Can schools disclose education records to community-based organizations performing outsourced tutoring programs using the school official exception?

Yes.  If a school chooses to outsource to a community-based organization a tutoring program that it would otherwise use school employees to provide, then the school may disclose the education records without the consent of the parents or eligible students under the school official exception.  However, the community-based organization must meet all the requirements in § 99.31(a)(1)(i)(B) to be considered a school official before the school may disclose the education records to the organization.