Frequently Asked Questions
Home Study/Private Instruction/Virtual Schooling
1. Q: Why is an Education Allowance
paid?
A: Title 5 United States
Code (USC) 5924(4)(A) provides the basis for the education allowance. The
intent of the law is embodied in Chapter 270 of the government-wide
Standardized Regulations (Government Civilians, Foreign Areas) maintained by
the Department of State (commonly referred to as the DSSR).
The education allowance is intended to assist
employees to meet the extraordinary and necessary expenses incurred by reason
of service in a foreign area, not otherwise compensated for, in providing an
adequate elementary or secondary education for their dependent children.
Reimbursement is limited to costs for educational services normally provided
free of charge in U.S. public schools.
While the law does not discuss Home Study/Private
Instruction/Virtual Schooling, it is in the best interest of the USG to ensure
students enrolled in a Home Study course, Private Instruction or Virtual
Schooling in a foreign area are able to reintegrate into a public education
system when they return to the United States.
2. Q: What is an adequate
education?
A: The major criterion of
"adequacy" is whether a child of normal ability, upon completion of a
grade, or its equivalent, can enter the next higher grade in a public school in
the United States.
3. Q: How can an employee/parent
ensure that their child obtains an adequate education?
A: The child should attend
an adequate school at post; attend an adequate school away from post; or
experience adequate Home Study/Private Instruction/Virtual Schooling.
4a. Q: What is adequate Home Study/Private
Instruction/Virtual Schooling?
A: Per DSSR 271f
definition:
(1) “Home Study” means a complete academic core
curriculum course in the home using guidelines and standards similar to or
equal to those established for the greater District of Columbia, Maryland or
Virginia region (referred to as the DMV).
(2) “Private Instruction” means instruction provided
on a regular basis using a recognized and accredited program of study in a
setting other than a school; and
(3) “Virtual Schooling” means a method of education
in an accredited program of study in which instructional delivery is either
synchronous or asynchronous.
4b. Q: What
does "accredited" mean in the DSSR? By USG's definition schools can
be accredited and teachers can be credentialed, but there is no accreditation
process for curriculum or programs that are unaffiliated with an educational
institution.
A:
Defined at DSSR 271p.
“Accredited means the recognition from an accrediting U.S. organization,
association, commission, or body that a U.S. or international institution
maintains a certain level of educational standards while honoring the unique
culture and context of each institution it supports.”
The DSSR requires an accredited
program be followed by the instructor (not a parent) who is teaching a child a
full course of study by Private Instruction [DSSR 271f(2)]. The DSSR also
requires that if a child is following Virtual Schooling [DSSR 271f(3)] the
program must be accredited. If a child is being educated at home by a
parent [DSSR 271f(1)] the requirement is that the parent has put together a
core curriculum of study similar to or equivalent to the core curriculum in the
greater District of Columbia, Maryland and Virginia region (referred to as the
DMV).
4c. Q: Where can I
find accredited programs of study for Private Instruction and Virtual Schooling?
A: The Department of
State’s Global Community Liaison Office (GCLO) Virtual
Learning Resources website contains a list of accredited programs
of study if using Private Instruction or Virtual Schooling.
5. Q: What is a core curriculum?
A: Per DSSR 271 o
definition: “Core Curriculum” means a complete academic core set of
courses including English/Language Arts, Foreign Language, Math, Science,
Social Studies, Art, Music, and Health/Physical Education. Physical Education develops motor skills,
knowledge, and behaviors for physical activity and physical fitness.
6a. Q: Where can I find Home Study
guidelines and standards for the greater District of Columbia, Maryland or
Virginia region (referred to as the DMV)?
A: The Department of
State’s Global Community Liaison Office (GCLO)
Homeschooling Resources and Curricula website contains links to Home Study
guidelines and standards for the DMV.
6b. Q: What if I have been
providing my home state’s guidelines for Home Study, can I continue to provide
my home state’s guidelines or am I going to be required to convert to
guidelines and standards for the DMV?
A: DSSR 277.3c(2)a states
For Home Study - Proof that the child is following the core curriculum of a Home
Study program similar to or equivalent to guidelines and
standards in the District of Columbia or one of the adjacent counties in
Maryland or Virginia (referred to as the DMV). Most of the home state
homeschool guidelines are similar to the DMV. It is recommended that
you review the guidelines and standards for the DMV and be able to provide your
reasoning as to how your selected state’s guidelines and standards align with
the DMV in the event the authorizing officer questions your
documentation. There is no requirement to convert to a DMV program.
7. Q: Where can I find accredited
programs of study for Private Instruction and Virtual Schooling?
A: The Department of
State’s Global Community Liaison Office (GCLO) Virtual
Learning Resources website contains a list of accredited programs
of study if using Private Instruction or Virtual Schooling.
8. Q: If Home Study/Private
Instruction/Virtual Schooling is the selected educational method, how can the
post ensure that an education allowance is being granted for an adequate
education in accordance with the law and regulation?
A: Intended in law at Title
5 United States Code 5924(4) and carried out in DSSR 277.3c(2) a post must
ensure that an education allowance is being granted for an adequate education
by obtaining the following from the employee/parent.
a. For Home
Study – Proof that the child is following the core curriculum of a Home Study
program that is similar to guidelines and standards in the District of Columbia
or one of the adjacent counties in Maryland or Virginia (referred to as the
DMV). You do not have to select a program in the DMV, but the chosen curriculum
needs to be similar to guidance as provided in the DMV. Each state offers
similarities to the DMV.
For Private Instruction - Proof that the child is
being instructed using a recognized and accredited program of study. Private
Instruction is not a tutor. Private Instruction as defined at DSSR
271f.(2) includes hiring an instructor to teach the complete lesson plan using
a recognized and accredited program of study.
For Virtual Schooling - Proof that the child is in a
recognized and accredited Virtual Schooling program.
b.
Academic requirements for Home Study/Private Instruction/Virtual Schooling
should be met each year to include:
Annual Plan;
Ability to Monitor
Progress;
Ability to Assess
End-of-Year Outcomes; and
Graduation Requirements
(grades 7-12)
9. Q: What is the education
allowance amount allowed for Home Study/Private Instruction/Virtual Schooling?
A: The annual maximums,
which are for grades K-6 and grades 7-12, respectively, are given at DSSR
274.12b. However, the maximum amount reimbursed for allowable expenses
cannot exceed the "at post" education allowance listed in DSSR
Section 920 when the school/grade at post is considered adequate and that
maximum rate for school at post is less than the applicable maximum rate
for Home Study/Private Instruction/Virtual Schooling.
Note: A separate education allowance for children
with special needs qualifying under PL-105-17, the Individuals with
Disabilities Education Improvement Act (IDEIA), is available from birth to the
21st birthday; for individuals receiving services or support pursuant to
Section 504 of the Rehabilitation Act of 1973 (Section 504) this allowance is
available for grades Kindergarten through 12th grade. The maximum education allowance
rate for Home Study/Private Instruction/Virtual Schooling of children with
special needs is shown at DSSR 274.12c. An additional 50% of the education
allowance may be reimbursed at the post level for necessary, allowable expenses
(DSSR 276.81). Requests for reimbursement for allowable expenses above
the additional 50% maximum must be submitted to the Director, Office of
Allowances, U.S. Department of State.
10. Q: Effective January 3, 2021,
why were the grade ranges changed from K-8 and 9-12 to grades K-6 and 7-12?
A: The change was
made to better address the transition to the secondary school level.
11. Not in use. Pertained to the 2020-2021 school year.
12. Q: Where in the DSSR can I find
allowable and non-allowable expenses for Home Study/Private Instruction/Virtual
Schooling?
A: DSSR 277.3a lists
allowable expenses and DSSR 277.3b lists non-allowable expenses. In
addition, the DSSR 960 Education Allowance Worksheet page 2 shows allowable and
non-allowable expenses.
13. Q: Can an employee be
reimbursed for expenses incurred prior to arrival at their foreign post of
assignment?
A: Per DSSR 273 reimbursement may not be
received prior to the employee or family member's arrival at a foreign post.
After the employee or family member has arrived at the foreign post of
assignment, the Standard Form (SF) 1190 and DSSR 960 Education Allowance
Worksheet may be filed to receive reimbursement of allowable expenses.
14. Q: What is the deadline for
submitting the Standard Form (SF) 1190 to request reimbursement for allowable
expenses under the Home Study/Private Instruction/Virtual Schooling method?
A: Per DSSR 273 “Evidence
of actual schooling costs for the ‘Home Study/Private Instruction/Virtual
Schooling’ educational method (DSSR 274.12b) must be submitted no later than
the end of the fiscal year (September 30) for schooling completed within the
past 12-month period or when requested by the officer designated to authorize
allowances, the Department of State, or other responsible authority.”
15. Q: Can I rent a computer,
laptop or tablet which will be used for my child’s school work?
A: Yes. Under
Allowable Expenses, DSSR 277.3a(7) states “Electronic
devices and other rentals: of a computer or similar devices of
curriculum-related equipment; and other items such as microscopes and band
instruments which would normally be provided free of charge in U.S. public
schools.”
16. Q: Can I be reimbursed for
allowable expenses under DSSR 277.3a if my child is enrolled in a Home Study
course with a religious focus?
A: Yes. You can be
reimbursed for allowable expenses under DSSR 277.3a. See DSSR 277.3c(2)
for required documentation for the Home Study/Private Instruction/Virtual
Schooling educational method.
17a. Q: What expenses are allowed
if an employee uses a third-party provider (referred to as an umbrella or cover
school) to assist with their child’s Home Study program?
A: DSSR 277.3b (7) “Third-party
expenses: An educational provider receiving payment must be
providing the course teaching and evaluations directly to the student.
The course of study provided by the educational provider may be online, by
correspondence, or through other appropriate materials. Indirect or
third-party service provider fees, such as umbrella schools/cover schools not
providing direct instruction, course, or accredited virtual education, are not
reimbursable fees or recognized as advisory fees. However, an employee/parent
can elect to pay them as a personal expense. Third-party service
providers may not receive an advance payment as they are not the direct
educational service provider. The educational service provider must
document that the child is enrolled and list out itemized goods/services/fee
costs paid by the third-party service provider or directly by the
employee/parent, and confirm that the fees paid are no higher than had the
employee/parent enrolled the student directly with the educational provider.”
17b. Q: Abeka will not accept payment
directly from the government. If we pay out of pocket and submit for
reimbursement, will it be approved?
A: When claiming expenses an invoice
should clearly describe each expense so there is not a doubt what is being reviewed.
Note: Employees/parents should review DSSR 277.3b(7) if Third-Party
Expenses are involved.
17c. Q: Also, if we purchase a
curriculum from Abeka that is not part of their full, accredited grade level
(e.g. just Language Arts classes to take over summer), is that
reimbursable?
A: Yes. DSSR 273 states the
following “Evidence of actual schooling costs for the ‘Home Study/Private
Instruction/Virtual Schooling’ educational method (DSSR 274.12b) must be
submitted no later than the end of the fiscal year (September 30) for schooling
completed within the past 12-month period or when requested by the officer
designated to authorize allowances, the Department of State, or other
responsible authority.”
17d. Q: Under Third-Party
Expenses [DSSR 277.3b(7)], there are many online classes
(i.e. Outschool, iTalki, etc.) that the private instructor is paid by
the company, not directly paid by the parent. Are these considered Third-Party
Expenses and not reimbursed? Also, why are administrative costs for schools
at post and virtual schools allowable expenses while administrative costs for
online education businesses not allowable?
A: DSSR 277.3b(7) states “The educational service provider must
document that the child is enrolled and list out itemized goods/services/fee
costs paid by the third-party service provider or directly by the
employee/parent, and confirm that the fees paid are no higher than had the
employee/parent enrolled the student directly with the educational provider.”
When dealing with schools at post
and virtual schools you are dealing directly with the school or accredited
program and not working through the additional layer of a company between you
and the instructor. The company is providing a service and charging for
it. This administrative charge is not an allowable reimbursement.
Cable 17 State 48162 made it clear what are allowable and non-allowable
expenses when using a third-party provider.
18. Not in use. Pertained to the 2020-2021 school year.
19. Q: How can I ensure
that my expenses claimed are allowable?
A: When claiming
expenses you should first review allowable (DSSR 277.3a) and non-allowable
(DSSR 277.3b) expenses. Your SF-1190/DSSR 960 Education Allowance
Worksheet should note which core curriculum course(s) pertain to the items on
your list of claimed expenses. Available on Opennet only - Post Support
Unit (PSU) Sharepoint provides a helpful Sample Template for Home School
Expense Claims. Available on both Opennet and Internet here is the link to
the Sample Template.
20a. Q: I am following Home Study
and educating my child at home. My child requires additional instruction
for a core curriculum course. Can I be reimbursed for expenses for this
additional instruction? Could I use Supplementary Instruction under DSSR
276.9 for this additional instruction?
A: Supplementary Instruction is
allowed only in addition to the “At Post” Education Allowance method. For
Home Study/Private Instruction/Virtual Schooling, DSSR 277.3a(5) allows
reimbursement for additional instruction when a child needs it for a core
curriculum course. DSSR 277.3b(3) does not allow reimbursement if a
parent provides this additional instruction.
20b. Q: Please confirm that
tutors are reimbursable under DSSR277.3a(5).
A: DSSR 277.3a(5) states
“Additional instruction: by an individual
other than the parent: costs only when
necessary when a child needs instructional assistance in order to successfully
complete a core curriculum (DSSR 271 o) course.
20c. Q: Homeschooling almost always includes tutors
and online courses. Can we be reimbursed for online courses and employ tutors
in core subject areas? How does accredited apply in these cases?
A: One-on-one tutoring is not normally provided free of charge
in U.S. public schools. Under the Home Study/Private Instruction/Virtual
Schooling method when a child requires additional assistance in a course then
there may be reimbursement for such additional assistance via DSSR 277.3a(5).
For this additional assistance accrediting does not apply.
21. Q: Can you explain why there
are different requirements depending on if I am educating my child at home (Home
Study); someone outside the home is providing the full course of study (Private
Instruction); or an online synchronous or asynchronous course of study (Virtual
Schooling) is being followed?
A: The requirements at DSSR 277.3c(1)
are intended to ensure that a child in a Home Study/Private Instruction/Virtual
Schooling (HS/PI/VS) course in a foreign area can reintegrate into a public
education system when and if returning to the United States.
If the child’s full course of study is via either Private
Instruction [DSSR 271f(2)] or Virtual Schooling [DSSR 271f(3)] documentation
under DSSR 277.3c(2) requires that a recognized and accredited course of study
be followed. Although not all-inclusive, a list of recognized and
accredited programs is available on the Global Community Liaison Office (GCLO) Virtual
Learning Resources website.
For Home Study [DSSR 271f(1)], DSSR 277.3c(2)
requires a core curriculum similar to or equivalent to the District of Columbia
or surrounding counties in Maryland and Virginia (DMV) and it does not carry
the same “recognized and accredited” verbiage as does Private Instruction and Virtual
Schooling. Links to the DMV school systems are available on the Global Community Liaison Office (GCLO)
Transitioning From School to School website.
22. Not in use. Pertained to 2020-2021 school year.
23. Not in use. Pertained to 2020-2021 school year.
24. Q: Why am I being told I must
use a curriculum of a Home Study program similar to or equivalent to guidelines
and standards in the District of Columbia or one of the adjacent counties in
Maryland or Virginia (referred to as the DMV)?
A: Once you research the guidelines
and standards for the DMV available on the Global Community Liaison Office (GCLO)
Transitioning From School to School website you will realize there
is a wide range of guidelines and standards which allow you flexibility in
choice of which DMV standards and guidelines to match up with whatever Home
Study standards and guidelines you are currently following. With most USG
agency headquarters in the Washington, D.C. area, if an employee is assigned to
the DMV region, s/he will be required to adhere to the applicable DMV
guidelines and standards.
25. Q: Can I continue to use the
curriculum that I put together from various sources to provide individualized
instruction for my children with different academic needs?
A: Yes, however, per DSSR 277.3c(2)a
For Home Study - Proof that the child is following the core curriculum of a Home
Study program similar to or equivalent to guidelines and standards in the
District of Columbia or one of the adjacent counties in Maryland or Virginia
(referred to as the DMV). Per DSSR definition 271 o “Core curriculum”
means a complete academic core set of courses including English/Language Arts,
Foreign Language, Math, Science, Social Studies, Art, Music, and
Health/Physical Education.
26. Q: Under the
redefinition of "Private Instruction" as using a "recognized and
accredited program of study", does this mean the instructor must be
accredited somehow? Must the instructor teach following a specific type of
program? Does the instructor have to be affiliated with a school or other
institution?
A: DSSR definition
271f(2) “Private Instruction” means instruction provided on a regular basis
using a recognized and accredited program of study in a setting other than a
school. It does not state that the instructor needs to be accredited or
affiliated with a school or other institution. However, when the full
course of study is provided by a private instructor the employee/parent must
provide documentation that the instructor is using or following a recognized
and accredited program of study. For reference, although not
all-inclusive, a list of accredited programs of study are available on
the Global Community Liaison Office (GCLO) Virtual
Learning Resources website.
27a. Q: Based on the
requirement at DSSR 277.3c(2)b that “Academic requirements for Home Study/Private
Instruction/Virtual Schooling should be met each year to include: Annual Plan;
Ability to Monitor Progress; Ability to Assess End-of-Year Outcomes; and
Graduation Requirements (grades 7-12)”, who will evaluate these? Financial
Management Officers? Finance Locally Employed Staff?
A: The DSSR requires that the post
obtain documentation for these elements but not evaluate them.
27b. Q: Why are these required
for ONLY Home Study/Private Instruction/Virtual Schooling but NOT required for
post school?
A: DSSR 277.3c provides the
employee/parent the tools to chart and evaluate their children’s
progress. These were developed by a working group
comprised of professional educators from the Office of Overseas Schools with
vast knowledge of all education allowance methods as well as representatives
from the Global Community Liaison Office, CGFS Post Support Unit and the
Office of Allowances with foreign post assignment and education
experience. The documentation is intended to assist and not to penalize
if an employee/parent chooses the Home Study/Private Instruction/Virtual
Schooling education method. When an employee/parent chooses either the At
Post or Away from Post education method these requirements
are innate to established schools as they are authorized to
operate in the country they are located and provide documentation to
the student, such as report cards with evaluations.
27c. Q: What specific documents do I need to submit to
comply with this requirement?
A:
There are no formal forms or documents that are required.
What is required is a statement from the employee/parent saying what they
will be following and how they will monitor progress and how they will
assess end-of-year outcomes.
27d. Q: How are assisted and non-assisted schools
held accountable to the Department of State with their student outcome?
A:
Schools whether assisted or non-assisted must be accredited, licensed,
registered or recognized within the country they are located in and requirements
are embedded in the yearly reports for these programs.
28a. Q: On the DSSR 960 Education
Allowance Worksheet, PE and music classes are specifically listed as
reimbursable "at school at post" and as "school charged
group" expenses. Does this mean we can only go through the at-post
school for these courses?
A: No. In addition to the
charges more than what is charged to students attending the school at post,
access fees are allowed for recreation facilities to attend group physical education
classes. Group music and physical education classes may be obtained
outside of the school at post.
28b. Q: Why does the
Department require reimbursable PE and music instruction to be in groups even
though this does not reflect foreign service realities such as availability,
demand, and gender restrictions?
A:
If PE and music instruction is not in groups this would be personalized
one-on-one instruction which is not allowed.
28c. Q: Can you please clarify what constitutes a
group for group PE classes?
A: A group may be defined as at least two persons.
28d. Q: Are two physical
education instructors allowed to teach the group at the same time?
A: Yes, if the two instructors are teaching the group in tandem
and not providing one-on-one instruction.
28e. Q: If two siblings
attend a class, can this be considered a group?
A: Yes
28f. Q: You do not reimburse PE activities that are not
available in the DC metro area. But you pay for post schools where instruction
includes sports that are not found in DC/VA/MD. Can you help us understand this
discrepancy?
A:
Physical Education/physical activity encompasses a wide variety of allowable
activity. In this age of COVID and the need for distancing physical
education/physical activity may include for example such sports as Tennis,
Bowling, Softball, Baseball, Cross Country and Archery.
29a. Q: On the DSSR 960 Education
Allowance Worksheet, non-allowable expenses including "set or collection
of books not part of curriculum". When reading skills and literacy
are foundational to education (and libraries overseas are often
unavailable) why are ANY book purchases being disallowed? How
do I prove every book I purchase for homeschooling is part of the
curriculum?
A: Book purchases may be reimbursed
when required for the curriculum [DSSR 277.3a(2)]. Available on
Opennet only - Post Support Unit (PSU) Sharepoint provides a helpful Sample Template for Home School
Expense Claims. Available on both Opennet and Internet here is the link to
the Sample Template. The template
allows you to enter each book with its associated core curriculum course.
29b. Q: Requiring that all books be
tied to a curriculum is not appropriate for elementary students, for example,
as all reading materials/leveled readers will be used as part of the language
arts curriculum and are not tied to a specific subject or theme.
A: Language Arts is part of the core
curriculum defined at DSSR 271 o. Book purchases may be reimbursed
when required for the curriculum [DSSR 277.3a(2)]. Available on Opennet only - Post Support Unit
(PSU) Sharepoint provides a helpful Sample Template for Home School
Expense Claims. Available on both Opennet and Internet here is the link to
the Sample Template. The template
allows you to enter each book with its associated core curriculum course.
29c. Q: Please explain how to
document that language arts books are not used outside the course.
A: The easiest ways to document this
is for the books to be required for the course. If an inordinate number
of books are being claimed for use by a student during only the current school
year questions may arise at the certifying level.
30a. Q: Homeschooling
families pay for U.S. public libraries and public schools with
our U.S. tax dollars. They rely
on public libraries. At most posts, we do not have access to
them. In general, “At Post” schools will not give homeschooled students
access to their libraries and online libraries are often not appropriate to
teach early or new readers.
A: Research shows that there are
many public libraries by State, with special sections for young readers as well
as paid libraries with dedicated grade appropriate materials starting with
Kindergarten. See openlibrary.org.
30b. Q: Can you specify which
online libraries will be reimbursed?
A: From a Post Support Unit (PSU)
perspective, we would accept any age-appropriate libraries.
31a. Q: Can there be a reasonable
stipend, determined by the Office of Allowances, for expendable supplies like
pencils, pens, markers, paper, paint, etc.? These items are sometimes provided
in public schools in the U.S. depending on which U.S. school district you are
comparing to. How are we to know what is reimbursable? Will you
provide a list of what WILL be reimbursed?
A: DSSR
277.3a(2) allows reimbursement for books and supplies required by the
curriculum. Emphasis is on required as
opposed to optional which is the employee’s expense. Non-allowable expenses include purchase of
computers or similar devices, printers, electronic devices, and furniture. Post Management should require evidence of books
and supplies required by the curriculum.
31b. Q: Why
does the Department allege that art supplies are not reimbursable because
public schools do not provide them, even though this is incorrect and
public-school students do not need to bring paint brushes and sculpting clay to
art class?
A: DSSR 277.3a(2) allows reimbursement for books and supplies required
by the curriculum. Emphasis is on
required as opposed to optional which is the employee’s expense. Non-allowable expenses include purchase of
computers or similar devices, printers, electronic devices, and furniture. Post Management should require evidence of books
and supplies required by the curriculum.
32. Q: I live in the Southern
Hemisphere and use the U.S. school calendar August-June to homeschool my
children. My concern is, “A home study program is timed to coincide with the
school year that predominates at local post schools.” Does this mean that
families in the Southern Hemisphere must shift their school year to
January-December? This would be a hardship for my family as I do not want my
child to have to be put in the grade ahead or in the grade they just completed
to simply coincide with the school year at local post schools.
A: A Home Study program does not
require conforming to the school year of the school at post and is not confined
to the school year as defined at DSSR 271h since Home Study is not “a specific
educational facility”. Home Study may be year around.
271 h. "School year" means the total
number of calendar days involved in obtaining, by means of a specific
educational facility, elementary or secondary schooling within one prescribed
maximum rate in one 12 month period.
Further supporting the year around nature of Home
Study, DSSR 273 states that evidence of actual schooling costs for the “Home
Study/Private Instruction/Virtual Schooling” educational method (DSSR 274.12b)
must be submitted no later than the end of the fiscal year (September 30) for
schooling completed within the past 12 month period or when requested by the
officer designated to authorize allowances, the Department of State, or other
responsible authority.
33. Q: Under the new DSSR,
regarding sports, it is unclear about whether dance classes or group sports are
still reimbursable, which they used to be. Can you clarify?
A: If group sports mean
extracurricular team sports affiliated with the school at post then expenses
charged above what is charged for children attending the school may be
reimbursed. Team sports outside of the school at post, such as
county-sponsored sports in the U.S. are paid for by the parents and are not
reimbursed under the education allowance. General group dance classes may
be reimbursed as physical education activity.
34. Q: Who within
the Department of State apart from the Office of Allowances is responsible for
advocating for and advising homeschoolers when there are concerns with reimbursements?
A: The Global Community Liaison Office (GCLO), Education and Youth
team are available and ready to listen, guide, and advocate with our
partner offices on any homeschooling issues that are brought to our attention
from employees and their families. We have been and
will continue to be a voice to convey policy concerns to
better serve all foreign service families. However, we are not the
education, allowances, or finance experts. In situations where there
are more complicated circumstances with allowances or reimbursements, we would
refer clients directly to the appropriate office. The Office of
Overseas Schools is also available to listen and provide guidance to support
families that choose to use homeschooling as an educational option and
will assist with clarification of common practices that exist within US
public schools and international schools abroad that serve our diplomatic
dependents.
35. Q: Why are final decisions
on allowable expenses being made by people who may or may not have any
experience with homeschooling (or education more broadly)? Particularly
overseas, homeschooling often means piecing together a curriculum and others
may not understand that.
A: The final
decision for a direct payment or reimbursement rests
with the certifying officer, as this person is personally and
financially liable for the legality and correctness of any
payment made, however, a certifying officer relies on the Office of
Allowances and Office of Overseas Schools for final interpretation of
educational materials for reimbursement.
36. Q: Why is every item scrutinized
for homeschooling families, but not post schools? They are not made to justify
(to non-educators) each purchase and connect it to a curriculum to receive
funding as we are. It is discriminatory and degrading. Can the Department
develop a spreadsheet with clickable options to standardize the process and
take less time away from our children and/or work?
A: This is a misconception.
Traditional school tuition bills are also reviewed for disallowable
items. Homeschooling parents do not have to be more accountable, however,
parents using a brick and mortar, or virtual school normally only forward the
school tuition bill to the finance office and not individual expenses. Each
education allowance method selected has a discrete set of regulations that governs
payments; however, all methods must provide an adequate education that is
provided free of charge by public schools in the US.
37a. Q: Why are families
using schools-at-post not held to any standard for subjects taken,
reimbursements, class size, or proof of progress? Why are school-using families
not asked to reimburse the USG for the many non-covered expenses that
homeschoolers are not reimbursed for (for example elective courses such as
a computer class/digital imaging)?
A: The school at post already has a developed curriculum,
progress established in testing and is accredited, licensed, registered or
recognized in the country the school is located in. In a core curriculum
there is flexibility for elective courses, especially at the high school
level. When parents enroll children in schools at post these schools have
curriculum articulations, courses of study, progress reporting expectations,
and standards that are subject to verification from local host country
authorities. Proof of progress would be the promotion to the next grade
level.
37b. Q: Can my child take a
computer class as a homeschooler; can we get reimbursed for computer coding
supplies and what about computer lab fees and technology rental at at-post
schools?
A: A computer class would normally be
an elective offered in middle or high school (grades 6-12), however, if a claim
is made for reimbursement of a computer class for grades K-5 it is recommended
that you submit reference documents to support a claim at these lower grade
levels. Per DSSR 277.3a(2) (allowable expenses): “Books and
supplies required by the curriculum”. If computer lab fees and
technology rental are stated as part of required course supplies,
then these are allowable expenses. Emphasis is on required as
opposed to optional which is the employee’s expense. Non-allowable expenses include purchase of
computers or similar devices, printers, electronic devices, and furniture. Post Management should require evidence of books
and supplies required by the curriculum.
38. Q: For supplemental materials, what is meant by
"do not have a broader use than the course being studied" and how
will that be clearly/consistently interpreted?
A: Effective 6/19/2022 ‘broader use’ language has been
eliminated from DSSR Chapter 270 for all education methods. DSSR
277.3b(1) (non-allowable items) states items that have a broader use.
They are “Purchase of computers or similar devices, printers, electronic
devices, and furniture”. DSSR 277.3a(2) (allowable expenses) now states
“Books and supplies required by the curriculum”. Post Management should require evidence of books
and supplies required by the curriculum.
39. Q: What record keeping
requirements exist that protect my child's personal information (educational
plan, progress monitoring and end of year results) from unauthorized disclosure
in the E2 process and elsewhere?
A: The electronic
submission of claims through E2 presents no greater risk of
unauthorized disclosure than the traditional paper method. E2 is the
official approved system for claims. In general, only the SF-1190 contains
PII material–the birthdates for the students. This information is
required in both processes. Electronic records within the E2
system have only limited access to select individuals. Posts
may further strengthen privacy by electing the routing to remove
travel arrangers for these claims.
40. Q: The Cognitive Abilities Test (CogAT) is
provided to all Northern Virginia (NOVA) students by Virginia law. It helps
identify 2e and other underrepresented groups for Gifted/Talented (G/T)
programs. It aids in transitions home and abroad. Why is it restricted only to
students attending school at post?
A: A generalization with G/T testing in the US
public schools is that assessments are done between the ages of 5-8 to
determine eligibility. Most international schools do not provide G/T testing
nor offer extended G/T services. Testing varies from district to district,
state by state to determine G/T. With that said, G/T testing is done free of
charge in US Public schools if the child is enrolled. For home
schooled children in the U.S. G/T testing is paid for by the parent. G/T
testing is not an allowable expense for reimbursement under DSSR
277.3.
The
Office of Overseas Schools (OS) does facilitate G/T testing if an assisted or
unassisted overseas school indicates the child is performing at such a high
level that G/T testing is recommended. For students enrolled in
Virginia’s Fairfax County Public Schools (FCPS), all grade 2 students are
tested annually to determine eligibility. For students entering
FCPS, the testing for G/T in NOVA is based on a referral process to identify a
student for potential Gifted services. Referral approvals then require
assessment to determine eligibility. If the child was not tested in grade
2, regardless of where they were enrolled for that school year, upon enrollment
in FCPS the district should initiate testing in the next available window.
Parents are encouraged to advocate for their children within the FCPS system
when they enroll to ensure the G/T testing occurs if this is something they
desire. There is not an option to test if the student does not attend FCPS. OS
does provide G/T testing to students who are referred or recommended for G/T
testing by schools overseas.
41. Q: In allowable
expenses at DSSR 277.3a(6), (8) and (10), what is an "other authorized
program"? Who is authorizing another program? How long will this
authorizing process take? Will this information be broadly shared?
A:
Effective 6/19/2022 this language has been eliminated. For (8) and (10)
these are allowable expenses as required by the curriculum.
42. Q: Why are regs not applied equally to ALL
students at post? Private schools are not put through this level of scrutiny,
to receive funding. If this is not applied to all children at Post, you cannot
selectively apply it to any Post children.
A:
This is a misconception. Tuition bills submitted for payment are also
reviewed before certification to ensure that funding does not go to
disallowable items, such as uniforms, lunches, overnight field trips,
yearbooks, etc. Homeschooling parents do not have to be more accountable,
however, parents using a brick and mortar, or virtual school normally only
forward the school tuition bill to the finance office and not individual
expenses. Each education allowance method selected has a discrete set of
regulations that governs payments; however, all methods must provide an
adequate education that is normally provided free of charge in US public
schools.
43a. Q: It is understood that the
Office of Allowances (ALS) “owns” the regulation that applies to Homeschool.
A: The Department of
State’s Office of Allowances (ALS) is delegated the responsibility to maintain
the government-wide Standardized Regulations (Government Civilians, Foreign
Areas), commonly referred to as the DSSR. DSSR 270 contains regulations
for the Education Allowance. ALS is not responsible for agency
implementing regulations which may be more restrictive than the DSSR but cannot
go beyond the scope of the DSSR.
43b. Q: Does ALS also “own” and
publish the applicable FAMs and FAHs that establish the policy?
A: No. The FAM and
FAH contain the implementing policy for the Foreign Affairs Agencies which may
be more restrictive than the DSSR but cannot go beyond the scope of the DSSR.
43c. Q: If not, which office does
“own” the policies (FAMs and FAHs)?
A: 4 FAM which
governs the execution of payments falls under the purview of CGFS.
44a. Q: Which office (Allowances,
PSU, Post FMO, other) has the authority and should be determining if a claimed
expense qualifies for reimbursement under the regulation (and associated
policies)?
A: The Post FMO or PSU
determines if a claimed expense is reimbursable consistent with the DSSR.
44b. Q: Which office has the final
decision on whether or not an item (that may fall into a grey area) is or is
not reimbursable? Is it Allowances, PSU, Post FMO, other?
A: The Post FMO or PSU
determines if a claimed expense is reimbursable consistent with the DSSR.
A certifying officer must ensure that funds are used appropriately and
consistent with regulation and law.
45. Q: What is the appeal or
resubmission process for an incomplete or denied claim?
A: The Office of
Allowances does not process claims. There should be instructions back to
the employee/parent designating what is incomplete and/or the reason for the
denied claim. The employee should resubmit the completed claim and/or how
the claimed expense is required by the curriculum.
46. Q: Can you please put all the
homeschool reimbursement forms and templates on platforms that are easily
accessible and in one clear location?
A: Templates are available
on both the internal State Department Opennet and
Internet. Available on Opennet only - Post Support Unit (PSU)
Sharepoint provides a helpful Sample Template for Home School
Expense Claims. Available on both Opennet and Internet is the link to
the Sample Template.
47. Q: Can you please provide the
ALDAC for the DSSR270 updates from January 3, 2021?
A: 20 State 125150
dated 12/31/2020.
48. Q: If reading books are
not reimbursable, why hasn't the Dept of State established an agreement with
digital library providers such as OverDrive or Libby in the same manner as the
military services? See: https://www.myairforcelife.com/libraries
A:
The Department of State’s Office of Allowances (ALS) maintains the government-wide
Standardized Regulations (referred to as the DSSR) and allowances under the
DSSR which are applicable to all USG civilians in foreign areas unless an
agency has its own authority. The Department of Defense (DoD) has its own
authority for educating children of both uniformed service personnel and DoD
civilian employees.
The Department of State’s
implementing policy pertaining to the DSSR are the Foreign Affairs Manual (FAM)
and Foreign Affairs Handbook (FAH) which are maintained separately from ALS.
Programs such as referenced are not part of ALS’s portfolio, however, we note
that both OverDrive and Libby are downloadable apps.
49. Q: We are the only
homeschooling family at our post in a non-English speaking country. How is it
fair to expect only group classes will be covered when there are not group
class options available? Isn't this discriminatory to homeschoolers?
A:
Group classes may be available online. Anything that is not a group
(which may be two or more persons) would be individualized instruction which is
not free of charge in U.S. public schools.
50. Q: When was the allowance
amount last updated, how was it formulated and why does it not reflect
differences in cost of living around the world and inflation as other
allowances do?
A:
Prior to the 1/3/2021 change from grades K-8 and 9-12 to grades K-6 and 7-12
the rates ($10,500 and $21,500, respectively) have been in effect since
8/5/2018. Well-known and respected programs are used to develop the
rates and the amounts are constant irrespective of world location. The
education allowance is one of the cost of living allowances mentioned in the
Law at 5 US Code 5924. The post allowance is a separate cost of living
allowance which measures differences and the effects of inflation on the market
basket of goods and services worldwide as compared with costs and inflation in
Washington, D.C. The post allowance is a separate measurement and does
not include children’s education.
51. Q: Are there
hourly limits for the number of hours a family can use
Additional Instruction [DSSR 277.3a(5)] for any of the 8 core courses under
Home Study (i.e., no more than 3 hours of PE/week, by additional instructor)?
If so, this info needs to be broadly shared and posted.
A:
Per DSSR 277.3a(5) “Additional instruction: by an individual other than
the parent: costs only when necessary when a child needs instructional
assistance in order to successfully complete a core curriculum (DSSR 271 o)
course.” There is not a limited number of hours attached to
Additional Instruction. All DSSR methods of education (At Post, Away from
Post, Home Study/Private Instruction/Virtual Schooling and Special Needs
Education Allowance) are represented by a single dollar amount with
reimbursement for all allowable expenses within the maximum rate set for each
method.
52. Q: Homeschool students are
now being held to double-state standards, the DMV on top of their legal state
of residence. This is an undue burden on parents, plus takes away from our home
state's legal rights to govern the child's education. WHY?
A:
The DMV provides a reference point, is not a restriction and does not impose
undue burden on the employee/parent.
53. Q: Allowable expenses (6a)
- can a family using Home Study submit expenses for reimbursement in this
category? Please give examples of "digital learning resources'' that any
family could submit for reimbursement, whether they use HS, PI, or VS.
A: DSSR 277.3a(6a) states “Access to digital learning
resources: for a recognized and accredited program of study or an
accredited Virtual Schooling program.” If a child is enrolled in whole or
in part in an accredited program of study and these are additional charges by
the accredited program then these are reimbursable expenses. If a child
is not enrolled in whole or in part in an accredited program then these are not
allowable expenses for reimbursement.
54. Q: Please clarify Private
Instruction in the DSSR? It appears to have two meanings (1) an Instructional
Method; and (2) as "additional instruction for a core curriculum
course."
A:
Effective 6/19/2022 the Private Instruction Method is at DSSR 277.3(a)(4) and
Additional Instruction is at DSSR 277.3(a)(5).
55. Q: Many current
homeschoolers are considering starting their own schools to avoid the
limitations and problems of the homeschool allowances. Can we expect any
changes to the DSSR regarding "School at Post” education allowances?
A:
The “School at Post” education allowances are reviewed annually and rates are
normally based on the least expensive adequate school at post.
56. Q: What is the name and
contact info for the person "in charge" of homeschoolers within DOS?
Who should we go to when we have questions? Our CLO and FMO at Post have zero
understanding of what homeschooling is nor the reimbursement process.
A:
The Office of Allowances, Office of Overseas Schools, the Global Community
Liaison Office and CGFS Post Support Unit are all good references for
questions. The employee/parent is ultimately the person in charge of
their children’s education.
57. Q: Regarding documentation
- who sees this information? Who has access? How is a child's privacy being
protected? What happens to this documentation, & where does it end up?
Private school students do not have to share this documentation with
Post.
A: The electronic
submission of claims through E2 presents no greater risk of
unauthorized disclosure than the traditional paper method. E2 is the
official approved system for claims. In general, only the SF-1190 contains
PII material–the birthdates for the students and is required for all
education methods. This information is required in both processes.
Electronic records within the E2 system have only limited
access to select individuals. Posts may further strengthen privacy by
electing the routing to remove travel arrangers for these claims.
58. Q: What plans are there to
provide more training about reimbursements for FMOs? Our FMO incorrectly quoted
a reimbursement number, costing us over 3K out-of-pocket when they realized
their error.
A:
FMO training is not part of the Office of Allowances’ portfolio, however,
perhaps this could be brought up in the State Department’s FINNET channel.
59. Q: It seems as though
homeschoolers are held to a higher standard than at-post schoolers. This
reflects lack of trust in DoS parents to know what is best for their kids, as
well as lack of understanding for what homeschooling entrails. Is there an
appropriate forum for Homeschooling families to share their concerns in a
productive manner to help the Department understand the unique challenges of
homeschooling overseas?
A:
The intent of required documentation is to protect homeschooling as an option
for families assigned to foreign areas. Homeschooling in the United
States is a choice and the main burden of expense is on the parent.
The Global Community
Liaison Office (GCLO) Homeschooling Resources and Curricula website is a valuable resource and sounding board for
homeschooling families.
60. Q: Can you please explain
the reimbursement process? How long should the reimbursement process take? I
would like a realistic expectation. And what is the appropriate way to follow
up?
A:
Each agency has its own procedures, including the Department of State.
You should probably first check with your FMO at post. Also available is
the Post Support Unit. Their email address is GFSPSU@state.gov.
61. Q: Is it possible to
invite DOS homeschooling parents on a panel to advise management and the Office
of Allowances on a reasonable, streamlined, non-discriminatory budget that
allows an exceptional education while still saving posts thousands of dollars?
A:
The education allowance is a cost of living allowance and not subject to
federal income tax because it is a reimbursement for necessary expenses.
All cost of living allowances under the DSSR are reimbursements for actual
expenses incurred as a result of an assignment to a foreign post. To
allow a lump sum of a cost of living allowance without justification opens this
up to Congressional oversight/inquiry which in turn could lead to taxation of
the homeschooling allowance.
62. Q: Many curricula do not
offer some of the 'specials', health or phys. ed. Can you please explain why
these are required for a curriculum to be accredited and reimbursable?
A:
DSSR definition 271o: “Core Curriculum” means a complete
academic core set of courses including English/Language Arts, Foreign Language,
Math, Science, Social Studies, Art, Music, and Health/Physical Education.
This definition is to highlight all parts of a core curriculum, bringing
attention perhaps to the less recognized such as Art, Music and Health/Physical
Education. By establishing what the core curriculum
includes allows for reimbursement for instruction in these courses in addition
to the accredited program the child is enrolled in.
Last updated on February 1, 2023