The honest version of the plan

The earlier concept — enroll a student full-time at CPA while presenting them to Florida as a part-time homeschooler — cannot work, and pursuing it would put families' scholarships and CPA's standing at risk. Florida draws one hard line, and the entire model has to sit cleanly on the right side of it.

What does work is genuinely good business: CPA operates as an approved part-time service provider to home-educated PEP students. The parent directs the education and is the school of record; CPA sells individual courses and eligible support services that families pay for with PEP funds, plus anything extra out of pocket. It scales, it's defensible, and it fits CPA's existing part-time tier almost exactly.

One rule the whole model obeys

PEP eligibility rests on a single bright-line requirement: the student cannot be enrolled full-time in a public or private school. A PEP student is, by statute, one whose instruction is directed by the parent — the parent satisfies the compulsory-attendance requirement, not CPA. Step Up is explicit that PEP families may not use the full-time school-enrollment function in the EMA platform; that function is for full-time, in-person learners only.

There is a separate, legitimate lane — the PEP-Hybrid eligible private school — but it requires in-person attendance at least two full days per week at an FLDOE-approved Florida location. An online California school can't meet that, so it isn't the route for CPA today.

Where the real risk sits

The part-time-provider model is well-trodden — providers across Florida run it. The risks are concrete and manageable, and each one maps to a specific safeguard.

Provider approval comes first

To receive PEP funds by direct pay through the EMA Marketplace, CPA must appear as an Approved provider. Families can only route funds to approved providers; an unapproved listing means families front the cost and chase reimbursement, which stalls enrollment. Confirm CPA's path to provider approval with Step Up before marketing anything. As an out-of-state online provider, expect extra scrutiny of qualifications.

Eligible services catalog

PEP funds cover a broad range of parent-directed educational expenses, and CPA can itemize each one as its own line. The test for every fee: does it correspond to an educational service actually delivered to the student? If yes, it's a candidate; if it's a charge for handling money or paperwork, it isn't. Confirm current eligibility against the year's Step Up PEP Purchasing Guide before listing.

Pricing and revenue

The design principle is simple: fund what's genuinely part-time through PEP, invoice everything else privately, and never let the two touch. Price funded courses at or slightly below CPA's current single-course rate to stay competitive in the Marketplace; reserve bundle discounts for private-pay families adding a fifth or sixth course.

Scaling strategy

The online model carries low marginal cost, so scale comes from volume and provider reputation rather than fixed overhead. Get approved, seed a strong first cohort, and let the Marketplace listing and Florida homeschool networks compound. Prioritize high-enrollment cores — English, Math, Bible, Spanish — where CPA's staff coverage is deepest, and add electives as demand proves out. Florida's PEP program is authorized to serve up to 140,000 students in 2026–27, so the ceiling on demand is not the constraint; approval and delivery quality are.

Four phases to launch

Who can teach what

CPA's team covers nearly every core for part-time delivery. For the EMA listing, attach credential proof per subject. Coverage strength below reflects degrees, credentials, and documented experience — verify transcripts before listing advanced courses.

Legal & compliance checklist

• Confirm provider approval and the out-of-state online-provider requirements directly with Step Up for Students provider support.
• Have a Florida education attorney review the Supplemental Services Agreement and the funded-vs-private billing separation before launch.
• Write the "part-time, parent as school of record" language into every contract, invoice, and marketing page — no ambiguity.
• Keep funded and private-pay invoices physically separate; never credit or rebate PEP funds toward private tuition.
• Charge PEP only for services delivered to the student; put registration or account-handling fees on the private-pay side — never bill "voucher oversight" to the ESA.
• Do not market or record PEP students as full-time CPA enrollees or issue them a CPA diploma through the part-time model.
• Document instructor qualifications per subject and re-verify against the current year's PEP Purchasing Guide each cycle.
• Support families' annual obligations: Student Learning Plan on file, norm-referenced testing arranged, evaluation completed before renewal.