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1342.12 Companion

July 12, 2017

Page 24

As stated above, the CSC must review and consider all IEEs, whether funded by DoDEA or obtained

privately and funded by parents.

DoDEA is not required to follow the findings of an IEE but must

consider the findings and provide PWN addressing any decisions made regarding the recommendations

from the evaluation.

Procurement of IEE:

Throughout the IEE process, the SPED ISS is to work closely with the district procurement office as soon

as the parental request is received and prior to obligating DoDEA for payment.

The Government Commercial Purchase Card (GPC) may be used for all IEEs where the total value of

the IEE is under $3,500.00 (the micro purchase threshold).

In the Americas, if the total value of the IEE exceeds $3,500.00, the SPED ISS shall submit a request

to DoDEA Procurement to procure the specific vendor, and DoDEA Procurement will create a

purchase order.

In the Europe and Pacific Regions, for any procurement exceeding $3,500.00, the SPED ISS shall

contact DoDEA Procurement for assistance. Under certain circumstances, an exception in the

procurement regulations allows the GPC to be used to obligate funds for purchases up to

$25,000.00 for overseas procurements. However, DoDEA Procurement will need to determine

whether a purchase order is necessary due to Privacy Act- and competition-related requirements

applicable to procurements exceeding $3,500.00.

Access to Records

Storage, access, and release of a student’s special education records are governed by the Privacy Act, 5

U.S.C. 552a as implemented by th

e DoD Directive 5400.11 ,

“DoD Privacy Program,” October 29, 2014

and

DoD 5400.11-R ,

“Department of Defense Privacy Program,” May 14, 2007.

NOTE

: Many parents believe their student is covered by the slightly different provisions of

the Family Education Right to Privacy Act (FERPA) that protects the privacy of student

education records. FERPA only applies to schools that receive funds from the Department

of Education and thus does not apply to DoDEA records, although the protections of the

Privacy Act are very similar to those under FERPA.

The parents of a student with a disability have the right to examine all educational records with respect

to the identification, evaluation, and educational placement of their student.

In the absence of a court order to the contrary, all parents, even those not having custody of their

students, have the right to examine education records pertaining to their student.

Parents have a right to:

1.

A response from the school on reasonable requests for explanations and interpretations of the

records;

2.

Request copies of the records;

3.

Have their selected representative examine the records; and

4.

A parent who believes that the information in their student’s record is inaccurate, misleading,

untimely, or irrelevant may request the record be amended. Amendment requests must be in

writing. However, in the normal course of daily business involving their student, the parent is