In Edmeston, a small district in Otsego County, Andrea Denekamp's son Warren started his senior year this fall needing one piece of paper from the superintendent's office. It was a letter saying his years of home instruction added up to the equivalent of a high school education. Over the summer, Superintendent Christine Nichols told the district's homeschooling families that parents could no longer administer their own children's year-end assessments if they wanted that letter. The person giving the test, she said, had to be state certified and unrelated to the student. "Without that letter of equivalence, then it would be pretty hard to get a job," Warren told Spectrum News 1 in August.

The dispute, which Denekamp and several other parents have appealed to the state Education Commissioner, is the sharpest version of a question every New York homeschooling family eventually faces. What does the state require, and who decides whether a family has met it? The answer sits in a single regulation, 8 NYCRR 100.10, which governs home instruction in New York from the first notice to the final test. It runs on deadlines measured in business days, a plan the district must approve, four quarterly reports and one annual assessment. The first of those quarterly reports falls due for many families in the next two weeks.

New York’s homeschooled student population reached 53,967 in 2024–25, marking a 7.5 percent single-year increase, according to Empire Center for Public Policy analysis of preliminary state data. However, managing that growth requires navigating unmatched bureaucracy. Home School Legal Defense Association staff attorney Ralph Rodriguez told Spectrum that New York's paperwork demands surpass all other states, calling it "by far... the most highly regulated state in the nation."

The notice and the IHIP

Everything starts with a letter from the parent to the district superintendent. The regulation's text sets the deadline at July 1 for families who plan to homeschool for the full school year. For parents who pull a child out after classes have started, the notice of intent is due within 14 days of the day home instruction begins. A family that decides in late October that a classroom is not working can start now, so long as the letter goes out promptly.

The district then has 10 business days to send back a copy of the regulation and a form for the individualized home instruction plan, known to every homeschooling parent as the IHIP. Parents have four weeks from receiving those materials to return the completed plan, and the district has another 10 business days to review it. If the superintendent finds the plan deficient, the parent gets 15 days to revise it, and the superintendent gets 15 days to rule on the revision.

The plan itself is shorter than its reputation. It lists the child's name, age and grade, along with the syllabi, textbooks or plan of instruction for each required subject. It also names the people doing the teaching, states that the child will meet compulsory education requirements, and sets the dates the parent chooses for quarterly reports. That last item is the one families most often underestimate, because the dates a parent writes into the IHIP in September become the deadlines the district enforces through June.

What has to be taught, and for how long

The required subjects track what public schools teach. In grades one through six, that means arithmetic, reading, spelling, writing, English, geography, United States history, science, health, music, visual arts and physical education. Bilingual education or English as a new language is added where needed. Grades seven and eight move to units of credit across English, history and geography, science and mathematics, with half units in art, music, health and physical education. High school requires four units of English, four of social studies including American history, two each of math and science, and three electives among other credits. Every grade also carries the state's standing topics, from patriotism and citizenship to fire and arson prevention.

The regulation sets the clock as well. Instruction in grades one through six must total 900 hours a year, and grades seven through twelve must reach 990, the same thresholds families report back to the district every quarter.

Quarterly reports and the November deadline

Each quarterly report has three parts. It gives the hours of instruction during the quarter, describes the material covered in each subject, and offers either a grade or a written narrative on the child's progress. If a child covered less than 80 percent of the material the IHIP promised in any subject, the report must explain why. The reports are due on whatever dates the parent wrote into the plan, and districts commonly publish a suggested calendar to help families choose.

In Syracuse, the city school district's home instruction packet recommends filing on or about November 15, February 15, April 15 and June 15, and notes that families may choose other dates. Other districts set their own suggested dates, so the packet from your district is the one to check. For a family on a calendar like Syracuse's that started in September, the first report covering roughly ten weeks of lessons is due in about two weeks. Parents who have not been logging hours since Labor Day should start reconstructing them from lesson plans and calendars now, while the weeks are still fresh.

The annual assessment, and who gets to give it

The fourth quarterly report must arrive with an annual assessment, and this is where the Edmeston dispute lives. The regulation allows a commercially published norm-referenced test, including the Iowa, Stanford, California, Metropolitan and Comprehensive Test of Basic Skills batteries, or a State Education Department test. A child passes by scoring above the 33rd percentile on national norms or by showing one year of academic growth over the prior year's result.

The test can be given in four settings. It may be given at the public school by its staff, at a registered nonpublic school with that school's consent, or at a nonregistered nonpublic school with the consent of both its chief officer and the superintendent. The fourth option is a test at home or another reasonable location, given by a New York State certified teacher or another qualified person with the superintendent's consent. That last phrase is the hinge. Edmeston families had been giving the tests themselves, and the district's new policy reads the superintendent's consent as the power to say no.

"The district's decision does not change a family's right to educate their children at home," Nichols said in her statement to Spectrum. Denekamp read it differently. "She is claiming parents cannot be trusted to be unbiased evaluators of their children's progress," she told the station. She estimated that a certified administrator could cost close to $100 an hour for a test that runs about four hours. Rodriguez said he expected the appeal to be resolved by spring.

The written narrative option ends at eighth grade

Younger children have a second path. In grades one through three, families may substitute a written narrative for a test every year. A certified teacher, a home instruction peer group review panel, or another person who has interviewed the child and reviewed a portfolio prepares it, chosen with the superintendent's consent and paid for by the parent. In grades four through eight, the narrative may be used no more often than every other year, which means a standardized test at least every second year. The regulation offers no narrative option for high school, so students in grades nine through twelve sit a test every year.

Probation, home visits and the diploma question

A child who does not pass the annual assessment puts the program on probation for up to two school years, and the parent must submit a remediation plan. The regulation allows home visits only during probation, and only when the superintendent has reasonable grounds to believe the program is in substantial noncompliance. Those visits require three days' written notice.

Homeschooled students in New York do not receive a high school diploma from their district. What they can receive, after four years of high school instruction under approved IHIPs, is the superintendent's letter certifying completion of the substantial equivalent of a four-year high school course of study. The Commissioner recognized that authority in Decision No. 15,413 in 2006, and it is the document colleges and employers ask for. Families planning for college aid should also read our guide to TAP eligibility for homeschooled and online-diploma students. Seniors building a winter calendar can work from our list of New York scholarship deadlines before December 15.

The practical lesson from Edmeston is that the letter depends on every earlier document being on file. Syracuse's packet says so plainly, offering the letter of substantial equivalence when all required documents are on file. Rodriguez estimated that families submit about seven documents, from the notice of intent to the final quarterly report, plus the assessment. A parent who keeps copies of each one, dated and filed, is the parent whose senior gets the letter in June.