STATE'S COMMENTS ON THE DEPARTMENT OF DEFENSE DEPENDENT SCHOOL LEGISLATION

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP86B00338R000400530002-0
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 4
• Document Creation Date: December 21, 2016
• Document Release Date: August 28, 2008
• Sequence Number: 2
• Publication Date: August 14, 1984
• Content Type: MEMO

Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0 Sc~ulue
0 OLL 84-27910
14 August 1984
&-E /UE(-f4[-
MEMORANDUM FOR: Deputy Director for Employees Benefits and Service
Chief, Administrative Law Division
Office of General Counsel
Chief, Operations Support Division
Office of General Counsel
Legislation Division
Office of Legislative Liaison
SUBJECT: State's Comments on the Department. of Defense
Dependent School Legislation
REFERENCE: Memo for DD/SP/OP, dtd 17 July 1984,
subj: draft bill on DODDS
Attached for your review and comment are the Department of
State's views on the Department of Defense's draft bill to
permit overseas United States Government minor dependents to
attend Department of Defense Dependent Schools. The Office of
Management and Budget (OMB) has requested the views of this
Office on this letter. Please provide me with your views on
this letter by noon Monday, 20 August 1984. If I do not hear
otherwise, I will inform OMB that we have "no comment' on the
Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0
 Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0
? 0
DISTRIBUTION
Original - Addressee
1 - C/ALD/OGC
1 - C/OSD/OGC
1 - D/OLL
1 - DD/OLL
1 - OLL CHRONO
1 - LEG SUBJECT (Personnel General)
1 - ROD SIGNER
OLL: LEG: ROD: sn (14 August 1984)
Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0
 .y-
Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0 State
Washington, D.C. 20520
AUG1-,1984
Dear Mr. Stockman:
We have carefully reviewed-DOD draft bill 98-152, 'To
amend the Defense Dependents' Education Act of 1978, as
amended, to permit the minor dependents of United States
Government personnel stationed overseas to attend the
Department of Defense Dependents Schools (DODDS) on a space-
required basis when buildings are available,' as well as the
accompanying letters addressed to you and to House Speaker
O'Neill.
Providing for the education of, the dependents of overseas
personnel continues to be a matter of highest concern to the
Department of State. The Department does not view the
proposed legislation as necessary and does not recommend its
submission to the Congress. We would like to call your
attention to several matters pertaining to the proposal.
Legally the education allowance authorized under the
Department of State Standardized Regulations is a cost of
living allowance, payable only to the employee. The funds
authorized cannot be assigned or allotted, and the 'agency of
the sponsor' therefore cannot 'reimburse the Department of
Defense for the cost of the education of the dependent
concerned,' as specified in paragraph (3) of the proposed
legislation. This is one of the fundamental differences
between the DOD and civilian agency education programs
overseas.
The Department of State does not agree with the view that
as a result of the proposed legislation '...the United States
Government would realize a significant cost savings in
educating its overseas dependents.' At the present time,
basic tuition costs under the Standardized Regulations are
calculated on the cost of DOD schools where such schools are
available within normal commuting time and distance. When an
employee opts for dependent children to attend a school that
is more expensive than the DOD school, the employee is
personally responsible for any additional tuition costs.
The Honorable
David A. Stockman, Director,
Office of management and Budget.
Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0
 Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0
? 0
When an alternative school is less expensive than the DOD
school, however, the employee is reimbursed allowable costs
only, with concomitant savings to the U. S. Government.
If all sponsors who are provided an education allowance
under the Standardized Regulations withdrew their dependent
children from the DOD schools, the magnitude of this dim-
inution would be less than one half of one per cent. This
would not appear to be a significant factor. However, we
believe that a large proportion of non-DOD Government
employees will continue to opt to use DOD schools where they
are available. Although precise figures are not yet avail-
able we do not believe that more than 20 to 30 dependents of
State personnel will actually withdraw from the DOD school
system.
We cannot accept the suggestion that the loss of a few
students will reduce the quality of education offered to
those who remain. It is inconceivable that the relatively
small number of children involved would have any impact on
the overall quality of the DODDS system. In addition, the
reduction of funds transferred to DOD from sister agencies
(and thereby retained by the Government) cannot be a
significant factor for the same reason.
The Department's obligation for tuition costs has not
increased as a result of the change in the Standardized
Regulations. On the other hand, the change, which permits
flexibility where there is a choice of schools, has had a
positive effect on employee morale.
Because of its concern for the educational needs of
'dependent children of its overseas employees, the Department
of State appreciates the opportunity to review and comment on
the proposed legislation.
Sincerely,
W. Tapley Bennett, Jr.
Assistant Secretary
Legislative and Intergovernmental Affairs
Approved For Release 2008/08/28: CIA-RDP86B00338R000400530002-0