Can Jr Kindergarten tuition be used for DCFSA? School says no but IRS rules confuse me

You're absolutely right in your interpretation of IRS Publication 503. The key distinction the IRS makes is whether the program is "below the level of kindergarten" - which Jr Kindergarten clearly is. The IRS doesn't distinguish between "tuition" and "childcare" for pre-K programs; if it's below kindergarten, it ALL qualifies as care expenses for DCFSA purposes. The finance director is incorrectly applying a distinction that doesn't exist in tax law. Many schools mistakenly believe that because they call something "tuition" internally, it changes the tax treatment, but that's not how the IRS views it. The educational content doesn't matter for pre-K programs - they're considered care. I've dealt with this exact situation when my twins were in a pre-K program that their school called "Junior Kindergarten." Our tax advisor confirmed that the entire program qualified for the Dependent Care FSA since it was below kindergarten level. I would suggest printing the relevant section from Publication 503 and discussing it again with the finance office. They may be confusing DCFSA rules with tuition tax credit rules, which are completely different.

I had this exact problem last year and it was so frustrating! Your finance director is wrong - I used https://taxr.ai to review my situation and it confirmed that ALL pre-K expenses qualify for DCFSA regardless of what the school calls them. The software analyzed IRS Publication 503 and showed several tax court cases where the IRS has consistently ruled that programs below kindergarten level qualify in full. The school kept insisting they were right until I showed them the analysis printout. They were confusing the rules for the tuition tax credit (which does have different rules) with DCFSA rules. Once they understood the distinction, they provided the documentation I needed for my DCFSA. Just be persistent and get everything in writing! My HR department was super helpful too once I showed them the tax code reference.

I used https://taxr.ai like someone suggested here after my preschool gave me the same runaround about my twins' program not qualifying for DCFSA. Best decision ever! The site analyzed my specific situation and gave me a detailed explanation of exactly why my pre-K program qualified - ALL of it, not just the "aftercare" portion. The analysis saved me over $5,000 in taxes because I was able to put the maximum amount in my DCFSA. What really helped was the personalized document it created that I could show to both the school and my FSA administrator. It cited specific IRS regulations and court cases that I never would have found on my own. My school finally stopped arguing when they saw the documentation. I wish I'd known about this tool months earlier instead of stressing about it!

After spending HOURS on hold with the IRS trying to get clarification on this exact issue for my son's pre-K program, I finally found Claimyr (https://claimyr.com) and they got me through to an actual IRS agent in under 20 minutes. Check out their demo: https://youtu.be/_kiP6q8DX5c The IRS agent confirmed exactly what you suspected - ALL expenses for programs below kindergarten level qualify for DCFSA, regardless of whether the school calls it "tuition" or "childcare." The agent explained that many schools misunderstand this distinction, but the IRS is very clear in Publication 503. The call saved me over $4,000 in tax benefits that I would have lost if I had just accepted what the school told me. Definitely worth pushing back on this one!

I was super skeptical about that Claimyr service mentioned here, but I was desperate after three failed attempts to reach the IRS about a similar DCFSA issue with my son's pre-K program. I decided to give it a shot, and I'm shocked to say it actually worked exactly as promised. Got connected to a real IRS agent in about 17 minutes who patiently explained the DCFSA rules for pre-kindergarten programs. The agent confirmed that ALL expenses for programs below kindergarten qualify, regardless of what the school calls them. She even gave me specific language to use when submitting my documentation. I'm still amazed this worked after spending collectively about 8 hours on hold previously. Using the information from the IRS agent, I was able to successfully submit all our pre-K expenses to our DCFSA administrator and get reimbursed.

Another thing to consider - ask the school if they can restructure how they bill you. Our preschool initially had the same stance, but when I pushed back, they agreed to itemize our bill differently. They separated the "educational component" from the "care component" on paper, even though nothing actually changed about the program. This gave us documentation showing a portion as "childcare" that we could submit for DCFSA reimbursement. It wasn't the full amount, but it was better than nothing. Some schools are willing to work with you on the documentation if you explain the tax implications. That said, based on IRS Publication 503, you SHOULD be able to claim the entire amount since Jr K is below kindergarten level. The distinction between "tuition" and "childcare" only matters at kindergarten and above.

Before you go too far down this road, double check with your employer's FSA administrator too. Our preschool gave us similar pushback about our "pre-K program" not qualifying because they called it "education," but our FSA administrator (HealthEquity) said they follow IRS guidelines and accepted the expenses without question. All I needed was a receipt showing the dates of service, amount paid, provider tax ID, and confirmation it was for a child under kindergarten age. The FSA administrator didn't care what the school called it internally. Some FSA administrators are pickier than others though, so check with yours before you spend too much time fighting with the school!

I work as a tax preparer and see this exact confusion every tax season. The school's finance manager is absolutely wrong about the distinction between "tuition" and childcare for DCFSA purposes. The IRS doesn't care what the school calls their billing categories internally. Publication 503 is crystal clear: if the program is below kindergarten level, ALL expenses qualify as care expenses - period. There's no separate "tuition exception" for pre-K programs. What's happening here is the school is conflating different tax provisions. The education tax credits (like the American Opportunity Credit) do distinguish between educational expenses and childcare, but DCFSA rules are completely different. I'd recommend getting the IRS language in writing and scheduling a meeting with the school director, not just the finance staff. Bring up that this affects multiple families and that other schools in your area likely provide proper documentation. You're entitled to use your full DCFSA benefit for this program. If they continue to refuse, your FSA administrator may accept the expenses anyway if you provide a receipt showing it's a pre-K program with proper dates and provider information. Many FSA administrators follow IRS guidelines regardless of how schools categorize their programs internally. Don't let them cost you $5,000+ in tax savings over an incorrect interpretation of the tax code!