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Background on the Home Education Association Diploma
Dr. Howard Richman - Executive Director
Pennsylvania Homeschoolers Accreditation Agency
June 25, 2014

Currently homeschooled students can only receive a Pennsylvania Higher Education Assistance Agency (PHEAA) grant for college if they have either:

  1. Received a high school diploma from a PDE-recognized home education association, or
  2. Received a certificate of high school completion signed by their local school superintendent, or
  3. Passed the GED.

Pennsylvania's House Bill 1013 would add a fourth option, a parent-issued diploma that is also signed by the home education program evaluator. Our organization favors this new provision, but when we read HB 1013 carefully, we became very concerned. While adding the parent-issued diploma, the bill may have inadvertently taken away recognition from the home education association diploma.

In order to understand this unintended consequence, it is necessary to understand the history and recognition of the home education association diploma option.

The PA Home Education Law Implied a Diploma but Didn’t Say Who Would Give It

When the PA home education law passed in December 1988, Pennsylvania became the first state in the country to recognize high school graduation from a home education program. It did so through language that was in the original bipartisan home education bill put together by Republican Representative (now Congressman) Joe Pitts, and continued in the second version of the bill put together by Democratic House Education Committee Chairman Ron Cowell. I am referring to Section D of the home education law which states:

(D) The following minimum courses in grades nine through twelve are established as a requirement for graduation in a home education program:
(1) Four years of English.
(2) Three years of mathematics.
(3) Three years of science.
(4) Three years of social studies.
(5) Two years of arts and humanities.

At the 11th hour, just before passage in the House, the Appropriations Committee, at the request of Governor Casey’s Department of Education, removed Section D from the bill. That was when we realized that when a law specifies graduation requirements, it implies that there is a diploma.

When the bill came up for a vote in the House, Representative Cowell put the graduation requirements back into the bill with an amendment. He told the House:

This amendment does three or four things, two of which are very significant…. Third, it would restore language to the bill which was removed in the Appropriations Committee, and so far as I know there has been no quarrel about the language which was removed. It’s language that provides for minimum curricular requirements for high school home education programs. The language is very similar to the language currently in the school code for non-public schools….

Recognition of Home Education Association Diplomas

Although the home education law included graduation requirements, it never said who would give the diploma, an omission that may eventually be addressed by Section D.1 of HB 1013.

After the home education law passed, we asked the Pennsylvania Department of Education (PDE) to give an answer to the question of who should give the diplomas that were implied by the law. The PDE had already told the school districts that they didn’t have to give diplomas to homeschoolers. The PDE did not want to give the diplomas themselves and did not want to recognize parent-issued diplomas (as HB 1013’s Section D.1 would require).

When we pressed them to award the diplomas themselves or recognize another option, they came up with the idea that home education associations should give the diplomas. On October 2, 1990, Dr. Philip Mulvihill, chief of the Advisory Services Office at the PDE, wrote me:

It seems more appropriate to me to have the credential for home schoolers issued by a home schoolers organization. The monitoring and evaluation could then be done by individuals familiar with these programs and the quality control could be enforced by those individuals who have a vested interest in maintaining the quality.

I immediately put together the first of those organizations, Pennsylvania Homeschoolers Accreditation Agency. After one of our early graduates applied for a Pennsylvania Higher Education Assistance Agency (PHEAA) grant, the PDE wrote a letter to PHEAA on July 11 1992 specifically recognizing our diploma.

The regulations governing PHEAA were soon changed so as to recognize home school “accreditation agencies.” Here is the text of the current regulation:

22 Pa Code § 121.21 Requirement for higher education grant applicants

(a) A State higher education grant applicant shall be a graduate of or attending an approved secondary school, or be a recipient of a Commonwealth secondary school diploma

(b) An approved secondary school shall be any public or private secondary school, located in this Commonwealth or elsewhere, including foreign institutions and United States schools overseas, which in the judgment of the Department of Education provides a course of instruction at the secondary level and maintains standards of instruction substantially equivalent to the standards of instruction of the public high schools located in this Commonwealth.

(c) For purposes of the State Higher Education Grant Program, an approved secondary school shall also include any home education program that is accredited by any home schooling accreditation agency approved by the Department of Education. If the home education program lacks the requisite accreditation, certification by the appropriate local school official attesting that the home education program is in compliance with section 1327.1 of the Public School Code of 1949 (24 P. S. § 13-1327.1) shall be submitted to the Agency by the appropriate local school official.

[PDE note: "the Agency" is defined in 22 Pa Code § 121.1. as PHEAA.]

The wording of this regulation apparently goes back to the brief period of time when Pennsylvania Homeschoolers Accreditation Agency was the only home schooling organization whose diplomas were recognized. When it is juxtaposed with letters written by the PDE to PHEAA and Penn State University at that time, it is clear that PDE was recognizing our organization as an “accreditation agency,” approved by them to accredit home education programs. However, we may be the only “accreditation agency” that was approved by the Department of Education.

In 1998, the PDE put together its current policy, which appears on its public website, recognizing home education “diploma-granting organizations.” Of the ten recognized non-profit associations currently listed, none, except for ours, has the words “accreditation agency” in its name. PDE describes the ten recognized home education associations as “diploma-granting organizations,” not as “accreditation agencies.” Specifically:

This table lists the diploma-granting organizations that currently are authorized by the Department to grant home education diplomas for Pennsylvania residents only. They may not grant a home education diploma to anyone who is not a resident of Pennsylvania. Additionally, they only may grant diplomas to students who have submitted a homeschool affidavit to their superintendent of schools.

This PDE policy, though never placed into statute or regulation, has worked well since 1998 under both Republican and Democratic administrations. In the absence of a law which specifies a different way that home education diplomas are to be awarded, it would likely continue indefinitely.

Since 1991, our association has awarded over 7,000 PDE-recognized diplomas, and the other associations have similarly awarded many diplomas. These recognized associations provide students not only with diplomas, but also with official transcripts that help both current students and graduates be admitted to colleges, get scholarships, get jobs, get promotions, and even transfer to a traditional high school.

The associations offer a range of choices, not only in fees (the least expensive charges just $35), but also in specific guidelines to encourage excellence. The PDE was correct that these organizations would enforce “quality control,” due to their “vested interest in maintaining the quality” of their diplomas.

Effect of HB 1013 upon Home Education Association Diplomas

Since House Bill 1013 does not mention home education association diplomas, the Representatives who voted for it in committee did not realize that they could be taking away an established option when they added in the new option. They may not have understood the following:

1. Specifying who gives the diploma. The PDE only recognized the association diploma because the home education law didn’t specify who gives the diplomas. HB 1013 would specify that the parent gives the diploma. As a result, there could be an interpretation that the PDE would no longer need to recognize home education association awarded diplomas.

2. Policy is subject to change. HB 1013 includes the following preamble to Section D.1: “Notwithstanding any provisions of this act or any other law or regulation to the contrary”. These words might not apply to those associations that are only recognized as “diploma granting organizations” by policy, not recognized by law or regulation.  

3. Regulation is subject to change. Although not as easily changed as policy, regulations are also subject to change, especially when the statutes that underlie them change. HB 1013 would probably add parent-issued diplomas to the very regulation that currently recognizes home schooling accreditation agencies such as ours. It is possible, though unlikely, that the language recognizing home schooling accreditation agencies would be removed when the language recognizing parent-issued diplomas is added.

4. Diploma must be issued on PDE form. Subsection D.1 (2) specifically states that the diploma must be issued on a single universal form to be published by the PDE on its website. As such, this could be seen as eliminating the possibility of home education associations issuing diplomas with their names on the diploma.

Our Amendment would put Current PDE Policy into Statute

As currently worded, the amendment that we advocate would be added to Subsection D.1 (2) of HB 1013 in a way which leaves the rest of the bill intact, including the original wording of D.1 (2). It should not be controversial, since it is entirely drawn from the language of the PDE policy that can be read on the PDE website. Our amendment is shown in boldface:

(2)(i) The diploma is issued to the student on a standardized form to be developed by the Department and which shall be made available on the Department's publicly accessible Internet website.

(ii) The diploma also may be issued by a nonprofit home education association which is recognized by the Department to grant home education diplomas. The diploma would then be issued on a form developed by that association. The Department will maintain a list of such associations as well as a Home Education Program Association Application For Recognition form on its publicly accessible website.

Again, our amendment simply puts current PDE policy into statute so that it would not be inadvertently lost when the parent-issued diploma is added. It would not subtract from the current language of HB 1013 in any way.


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