Gainesjs,
It would qualify in my state too and they even admitted I had followed all the rules correctly. However it was said there were some "unwritten guiding principals" involved here. I guess what bothers me the most is I have tried to suggest improvements in their program due to my involvement in mounting several state records, but I was ignored.
I know a good lawyer could blow their denial out of the water without ammunition, but it's not worth it.
I see problems down the road if they continue to make the rules up as they go. Someone won't be as nice as me.