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In 1996, the Florida Legislature established the Gold Seal Quality Care program to acknowledge child care facilities and family day care homes that are accredited by nationally recognized agencies and whose standards reflect quality in the level of care and supervision provided to children. Dual Enrollemnt White Pater
Florida Coalition of Christian Private Schools Accreditation
White Paper: August 13, 2013
Re: Florida College System institutions that have added paying the state standard tuition for private school students.
Background and Details
Recently, several of the state and community colleges have begun changing their Dual Enrollment Articulation Agreements that they have had with private schools. In effect, they are now requiring the private schools to reimburse the institution for the student's tuition for all dual enrollment courses. ($71.98 per credit hour.) This has come as a shock to many of the schools since the legislation specifically requires that the student not be charged for registration, tuition or lab fees. The communications from the colleges have all listed the "recent" changes in the statute as the reason for the changes in the policy.
Florida Statute 1007.271
While there were changes in the dual enrollment statute, those changes were directed to school districts, not to private schools, or county registered homeschoolers.
F.S. 1007.271 (21)(n) "A funding provision that delineates costs incurred by each entity. School districts should share funding to cover instructional and support costs incurred by the postsecondary institution."
There is no provision in the statute that indicates the legislature had intended for those costs to be passed on to private schools. In fact, the opposite is indicated with the clear statement in section (2) "Any student enrolled as a dual enrollment student is exempt from the payment of registration, tuition, and laboratory fees." This statement is repeated three additional times in the statute.
Section (2) of the statute includes details for the districts on how to count the student's hours of attendance in dual enrollment for use in their calculations for payment through the Florida Education Finance Program. (FEFP) Clearly the change the legislature intended is for the districts to pay for the dual enrollment tuition from the FEFP funds, and the Florida Department of Education agrees. In the FLDOE Dual Enrollment FAQ June 2013 Publication, question 37 makes the connection clear.
37. How are the dual enrollment costs shared between the school district and the Florida College System institution?
For dual enrollment courses offered on a Florida College System institution campus, the school district pays the standard tuition rate per credit hour from the Florida Education Finance Program (FEFP).
This connection is re-enforced in that during the summer months when the districts do not receive any funding from the FEFP they are exempt from paying the standard tuition rate. As question 44 from the same Dual Enrollment FAQ June 2013 makes clear.
44. Does the school district have to pay the Florida College System institution tuition for dual enrollment taken during the summer?
No. The law states that the tuition payments are from funds provided in the Florida Education Finance Program (FEFP). School districts do not receive funds under the FEFP for the summer.
Why then have some of the colleges begun treating private schools the same as the districts even though most private school students do not receive funding through the FEFP?
While the exact answer as to why some, but not all Florida College System (FCS) institutions are applying the changes to private schools is not clear, we know that dual enrollment students are an added expense for the colleges beyond the cost of a regularly enrolled student. While Florida students who attend a state college after graduation pay a reduced tuition rate (based on the investment from the taxpayers of Florida), they do pay registration, tuition and lab fees. Dual enrollment students are exempt by the statute from paying for dual enrollment classes so the college receives less funding than for regular students attending the same class. That is why it was appropriate for the legislature to require the district to transfer an appropriate amount of the funding from the FEFP to the college.
The communication from the colleges may give some indication as to their position.
The letter to private schools from Hillsborough Community College states: "Since the change affects school districts, we have taken the position that, in the spirit of fairness, the change should also be applied to private schools."
The Lake Sumter State College email to private schools is more blunt: "As a private school, you are also required to pay LSSC for DE courses that your DE students take."
Valencia College's email included additional details: "(2) it is optional for Florida College System (FCS) institutions to enter into articulation agreements with private secondary schools; and (3) FCS institutions may negotiate a tuition or fee structure for student participation in dual enrollment that is payable by the private school."
From the "spirit of fairness" to the "we are making this up" and "you are required to pay" seems a wide range considering none of that wording is in the statute. Valencia gets to the heart of the matter with specifics based on the actual statute and the Department of Education FAQ referenced earlier.
F. S. 1007.271 (24) Postsecondary institutions may enter into dual enrollment agreements with private secondary schools pursuant to section (2).
Since the description of an eligible student in section (2) includes "a student enrolled in Florida public secondary school or in a Florida private secondary school which is in compliance with s. 1002.42(2) and provides a secondary curriculum pursuant to s 1003.428, s. 1003.429, or s. 1003.43", the clear intent of section (24) is that it is in keeping with the statute for an FCS institution to enter into dual enrollment agreements with private secondary schools. The word "negotiate" is not in the statute. The statute clearly intended for qualified private school students to have the same equal access to dual enrollment courses as public school, and homeschool students.
The FCS institutions find the "loop hole" or "work around" to add additional requirements for private schools, and, consequently, the private school student in an opinion expressed by the Florida Department of Education in the Dual Enrollment FAQ June 2013 Publication, question 40.
40. Does the law require that the Florida College System institution receive tuition payments for the dual enrollment of students at eligible private secondary schools?
No. However, a Florida College System institution may enter into a Dual Enrollment Articulation Agreement with a private secondary school and may negotiate for payment from the private secondary school for students eligible to participate in dual enrollment.
The statute does not say that the FCS institution "may negotiate for payment," but many of the FCS institutions and the FLDOE consider it optional and completely at the discretion of the FCS institution to choose whether they enter into an articulation agreement with private schools that are in compliance with section (20). This has allowed some FCS institutions to demand payments that we believe are in violation of the statute, or to simply refuse to enter into articulation agreements with qualified private schools, the effect of which discriminates against a specific class of individuals: the private school student. If the private school does not agree, the FCS institution will simply not renew or enter into a new articulation agreement.
The Dual Enrollment FAQ June 2013, question 8 summarizes the standard procedures followed by most institutions, but acknowledges (in the opinion of the FLDOE) that entering into an articulation agreement is optional for the FCS institutions. Regrettably, it may take legal action by students (who will soon be denied access to dual enrollment) to force the Florida Department of Education and/or the legislature to adopt guidelines protecting all students.
With these changes coming from the colleges long after students have enrolled in classes (in most cases with classes beginning in less than three weeks), and clearly from a position of, "agree to pay or we will not renew your articulation agreement," it does not seem like a "negotiation" to the private schools. It seems more like coercion.
Background Summary
It is the position of the FCCPSA that the changes made in the dual enrollment statute 1002.271 were intended to clarify the financial obligations of the districts, and have no application to private schools. Specifically, it is addressing the changes applied to funding of dual enrollment courses for students who were being funded through the Florida Education Finance Program (FEFP).
Since private schools do not (in most cases) receive FEFP funding, and no changes were made in the statute with regards to private school students (or home educated students registered through the district office), the intent was clearly that those students would continue to receive dual enrollment courses without incurring additional financial obligations on the part of the student or the private school. Just as the districts have no financial obligation for public school students during the summer months when they do not receive FEFP funding, private schools that do not receive FEFP funding do not have a financial obligation to pay the college the state standard tuition.
Although not addressed directly in the statute, it may be appropriate for private schools that have students who receive funding through the McKay Scholarship and/or the Corporate Tax Scholarship to enter into articulation agreements with a Florida College System institution that includes payment of the state standard tuition for those students.
Because the statute is clear that "Any student enrolled as a dual enrollment student is exempt from the payment of registration, tuition, and laboratory fees", passing the cost of tuition to the private school from funds paid by the family on behalf of the student is problematic. Although the bill would be sent to the private school, the school would either use funds the families have already paid (or would be required to pay as a condition of dual enrollment), and this is a clear violation of the statute. In essence, the FCS institution is demanding that the private school violate the statute on behalf of the college.
Possible responses by private schools and possible consequences.
Private schools are now faced with a last minute decision due to the fact that the Florida College System institutions have only begun updating the articulation agreements a few weeks before classes resume. As an example, Lake Sumter State College sent an email with the details of their changes on July 18, and Valencia College's email went out late in the day on July 26th. With most classes beginning on August 19th, the private schools were left with little or no time to consider options, much less "negotiate" agreements before classes begin. The content of most of the communications from the colleges makes it clear that maintaining an articulation agreement is contingent upon accepting their new terms, no option to negotiate or review the validity of the changes is given.
This puts the academic plans for students who enrolled in the courses months before in jeopardy. Academic planning completed in April or May with graduation implications and earning scholarships like the Bright Futures Scholarship are now at risk.
In considering how an individual school will choose to proceed, it is necessary to keep in mind that the student, and, by extension, the parent cannot be required to pay the state standard tuition that the colleges are requiring. We would argue that collecting from the private school from tuition paid to the school by the parent for the student is in fact a violation of the statute. Only the item named on the invoice and the third party that writes the check has been changed to circumvent the law.
Option One: Accept the new articulation agreement.
The private school can agree to the new articulation agreement with the Florida College System institution. In most cases, at the end of the term, the college will send a bill to the private school for payment based on the number of credit hours their students have completed. Senator Tom Lee described this as a "work around" of the statute that specifically exempts the student from payment.
The result of this option will have several outcomes, all to the detriment of the dual enrollment program and the students it is intended to serve.
The first will be that students in those schools will not be approved for as many dual enrollment courses because it will increase the cost of operations for the school. While districts are prohibited from denying participation in the dual enrollment program to qualified students, there is no such guarantee protecting equal access of private school students.
The second result will be an increase in the tuition families will be required to pay for enrollment in private schools. Every school (or any business) operates on a budget. Most private schools operate at an annual cost per student that is much lower than the districts receive from the FEFP funding. A private school will now have to include the cost of dual enrollment in the calculations of their annual budget, and the increased cost will be passed on to the families in the form of additional tuition. The intent of the statute was for the student to have access to dual enrollment without tuition costs, but, if the FCS institutions are permitted to bill the school for the state standard tuition, then that cost will be passed to the family.
Additionally, as listed in the conclusion, transferring funds that the family paid to the college may be a violation of the statute.
Option Two: Attempt to persuade the Florida College System institutions to extend the current articulation agreement for one year, while we work together to secure fair and equitable funding for all dual enrollment students.
From a legal standpoint, most private schools will have no choice but to reject the new articulation agreements being offered by the institutions that have proposed changes on such short notice. Private schools have long since entered into agreements with their families based on a budget for the 2013-2014 academic school year, and that did not include thousands of dollars in tuition fees being diverted to the colleges. In many cases, for small or non-traditional schools, the total tuition collected from the families would not cover the cost of more than one or two dual enrollment courses, leaving the private school with no funds to operate. Even larger schools simply do not have enough programs to cut or employees to lay-off to offset this new non-budgeted item.
Since the statute prohibits the student from paying registration, tuition or lab fees, there simply is no source of funding for the students. The result will be that private school students will no longer have access to a program on the same basis as other students in Florida. Public school students will have access based on their FEFP funding. Home educated students will have access based on F. S. 1007.271, while private school students who should be provided the same opportunity as detailed in the statute will be denied assess by the FCS institution.
In communicating with the specific Florida College System institution, the following is a summary relevant of relevant points.
1) Private schools have enjoyed a long and beneficial relationship with the colleges and want to work with the institution to establish an equitable funding program for all students who are qualified for and wish to participate in dual enrollment. We are committed to working with the colleges, our state senators and representatives to insure that the colleges receive adequate funding for all dual enrolled students, including private school students, home educated students, and public school students, which were addressed in the last legislative session.
2) While it is understandable that the institution would like to apply the funding requirement that has been placed on districts to private schools, that is not the requirement of the statute. The statute is specific in that the changes are directed to the districts, not private schools. It is also important to note that the changes in the statute are linked to the Florida Education Finance Program (FEFP) through which most private schools, dual enrollment students are not funded. It is through those funds the districts are to pay for dual enrollment, but only during the fall and spring terms. During the summer term, the districts do not receive FEFP funding and do not have to pay for dual enrollment. If the district is not required to pay during the summer because it does not receive FEFP funding, how can the private school be required to pay because it never receives FEFP funding. F.S. 1007.271 (21)(n)
3) "Any student enrolled as a dual enrollment student is exempt from the payment of registration, tuition, and laboratory fees." Passing the cost of tuition to the private school would either use funds the families have already paid (or would be required to pay as a condition of dual enrollment), and this is a clear violation of the statute. In essence, the FCS is demanding that the private school violate the statute on behalf of the college.
4) Because many of the individuals proposing these changes at the college may not have a realistic understanding of the actual levels of funding on a per student basis, it may be well to provide some details of the amount of tuition charged by the private school. The new Florida budget increases the per student budget to $6779 per student. (Plus $480 million set aside to increase teacher salaries.) Students that receive the Corporate Tax Scholarship (by comparison) receive only $4880 per year. Many small, community or non-traditional schools may not even charge enough to pay for two dual enrollment classes if they diverted the entire yearly tuition to the college.
5) Close by asking that the college extend the articulation agreement from the 2012-2013 school year, so that students who have already made academic decisions do not have their graduation and scholarship opportunities placed at risk.
Where do we go from here?
Every private school, whether or not the FCS institution that serves their students has presented a new articulation agreement requiring the school to pay tuition, should immediately begin educating their parents of the changes. Short of legal action by a group of students against the FCS institutions, it will only be in the volume of calls from voters throughout the state that lasting positive change will be accomplished.
As a school and individual parents (grandparents, too), we must begin to reach out to our state senators and representatives in every district throughout the state, encouraging them to speak out for all of the students in their districts. While our legislators may not have the legal power to stop implementation, calls from several state representatives and senators to the colleges asking them to stop the implementation of the new articulation agreements may convince some of the institutions that it is not in their best interest to proceed until the legislature addresses the issue in more detail. We must continue to work up to (and during) the next legislative session to fully fund dual enrollment for the colleges, and correct a system that allows discrimination against one class of citizens.