Report 2012-108 Recommendations and Responses in 2014-041

Report 2012-108: School Safety and Nondiscrimination Laws: Most Local Educational Agencies Do Not Evaluate the Effectiveness of Their Programs, and the State Should Exercise Stronger Leadership

Department Number of Years Reported As Not Fully Implemented Total Recommendations to Department Not Implemented After One Year Not Implemented as of 2013-041 Response Not Implemented as of Most Recent Response
California Department of Education 1 4 3 n/a 3
Los Angeles Unified School District 1 5 4 n/a 2
Sacramento City Unified School District 1 8 6 n/a 4

Recommendation To: Los Angeles Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Los Angeles Unified should monitor school sites to ensure that they implement school safety programs.

Response

- The District submits Exhibit 1, samples of completed biannual Rubric of Implementation, a monitoring tool to ensure that schools implement and assess school safety programs. The Rubric of Implementation was revised to identify the school administrator and school operations coordinators who review the plan for effectiveness.

- The District submits Exhibit 2, the School Operations iSTAR Evidence of Monitoring and Resolution report. This document memorializes the process by which iSTAR bullying reports are reviewed for school site compliance with the 30-day requirement for action and updates, and the 90-day requirement for resolution. The report is shared with the Operations Coordinators at the ESC levels who support the individual schools.

Recommendation To: Los Angeles Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Los Angeles Unified should measure the effectiveness of its school safety programs at both the district and school site levels.

Response

- The District submits Exhibit 3, the revised Bullying and Hazing Policy, to denote 30-day requirements for updates and 90-day requirements for determination of resolution.

- The District submits Exhibit 4, the completed analysis of the bullying prompts on the 2013/14 School Experience Survey. The School Experience Survey queries staff, students, and parents on numerous measures associated with school satisfaction and safety. The 2013/14 version added nine prompts related to bullying. A cluster analysis identifies the prompts that, when grouped, provide a score for a given variable. The data can be disaggregated to the individual school site to inform site administrators, ESC and central office as to the stakeholders' rating of the efficacy of their school's bullying prevention and intervention practices.

- The District submits Exhibit 5, signed copies of Administrators Certification Form of the Safe School Plan for the 2014/15 school year. School administrators electronically certify that they analyze and monitor the efficacy of their Safe School Programs.

- The District submits Exhibit 6, samples of the Bullying Complaint Log. The log is completed by the school site's Bullying Complaint Manager to monitor critical information (dates of report, closure, monitoring, notification to complainant).

- The District submits Exhibit 7, sample iSTAR incident reports, illustrating school compliance with investigating, documenting and resolving incidents of bullying.

Recommendation To: Los Angeles Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Los Angeles Unified should ensure that school sites evaluate the effectiveness of the programs they choose to implement.

Response

- The District has two external protocols by which the schools' evaluative processes are monitored:

o The District submits Exhibit 1, samples of completed biannual Rubric of Implementation (ROI). The Rubric of Implementation is a tool by which the local ESC School Operations Coordinators evaluate the effectiveness of the school's safety programs on a 4-point Likert scale across eight key features.

o The District submits Exhibit 4, the completed analysis of the bullying prompts on the 2013/14 School Experience Survey. The School Experience Survey queries staff, students, and parents on measures associated with school satisfaction and safety. The 2013/14 version added nine prompts related to bullying. The data are disaggregated to the individual school site to inform site administrators, ESC and central office as to the stakeholders' rating of the efficacy of their school's bullying prevention and intervention practices. These data are used in conjunction with iSTAR reports and bullying complaints to determine the effectiveness of school safety efforts on the Rubric of Implementation.

- The District submits Exhibit 3, the revised Bullying and Hazing Policy which denotes 30-day requirements for updates and 90-day requirements for determination of resolution. The Bullying policy directs schools to measure the effectiveness of their programs.

Recommendation To: Los Angeles Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Los Angeles Unified should resolve complaints within 60 calendar days regardless of the complaint process selected.

Response

- Auditor Rosa Reyes approved a 90-day timeline. The District submits Exhibit 3, the revised Bullying and Hazing Policy which denotes 30-day requirements for updates and 90-day requirements for determination of resolution.

- The District submits Exhibit 2, the School Operations iSTAR Evidence of Monitoring and Resolution report. This document memorializes the process by which iSTAR bullying reports are reviewed for school site compliance with the 30-day requirement for action and updates, and the 90-day requirement for resolution. The report is shared with the Operations Coordinators at the ESC levels who support the individual schools.

Recommendation To: Education, Department of

To provide stronger leadership with respect to school safety and nondiscrimination laws, Education, with direction from the superintendent of public instruction, should prioritize the review of parent, student, guardian, or interested party appeals to ensure that the EO office follows state regulations by processing appeals more promptly, notifying LEAs of when appeals are filed, and obtaining the investigation files and other documents when reviewing complaint appeals.

Response

Education continues to review the Uniform Complaint Procedures and update/revise the process on an as-needed basis to remain in compliance with state regulations. Currently, Education is in the process of securing funding to support three positions for the sole purpose of reviewing and processing the appeals, according to regulations, and in compliance with all federal timelines.

Recommendation To: Education, Department of

To provide stronger leadership with respect to school safety and nondiscrimination laws, Education, with direction from the superintendent of public instruction, should use data from the kids survey and reported suspensions and expulsions to evaluate the levels of discrimination, harassment, intimidation, and bullying students encounter and to determine the effectiveness of its own and the LEAs' efforts, and report the results to the Legislature by August 1, 2014.

Response

The bullying-related data for the 2013-14 school year is collected through the California Longitudinal Pupil Achievement Data System (CALPADS). The window for submitting this data closes September 30, 2014. The 2012-13 bullying-related data was posted on Education's DataQuest Web site in February 2014, and was analyzed by Education staff.

Recommendation To: Education, Department of

To provide stronger leadership with respect to school safety and nondiscrimination laws, Education, with direction from the superintendent of public instruction, should within the next six months and annually thereafter, update and replace the resources on its Web site to provide more relevant information on best practices, such as preventing and responding to incidents related to a protected characteristic or that occur through cyberbullying, the U.S. DOE report on state bullying legislation, and best practices in other states, such as the Massachusetts law on LEA staff training requirements.

Response

1. Education staff virtually attended the 2014 Federal Bullying Prevention Summit, "Keeping Kids Safe: Opportunities and Challenges in Bullying Prevention," held August 15, 2014. Twenty-two speakers presented on topics ranging from the state of current bullying prevention research, multi-tiered behavioral frameworks, cyberbullying, and school discipline.

As a result of this training, Education is adding resources from the Bullying and Hate Motivated Behavior Web site that were shared at the 2014 Federal Bullying Prevention Summit to Education's Web site. Resources include:

- Educator's Guide

- 2000 Dear Colleague Letter (DCL) on Disability Harassment

- 2010 DCL on Harassment and Bullying

- 2013 DCL on Bullying of Students with Disabilities

- A Parent's Guide to Cyberbullying

- Campus Pride Fact Sheet

- Campus Pride Index Fact-Sheet

- Community Action Toolkit

- Educators and Community Leaders' Guide

- Facebook Resources for Teachers 2014

- Hazing in View High School Report

- Know Bullying App Postcard

- National College Fair-Program Fact-Sheet

- OSERS Dear Colleague Letter Bullying-8-20-13

- StopBullying.gov Infographic

- StopBullying.gov Training Module

- Supportive School Discipline Initiative Information Sheet

- SBSU videos for Federal Conference

2. Education is adding the following links to Speaker Presentations from the Federal Bullying Prevention Summit onto our Web site:

- Laws and Policies: Sarah Allen PowerPoint

- Media Guidelines: Media Guidelines PowerPoint

- Related High-Risk Behaviors: Darlene Johnson PowerPoint; Elizabeth Allan PowerPoint

3. Education is providing the link to Substance Abuse and Mental Health Services Administration's (SAMHSA) new App, "Know Bullying," revealed at the 2014 Federal Bullying Prevention Summit.

4. Education staff presented a workshop at the 5th Annual Safe Schools Conference, "Bullying 101," July 31, 2014.

Recommendation To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should ensure the impartial resolution of complaints by not assigning the investigation to site administrators or other staff specifically named in the complaint.

Response

Complaints simultaneously filed against school staff AND school site administrator generates two complaint investigations instead of one. Specifically, the school administrator is the investigator of record for the school staff related complaint and the site administrator's supervisor, the Area Superintendent, is the investigator of the allegations against the school administrator.

Additionally, the district has modified its complaint log database to include target dates (30-day and 45-day) within the 60-day investigation period to contact or "check-in" with the designated investigation(s) responsible for resolving the case. These periodic check-in's are avenues to determine current status of complaint investigations and provides an opportunity to offer assistance to the investigator to ensure compliance established deadlines.

Recommendation To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should resolve complaints within 60 calendar days regardless of the complaint process selected.

Response

The District has modified its general complaint acknowledgement letter to reflect the 60-day resolution guideline. The District has also modified its complaint log database to include target dates within the 60-day investigation period to contact or check in with the designated investigator of the case.

These periodic check-in's are avenues to determine current status of complaint investigations and provides an opportunity to offer assistance to the investigator to ensure compliance established deadlines as needed.

Additionally, the Uniform Complaint Procedure Extension form has been updated to include an extended deadline date to complete the investigation.

Recommendation To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should ensure that school sites follow the complaint procedures established in its policies.

Response

The district conducts annual harassment prevention training to site administrators, supervisors, and managers which includes addressing complaints in accordance with district processes and procedures. Staff from the Bullying Prevention Office, Student Behavior Office and the Human Resources Department work closely with school leadership to ensure adherence to related policies.

Recommendation To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should ensure that school site staff complete the training required under its anti-bullying policy.

Response

The district has provided training to all site administrators, except the ones who have been newly hired. There was a site administrator training provided on 8/14/14 and 34 site administrators participated. The Board policy requires that site administrators "develop an annual process for discussing the school district policy on harassment and bullying with students and staff." We are working with site administrators to ensure that they complete this requirement. In the 2013/14 school year, 15 extensive staff trainings were provided. For the 14/15 school year, there have already been 10 school staff trainings scheduled in the upcoming months. The staff training power point has been made available to all site administrators who have been trained to train their school staff.

Recommendation To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should measure the effectiveness of its school safety programs at both the district and school site levels.

Response

One way we will measure the effectiveness of school safety programs is to look at the number of reports of suspected bullying forms received and the number of parent and staff trainings that were provided and compare the data between the school years of 2012/13 and 2013/14.

In 2012/13, there were 67 reports of suspected bullying submitted; but in 13/14, there were only 53 reports received.

In the 2012/13 period, there were 13 parent and staff trainings, but in the 2013/14 period, there were 27 trainings provided.

In addition, select schools implemented a 10-week eVibe Stop and Think and Too Good for Violence anti-bullying curriculum. Included in this program was a pre and post test to measure the effectiveness of the program. We are waiting to receive that data.

Recommendation To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should update its policies and procedures to calculate the state-mandated time limit for resolving complaints in accordance with state regulations.

Response

The District will update current board policies and administrative regulations to reflect the state-mandated time limits for resolving complaints in accordance with state regulations.

Current Status of Recommendations

All Recommendations in 2014-041