Yes. This substitute language makes the bill more vulnerable in Appropriations, not less.
The new version tries to solve the political problem by adding a funding mechanism, but in doing so it creates a new fiscal and administrative burden on towns, boards of education, the State Department of Education, and DCF. It is still a bad bill, and now it is easier to oppose on cost, bureaucracy, and misplaced priorities.
Below we offer 3 approaches to considering the effects of the bill.
1. A one-page Appropriations memo
2. A very short legislator handout
3. Brief analysis of the current bill language
One-Page Appropriations Memo
RE: Fiscal Concerns with Proposed Substitute Bill No. 5468
An Act Concerning the Provision of Equivalent Instruction
Summary
Proposed Substitute Bill No. 5468 should be rejected in Appropriations because it creates a new, recurring statewide administrative system that Connecticut cannot justify financially. Even with an attempted funding mechanism, the bill imposes substantial costs on local school districts, the State Department of Education, DCF, and related entities, while diverting resources away from core educational and child-protection priorities.
What the bill does
This bill no longer simply defines “equivalent instruction.” It creates a broad compliance structure requiring:
annual intent-to-educate and continuation filings,
in-person district appearances in multiple circumstances,
district follow-up when forms are missing,
DCF checks before certain public-school withdrawals,
annual demonstrations of equivalent instruction,
records retention,
state guidance and new forms,
data collection and reporting,
and possible contracts with third-party entities to review homeschool submissions.
This is not a minor administrative update. It is a new oversight apparatus.
Primary fiscal concerns
1. New bureaucracy with recurring costs
The bill creates ongoing duties for school districts and state agencies, including intake, recordkeeping, communications, compliance review, reporting, and coordination. These are recurring, not one-time, obligations.
2. Costs spread across multiple agencies
Implementation would involve:
local and regional boards of education,
the State Department of Education,
DCF,
the Comptroller,
and potentially RESCs, SERC, and magnet operators.
The more entities involved, the greater the total implementation cost and the greater the risk of inefficiency.
3. Education funds diverted into regulation
Section 3 is especially concerning. It withholds and redistributes public funds to support implementation, review, and oversight functions. This redirects scarce education dollars away from classroom instruction, staffing, transportation, special education pressures, and other direct student needs.
4. Open-ended growth in administrative burden
The bill’s workload grows with the number of children receiving equivalent instruction. More participation means more forms, more follow-up, more reviews, more recordkeeping, and more state involvement. That makes this a potentially expanding cost structure, not a contained expenditure.
5. DCF resources diverted from actual child-protection work
The bill requires boards to request DCF checks before certain withdrawals to equivalent instruction. That uses agency time and personnel for administrative screening even when there is no active abuse allegation. In a resource-constrained environment, DCF should not be burdened with new noninvestigatory mandates.
6. High risk of inconsistent implementation and dispute
The bill relies on future guidance and subjective review of portfolios, academic work, tests, coursework, and other demonstrations. That invites inconsistency among districts and contractors, increasing the likelihood of disputes, appeals, legal conflict, and additional cost.
Key sections of fiscal concern
Section 2: Annual demonstrations of equivalent instruction and review burden
Section 3: Funding transfer and withholding mechanism; core fiscal objection
Section 4: State development of guidance, forms, and expenditure rules
Section 5: Added public-school participation complexity and associated costs
Section 8: Expanded DCF disclosure/response burden tied to board requests
Bottom line
HB 5468 is fiscally unsound. It creates a statewide compliance system without demonstrating a proven need, a measurable educational benefit, or a cost-effective outcome. At a time when Connecticut faces real educational and child-protection demands, this bill would spend public money on bureaucracy, paperwork, and oversight rather than core services.
Appropriations should stop this bill.
Very Short Legislator Handout
Why HB 5468 Should Fail in Appropriations
HB 5468 is not a simple education bill. It creates a new statewide bureaucracy for monitoring “equivalent instruction,” with ongoing costs for school districts, the State Department of Education, DCF, and taxpayers.
Main problems
Creates recurring administrative costs for forms, tracking, follow-up, review, reporting, and coordination
Diverts education dollars from classrooms and student services into regulation and compliance
Expands DCF workload for administrative checks unrelated to active abuse investigations
Builds an open-ended cost structure that grows as more families use equivalent instruction
Invites implementation disputes and uneven enforcement, increasing long-term risk and cost
Most problematic sections
Sec. 2: Annual demonstration/review requirements
Sec. 3: Funding transfer and withholding mechanism
Sec. 4: New state guidance, forms, and administration
Sec. 5: Added public-school participation complexity
Sec. 8: Expanded DCF disclosure burden
Simple fiscal message
This bill creates a costly oversight bureaucracy without proving need, benefit, or affordability.
Bottom line
Connecticut cannot afford to divert scarce education and child-protection resources into a new compliance regime.
HB 5468 should not pass Appropriations.
Brief analysis of the current bill language
The bill no longer just “defines” equivalent instruction. It now builds a full state oversight system around homeschooling.
It does that by requiring:
annual intent to educate and continuation forms,
in-person appearances at district offices in multiple situations,
board follow-up and contact attempts for missing forms,
DCF checks before a child can be withdrawn from public school for equivalent instruction,
annual demonstrations of equivalent instruction through portfolios, testing, or other records,
retention of education records,
state guidance, forms, data collection, and reporting,
possible use of RESCs, SERC, magnet operators, and boards to review homeschool submissions,
and new data-sharing authority for boards to obtain DCF information.
So this is not a small clarification bill. It is a new compliance and enforcement structure.
Why it is financially bad
1. It creates a brand-new bureaucracy
This bill requires systems that do not currently exist at this scale:
form creation and processing,
district intake and recordkeeping,
follow-up contacts,
DCF checks,
review of portfolios and demonstrations,
state guidance development,
data tracking and reporting,
contracts with third parties,
and ongoing compliance administration.
That means staffing time, training, IT, legal review, storage, coordination, and oversight.
2. It imposes costs on multiple agencies at once
This is not just a local school issue. It drags in:
local and regional boards of education,
the Connecticut State Department of Education,
the Comptroller,
DCF,
RESCs/SERC/magnet operators.
A bill that touches this many entities is expensive to implement and hard to control. Even if each individual step sounds small, the total system cost adds up fast.
3. It diverts education dollars away from actual public-school students
Section 3 is especially problematic. The bill withholds money based on the number of children receiving equivalent instruction, transfers those funds, and then sends money back out for administration and review.
That means public funds are being redirected to build a regulatory system for children not enrolled full-time in public school. In plain English, it forces taxpayers and school districts to spend money on compliance machinery instead of classrooms, teachers, reading support, special education pressures, transportation, or school safety.
That is a terrible priority argument for Appropriations.
4. It creates an unstable and potentially expanding cost structure
The more families who choose equivalent instruction, the larger the administrative burden becomes:
more forms,
more tracking,
more reviews,
more data collection,
more follow-up,
more DCF requests.
So the bill does not create a fixed, easily contained cost. It creates an open-ended workload model tied to participation.
5. It uses government labor for paperwork instead of real child-protection work
The DCF-related withdrawal check is especially vulnerable from a fiscal standpoint. The bill requires boards to request checks and DCF to respond on a short timeline. That consumes agency time and resources even where there is no allegation, no report, and no emergency.
That is a poor use of limited child-protection resources. If DCF is already strained, this bill adds administrative screening work unrelated to an active abuse investigation.
6. It invites implementation inconsistency and litigation risk
The bill says districts may review portfolios, testing, coursework, and other demonstrations under future guidance. That means districts and contractors will be interpreting educational adequacy in practice.
That creates risk of:
uneven enforcement,
disputes with families,
appeals,
legal challenges,
and additional administrative cost.
Appropriations members should care about this because bad drafting often becomes expensive after passage.
7. It pays for regulation first and asks questions later
The bill assumes the state should build an oversight apparatus before showing a proven need, measurable benefit, or cost-effectiveness. That is backwards budgeting.
There is no clear showing in this language that the expenditure will improve outcomes enough to justify the cost.
Most vulnerable fiscal points in the bill
These are the sections I would hit hardest:
Section 2
Annual demonstrations of equivalent instruction create recurring review costs, recordkeeping burdens, and possible contractor costs.
Section 3
This is the clearest fiscal objection. It withholds and reallocates money to support implementation and review. That is the funding engine for the bureaucracy.
Section 4
State DOE must develop guidance, forms, and expenditure rules. That means state administrative cost up front and ongoing.
Section 5
Permitting participation in classes and activities can create additional enrollment, scheduling, supervision, eligibility, and administrative complexity.
Section 8
Adding DCF disclosure authority in response to board requests expands administrative involvement and raises privacy/compliance concerns that may also carry cost.
Best fiscal framing for Appropriations
The strongest message is not just “we dislike the bill.” It is this:
This bill creates a costly, statewide compliance system without demonstrating a corresponding public benefit.
You can also say:
It is an unfunded or underfunded mandate in practical effect, because even with a funding formula, districts and agencies will bear operational burdens beyond whatever the bill contemplates.
It diverts scarce education and child-protection resources away from core responsibilities.
It builds a new administrative regime for a population the state has not shown to be a fiscal or safety problem.
It is the wrong bill at the wrong time in the wrong budget climate.
Short talking points you can use
Here are some crisp lines:
“This bill does not simply regulate; it builds a new bureaucracy.”
“It creates recurring costs for boards, the State Department of Education, DCF, and taxpayers.”
“It diverts public resources from actual public-school needs into paperwork, review, and compliance.”
“Appropriations should not fund a speculative oversight system without proof of need or proof of benefit.”
“DCF resources should go to real child-protection cases, not administrative gatekeeping for lawful homeschooling withdrawals.”
“This bill is fiscally irresponsible because its workload expands as participation expands.”
“Even with a funding mechanism, the state is still creating a costly administrative apparatus it cannot justify.”
Bottom line
From a financial standpoint, this bill is bad because it:
creates a new bureaucracy,
spreads costs across multiple agencies,
redirects education funds into regulation,
burdens DCF with noninvestigatory screening work,
and creates open-ended administrative growth with unclear benefit.
For Appropriations, that is enough reason to stop it even before getting to the constitutional and parental-rights problems.