Child support for vocational education: Concepts to improve determination and enforcement

Megan B. Benton
Megan B. Benton is an associate circuit judge in the 6th Judicial Circuit in Platte County. Licensed in Missouri and California, she previously was an assistant prosecuting attorney and an associate in a Kansas City litigation firm, after clerking for two years on the Superior Court of Los Angeles County.

“In 2021, the percentage of companies reporting that at least some jobs were available to individuals with short-term training was the highest to date (81%). Seventy-four percent said the same in 2020 and only 69 percent in 2019. Forty-four percent of companies reported at least half of their positions were available to applicants with short-term training.”⁴

Vocational education is also a challenge for child support law. In Missouri family law, “vocational education” has a specific definition: “any postsecondary training or schooling for which the student is assessed a fee and attends class regularly.”⁵ “Child support” also has a specific definition: “duty of support to a child of the marriage to pay an amount reasonable or necessary for the support of the child . . . after considering all relevant factors.”⁶ A parent’s obligation to support a Missouri child ends with the child’s emancipation, most commonly at age 18.⁷ However, for a child attending an institution of “vocational or higher education,” Missouri law authorizes a court to order parental child support until age 21, or until the child completes their education, whichever first occurs.⁸ Two of the surrounding states, Illinois and Iowa, also authorize their courts to award support for postsecondary education.⁹ Arkansas, Kansas, Kentucky, Nebraska, Oklahoma, and Tennessee recognize a voluntary agreement between parents about postsecondary education but, according to the National Conference of State Legislatures, do not have a statute or case law stating that parents have a duty for college support.¹⁰

During the 34-year life of Missouri’s law, several statutory amendments and many court cases have addressed child support for postsecondary education. Almost all these amendments and cases focus on traditional “college” higher education, but they say almost nothing about vocational education programs.  

For these programs, judges, lawyers, child-support enforcers, parents, and children now lack approaches about the rules for child support. This article analyzes this issue and suggests concepts to improve determination and enforcement of child support for vocational education.

Statutory framework: Child support for postsecondary education

The original 1988 law, codified in § 452.340.5 RSMo, had two straightforward sentences:

If the child is attending an institution of vocational or higher education, the parental support obligation shall continue until the child completes his education, or until the child reaches the age of twenty-two, whichever first occurs. If the child is attending such a school, the child or obligated parent may petition the court to amend the order to direct the obligated parent to make the payments directly to the child.¹¹

Within two years, the Missouri General Assembly added definitions of “vocational education” and “higher education.” It also added the requirement that the child enroll by Oct. 1 following high school graduation or GED completion (with the date waivable by court order).¹² The initial framework treated vocational and higher education equally, in terms applicable to both.

Over the next two decades, however, the General Assembly amended the subsection many times and in great detail. Each amendment expressed the change in traditional college terms. In 1997, the legislature required that the child take and “complete” at least 12 credit hours each semester (not including the summer semester); achieve grades sufficient to re-enroll; and send each parent a detailed transcript with courses, grades, and credits.¹³ In 1998, the legislature added a sentence, relaxing the credit-hour requirements for children with developmental disabilities.¹⁴ The 1998 amendment also added more specifics about the timing and form of the transcript itself, and allowed a child to take as few as nine credit hours if employed for at least 15 hours per week.¹⁵ A 2007 amendment provided that failing half or more of the courses in a semester or delaying sending required documents may end child support (without accrual of any arrearage), as well as changed the age for ending child support from 22 to 21.¹⁶ The legislature has not amended § 452.340.5 since 2007.

As a result, § 452.340.5 has expanded to 12 complex sentences, each about 50 words long. It now gives very specific concepts about continuing child support for higher education, but almost none about continuing child support for many programs of vocational education.  

Caselaw: Child support for postsecondary education

The Supreme Court of Missouri upheld the constitutionality of § 452.340.5 in 1993 and 1999, the only times it has considered the subsection.¹⁷ The Missouri Court of Appeals, as with most family law, therefore, has developed law about child support for vocational education, discussing it in about 140 opinions (per Westlaw and Fastcase).

Of these 140 opinions, almost all address “higher education” in the traditional “college” sense.¹⁸ These cases always follow a “semester-by-semester” approach to abating, ending, or requiring child support.¹⁹ Many opinions address whether one parent has received notification (or timely notification) of transcripts, courses, grades, and credits.²⁰ Several cases tackle the issue of “completing” enough credit hours²¹ or excusing a “temporary” failure to enroll and earn credits.²² Some opinions face such “college” issues as dual-degree programs;²³ an unaccredited college;²⁴ a child’s choice of private, rather than public, schools;²⁵ and whether a community college course during high school qualifies as enrolling in college after graduation.²⁶ Echoing § 452.340.5, a general theme is whether the child “continues” to attend college so child support “shall continue.”²⁷

Out of the 140 opinions, only one case addresses child support for vocational education.²⁸ In Wilkins v. Wilkins,²⁹ the child began a 60-week “Heating, Air-Conditioning and Refrigeration Mechanics” program at a private technical school.³⁰ The school did not use a semester format but had consecutive 10-week phases year-round with no breaks or summer vacation.³¹ The child completed the HVAC “diploma” program in 60 weeks but did not attend any programs for 10 weeks.³² The child then completed a 30-week “HVAC associate degree program.”³³ The father filed a motion to terminate child support based on noncompliance with § 552.340.5.³⁴ The circuit court ruled that child support continued during the first 60-week diploma program, but not for the 30-week program.³⁵

The Court of Appeals reversed the decision, ruling that the child complied with the continuous enrollment requirements of § 452.340.5.³⁶ The court recognized that “§ 452.340.5 does not explicitly address vocational settings that do not employ traditional semester breaks.”³⁷ The court ruled that, for higher education, the subsection contemplates a semester-long break, which should also apply to vocational education.³⁸ The court emphasized the subsection’s intent to treat vocational and college education equally and the policy of liberally construing “continuous enrollment.”³⁹ The court held that the child was continuously enrolled until the end of the second 30-week program, so the obligation for child support continued through both programs.⁴⁰

In the alternative, the Court of Appeals held that any failure of continuous enrollment was temporary. In an earlier decision, Harris v. William,⁴¹ the court addressed a child’s brief attendance at the same technical school as in the Wilkins case, interrupted by six months in the National Guard, followed by attendance at a local community college.⁴² In Harris, the court had waived the continuous-enrollment requirement based on the “manifest circumstances” doctrine: (1) interruption of enrollment was temporary; (2) there was evident intention to re-enroll; and (3) “manifest circumstances” beyond the child’s control, prevented continuous enrollment.⁴³

Statute vs. caselaw

The Wilkins case ruling appears fair and just, considering the oft-stated purpose of § 452.340.5 to encourage children to pursue postsecondary education.⁴⁴ But § 452.340.5 has many plain requirements: completing at least 12 credit hours each semester with grades sufficient to re-enroll; notification to parents of grades, courses, and credits; not failing half of the courses in a semester; and all the other requirements in the subsection.

Based on the legislature’s specific requirements, courts often enforce the plain language of § 452.340.5.⁴⁵ The plain language does give approaches for those vocational education programs that follow college-like formats. State Technical College of Missouri in Linn, the 12 community colleges, and some other colleges do follow the traditional structure of semesters, courses, credit hours, grades, etc. for many programs.⁴⁶ It should be emphasized that they are already within the statutory definition of “higher education” by simply being a “community college, college or university at which the child attends classes regularly.”⁴⁷

But for many “vocational education” programs, enforcing some of the plain language of the subsection is impossible. The complete definition of “vocational education” in § 452.340.5 is “any postsecondary training or schooling for which the student is assessed a fee and attends classes regularly.” The subsection intends that child support continue for non-traditional education, by covering “any” postsecondary “training” or “schooling” with a “fee” and regular “classes.” Missouri has nearly 500 “proprietary” (both for-profit and not-for-profit) schools offering 1,155 postsecondary certificates or degrees in 36 different career sectors, such as health care, information technology, transportation, aviation, and criminal justice.⁴⁸ A list of programs is available on the Missouri Department of Higher Education and Workforce Development’s website.⁴⁹ Many of these programs, according to the department, are “Certificate < 1 semester.”⁵⁰ This general category understates the vast diversity of vocational education. According to Accredited Schools Online, “[m]any vocational school students earn a certificate or diploma in only three months. However, associate degrees generally require two years.”⁵¹ Vocational schools have “career-specific,” “hands-on” training in classrooms and job sites, so students may “practice skills and network with potential employers.”⁵² Missouri’s state-coordinated apprentice program allows combining a paid job with “related technical education,” which may be at a technical school or an apprenticeship training school.⁵³ Missouri has about 17 “bootcamps,” programs lasting about three to six months, with 80% focused on computer science generally (many of those on coding).⁵⁴

For these vocational education programs, the caselaw and text of § 452.340.5 give little guidance about child support. Trial judges need to know the rules to draft orders (and consider contempt and enforcement proceedings), so that a vocational-education support award is “sufficiently definite to protect the complaining party and at the same time not be so general as to unjustly circumscribe the rights of the party enjoined.”⁵⁵ Lawyers do not now have concepts to advise their clients (as shown by the fact that experienced practitioners who write the standard resources about family law hardly even mention vocational education.⁵⁶ State enforcers of child support also would benefit from clarity as they consider and modify child support orders.⁵⁷ Missouri parents and children deserve to know their legal obligations. Now, judges, lawyers, administrators, and parties must guess about many of the rules for child support for vocational education.

Concepts to determine and enforce child support for vocational education

The General Assembly could provide general policy for orders about vocational education child support by amending § 452.340.5. A general policy statement could re-state the original purpose of treating vocational education the same as higher education, with the only exception being where the structure of the vocational program prevents a statutory requirement. A general policy amendment could be as simple as one (long) sentence.⁵⁸ Beyond that, the programs are too diverse for a legislative fine-tuning of details like the legislature has done with the many amendments to § 452.340.5 about higher education.

Whether or not the General Assembly states a general policy, courts must resolve cases about child support for vocational education by interpreting and applying § 452.340.5. The concepts and approaches for interpretation should be as follows:

Strictly enforced statutory rules

Generally, as clear from the original § 452.340.5, the rules for child support for vocational education should parallel those for higher education. Some of the rules for higher education should normally be strictly enforced for vocational education, including:

• The Oct. 1 deadline (to enroll after high school) should apply equally to vocational as to higher education (with the opportunity for court waiver). Thus, the child and the parents can know the funding for vocational education and the child support obligation.
• The notification of parents (at the initial enrollment and the beginning of each phase or program) should apply to vocational education. Again, the paying parent(s) deserves to know. The developed “college” caselaw on notification will benefit all concerned.
• The requirement for “official documents” should apply to vocational education. Again, the caselaw provides guidance.
• The “continuous education” requirement should apply to vocational education. Child support should continue if education continues. The only modification is that the “semester-by-semester” approach for higher education should be “phase-by-phase” or “program-by-program” for vocational education.

Impossible-to-satisfy statutory rules

A vocational student cannot satisfy some of the rules in § 452.340.5. The subsection’s specific provisions about the number of credit hours per semester, failing grades, and earned credits cannot apply to many programs of vocational education. Courts should apply the “manifest circumstances” doctrine to excuse these requirements beyond the child’s control. More generally, courts should apply the “manifest circumstance” doctrine where the structure of the child’s program at the vocational education institution prevents meeting the requirements of § 452.340.5.

These suggestions expand on the Court of Appeals’ approach in the Wilkins case. It is true that they lack the specificity of § 452.340.5’s guidance about college education. But vocational programs are diverse, lacking a set, traditional structure seen in stereotypical college education. These suggestions for improvement should prevent, or at least lessen, the cost of case-by-case development for all those concerned, particularly for the child who needs the support. They also should help lawyers (and their clients) when drafting and negotiating separation agreements and parenting plans. By focusing on these suggestions, courts can promote child support for vocational education.           

Conclusion

In 2019, Gov. Mike Parson signed an executive order changing the “Department of Higher Education” into the “Department of Higher Education and Workforce Development.”⁵⁹ The purpose was to promote “post-secondary talent development” for Missouri citizens.⁶⁰ Later that year, another executive order created an “Office of Apprenticeship and Work-Based Learning” within the department.⁶¹ The purpose was to “enhance education and workforce training in the State to foster talent and skills in its workforce.”⁶² These executive orders – issued just before the pandemic – immediately faced Missouri’s large job losses in 2020, but the Missouri Economic Research and Information Center projects a high growth rate in vocational jobs for the next decade.⁶³

Likewise, the suggestions for improvement can help all concerned to understand their rights and obligations about child support for vocational education, and thus fulfill the purpose of § 452.340.5 to promote the post-secondary education of Missouri’s youth.

Note: According to the Missouri Department of Higher Education & Workforce Development, the state’s higher education institutions include 13 public four-year universities, 14 public two-year colleges, 24 independent colleges, 11 specialized/technical colleges, 17 theological institutions, and more than 150 proprietary and private career schools.   

 
ENDNOTES

1 Megan B. Benton is an associate circuit judge in the 6th Judicial Circuit in Platte County. Licensed in Missouri and California, she previously was an assistant prosecuting attorney and an associate in a Kansas City litigation firm, after clerking for two years on the Superior Court of Los Angeles County.

2 See CTE Factsheet, https://dese.mo.gov/media/pdf/ccr-career-ed-fact-sheet (last visited Oct. 5, 2022); Career and Technical Education, https://dese.mo.gov/college-career-readiness/career-education (last visited Oct. 5, 2022). This article uses the term “vocational education” because it is used in the child support statute and the Missouri cases.

3 Missouri Workforce 2021 Employer Survey Report, at 2 (Dept. of Higher Ed. & Workforce Dev. Dec. 2021), available at https://meric.mo.gov/media/pdf/missouri-workforce-2021-employer-survey-report (last visited Oct. 5, 2022).

4 Id. at 9.

5 Section 452.340.5, RSMo 2016.

6 Section 452.340.1, RSMo 2016.

7 Schubert v. Schubert, 366 S.W.3d 55, 66 (Mo. App. E.D. 2012) (citing § 452.340.3(5)).

8 Section 452.340.5, RSMo 2016.

9 750 Ill. Comp. Stat. Ann. 5/513 (West 2022); Iowa Code Ann. §§ 598.1(8), 598.21(4) (West 2022).

10 National Conference of State Legislatures, “Termination of Child Support,” https://www.ncsl.org/research/human-services/termination-of-child-support-age-of-majority.aspx (last visited Oct. 5, 2022). See Van Camp v. Van Camp, 969 S.W.2d 184, 186 (Ark. 1998); Kan. Stat. Ann. §23-3001(b)(1); Stevens v. Stevens, 798 S.W.2d 136, 139 (Ky. 1990); Zetterman v. Zetterman, 512 N.W.2d 622, 625 (Neb. 1994); Holleyman v. Holleyman, 78 P.3d 921, 925-26 (Okla. 2003); Nash v. Mulle, 846 S.W.2d 803, 806 (Tenn. 1993) (court can order a trust fund for education). In Missouri, the circuit court can order marital property be held in trust for college education. Rich v. Rich, 871 S.W.2d 618, 625-26 (Mo. App. E.D. 1994). Missouri parties may contract for child support beyond the minimum requirements of § 452.340.5. Shands v. Shands, 237 S.W.3d 597, 600 (Mo. App. S.D. 2007). But if there is a conflict between a judgment of dissolution and § 452.340.5, the statute controls. Id.

11 1988 Mo. Laws 957 (H.B. 1272, 1273 & 1274).

12 1989 Mo. Laws 1168 (1st Ex. Sess., H.B. 2); 1990 Mo. Laws 1086-87 (S.B. 834) (adding only one sentence that, “If the circumstances of the child manifestly dictate, the court may waive the October first deadline for enrollment”).

13 1997 Mo. Laws 1160 (S.B. 361).

14 1998 Mo. Laws 1598-99 (S.B. 910).

15 Id.

16 2007 Mo. Laws 735 (S.B. 25). The 2007 amendment also repealed a short-lived 2005 amendment. 2005 Mo. Laws 1495 (S.B. 420 & 344).

17 In re Marriage of Kohring, 999 S.W.2d 228, 233 (Mo. banc 1999) (requiring unmarried, divorced, or legally separated parents to pay child support for college expenses does not violate equal protection; § 452.340.5 rationally advances legitimate state interest by requiring financially capable parents to support their children pursuing higher education); Leahy v. Leahy, 858 S.W.2d 221, 229-30 (Mo. banc 1993) (noting equal protection challenge to § 452.340.5 was abandoned on appeal, but addressing related constitutional issues).

18 Many of these cases are summarized in James H. Young & Michelle E. Jakobe, Child Support and Maintenance, I Mo. Family Law §§ 10.41, 10.59, at 10-42 to 10-49, 10-71 to 10-74 (MoBar 7th ed. 2012, Supps. 2014, 2019); Dana M. Outlaw, Modification of Decrees, id., § 26.16, at 26-32 to 26-35: Nancy A. Garris, Family Law, 21 Mo. Prac., § 14:9, at 325-29 (2022).

19 In re Marriage of Kohring, 999 S.W.2d at 233 (a “semester-by-semester” basis). See In re Marriage of Noland-Vance, 344 S.W.3d 233, 240 (Mo. App. S.D. 2011); Brown v. Brown, 370 S.W.3d 684, 688 (Mo. App. W.D. 2012); Peine v. Peine, 200 S.W.3d 567, 572 (Mo. App. W.D. 2006); Windsor v. Windsor, 166 S.W.3d 623, 630 (Mo. App. W.D. 2005). Accordingly, noncompliance with § 452.340.5 does not necessarily result in emancipation of the child or the end of child support for future semesters. Librach v. Librach, 575 S.W.3d 300, 310 (Mo. App. E.D. 2019).

20 Halper v. Halper, 604 S.W.3d 904, 910-11 (Mo. App. E.D. 2020) (summarizing cases); Schubert, 366 S.W.3d at 67 (summarizing cases); Div. of Fam. Servs. ex rel. Lair v. Portincaso, 347 S.W.3d 596, 599 (Mo. App. E.D. 2011) (one parent can send notice for child); Jansen v. Westrich, 95 S.W.3d 214, 218-19 (Mo. App. S.D. 2003) (sending only grades, without the other statutory details, is not enough to continue child support for college). The obligated parent must raise these issues as an affirmative defense and has the burden of proof. Craig v. Craig, 644 S.W.3d 857, 861-62 (Mo. App. W.D. 2022).

21 Le v. Le, 638 S.W.3d 583, 590 (Mo. App. E.D. 2021); Bryant v. Bryant, 218 S.W.3d 565, 571 (Mo. App. E.D. 2007); Klein v. Klein, 475 S.W.3d 194, 199 (Mo. App. W.D. 2015); Rozelle v. Rozelle, 320 S.W.3d 225, 229 (Mo. App. E.D. 2010) (court has discretion to continue child support despite a full-time student’s not earning 12 credit hours several semesters); Paden v. Kerns, 318 S.W.3d 304, 308 (Mo. App. W.D. 2010) (“W” withdrawal grade treated the same as “F” failure grade).

22 Pecher v. Pecher, 398 S.W.3d 580, 587-88 (Mo. App. W.D. 2013); In re Marriage of Maggi and Wood, 244 S.W.3d 274, 278 (Mo. App. S.D. 2008) (summarizing cases).

23 Bryant, 218 S.W.3d at 571-72.

24 State ex rel. Div. of Child Support Enf’t v. Gosney, 928 S.W.2d 892, 894 (Mo. App. E.D. 1996).

25 Jones v. Jones, 958 S.W.2d 607, 613-14 (Mo. App. W.D. 1998); Shiflett v. Shiflett, 954 S.W.2d 489, 495 (Mo. App. W.D. 1997).

26 State ex rel. Div. of Fam. Servs. v. Hellems, 948 S.W.2d 178, 181 (Mo. App. E.D. 1997).

27 Section 452.340.5, RSMo 2016.

28 Cf. McIlroy v. Simmons, 832 S.W.2d 949, 951 (Mo. App. E.D. 1992) (court did not have to answer whether Italian “Technical Institute of Accounting” was vocational education institution because it relied on waiver of Oct. 1 deadline for enrollment before later attendance at a university); In re Marriage of Copeland, 850 S.W.2d 422, 425 (Mo. App. E.D. 1993) (program at vocational-technical school, before passing GED test, was “secondary school program of instruction” under § 452.340.5; child later enrolled in junior college).

29 300 S.W.3d 594 (Mo. App. E.D. 2009),

30 Id. at 596.

31 Id.

32 Id.

33 Id.

34 Id. at 596-97.

35 Id. at 597.

36 Id. at 598-99.

37 Id. at 598.

38 Id.

39 Id. at 599. Subsection 452.340.5 is “construed liberally” to encourage children to pursue postsecondary education. Pecher, 398 S.W.3d at 587.

40 Wilkins, 300 S.W.3d at 599.

41 Harris v. Williams, 72 S.W.3d 621 (Mo. App E.D. 2002).

42 Id. at 625.

43 Id. at 624. According to Westlaw and Fastcase, about 24 cases have considered the manifest circumstances doctrine in interpreting § 452.340.5 for “college” higher education.

44 Pecher, 398 S.W.3d at 587; Schubert, 366 S.W.3d at 67.

45 Cox v. Cox, 384 S.W.3d 298, 304-05 (Mo. App. S.D. 2012) (“the plain and unambiguous language of § 452.340.5 required Son to achieve grades sufficient to reenroll at MSU for the Fall 2010 semester in order to remain eligible for continued child support. Accordingly, the statute requires no construction, liberal or otherwise.). See also Klein, 475 S.W.3d at 199; Schubert, 366 S.W.3d at 69.

46 Missouri Department of Elementary and Secondary Education, Career and Technical Education, https://dese.mo.gov/college-career-readiness/career-education (last visited Oct. 5, 2022); “College Catalog,” State Technical College of Missouri, https://www.statetechmo.edu/college-catalog (last visited Oct. 5, 2022).

47 Section 452.340.5, RSMo 2016.

48 Coordinating Board for Higher Education, Proprietary School Certification Program Annual Report, at 1, 3 (Dec. 8, 2021) (available at https://dhewd.mo.gov/cbhe/boardbook/documents/Tab201208.pdf (last visited Oct. 5, 2022).

49 Missouri Department of Higher Education and Workforce Development, College and Degree Search, https://web.dhewd.mo.gov/collegedegreesearch/collegesearch.faces (under “college,” select “Professional and Technical Schools” and “Proprietary Schools,” and search) (last visited Oct. 5, 2022). The entry for each school shows whether it is accredited. For details about accreditation, go to “Accreditation,” https://dhewd.mo.gov/psc/Accreditation.htm (last visited Oct. 5, 2022).

50 Id. 

51 Accredited Schools Online, The Ultimate Guide to Trade and Vocational Schools, https://www.accreditedschoolsonline.org/vocational-trade-school (last visited Oct. 5, 2022).

52 Id.

53 Missouri Office of Workforce Development, Apprenticeship Missouri, https://jobs.mo.gov/content/moapprenticeships (last visited Oct. 5, 2022). Whether or not the wages themselves might end child support is beyond the scope of this article. See generally Colabianchi v. Colabianchi, 646 S.W.2d 61, 65-66 (Mo. banc 1983) (holding court properly exercised discretion in ending support for child working full-time, at minimum wage, due to “the financial resources of the child” under § 452.340.1) (citing In re Marriage of Berkbigler, 560 S.W.2d 36, 39 (Mo.App.1977) (upholding denial of child support for a partly-employed child working 20 to 40 hours a week at minimum wage, while attending a fashion-design course at a career school)).

54 From bankrate.com (https://www.bankrate.com/loans/student-loans/alternatives-to-college-degree) (defining coding boot camp as a short-term program that gives students the skills necessary to enter a career in computer science.  These programs typically last for a few months and cost several thousand dollars, but often they can help with job placement.  Plus, these programs are an easy way to network with other professionals and are much cheaper than a four-year or even two-year computer science degree) (last visited Oct. 5, 2022).  See also C.A. Arbeit, A. Bentz, E.F. Cataldi, & H. Sanders, Alternative and Independent: The Universe of Technology-Related “Bootcamps.” RTI Press Pub. No. RR-0033-1902 (2019), (available at https://www.rti.org/rti-press-publication/alternative-and-independent/fulltext.pdf) (last visited Oct. 5, 2022) (identifying 17 bootcamps in Missouri (p. 32) – Cape Girardeau (1); Kansas City (3); St. Louis (13); explaining average lengths of bootcamps (p. 11, figure 5) – 16.5 weeks for all programs; 24.3 weeks for part-time programs; and 13.1 weeks for full-time programs).

55 Landewee v. Landewee, 515 S.W.3d 691, 696 (Mo. banc 2017) (quoting State ex rel. Mo. Dam and Reservoir Safety Council v. Rocky Ridge Ranch Prop. Owners Ass'n, 950 S.W.2d 925, 929 (Mo. App. E.D. 1997)). For the model format for decrees awarding child support for postsecondary education, see Carlson v. Carlson, 275 S.W.3d 356, 365 (Mo App. W.D. 2008) (citing Echele v. Echele, 782 S.W.2d 430, 437 (Mo. App. E.D. 1989)); Scott A. Robbins, “Parenting Plan—Form,” I Mo. Family Law § 8.11, at 8-35 to 8-38 (MoBar 7th ed. 2012, Supps. 2014, 2019); Nancy A. Garris, “Joint parenting plan—Form,” 21 Mo. Prac., § 29:8, at 847-50 (2022).

56 Specifically, the Missouri Bar CLE’s Family Law and West’s Missouri Practice: Family Law, fully cited in footnotes 16 and 51 above.

57 See, e.g., Henderson v. Dept. of Soc. Servs., Family Support Div., 626 S.W.3d 267, 271-72 (Mo. App. W.D. 2021) (reviewing Family Support Division’s order increasing child support to continue it for college, by analyzing § 452.340.5).

58 The General Assembly could add at the end of § 452.340.5 this sentence:

If a child is enrolled in an institution of vocational education and cannot comply with a specific provision of this subsection due to the structure of the child’s program at the institution of vocational education, the parental support obligation shall continue until the child completes his or her vocational education, or until the child reaches the age of twenty-one, whichever first occurs, so long as all other requirements of this subsection are complied with and the child meets all requirements of the program set by the institution of vocational education.

This approach parallels the approach taken for developmentally disabled students in the current last sentence of § 452.340.5.

59 Executive Order 19-03, Gov. Mike Parson (Jan. 17, 2019, eff. Aug. 28, 2019), available at https://www.sos.mo.gov/library/reference/orders/2019/eo3 (last visited Oct. 5, 2022).

60 Id.

61 Executive Order 19-20, Gov. Mike Parson (Nov. 12, 2019), available at https://www.sos.mo.gov/library/reference/orders/2019/eo20 (last visited Oct. 5, 2022).

62 Id.

63 Missouri 2020-2030 Projected Growth and Recovery, at 1-2 (Dept. of Higher Ed. & Workforce Dev. Sept. 2022), available at https://meric.mo.gov/media/pdf/missouri-2020-2030-projected-growth-and-recovery (last visited Oct. 5, 2022).