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Comment: Residency Verification Rulemaking for Public Schools & Public Charter Schools

Policy Attorney Aubrey Edwards-Luce, on behalf of Children’s Law Center, submitted comments to the Office of the State Superintendent of Education (OSSE) regarding residency verification rulemaking for public schools and public charter schools. The stated purpose of the rulemaking is to clarify the policies and procedures required to ensure District residents have access to available space at local schools, and that when extra space is available, non-resident students are permitted to enroll in a public school and pay non-resident tuition.

In her comments, Aubrey discussed the impact the proposed rulemaking might have for students, highlighting that the rules:

  • Place a greater burden on students with disabilities and students in foster care;
  • Don’t require LEAs to give notice of exceptions to the Residency Verification Requirement;
  • Don’t include an exemption created by the “Education Continuity Act of 2014;”
  • Lack a strong limiting principle for investigations;
  • Require documents that may be difficult for the public to acquire;
  • Create a heavier verification burden for parents with informal custody agreement; and
  • Don’t include pre-kindergarten students in the definition of school-age student, among others.


Click below to read her full comments.