The Foreign Service Journal, June 2016
18 JUNE 2016 | THE FOREIGN SERVICE JOURNAL families and maximize employee skills and expertise, the State Department needs to provide consistent support to families with special needs children. This is a complex problem that requires a well-thought-out, long-term solution. To address it one bidding cycle at a time—as is now done—is short-sighted, especially in light of the ever-growing number of hardship and hard-to-fill posts, not to mention the rising rate of special needs diagnoses among American children. The rate of diagnosis of conditions such as autism, ADD/ADHD and dyslexia among American children, including within the FS community, has been on the rise for the past decade. According to the Centers for Disease Control and Pre- vention, approximately one in six children in the United States has a developmental disorder. A CDC study of the prevalence of developmental disabilities in U.S. chil- dren from 1997 to 2008 found an absolute increase during that decade of 1.8 million children diagnosed with developmental disabilities (a 17-percent rise). Diagnoses of autism increased by 289 percent and ADHD by 33 percent. In terms of funding support, State Department regulations governing the use of SNEA make the intent clear: the “Special Needs Education Allowance … applies to children who would fall under Public Law 108-446, the Individuals with Disabilities Education Improvement Act (IDEIA), if residing in the United States.” Since financial support is, in principle, available via SNEA, the biggest challenge is usually the tremendous variability from country to country in terms of the avail- ability of schools willing to accept special needs children and in-country therapy providers. There is little consistency. Parents often have no problem finding excellent services in some developing countries, and yet are unable to find adequate pro- grams or schools in parts of Europe or the therapy services they need in the child’s native language. In some cases, many posts are completely out of reach of an employee due to a child’s learning needs. It would, of course, be naive to expect to duplicate perfectly the services typically available and provided in a U.S. public school system. Still, the process must recognize the uniquely challenging aspects of educating and raising chil- dren with special needs in an overseas environment, while entrusting basic care decisions to parents in consultation with relevant authorities, such as MED’s Child and Family Programs, the Family Liaison Office and the Office of Overseas Schools. The department’s support via SNEA has been a critical, and invaluable, part of the solution for many years. So during the recent period, when, without announce- ment or explanation, that benefit became increasingly hard to obtain because of bureaucratic and what seem to be arbi- trarily strict interpretations of the govern- ing regulations, it was a serious blow. The change in how allowances are authorized seems to date from June 2013, when administration of SNEA shifted fromMED’s Employee Consultation Ser- vices (ECS) office to the Child and Family Programs (CFP) office, both under the umbrella of MED/Mental Health Services. For members of the Foreign Service with special needs children, the challenge of planning their overseas bidding has become even more onerous. There Are Solutions There are many ways to make the process less stressful and more supportive while still adhering to the regulations. Here are some recommendations to consider. ■ Engage parents directly in setting policies and procedures. We understand that there is a SNEA working group, but it includes no parental representatives. Direct and frequent engagement with parents to discuss the impact of policies and provide clarity about concerns—in both directions—would be invaluable. ■ Always announce policy changes well in advance of the bidding season. ■ Increase flexibility in using SNEA in a manner that (1) empowers parents to make decisions regarding the educa- tion of a child with special needs and (2) conforms to regulatory requirements. In most cases, this would entail recognizing that even though a supportive arrange- ment may not duplicate the way a service is provided in the United States (such as using SNEA funds to directly hire an educational aide when there isn’t one at a school), it should be authorized if the end result is the same. ■ Decouple the medical clearance process from the use of SNEA. MED should provide Class 1 medical clear- ances to children with special needs who have no ongoing medical condition, rather than the current practice of issuing a Class 2 or a Class 6 clearance based solely on educational needs. ■ Ensure transparency in the SNEA eligibility process and greater clarity in what services will and won’t be autho- rized for reimbursement—not only in terms of the types of services that are covered, but also whether there are restrictions on how the support services are delivered. ■ Authorize broader access to board- ing schools that serve children with special needs, including the use of SNEA in lieu of other educational allowances when a school at post cannot adequately meet a child’s special needs. ■ Reinstate SNEA funding for use in
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