Questions Answered: Category IV Schools and “Special Approval”

What is “special approval”?

There is no exceptional “special approval.” What’s being referenced is an alternative way for Category IV (church-related) schools to gain approval—through the State Board of Education rather than through a recognized association like ACSI.

There are two ways Category IV schools can be approved. Almost all umbrella schools including HLA choose this first option:

Option 1: Through membership/accreditation with a state-recognized association like ACSI, TANAS, TACRS, SACS, TAIS, etc.

Option 2: Through the State Board of Education, by applying directly.

Why HLA chooses Association Membership (ACSI) over State Board Approval:

Autonomy: We maintain our independence from additional and unnecessary government oversight and preserve flexibility in how we operate.

Alignment: ACSI aligns with our mission and vision to serve all homeschoolers through parent-directed education, freedom and flexibility, and faith-based education for those that seek it.

Privacy: We do not report family or student names to ACSI or other external third parties; and also do not have to submit anything to the DOE through their ePlan systems. The only required reporting is to the local boards of education for purposes of compulsory attendance. All schools have this requirement whether agency or state board approved.

Do state board-approved schools have fewer requirements?

No. The list of operating requirements for all Category IV schools is the same, However, state-approved schools are monitored directly by the DOE. They must complete detailed reporting twice a year via the state’s ePlan system, and they may be subject to Tier 2 (on-site or virtual) reviews. In contrast, schools like HLA (approved through ACSI) are monitored only through the association, which means:

No ePlan reports – No DOE involvement unless there’s a compliance issue submitted by the association.

Does HLA report enrollment to external 3rd parties?

No. HLA does not report student names or family information to ACSI or any external agency. HLA and any other Category IV approved school, even those who are state board approved, must submit enrollment to the local boards of education (each county not the state DOE) for compulsory attendance as required by state board rule 0520.-.07-.02 (5).

Who are the state board-approved schools?

Only two Category IV schools in Tennessee are currently approved via the State Board:

               The Farm School – A long-standing, secular homeschool umbrella

               Honor School of Tennessee – A newer, hands-off umbrella established in TN in 2020

Final Thoughts:

We’ve spoken with Diana Burton, who oversees non-public schools in Tennessee, to ensure the accuracy of this information. At HLA, we believe in protecting parent-directed education, faith-based support (for those who seek it), and avoiding unnecessary government oversight. That’s why we continue our long-standing membership with ACSI as our means of approval as a Category IV school.

Thank you for choosing HLA. Please email admin@homelifeacademy.com if you need further clarification. Also attached is a more detailed memo including the state board rule referenced above.

Summary: HLA is not interested in state board approval due to the unnecessary oversight by the Department of Education and would rather seek approval through an association that is in line with our mission and vision. State board approved schools’ are monitored by (see below) the Department of Education rather than the association. We have autonomy with our association (ACSI) to preserve flexibility in how we operate and do not have to report the names of students or families to them or any other 3rd parties.

Details: In the State Board Rule 0520-.07-.02 approval for non-public schools. Category IV church-related schools like ours can seek approval one of two ways:

(1) Category IV schools are schools that are “church-related” and exempt from certain regulations regarding faculty, textbooks, and curriculum. T.C.A. § 49-50-801 defines a church-related school as a school operated by denominational, parochial or other bona fide church organizations, which are required to meet the standards of accreditation or membership of the Tennessee Association of Christian Schools, the Association of Christian Schools International, the Tennessee Association of Independent Schools, the Southern Association of Colleges and Schools, the Tennessee Association of Non-Public Academic Schools, the Tennessee Association of Church Related Schools, the Association of Classical and Christian Schools, the Tennessee Alliance of Church Related Schools, or a school affiliated with Accelerated Christian Education, Inc.

(2) Church-related schools not accredited by or members of one of the agencies [association] set forth in paragraph (1) of this rule may seek approval from the State Board as provided for in T.C.A. § 49-50-801(e)(1) by submitting the application on a form developed by the State Board staff and meet any deadlines for application established by the State Board staff. State Board staff shall review any complete and timely submitted application and provide a recommendation for approval or denial of the application to the State Board.

All but two Category IV schools in the state of Tennessee choose option one. I can’t speak for all umbrella schools in Tennessee but as a church-related school and one that values parent-directed education, freedom and flexibility, faith-based education for those that seek it, and minimal government involvement, registering with an association helps to protect and support these values. There are fees for membership with the associations that are based on student enrollment, so it can be a benefit to seek approval through the state if a school does not want that cost. We choose this option because we want autonomy from more limited government involvement; and the associations typically have the same goals for families and education. Depending on the association a school chooses determines the requirements they have for the school. We hold membership with ACSI which does not require a statement of faith from our families and also does not require any reporting of our students and families to them or any other 3rd parties. We believe that education should be available to all and that we can best reach people and help families through our service to them. There are two schools that have sought approval through the state board. One is Farm School and they have been around since the 1970’s and provides a secular option for homeschoolers who may not want to associate with a “denominational church-related school”; and the second school is Honor School of Tennessee which was established in Tennessee in 2020 during Covid and opted for state board approval this year according to the department of non-public schools.

According to state board rule 0520-.07-.02(5), for schools that are members of an association, the association gets confirmation, typically through form, that all requirements are being met. As long as the school is in compliance, the state is not involved in monitoring unless the association reaches out for non-compliance. For schools that are state board approved, the monitoring process is done through the Department of Education and is reviewed in the fall and in the spring each year according to the Monitoring guidebook (see below).
Note: This monitoring is for the school and not the individual families.

State-Approved Non-Public Schools: All Category I, I-Special Purpose, IV-State Board Approved, and V non-public schools shall participate in tier 1 annual reporting through ePlan each fall and spring. School leaders are required to submit the Non-Public Schools Annual Compliance – Fall monitoring instrument by October 15 and the Non-Public Schools Annual Compliance – Spring monitoring instrument by April 15. Note: Category II, III, and IV-Membership Agency Approved non-public schools do not complete the ePlan reporting instruments. Non-public schools approved under these category designations will be monitored by the membership or accrediting agency. The October 15 fall monitoring submission includes the following components appropriate to the school’s designated category: ▪ Directory Information ▪ Enrollment and Attendance ▪ Facilities, Health, and Safety ▪ Curriculum, Graduation, and Assessment ▪ Credentials and Evaluation ▪ Administrative Rules ▪ Student Transfers ▪ Required Uploads The April 15 spring monitoring submission includes the following components for all state-approved categories: ▪ Basic Directory Information ▪ Attestation of Compliance ▪ School Calendar ▪ Required Uploads State-approved non-public schools that demonstrate compliance concerns or those that are selected by the department may be asked to participate in tier 2 monitoring. Tier 2 monitoring involves the submission of additional documentation and an on-site or virtual monitoring visit by the department’s non-public team. Selection for tier 2 monitoring will begin in the 2025-2026 school year.

Schools that are state board approved have the exact same operating requirements as any other Category IV school. Monitoring however is overseen by the DOE for those schools. Any varying requirements would be based on the association in which the school chooses to hold membership. Schools can apply anytime to be state board approved by filling out an application, which is then reviewed for compliance and voted on by the state board. Both options are valid, HLA chooses to align with organizations that support our mission and values.

I hope this helps to answer any questions surrounding this topic. Thank you for choosing HLA. Please email admin@homelifeacademy.com if you need further clarification.

Angela K. McKee

Senior Administrator

HomeLife Academy