They include PBA implementation and their culture is working already such that the CBA is producing schoolwide conversations about student achievement. However, they should not be held accountable based on CBA - only the PBA layer should be used for that purpose. In other words, for statewide or citywide reform to succeed, policymakers should not examine more than what PBA easily provides. We arrive at the critical question for New York State's Portrait of a Graduate initiative. POG defines competencies that represent the "portrait" of what graduates should be able to do. In this way, it looks and sounds very much like CBA at scale—instead of individual schools defining graduation skills, the state establishes a common framework for all schools to align their efforts.

Given the growing adoption of competency-based approaches across New York schools, such statewide alignment could be powerful, providing common language and expectations. However, POG is also explicitly designed to replace standardized testing—specifically, the Regents exams. In this capacity, it opts for portfolio assessment over standardized examinations. This is performance-based assessment: instead of looking to bubble sheets and speed essays, POG clearly suggests that examining authentic student work is preferable to evaluating test scores.

POG emerges from the Performance Standards Consortium, which pioneered PBA as an alternative to Regents exams. The Consortium model succeeds precisely because it focuses on authentic student work and many schools also practice CBA. Yet the current lack of specificity in POG implementation threatens to transform it into a statewide competency-based initiative—essentially, a new generation of Common Core Learning Standards for all students, implemented through competency frameworks.

Getting Implementation Right: Focus on Student Work

On the New York State official POG website, the initiative connects to several related reforms. Notice what's missing: despite the competency-based nature of the portrait itself, competency-based assessment isn't mentioned. Performance-based assessment is.

Individual districts will decide which path to take. Do they focus on high-quality validation of student work products presented to authentic audiences? Or do they spend their time articulating and evaluating locally-defined subskill lists?

I'm not suggesting POG should be amended or that its competencies are problematic. Students should be able to answer to each of the skill category when presenting their final transcript to the state for the right to graduate with a diploma. These are broad enough that students can easily fit twenty published projects into the statewide framework. 

Leave it to students, state officials, and university admissions officers to make inferences about individual learners. Leave teachers the space to focus on one high-quality project at a time. PBA keeps focus where it belongs: on classrooms where students engage in meaningful project-based learning. CBA tends toward administrative tracking systems where teachers collect evidence for competency checklists. The former transforms teaching and learning. The latter risks becoming sophisticated compliance theater, at its worst.

The Common Core offered a cautionary tale: well-intentioned standards, rigidly implemented and tied to high-stakes accountability, can narrow curriculum and increase anxiety. A competency-based POG risks similar pitfalls—new mandates that, despite emphasizing skills over content, still impose a uniform vision on all students and schools.

Truly performance-based implementation would establish common rubrics and PBATS for students to work within, ensuring each content area is represented. No more comprehensive competency lists beyond what POG defines at a very high level. It would develop robust rubrics that multiple assessors are trained to apply reliably. Students would curate portfolios of their best work across disciplines. Teachers would build capacity through training in evaluation and feedback while maintaining choice in how students demonstrate capabilities. Most importantly, it would focus on the work itself rather than tracking progress through narrow competency hierarchies.

The Performance Standards Consortium proves this works. Their students, evaluated primarily through PBATs, show higher college graduation rates than peers from traditional schools—even when those peers have higher SAT scores. The portfolio approach doesn't just predict college success; it prepares students for it. Adding another layer of detailed competency frameworks is not necessary. 

Platforms like hscred.app demonstrate how performance-based assessment scales. By enabling any student to submit work for evaluation by multiple independent experts using transparent rubrics. This is the democratization of quality assessment. This is crucial for students in under-resourced schools who lack access to AP courses or CBA portfolios. 

Portrait of a Graduate promises transformative assessment that captures what students can actually do, not just what they recall on a test. But that promise requires implementation that stays true to performance-based principles without mission creep into additional layers of bureaucracy. 

To legislators, education officials, and policy leaders: You have a once-in-a-generation opportunity to fundamentally transform assessment in New York. Phasing out Regents exams was courageous. Now comes the harder part—implementation that realizes the vision in a way that empowers young people to record hard work.

For more information on performance-based assessment implementation and to see examples of student work evaluated through robust portfolio systems,visit the New York Performance Standards Consortium and HS Cred.