Proposed Changes to the Home Instruction COMAR

Offered by Wendy Bush, The Excelsior Academy. All Rights Reserved. Please forward this only in its entirety. 

Below are my comments on the proposed changes to the COMAR and a little background on why the changes were initiated. I was one of four Maryland homeschool representatives, plus HSLDA, that were invited earlier this past year by Maryland State Department of Education (MSDE) to offer input to MSDE as they worked to change a specific portion of our current home instruction regulation.


The purpose was to make it clear that parents do not have to provide all of the instruction and that homeschool students can take college classes. MSDE’s motivation to change the regulation was to bring it more in line with our actual practice. MSDE realized that outsourcing of instruction has greatly increased since the regs were written in the 1980s. Plus, the College and Career Readiness Act passed in 2013 encourages public school students to take college classes, and MSDE wanted to make sure the home instruction regulation also made it clear that our students are encouraged to take college classes in high school, too.


Even though many of us have been outsourcing and taking college classes for many years with no issue, for the past 30 years since our COMAR was passed, there has been a running disagreement between the homeschool community and some county coordinators and some at MSDE over who can do the teaching. For example, some counties have tried to stop families from using co-ops for academic classes or taking more college classes than they felt were allowed.


In his position as Section Chief within MSDE’s Division of Student, Family, and School Support, Richard Scott has worked with homeschool families and umbrellas for many years helping to resolve these disagreements with their counties and MSDE. It was Richard who proposed to his bosses that the home instruction regulation be changed to make it clear that parents do not have to provide all of the instruction and our students can take college classes, even full-time. Richard is also the person who contacted the people mentioned above for comment. (I was not part of the discussion from the beginning, but was invited by Richard after some initial meetings.)  Even though we wanted to address some other issues in the regulation, Richard said his bosses were only open to address the instruction issue. After much discussion over wording and which items of the COMAR to try to improve, MSDE said they would take our suggestions and work on the language.


Months later, the next thing we heard was that there were proposed changes to our COMAR on the agenda for the Maryland State Board of Education meeting being held the next day. The language proposed at the September 22nd meeting has two areas where change is definitely needed, but otherwise it clarifies that parents do not have to deliver all of the instruction and that our students can take college classes. If those two changes are made, then I highly support this proposed language because (1) it will clarify this nagging issue and (2) it does not negatively impact any other areas of our homeschool liberties.


I offered modified wording to the others in the working group which they appear to agree with, and it is these changes that I will recommend during the public comment period once it begins. My recommendation makes it optional for families to submit a college transcript in lieu of a portfolio for the college class. And, it strikes the part requiring students enrolled in umbrellas to get approval from their umbrella in order to take college courses.


Here are my recommended changes:


(2) A parent or guardian who chooses to enroll his or her child under § C (2) of this regulation MAY ELECT TO provide to the local superintendent or the superintendent’s designee a copy of a report card or transcript from the accredited or unaccredited college at the conclusion of each semester of the accredited or unaccredited college in lieu of a portfolio of materials for the courses in which the child is enrolled under § C (2).


 B. The home instruction program may include enrollment on a part-time or full-time basis in courses offered by accredited or unaccredited colleges with the approval of the supervising nonpublic school or institution described in § A of this regulation. 

You can read the full text of the proposed language HERE. 

As you form your own opinion on the proposed language, I hope this information is helpful as families seek to understand the background of this language and how the changes will affect our right to educate our children.  Sincerely,   Wendy Bush