>It’s a very odd gap in statutory coverage for a very vulnerable population.

I agree. Good catch! I would be interested in hearing what DOE or DHHS would have to say about that gap. It is likely they will both default to well, traditionally X covers it as it is attached to the school.

My view is that is wrong and it should be codified in our statutes.

Unfortunately there are gaps and competing laws throughout all the states as legislators add and remove stuff piecemeal. I would love to see an initiative, both local and federal, to review what is on our books. Even if it takes five years-review a few sections a week to identify conflicts, while using the last week of the month to piece together fixes. Have a couple special sessions from the legislative bodies to bless off on them before final approval.