The article is about the early phase of implementation of a New York state testing policy in two academic departments in an urban, comprehensive high school. It describes and analyzes a high school?s failure to construct a coherent internal accountability system when encountering an external high-stakes testing policy. Drawing on interviews with teachers and administrators conducted over a period of one year, the article explores two aspects of the school's implementation of the state policy: what actions were being undertaken in these two departments; and the perceptions and understandings of the teachers and administrators within the organization. The organizational consequences of changing the stakes for graduation for a high school serving almost all disadvantaged students are discussed.