Matt has been identified, according to the District's criteria and procedures, as a Gifted and Talented pupil. Because of that, he was eligible to attend Indian Hills Community College as a 9th grader to take a class in "Technical Math I." This was done under the authority of the "Postsecondary Enrollment Options Act" [hereinafter, "PSEO"] enacted by the Legislature to "promote rigorous academic or vocational-technical pursuits and to provide a wider variety of options to high school pupils by enabling ninth and tenth grade pupils who have been identified as Gifted and Talented, and eleventh and twelfth grade pupils, to enroll part-time in nonsectarian courses in eligible postsecondary institutions of higher learning in this state." Iowa Code ? 261C.2 (1995). The Act further provides that "high school credits granted to an eligible pupil under this section shall count toward the graduation requirements and subject area requirements of the school district of residence, ?". Iowa Code ?261C.5 (1995). However, in order to be eligible for tuition reimbursement by the school district, the course taken at the eligible postsecondary institution must not be "comparable" to a course already offered by the school district. Iowa Code ?261C.4 (1995).

Ms. Davis testified that last May, Matt went to the guidance counselor and asked to fill out the forms to participate in the PSEO program for the 1996-97 school year. He was told to wait until the Fall of 1996. When Fall arrived and it was time to sign up for classes, Ms. Davis took it upon herself to enroll Matt in two courses at Indian Hills. One was entitled, "College Communications I" and the other was entitled, "U.S. History I." Ms. Davis then sought authorization for payment from the principal, the superintendent and the finally, she went to the Board meeting on September 16, 1996, to address the Board.

As evidence at the appeal hearing, Ms. Davis introduced descriptions of the courses at both the high school and at Indian Hills to show the differences between them. Although the course in U.S. History at Indian Hills covers a different period than the course offered at the District high school, Superintendent Godrey testified that during 8th grade, the same material is covered by the District's history class. Superin-tendent Godrey further testified that it's the Board's position that the purpose of the Postsecondary Enrollment Options Act is to allow the students to take coursework in an area not avail-able at the high school. In contrast, Appellant contends that the purpose of PSEO is to promote "rigorous academic pursuit." She disagrees that a history class offered in the eighth grade can be "comparable" to one available at a postsecondary institution. The issue presented by this appeal is "What is a'comparable' course for the purposes of the Postsecondary Enrollment Options Act?" Iowa Code ?261C.4 states that in order for an eligible pupil to enroll in a postsecondary course for credit, a comparable course "as defined in rules made by the board of directors ? must not be offered by the school district." Id. The Departmental rules implementing the Act did not elaborate on that definition. See, 281?IAC 22.4. Therefore, we believe the determination of "comparable course" is left to the local district board.

In reviewing the facts of this appeal under the above-enunciated standards, we find that the District Board acted reasonably in denying Appellant's request for tuition reimbursement for these courses. First of all, a student anticipating enrollment under this Act is required to do three things: 1) inform the school district of the intent to participate; 2) apply at the postsecondary institution; and 3) sign a statement indicating that the student and parent or guardian will be responsible for the payment of the tuition if the student fails to complete the course for credit. See, 281?IAC 22.3.

That the decision of the Board of Directors of the Cardinal Community School District made on September 16, 1996, was affirmed.