ICF and frost protected shallow foundation R-value requirements

Does anyone know if both layers of EPS (exterior/interior) count towards the required R-value in a FPSF. In particular, the vertical R-value needed. Or, is it just the thickness of the exterior portion of the ICF foam that counts.
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The Builders Revised Guide for FPSF PDF does not address using an ICF block explicitly. I used the external insulation then added an energy stick to the form - as my height was in the 24 inch range. (Detailed method).