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Office of Allowances

Frequently Asked Questions
Home Study/Private Instruction/Virtual Schooling

QUESTIONS:

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 his/her 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:  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.  The DSSR also requires that if a child is following Virtual Schooling the program must be accredited.  If a child is being educated at home by a parent 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) 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.

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) contains links to home study guidelines and standards for the DMV.

6b. Q:  What if I’ve 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) 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. Q:  With the change from grades K-8 and 9-12 to K-6 and 7-12 effective January 3, 2021, can I be reimbursed for additional allowable expenses for my children in 7th and 8th grade? 

A:  Yes.  You will need to submit a Standard Form (SF) 1190 for each child to request reimbursement for additional allowable expenses that may have been incurred either prior to or subsequent to this change.  The DSSR 960 Education Allowance Worksheet (revised effective 1/3/2021) should be used to itemize allowable expenses.  Page 2 of the revised worksheet shows allowable and non-allowable expenses for all education allowance methods.

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 (rev. 1/3/2021) page 2 shows allowable and non-allowable expenses.

13. Q:  Can an employee be reimbursed for expenses incurred prior to arrival at his/her foreign post of assignment?

A:  Per DSSR 273 reimbursement may not be received prior to employee'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, laptop, and/or other electronic device of curriculum-related equipment; and other items such as microscopes and band instruments (such as the Sousaphone) which would normally be provided in the DMV.”

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 won’t 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 isn’t 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 isn't 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. Q:  Reviewing DSSR 277.3a(3) it states “expendable supplies which are normally provided free of charge in the DMV (see DSSR 960 Education Allowance Worksheet page 2 for non-allowable expendable supplies).”  This worksheet states that non-allowable supplies include binders, composition books, notebooks, pens, pencils, markers, crayons, paint sets, paper, rulers, facial tissue, hand sanitizer and scientific calculator.  I’ve already been reimbursed for some of these expenses I claimed prior to the 1/3/2021 effective date.  Will I be required to repay these amounts?  What if I purchased these prior to 1/3/2021 and other employees at post have been reimbursed for these expenses?

A:  These are all items not normally provided free of charge in U.S. public schools and are now clearly stated as non-allowable in the DSSR effective 1/3/2021 for all education allowance methods ("At Post"; "Away from Post"; and "Home Study/Private Instruction/Virtual Schooling").  If the authorizing officer considered these items you claimed as allowable and approved them prior to 1/3/2021 you will not be required to repay these expenses.  Also, if these had been considered allowable at post for other employees' claims prior to 1/3/2021 then the authorizing officer may approve claims for these expenses if the employee produces a receipt that they were purchased prior to 1/3/2021. 

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(4) 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(4).   

A:  DSSR 277.3a(4) states “costs to ensure that a child receives age/grade-appropriate instruction or when a child needs additional instruction for a core curriculum course”.  When a child needs additional instruction in a core curriculum course or courses then private instruction may be reimbursed for such assistance which is distinct from private instruction for the full course of study defined at DSSR 271f(2).

20c. Q:  Homeschooling almost always includes private instruction (tutors) and virtual schooling (online courses). Can we be reimbursed for online courses and employ tutors in core subject areas? How does accredited apply in these cases? After the January 3rd change, we enrolled our kids in a local school and the quality of their education has decreased. Why the strict limitations for homeschoolers and not for local schools?  

A:  One-on-one tutoring is not normally provided free of charge in U.S. public schools.  If a child needs additional assistance connected with a school at post, Supplementary Instruction (DSSR 276.9) is available.  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(4).  For this additional assistance accrediting does not apply.

21. Q:  Can you explain why there are different requirements depending on if I’m 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 is able to 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 is being followed.  Although not all-inclusive, a list of recognized and accredited programs is available on the Global Community Liaison Office (GCLO) website.

For home study [DSSR 271f(1)], DSSR 277.3c(2) requires a core curriculum similar to or equivalent to the 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) website.

22a. Q:  Why were the Education Allowance changes made mid-school year?  

A:  If conditions faced by the Department were normal and did not include a global authorized departure and pandemic-related issues commencing in early 2020 carrying through late in the year, these amendments would have become effective during the summer of 2020, occurring right before the beginning of the school year.  With these amendments occurring mid-year this gives employees/parents ample time to prepare for the 2021-2022 school year.  

22b. Q:  Why were community members not given the option to comment on these changes prior to their implementation? 

A:  Amendments to the government-wide DSSR are made following a 30-day period of interagency clearance and union consultation.  During that period agencies clear and submit any comments to the Office of Allowances (ALS).  Unions are consulted however they do not clear these government-wide regulations.  Unions may submit comments to ALS via GTM/PC.  Comments were not received from the unions for amendments to either DSSR Chapter 270 (Education Allowances) or DSSR Chapter 960 (Education Allowance Worksheet) effective 1/3/2021.  

22c. Q:  Will the Department consider reversing some of these decisions given that homeschoolers were not given any advance notice? 

A:  The amendments to the DSSR were announced in ALDAC 20 STATE 125150 dated 12/31/2020.  These amendments have the force and effect of Law.  The recommended changes were developed by a working group 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.

22d. Q:  If the homeschooling community wants to submit a proposal for a new system which grants full funding of the allowance for the homeschoolers while affirming to the Department of State or another employing agency that funds are being used to educate the child, is there a process to do this, and if so, whom do they contact?  

A:  The education allowance can only be used to reimburse items authorized by the statute.  Additionally, the Education Allowance is a cost of living allowance and is not currently subject to Federal Income Tax.  For that reason all cost of living allowances under DSSR Chapter 200 (COLA, FTA, HSTA, SMA, Education and Educational Travel) are reimbursements for necessary expenses. 

Congress requires an accounting of all allowances from agencies approximately every five years.  If an employee were given an amount of money without documentation this could move their allowance to taxable income.  It is not so simple as to just advance this allowance. Regulations in the DSSR are specific and the allowance may only be advanced when it is necessary and monetarily benefits the USG.  “275 Payments Education allowances may be paid in advance, either by lump sum or by installments, only as necessary for the employee to meet periodic educational expenses or when a monetary advantage, such as a discount, would accrue to the Government.  If a grant payment is made by lump sum to the employee, the authorizing officer must require proof of school payment within a reasonable amount of time in order to certify that school bills were paid at the beginning of the school year.” 

23. Q:  If I determine the program I’m using is not similar to or equivalent to the DMV standards, do I have to switch programs mid-year. 

A:  No.  You do not need to switch programs mid-year, however, when submitting the SF-1190 for the next school year DSSR 277.3c documentation will be required.

24. Q:  Why am I being told I have to 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) 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) website.

27a. Q:  Based on the new 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 evaluation of these.

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 in excess of 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, as long as 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 don't reimburse PE activities that aren't available in the DC metro area. But you pay for post schools where instruction includes sports that aren't 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 eligible for reimbursement.  Questions to answer in order for claims to be allowed:  1) how does this book apply to the course or courses being studied; (2) does the book or books have use broader than the course or courses being studied; and (3) is this normally (in at least 50% of the U.S.) provided free of charge in the U.S. public schools?  Supplemental books are reimbursable expenses when clearly tied to the course requirements (example:  British Literature – Shakespeare’s Plays) and are not purely entertainment or so vaguely associated with a curriculum that a connection between the expense and the course cannot be made.  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 are 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.  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 then 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 don't have access to them.  In general, “At Post” schools won’t 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're comparing to.  How are we to know what is reimbursable? Will you provide a list of what WILL be reimbursed? 

A:  These expendable supplies are not normally provided free of charge in the majority (over 50%) of U.S. public schools.  These supplies are not included in any of the education allowance methods - “At Post”, “Away from Post” or “Home Study/Private Instruction/Virtual Schooling”.  Representatives from the Office of Allowances, Office of Overseas Schools, Post Support Unit and the Global Community Liaison Office met to discuss changes to DSSR 270 and 960 pertaining to the Education Allowances.  The question came up whether or not to still include expendable supplies in the list of allowable expenses since the responsibility for these supplies has shifted to parents. DSSR 960 Education Allowance Worksheet page 2 lists non-allowable expendable supplies for all education allowance methods.

31b. Q:  Why does the Department allege that art supplies are not reimbursable because public schools don't 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:  In an art class in a Fairfax County High School the child/parent is required to pay an art fee which covers use of such items.  At the elementary school level the parent is required to provide the small eight color paint set as part of required supplies.

32. Q:  I live in the Southern Hemisphere and use the U.S. school calendar Aug-June to homeschool my children. My concern is, “A HS program is timed to coincide with the school year that predominates at local post schools.” Does this mean that families in the Southern Hemisphere have to shift their school year to Jan-Dec? 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 s/he 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 means 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 HS families, but not post schools? They are not made to justify (to non-educators) each purchase and connect it to a curriculum in order to receive funding as we are. It's 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):  “Course materials: textbooks and supplemental course-related materials which do not have a broader use than the course being studied and are normally provided free in the DMV.”  If computer lab fees and technology rental are stated as part of course materials then these are allowable expenses.  

38a. 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:  If there is a question of broader use than the course or courses being studied the employee/parent needs to be prepared to explain how this doesn’t have a broader use than the course or courses being studied.  Before ordering, the employee/parent should ask him/herself “would this normally be provided free of charge in the U.S. public schools”?  Several factors are considered in whether a homeschooling expenditure can be reimbursed.  A certifying officer will first look to the language in the DSSR 270 regulations and 960 worksheet to see if an expense is allowable or prohibited from reimbursement. In general, items that have a broader use beyond just academic or are not given to a student free of charge in a U.S. public school are not allowed for reimbursement.  A certifying officer may also deny an expense reimbursement if it is not relevant to the curriculum or courses being studied and will seek guidance from the Office of Overseas Schools as education experts.  

38b. Q:  If this is the standard, how is it applied for reimbursement for school at post?

A:  The school should provide a list of required reading for the course which will verify the expenses being claimed.  Also, parents in the U.S. public schools have had to pay for books other than the standard textbook whereas these additional books are allowed under all education methods.

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:  “Other authorized program” is carryover language from DSSR 277.3 prior to the changes effective 1/3/2021 and was referring to a program such as the distance learning program through the University of Nebraska High School.

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, 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. 

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 relates to a course or courses being studied.

46. Q:  Can you please put all of 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 recent DSSR270 updates from January 3, 2021? 

A:  20 State 125150 dated 12/31/2020.

48. Q:  If reading books aren't 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 be 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 aren't group class options available? Isn't this discriminatory to homeschoolers?

A:  Group classes may be available online.  Anything that isn’t 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.  Rates are reviewed annually with no changes required in the last two reviews.  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 private instruction 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:  There is not a limited number of hours attached to private 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 (6) - 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(6) states “Access to digital learning resources:  for a recognized and accredited program of study, an accredited virtual schooling program or other authorized 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) as 1/3 options HS/PI/VS (2) as "additional instruction for a core curriculum course," FAQ 20 says it can be used when a family chooses the category of Home Study. 

 

A:  Yes, there are two meanings.  One meaning is for a full course of study being provided by an instructor or instructors.  The other meaning is for supplemental instruction regardless of HS/PI/VS when a child needs additional assistance in one or more courses.

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 don’t 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's 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) 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 OoA 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 DSSR The cost of living allowances contained in DSSR Chapter 200 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 don't 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 August 3, 2021