ALERT! – Proposed Regulations About Attendance

DC homeschooling advocates are becoming increasingly concerned about the inclusion of homeschooling in a recently proposed revision to the DC regulations on compulsory school attendance. The proposed rule can be found here: 5-A21 COMPULSORY EDUCATION AND SCHOOL ATTENDANCE

The concern comes from the inclusion of the term “home-schooled instruction” in just one paragraph:

2101.1 Each educational institution operating in the District of Columbia, whether public, chartered, private, parochial, private instruction, or home-schooled instruction shall maintain an accurate, contemporaneous, and daily attendance record for each student enrolled in the educational institution.

Back in 2008 DC homeschoolers made their voices heard as the DC State Board of Education (SBOE) considered a complete homeschool regulation. A group of DC homeschoolers spent many hours in joint meetings with the SBOE and the Office of the State Superintendent of Education (OSSE) to work out a full set of regulations that, while not perfect, was something that DC homeschoolers could live with. That regulation is now DCMR 5200. During that extensive negotiation process the SBOE came to recognize that attendance for homeschoolers didn’t look anything like attendance in a school classroom. Accordingly, the OSSE and SBOE dropped any specific attendance requirement from the final homeschool regulation.

Now, however,  it appears that we may be saddled with an attendance requirement that is simply ridiculous for a homeschool. This proposed regulation is packed with detailed attendance regulations designed for District public, charter, and private schools. Here are just a few:

2100.4   A school year for attendance purposes shall include a minimum of one hundred eighty (180) regular instructional days.

2100.5 An instructional day shall be at least six (6) hours in length for students, including time allotted for lunch periods, recess, and class breaks; provided, the six (6)-hour minimum instructional day requirement shall not be applicable to an evening school program, prekindergarten program, or kindergarten program.

2100.6 Student attendance shall be based upon the number of days the student is in attendance during the entire year.

2101.5 The name and contact information of the designated attendance monitor(s) shall be reported by the educational institution to OSSE prior to the first official school day of each school year.

2101.4 . . . attendance monitor(s) shall:

(d) Submit to OSSE all attendance records described in paragraphs 2101.3 (a)-(g) of this chapter in conformance with the format and timeframes established by OSSE policy;

(e) Review the accuracy and reliability of attendance records submitted to OSSE via an automated, electronic feed, and make corrections as needed within five (5) business days of submission;

(f) Timely respond to OSSE requests for clarification of submitted attendance records;

Obviously this regulation was not designed for homeschoolers. In fact, the OSSE probably didn’t mean to add new homeschooling requirements. One part of the regulation even says that homeschoolers are exempt from the requirements of this particular regulation. Why then would the OSSE and the SBOE include homeschoolers in the section on required attendance records? Regulations regarding homeschooling are entirely maintained within DCMR 5200 and that regulation does not contain such a requirement. Let’s not allow such a requirement to come in through a back door.

Homeschoolers need to speak up about this or the new regulations will just sail through the approval process without any changes. You can do two things to help. First, join DCHEA through Facebook or our Google Group — links are on our website. Second, send an e-mail to the following officials, requesting that the term “home-schooled instruction” be removed from paragraph 2101.1 of the “Proposed Rulemaking Amending Compulsory Education and School Attendance Rule”:

State Superintendent Hosanna Mahaley Jones
State Superintendent of Education
Stephanie Thomas
Home School Coordinator, OSSE
Laura Slover
President, State Board of Education

Please also contact the Board representative for your ward. The list may be found here: State Board of Education Members

Thanks for helping us keep homeschooling legal and reasonable in the District.