Wisconsin Parents Association (WPA) and Home School Legal Defense Association (HSLDA) are getting involved in the legal debate over the new electronic filing requirement by the Wisconsin Department of Public Instruction (DPI).
HSLDA Senior Counsel, Scott A. Woodruff, wrote:
Dear HSLDA Members and Friends:
The Wisconsin Department of Public Instruction has announced that they will no longer mail blank enrollment forms to homeschool families, but will make the form accessible for filling in online.
I have asked Merry Larsen at the DPI to make several changes.
First, I have asked her to make sure that families can obtain a copy
of the paper form conveniently if they want it. Some families don’t
have computers. Others may object to using the online process out of
concerns for privacy, since reports of hackers breaking into
supposedly secure databases are all too frequent.
Second, I have asked her to change the form to stop asking for
enrollment by each individual grade. The statute only requires that
enrollment be broken down by elementary and high school.
Third, I have asked her to remove the request for the gender of the
children. The law does not require families to identify the gender of
Finally, I have asked her to modify the form so it is clear that a
family who supplies a post office box for an address is not required
to supply a street address in addition.
The deadline for filing the form is October 15. Hopefully that will
allow enough time for the kinks to be worked out.
Scott A. Woodruff
HSLDA Senior Counsel
To which, homeschoolers requested that WPA respond to HSLDA:
Subject: PI-1206: Problems with HSLDA’s Requests and What You Can Do Instead
Dear WPA Members and Other Homeschoolers,
Homeschoolers have asked WPA to respond to an email sent on September 1. 2010, by Scott Woodruff of Home School Legal Defense Association (HSLDA) outlining 4 changes he has asked the DPI to make in the new electronic PI-1206 form. WPA does not agree with HSLDA’s request. However, WPA has other concerns about the new form and important suggestions for what you can do to protect homeschooling freedoms and your family’s privacy.
Why WPA Does Not Agree With HSLDA’s Requests
HSLDA’s 4 requests are inappropriate and undermine our homeschooling
freedoms and family privacy.
1)Woodruff asked the DPI “to make sure that families can obtain a copy of the paper form conveniently if they want it.” This request is basically reasonable. In fact, in May, WPA urged the DPI to do so, and they said they would. WPA reported this on page 12 of Newsletter #104, June 2010. In addition, WPA has informed homeschoolers that they can use any computer, including a friend’s or their local public library’s. They do not need an email account. Because information from paper forms will be entered into the DPI’s database, filing a paper form does not protect data from hackers.
2)Woodruff asked the DPI “to stop asking for enrollment by each individual grade.” Woodruff writes, “The statute only requires that enrollment be broken down by elementary and high school.” This is a questionable paraphrase of Wisconsin statute 115.30 (3), which covers “Forms and reports” and states, “a statement of the enrollment on the 3rd Friday of September in the elementary and high school grades.” It should be noted that in 1984, homeschoolers working
through WPA succeeded in having “Ungraded 1-8 and 9-12” included on the form. These categories can be used by anyone who does not want to list specific grades for any reason, including privacy, children working on different grade levels in different subjects, etc.
3) Woodruff asked the DPI “to remove the request for the gender of the children.” WPA’s goal has always been for homeschoolers to provide the DPI with the least amount of information possible under the law. In 1984, homeschoolers working through WPA convinced legislators to exempt homeschoolers from the requirement that they report their children’s names and ages. For 27 years, the DPI and local school districts have accepted only gender and grade level (or ungraded) both on PI-1206 forms and for the school census. If homeschoolers now request that their children’s genders and grades not be required, the DPI and/or the Legislature might respond by increasing reporting requirements instead. Why would we want to trigger this since we have such a reasonable law that has worked so well for so many years?
4)Woodruff asked the DPI “to modify the form so it is clear that a family who supplies a post office box for an address is not required to supply a street address in addition.” Because school district boundaries are sometimes irregular, street addresses are used to identify the school district in which
homeschoolers live, information that is needed to enforce the compulsory school attendance law that applies to all children, including homeschoolers.
Important note:The same HSLDA lawyer recently requested that the DPI change the wording of its response to one of the questions about homeschooling on its Web site. The resulting change is worse for Wisconsin homeschoolers and threatens our freedoms. For details, see page 6 of WPA Newsletter #105, September 2010.
What You Can Do About Real Concerns About the New Form, Homeschooling Freedoms, and Privacy
WPA has raised with the DPI serious concerns about the impact of the
new electronic version of the form, the Web site on which it is posted, the process by which homeschoolers file it, and how local school officials might misuse homeschoolers’ personal information. (WPA’s concerns are very different from HSLDA’s.) It is not clear how the DPI will respond. Therefore, we need to be prepared to act appropriately by refusing to give them information not required by law.
Here’s what you can do. For more information, see the WPA Web site at http://homeschooling-wpa.org/getting-started/#file.
• File form PI-1205 after the third Friday in September (September 17 this year) and by October 15 (unless your child is currently formally enrolled in a public school or a private school that is not a homeschool. If they are enrolled, you need to file the form before you begin homeschooling.)
• When filing your PI-1206 form, don’t use your email address as your ID. (If the DPI Web site still says, “We strongly encourage you to use your email address as your ID,” ignore this suggestion.) Instead, where the DPI Web site says, “Required: Email / ID,” use your name or a combination of letters and/or numbers that you choose. omeschoolers who use their email address may receive emails from their local school districts and others. To solve this problem, WPA has asked that the DPI remove the suggestion that parents use their email address as their ID. If the DPI does not remove it, WPA has asked that the DPI
not provide email addresses to local school districts.
• Don’t give the DPI your phone number(s). There is no good reason for the DPI to request them, and they haven’t done so in the past. Because an enormous amount of information is available to anyone who has your phone number, giving it to the DPI undermines your family privacy. Also, some local school districts may use these phone numbers to contact homeschoolers.
• Don’t give the DPI or your local school district any other information not required by law. Know your rights and don’t respond to surveys or questionnaires your school district may send you.
• Don’t trust information from the DPI, including what is posted on the Web site that has the new electronic version of the form. Much of this information is misleading and/or inaccurate. See the WPA Web site and “For Information, Trust WPA and Beware of the DPI” on page 10 of Newsletter #105.
• Our freedoms and our privacy are much more secure when we know how to protect our freedoms in spite of the policies and procedures of the DPI and local school districts. We will be in a much weaker position if we try to rely on outside experts instead of taking responsibility ourselves. Many states (such as NY, NH, and PA) that relied on outside experts have ended up with restrictive homeschooling laws as a result.
• Forward this email and share this information with other homeschoolers, including members of your support group.
The WPA Board
Wisconsin Parents Association
I’m not a lawyer, and don’t play one on television. Read the statutes for yourself. Data collection over the internet issues notwithstanding, privacy is still afforded under the statutes. Although they may ask for more — you only need to provide certain pieces of information. Let’s protect our freedoms in the face of this change. Take responsibility. Know the law. You can find it all online or in the library. What an opportunity for learning!