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JUNE 2016



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


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


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


■ 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