Wash. Rev. Code » Title 26 · Chapter 26.19
Revised Code of Washington

Wash. Rev. Code § 26.19.090 (2026)

Standards for postsecondary educational support awards

✓ current as of May 2026
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(1) The child support schedule shall be advisory and not mandatory for postsecondary educational support.
(2) When considering whether to order support for postsecondary educational expenses, the court shall determine whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life. The court shall exercise its discretion when determining whether and for how long to award postsecondary educational support based upon consideration of factors that include but are not limited to the following: Age of the child; the child's needs; the expectations of the parties for their children when the parents were together; the child's prospects, desires, aptitudes, abilities or disabilities; the nature of the postsecondary education sought; and the parents' level of education, standard of living, and current and future resources. Also to be considered are the amount and type of support that the child would have been afforded if the parents had stayed together.
(3) The child must enroll in an accredited academic or vocational school, must be actively pursuing a course of study commensurate with the child's vocational goals, and must be in good academic standing as defined by the institution. The court-ordered postsecondary educational support shall be automatically suspended during the period or periods the child fails to comply with these conditions.
(4) The child shall also make available all academic records and grades to both parents as a condition of receiving postsecondary educational support. Each parent shall have full and equal access to the postsecondary education records as provided in RCW 26.09.225.
(5) The court shall not order the payment of postsecondary educational expenses beyond the child's twenty-third birthday, except for exceptional circumstances, such as mental, physical, or emotional disabilities.
(6) The court shall direct that either or both parents' payments for postsecondary educational expenses be made directly to the educational institution if feasible. If direct payments are not feasible, then the court in its discretion may order that either or both parents' payments be made directly to the child if the child does not reside with either parent. If the child resides with one of the parents the court may direct that the parent making the support transfer payments make the payments to the child or to the parent who has been receiving the support transfer payments.
[ 1991 sp.s. c 28 s 7; 1990 1st ex.s. c 2 s 9.]

Notes:

Severability—Effective date—Captions not law—1991 sp.s. c 28: See notes following RCW 26.09.100.
Effective dates—Severability—1990 1st ex.s. c 2: See notes following RCW 26.09.100.
Notes of Decisions
Cited in 52 cases (7 in the last 5 years), 1993–2025 · leading case: In re the Marriage of Cota, 312 P.3d 695 (Wash. Ct. App. 2013).
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In re the Marriage of Cota, 312 P.3d 695 (Wash. Ct. App. 2013). · cites it 15× “¶21 Anthony argues that the record does not show that the trial court had properly considered the factors in RCW 26.19.090(2). However, the parties presented evidence and argument regarding the factors, and the trial court stated that it had reviewed the factors to determine…”
In re the Marriage of Schneider, 268 P.3d 215 (Wash. 2011). · cites it 7× “RCW 26.19.090. Educational expenses for minor children are also available in a child support award.”
Goude v. Lieser, 152 Wash. App. 784 (Wash. Ct. App. 2009). · cites it 10× “Lieser contends the trial court erred by not considering several postsecondary support factors in RCW 26.19.090 and in utilizing the child support schedule in calculating post-secondary support.”
Newell v. Newell, 72 P.3d 1130 (Wash. Ct. App. 2003). · cites it 10× “In considering whether to award postsecondary educational support, the court must determine "whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life".”
In re the Marriage of Newell, 117 Wash. App. 711 (Wash. Ct. App. 2003). · cites it 9× “In considering whether to award postsecondary educational support, the court must determine “whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). · cites it 6× “” There is no such requirement for written findings in RCW 26.19.090. Rather, it requires that the court “determine” whether the child is dependent upon the parents and exercise its discretion “upon consideration” of relevant factors.”
In re the Marriage of Daubert, 99 P.3d 401 (Wash. Ct. App. 2004). · cites it 6× “The balance of RCW 26.19.090 provides: (2) When considering whether to order support for post-secondary educational expenses, the court shall determine whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
In Re Marriage of Daubert, 99 P.3d 401 (Wash. Ct. App. 2004). · cites it 6× “The balance of RCW 26.19.090 provides: (2) When considering whether to order support for postsecondary educational expenses, the court shall determine whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
In Re the Marriage of Kelly, 934 P.2d 1218 (Wash. Ct. App. 1997). · cites it 6× “Ideally, the court should have been more explicit in its consideration of RCW 26.19.090’s factors. But because *794 Hannan has not shown that the trial court failed to consider them, we affirm the postsecondary support order.”
In re the Marriage of Jess, 136 Wash. App. 922 (Wash. Ct. App. 2007). · cites it 6× “¶8 RCW 26.19.090 sets conditions for receiving postsecondary educational support.”
In Re the Marriage of Shellenberger, 906 P.2d 968 (Wash. Ct. App. 1995). · cites it 4× “The trial court’s order and RCW 26.19.090 merely suspend the obligation during periods of noncompliance by the children.”
In Re Goude, 219 P.3d 717 (Wash. Ct. App. 2009). · cites it 10× “Lieser contends the trial court erred by not considering several post-secondary support factors in RCW 26.19.090, and in utilizing the child support schedule in calculating post-secondary support.”
Show all 52 citing cases →
— Wash. Rev. Code § 26.19.090(1) — 12 cases
In re the Marriage of Daubert, 99 P.3d 401 (Wash. Ct. App. 2004). “The balance of RCW 26.19.090 provides: (2) When considering whether to order support for post-secondary educational expenses, the court shall determine whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
In Re Marriage of Daubert, 99 P.3d 401 (Wash. Ct. App. 2004). “The balance of RCW 26.19.090 provides: (2) When considering whether to order support for postsecondary educational expenses, the court shall determine whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
Goude v. Lieser, 152 Wash. App. 784 (Wash. Ct. App. 2009). “Lieser contends the trial court erred by not considering several postsecondary support factors in RCW 26.19.090 and in utilizing the child support schedule in calculating post-secondary support.”
In re the Marriage of Newell, 117 Wash. App. 711 (Wash. Ct. App. 2003). “In considering whether to award postsecondary educational support, the court must determine “whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
Newell v. Newell, 72 P.3d 1130 (Wash. Ct. App. 2003). “In considering whether to award postsecondary educational support, the court must determine "whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life".”
— Wash. Rev. Code § 26.19.090(2) — 36 cases
In re the Marriage of Cota, 312 P.3d 695 (Wash. Ct. App. 2013). “¶21 Anthony argues that the record does not show that the trial court had properly considered the factors in RCW 26.19.090(2). However, the parties presented evidence and argument regarding the factors, and the trial court stated that it had reviewed the factors to determine…”
Newell v. Newell, 72 P.3d 1130 (Wash. Ct. App. 2003). “In considering whether to award postsecondary educational support, the court must determine "whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life".”
Goude v. Lieser, 152 Wash. App. 784 (Wash. Ct. App. 2009). “Lieser contends the trial court erred by not considering several postsecondary support factors in RCW 26.19.090 and in utilizing the child support schedule in calculating post-secondary support.”
In re the Marriage of Newell, 117 Wash. App. 711 (Wash. Ct. App. 2003). “In considering whether to award postsecondary educational support, the court must determine “whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). “” There is no such requirement for written findings in RCW 26.19.090. Rather, it requires that the court “determine” whether the child is dependent upon the parents and exercise its discretion “upon consideration” of relevant factors.”
— Wash. Rev. Code § 26.19.090(3) — 3 cases
In Re the Marriage of Kelly, 934 P.2d 1218 (Wash. Ct. App. 1997). “Ideally, the court should have been more explicit in its consideration of RCW 26.19.090’s factors. But because *794 Hannan has not shown that the trial court failed to consider them, we affirm the postsecondary support order.”
In Re The Marriage Of: Virginia Berry v. David Berry (Wash. Ct. App. 2017).
Jesse Finken v. Brianne Finken (Wash. Ct. App. 2017).
— Wash. Rev. Code § 26.19.090(4) — 6 cases
In re the Marriage of Jess, 136 Wash. App. 922 (Wash. Ct. App. 2007). “¶8 RCW 26.19.090 sets conditions for receiving postsecondary educational support.”
In Re the Marriage of Kelly, 934 P.2d 1218 (Wash. Ct. App. 1997). “Ideally, the court should have been more explicit in its consideration of RCW 26.19.090’s factors. But because *794 Hannan has not shown that the trial court failed to consider them, we affirm the postsecondary support order.”
In Re Marriage of Jess, 151 P.3d 240 (Wash. Ct. App. 2007).
In Re: Daryl Lantz, V Dawn Lantz (Wash. Ct. App. 2019).
Stuart Sinsheimer, X-app/resp v. Elizabeth Kruger, App/x-resp (Wash. Ct. App. 2018).
— Wash. Rev. Code § 26.19.090(5) — 7 cases
In re the Marriage of Schneider, 268 P.3d 215 (Wash. 2011). “RCW 26.19.090. Educational expenses for minor children are also available in a child support award.”
In Re the Marriage of Shellenberger, 906 P.2d 968 (Wash. Ct. App. 1995). “The trial court’s order and RCW 26.19.090 merely suspend the obligation during periods of noncompliance by the children.”
In re the Marriage of Sagner, 159 Wash. App. 741 (Wash. Ct. App. 2011).
Sagner v. Sagner, 247 P.3d 444 (Wash. Ct. App. 2011).
In Re The Marriage Of Vernon Blank, V Amanda Blank (Wash. Ct. App. 2014).
— Wash. Rev. Code § 26.19.090(6) — 6 cases
In re the Marriage of Schneider, 268 P.3d 215 (Wash. 2011). “RCW 26.19.090. Educational expenses for minor children are also available in a child support award.”
In re the Marriage of Newell, 117 Wash. App. 711 (Wash. Ct. App. 2003). “In considering whether to award postsecondary educational support, the court must determine “whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life.”
Newell v. Newell, 72 P.3d 1130 (Wash. Ct. App. 2003). “In considering whether to award postsecondary educational support, the court must determine "whether the child is in fact dependent and is relying upon the parents for the reasonable necessities of life".”
In Re the Marriage of Kelly, 934 P.2d 1218 (Wash. Ct. App. 1997). “Ideally, the court should have been more explicit in its consideration of RCW 26.19.090’s factors. But because *794 Hannan has not shown that the trial court failed to consider them, we affirm the postsecondary support order.”
In re the Marriage of: Lane Lehman & Cynthia Lehman (Wash. Ct. App. 2017).
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