Three areas of concern for those considering competency-based graduation requirements are discussed. First, what is involved in implementing a competency-based graduation requirement? The first tasks are the specification of performance standards and the performance skill areas. Then, appropriate certification procedures can be selected, and their reliability and validity can be verified. The second area of concern is the effect of the new requirements on school practices. The curriculum may be narrowed to concentrate on the skills to be measured, the year of certification may influence curriculum development, and expectations for the students may decline. Options for in-depth study of a particular area may be limited, the focus may be shifted to the slow learner, and slow learners may be discouraged from competing for a diploma. Teachers' organizations may react against the program, the amount of paperwork will increase, and the program may have a negative effect on staff morale. The third areas of concern are financial and legal aspects. The cost of the testing program and of increased remedial programs must be considered, and the probability of lawsuits is quite high. Though competency-based graduation requirements may be valuable, these potential negative effects must also be considered. (BW)