COMAR 13B.08.10.02 Rawlings Grant Proposed Change

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DEFEATED: MHEC Pulls Proposed Regulations

MDHSA received official written confirmation from the Maryland Attorney General's Office that - due to the large number of comments received from the homeschool community - the Maryland Higher Education Commission will NOT be moving forward with the proposed change to eligibility requirements for the Rawlings Grant. GREAT JOB, homeschool community! This is a win for your children.

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The Maryland Higher Education Commission (MHEC), the state agency that oversees post-secondary educational institutions and state-sponsored financial aid, has proposed a minor change to the Delegate Howard P. Rawlings Grant. While the change may seem insignificant to many, it has a tremendous negative impact for homeschool students.

The Rawlings Grant Program offers needs-based grants of up to $3,000 a year to Maryland students. Currently, the Rawlings Guaranteed Access Grant eligibility criteria requires a student to “have successfully completed a college preparatory program in high school that is designed to prepare students for college level work”. Alternatively, students must obtain a GED with a passing score of at least 165 per module.

As published in the January 31, 2020 Maryland Register, MHEC seeks to add the following definition to the regulation:

13B.08.10.02 Definitions.
B. Terms Defined.

¬†¬†¬†(3) ‚ÄúCollege preparatory program‚ÄĚ means any program of study leading to the award of a Maryland high school diploma.

COMAR 13B.08.10

What This Means For Homeschoolers

Current state law does not allow Maryland homeschool graduates – or nonpublic school students – to earn a state-issued high school diploma. While families can provide their homeschool graduates with parent-issued diplomas, these documents are not universally held in the same legal light as a state-issued diploma.

Should this proposed regulatory change go into effect, it is possible that MHEC would begin to require Maryland homeschool graduates – as well as nonpublic school students – to take the GED in order to qualify for the Rawlings Grant. The Maryland Homeschool Association believes this to be an unnecessary and inequitable change. Because the Rawlings Grant already requires applicants to be accepted into college, MHEC implicitly acknowledges that a student’s transcript – not a diploma – is what demonstrates completion of a college prep program.

Call to Action

Maryland homeschoolers have until Monday, March 2, 2020 to submit written comments urging MHEC to NOT ADOPT the proposed regulatory change. Families are welcome to use or adapt the following email message as their own comment.


Subject:    COMAR 13B.08.10 Public Comment

Message:  Mr. Newman,

I am writing to urge the Maryland Higher Education Commission to NOT adopt the proposed change to 13B.08.10.02, which seeks to define “college preparatory program” as a program of study that leads to the award of a Maryland high school diploma.

It is my belief that the eligibility requirements already set out in 13B.08.10.03.A.(3) are sufficient and render the proposed regulation unnecessary. Specifically, 13B.08.10.03.A.(3) currently requires an applicant to be “accepted for admission, or enrolled as a full-time student, in a regular undergraduate program leading to a degree or diploma at an eligible institution, or be enrolled full-time in a 2-year associate degree program in which the course work is acceptable for transfer credit to an accredited baccalaureate program at an eligible institution“. If a college has accepted a student into their post-secondary program, then it goes without saying that the student has completed (or is in the process of completing) a college preparatory program. The student’s transcript – not a diploma – demonstrates and confirms that this criteria has been met.

Additionally, MHEC must keep in mind that the wording of the proposed change suggests that only a state-issued diploma will now meet the eligibility criteria. Because students attending elite private schools, church-exempt nonpublic schools, and homeschool graduates are not eligible to receive a Maryland high school diploma, this proposed change will effectively require all nonpublic school and homeschool students to take the GED to qualify for the Rawlings Grant. That would be neither fair nor equitable to thousands of Maryland high school graduates that otherwise qualify for this financial aid program.

For these reasons, I respectfully request that MHEC withdraw the proposed change to COMAR 13B.08.10.02 and leave the regulation as is.


[your name and address]

What Happens Next

Once the period for open comments closes on March 2, MHEC will compile all the responses it has received. A summary of PRO and CON responses will be presented to the MHEC Commissioners, who will then vote to (1) Implement the proposed change; (2) Not implement the proposed change; or (3) Edit the proposed change and send it out for public comments, again. If the public sends in an overwhelming amount of negative comments, MHEC will be hard-pressed to implement this change.

In the past, when MDHSA has put out a Call To Action to lobby against a regulatory change, homeschool families stepped up and sent in hundreds of public comments. We have successfully stopped anti-homeschooling measures in the past and we can do it, again – with your help.

Last modified on March 31, 2020

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