By now, most families who homeschool their 26,000 children in Maryland have heard about the proposed regulation changes that the State Board of Education would like to implement. The majority of the changes focus on the state giving families “permission” to choose dual enrollment as a form of homeschool instruction.
Last week, we offered our opinion on why these proposed changes are bad for homeschooling families. Since then, we’ve continued to dig into this topic because – frankly – the process that MSDE has engaged in with this regulatory review process just doesn’t feel right.
The public documents we’ve since read through shed much needed light on the lack of transparency that the Maryland State Department of Education has used. In fact, we’ll go as far to say that this regulatory review process is a complete farce that has nothing to do with the best interest of homeschool families.
Here’s What MSDE Doesn’t Want You To Know
- The College and Career Readiness Act, passed by the Maryland General Assembly in 2013, is a broad initiative that seeks to increase the number of adults who obtain at least an Associates Degree. Maryland is considered a national leader within the CCRA movement. With that national leadership position comes copious amounts of grant money that can be used to pay the actual tuition for individually dual-enrolled students.
The State Board of Education issued a public document on January 31, 2014 that addresses how CCRA applies to homeschoolers. Start by looking at Question #1 of the Frequently Asked Questions, which states:
1. What is the definition of “dually enrolled students” in the College and Career Readiness and College Completion Act (CCR-CCA) of 2013 (here after referred to as “the law”)?
The term “dually enrolled students” means a student who is dually enrolled in a public secondary school in the state and a public institution of higher education (IHE) in the state. 18-14A-01.(a)(2) (Found in the section about the Early College Access Grant).
Question #18 of the FAQs then follows up more specifically with:
18. Does the law apply to dually enrolled private secondary school students or homeschool students?
No, the law indicates that local school systems must pay for courses taken by dually enrolled students who are enrolled in a public secondary school in the state. 18-14A-04.
In other words, CCRA – the law that the Board of Education is using as its compelling rationale for why we need changes to Maryland’s homeschool regulations – has no legal application to homeschoolers.
- The College and Career Readiness Act of 2013 requires a report on dual enrollment data to be submitted to Maryland’s governor by mid-December of every year. The Maryland Longitudinal Data System Center prepared and issued its first report in 2014. We’ll highlight two statements in the report that we believe exposes the real truth behind MSDE’s proposed homeschool regulatory changes.
Page 3 of the report offers a brief Analysis of dual enrollment numbers for Maryland’s community colleges. The report also states a problem with its data gathering process.
The report will also use the population of Maryland public high schools for certain comparisons with the dually enrolled population, despite the fact that this comparison is much more problematic. The present data do not differentiate between students enrolled in Maryland public high schools and students enrolled in other kinds of high schools (such as homeschools, private schools, or out-of-state schools). It is likely that a significant minority of dually enrolled students are enrolled in high schools of this type. Nevertheless, comparisons of the dually enrolled population with the public high school population can be helpful in identifying relationships of interest and areas for further study. [emphasis added]
Scroll to the very end of the report, and you’ll discover an action item on the state’s to-do list regarding dual enrollment data:
As more data become available, future editions of this report will begin to examine additional topics related to dual enrollment, including:
* The number of public high school students who are dually enrolled, compared to the number of students from other kinds of high schools;
To sum it up succinctly, MSDE wants homeschool dual enrollment data for a state law that does not apply to homeschoolers. They need the data so they can break down the dual enrollment numbers for state reporting requirements, not to mention grant reporting requirements.
MSDE wants this data so badly that they’ve proposed regulatory language that gives parents no choice in the matter. Under the new homeschool regulations that MSDE wants passed, parents who refuse to submit a transcript of their child’s dual enrolled classes will be found non-compliant.
What happens to a non-compliant homeschool parent? The state forces that family’s homeschool children to enroll in school and the parent will lose their right to homeschool.
The facts in this case appear to point at the same bottom line: MSDE staff – and the Board itself – has not been honest nor forthright in discussing the true intention for the proposed changes to Maryland’s homeschool regulations.
MSDE continues to offer appeasing comments, suggesting that these changes are necessary for the self-interest of homeschooling families. Statements have been made in conversation and in writing that current regulations do not specifically allow for anyone but the specific parent to conduct all home instruction for their child, so we need this change.
Our concern is that the more we push back and demand a recall on these proposed changes, the more likely MSDE will retaliate by issuing a hardline policy on how county homeschool liaisons must conduct future compliance reviews.
What happens if we just hang in there and hope for the best?
Well, the open comment period for the proposed changes will begin within the next week or so. While we do not have a crystal ball, our concern is that regardless of how many families submit comments, MSDE will not change the proposed language – because there is simply too much at stake – money that will never benefit homeschool families under the current laws.
What You Can Do
- Share this blog with other homeschoolers so they can be fully informed about the issue.
- Use the Twitter hashtag #MdHS_COMAR to help alert your elected officials and local news sources to what’s happening.
- Request that the proposed changes to homeschool regulations NOT be published and that the regulatory review process start over – this time with a group of homeschool stakeholders that includes representatives of African-American, Jewish, and secular families, as well as those who do not use umbrella services. Emails can be sent to:
- Maryland State Board of Education at firstname.lastname@example.org, the state agency responsible for initiating the proposed changes.
- Maryland Attorney General Brian Frosh at email@example.com, the state’s top attorney, whose office provides MSDE with legal advice.
- Division of State Documents at firstname.lastname@example.org, the agency responsible for ensuring regulatory changes follow proper procedure.
What do you think?
Has MSDE been out of line with how they’ve conducted this regulatory review for homeschoolers?