The Foreign Service Journal, April 2020

THE FOREIGN SERVICE JOURNAL | APRIL 2020 43 child who would normally reside at post while not attending school if the child’s medical clearance allowed it. Parents and educational consultants, however, are still unclear as to how these changes will affect individual cases. One parent says she has spent more than $50,000 out of pocket to pay for her child’s therapeutic boarding school because the cost of such a school exceeds the normal away- from-post allowance. She was afraid to request financial help for the school, she says, because she knows of families who were forced to curtail when MED determined that their edu- cational challenges couldn’t be met at post. She has written to MED several times since the December 2019 cable came out, but says she has yet to receive a reply as to whether the policy changes apply to her family. Other important changes to SNEA include clarification that it applies not only to children who would be covered in the United States by the Individuals with Disabilities Education Act, but also to those covered under Section 504 of the Reha- bilitation Act. Speech therapy and language therapy will now be covered by SNEA even when provided outside the school setting or normal school hours. Further, extended school year services may be reimburs- able even when they are provided in noneducational settings, as long as those settings offer the services specified in the child’s individual learning plan (ILP). Another change is one that parents have long wanted: In some circumstances, the services of an instructional aide hired directly by the parents are now reimbursable. The New SNEA There has never been an appeals process available to parents. The department is reportedly at work, however, on a new 16 FAM section that will lay out a SNEA appeals mecha- nism. Townsend says AFSA is still waiting to see and comment on 16 FAM. AFSA is also expecting to comment on the new centralized vouchering mechanism that the department is developing. The department anticipates that a central system for processing payments will remove the discrepancies that parents currently face as they work with different financial management officers from post to post, all of whom read the regulations differently. Some parents, though, have expressed concern that this centralized system, once implemented, will continue to delay decisions regarding payments. Ultimately, Townsend says, AFSA “would like to see the availability of special education resources eliminated as a consideration in the MED clearance process altogether.” And,

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