Chair Rick Ladd invited Matt Southerton, director of policy and compliance for the Children’s Scholarship Fund, to explain how the state’s Education Freedom Account (EFA) program qualifies students for differentiated aid.

Southerton said the program accepts two pathways: (1) district evaluations and existing IEPs and (2) a medical certification of disability (MCD) signed by a medical professional. He said the MCD form (referred to in CSF policy as STU 19) lists qualifying disabling conditions and requires the signing clinician to state their credentials and diagnosis. Southerton said CSF will accept district evaluations or an MCD and that his organization uses a parent agreement requiring families to use insurance when applicable.

Commission members repeatedly said the two pathways create very different levels of rigor. One commissioner said DOE reporting currently shows roughly 890 students receiving differentiated aid, of whom about 240 have school-district documentation (IEP/evaluation) while some 600+ are identified through the MCD/private pathway. That gap prompted requests for the underlying documentation and for DOE to clarify which students were identified by a district process versus by an MCD. Southerton said he could provide information on what CSF receives: a signed evaluation or MCD, the provider credentials, and a diagnosis; he also said additional documentation is often submitted and helpful when adjudicating allowable expenses.

Commissioners asked whether an IEP must be current to qualify; Southerton said DOE guidance now allows an IEP from any time to qualify unless the child was formally exited or the parent rejected services. He also confirmed families must requalify each year and re-upload documentation; MCDs require yearly re-documentation. On out-of-state IEPs and precise credentialing for every disability category, Southerton said CSF would follow up with DOE for definitive guidance.

The commission asked DOE to provide district-level DOE 25 reports and to identify how many EFA recipients were documented through district IEPs versus MCDs so the panel can assess whether identification pathways and data tracking are producing accurate counts. The next steps included formal data requests of DOE and CSF and a follow-up on documentation standards for qualified examiners.

The commission did not take a formal vote on policy changes in this session; members requested that CSF and DOE produce the source documents and a clearer count before the commission develops final recommendations.