BILL ANALYSIS Ó
SENATE COMMITTEE ON EDUCATION
Senator Carol Liu, Chair
2015 - 2016 Regular
Bill No: SB 884
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|Author: |Beall |
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|Version: |March 17, 2016 Hearing |
| |Date: April 6, 2016 |
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|Urgency: |No |Fiscal: |Yes |
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|Consultant:|Lynn Lorber |
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Subject: Special education: procedural safeguards and records
SUMMARY
This bill requires local educational agencies and special
education local plan areas to collect and report specific
information relative to mental health services, requires the
California Department of Education to monitor and compare
specific information, and expands the situations in which
parents must be provided with notice of procedural safeguards
and prior written notification of proposed activities.
BACKGROUND
Existing federal and state law provides that every individual
with exceptional needs who is eligible to receive special
education instruction and related services shall receive that
instruction and those services through a free appropriate public
education in the least restrictive environment. (United States
Code, Title 20, § 1412; Code of Federal Regulations, Title 34, §
300.101 and § 300.114; Education Code § 56040 and § 56040.1)
Existing federal law provides that related services means
transportation, and developmental, corrective, and other
supportive services (including speech-language pathology and
audiology services, interpreting services, psychological
services, physical and occupational therapy, recreation,
including therapeutic recreation, social work services, school
nurse services designed to enable a child with a disability to
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receive a free appropriate public education as described in the
individualized education program of the child, counseling
services, including rehabilitation counseling, orientation and
mobility services, and medical services, except that such
medical services shall be for diagnostic and evaluation purposes
only) as may be required to assist a child with a disability to
benefit from special education, and includes early
identification and assessment of disabling conditions in
children. (United States Code, Title 20 § 1401(26); Code of
Federal Regulations, Title 34 § 300.34)
Individualized education program (IEP)
Existing federal and state law provides that the IEP is a
written statement for each individual with exceptional needs
that is developed, reviewed, and revised by the IEP team, as
specified. Each IEP must include:
a) A statement of the individual's present levels of
academic achievement and functional performance.
b) A statement of measurable annual goals, including
academic and functional goals.
c) A description of the manner in which the progress of the
student toward meeting the annual goals will be measured
and when periodic reports on the progress the student is
making toward meeting the annual goals.
d) A statement of the special education and related
services and supplementary aids and services to be provided
to the student, and a statement of the program
modifications or supports for school personnel that will be
provided.
e) An explanation of the extent to which the student will
not participate with non-disabled students in the regular
class and activities.
f) A statement of individual appropriate accommodations
that are necessary to measure the academic achievement and
functional performance of the student on state and
districtwide assessments.
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g) The projected date for the beginning of the services and
modifications, and the anticipated frequency, location, and
duration of those services and modifications.
h) Beginning with the first individualized education
program (IEP) to be in effect when the student is 16 years
old, appropriate measurable postsecondary goals and
transition services. (United States Code, Title 20 §
1414(d); EC § 56345)
Outcomes for students with exceptional needs
1) Existing federal law requires each state to:
a) Monitor each local educational agency (LEA),
using quantifiable indicators, and qualitative
indicators as needed, in each of the following
priority areas:
b) Provision of a free appropriate public
education (FAPE) in the least restrictive environment.
i) State exercise of general supervisory
authority, including child find, effective
monitoring, the use of resolution sessions,
mediation, voluntary binding arbitration, and a
system of transition services.
ii) Disproportionate representation of
racial and ethnic groups in special education and
related services, to the extent the
representation is the result of inappropriate
identification.
c) As part of the State Performance Plan, to
establish measurable and rigorous targets for the
indicators for each priority area described above.
d) Report annually to the public on the
performance of each LEA on the targets in the state's
performance plan. (United States Code, Title 20 §
1416; 34 Code of Federal Regulations § 300.602)
e) Provide assurances to the United States
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Secretary for Education that it has in effect policies
and procedures to ensure that, among other things, the
state has established goals for the performance of
students with disabilities that are the same as the
State's definition of adequate yearly progress, and
address graduation rates and dropout rates.
(United States Code, Title 20 § 1412)
1) Existing state law requires:
a) The Superintendent of Public Instruction (SPI) to
ensure that student and program performance results
are monitored at the state and local levels by
evaluating student performance against key performance
indicators.
b) The SPI, as part of state monitoring and
enforcement, to use quantifiable indicators, and
qualitative indicators as needed, to adequately
measure performance in the indicators established by
the United States Secretary of Education in the
priority areas described in #1 above. (EC § 56600.6)
Reporting by LEAs
Existing state law requires each special education local plan
area (SELPA) to submit to the SPI at least annually information
in order for the SPI to carry out the evaluation
responsibilities described in #2 above. (EC § 56601)
Notification
1) Existing federal and state law requires parents to be given
a copy of their rights and procedural safeguards only one
time a school year, except that a copy also must be given
to the parents:
a) Upon initial referral or parental request for
assessment.
b) Upon receipt of the first state complaint in a
school year.
c) Upon receipt of the first due process hearing
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request in a school year.
d) When a decision is made to make a removal that
constitutes a change of placement because of a
violation of a code of student conduct.
e) Upon request by a parent. (EC § 56301; United
States Code, Title 20 § 1415(d)(1)(A); Code of Federal
Regulations, Title 34, § 300.50(a))
2) Existing state law also requires an LEA, when convening an
individualized education program team meeting, to inform
the parent and student of the federal and state procedural
safeguards that were provided in the notice of parent
rights. (EC § 56500.1)
Prior written notice
Existing federal and state law:
1) Requires LEAs to provide prior written notice to parents
and in a reasonable time before the local educational
agency (LEA) proposes to initiate a change, or refuses to
initiate or change the identification, assessment, or
educational placement of the student, or the provisions of
free appropriate public education (FAPE) to the student.
2) Requires the notice to include all of the following:
a) A description of the action proposed or refused
by the LEA.
b) An explanation of why the LEA proposes or refuses
to take the action.
c) A description of each assessment procedure,
assessment, record, or report the LEA used as a basis
for the proposed or refused action.
d) A statement that the parents have protection
under the procedural safeguards and the means by which
a copy of a description of the procedural safeguards
can be obtained.
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e) Sources for parents to contact to obtain
assistance in understanding laws.
f) A description of other options that the
individualized education program (IEP) team considered
and the reasons why those options were rejected.
g) A description of other factors that are relevant
to the proposal or refusal of the LEA. (United States
Code, Title 20 § 1415; Code of Federal Regulations,
Title 34, § 300.503; EC § 56500.4)
ANALYSIS
This bill requires local educational agencies and special
education local plan areas to collect and report specific
information relative to mental health services, requires the
California Department of Education to monitor and compare
specific information, and expands the situations in which
parents must be provided with notice of procedural safeguards
and prior written notification of proposed activities.
Specifically, this bill:
Contents of IEP
1) Expands the required components of a student's IEP by
requiring each IEP to document the type of provider
delivering each related service listed in the IEP.
Frequency and duration of related services
2) Requires the local educational agency (LEA) that is
responsible for implementation of a student's
individualized education program (IEP) to annually report
to the California Department of Education (CDE) the actual
frequency and duration of each related service provided to
the student pursuant to the student's IEP.
Student outcomes
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3) Requires each LEA, for each student receiving IEP related
services, to annually provide the data needed to document
the student's outcomes on all of the following outcome
indicators that are applicable to the student:
a) Graduation rate.
b) Dropout rate.
c) Statewide assessment results.
d) Suspension and expulsion rates.
e) Participation in general education classes.
f) Post school outcomes.
CDE monitoring
4) Requires the CDE to monitor the number and frequency of
related services reported annually by LEAs and compare
year-to-year changes for each LEA. This bill requires the
CDE to investigate the cause for any significant decline in
service provision.
5) Requires the CDE, as part of its monitoring activities, to
review each LEA's procedures and documents used to meet the
prior written notice requirement, and require corrections
to those procedures and documents if the CDE finds that the
procedures or documents do not fulfill statutory
requirements.
Accounting
6) Requires a school district or special education local plan
area (SELPA) to document and report to the CDE all mental
health and special education services funding allocations
and expenditures, and specify the dollar amount for each
service. This bill requires the CDE to post the
information on its website.
7) Requires the CDE align accounting code systems to allow the
CDE and school districts or SELPAs to accurately document
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the amount of funds expended for the provision of mental
health and special education services from each funding
source.
Prior written notice
8) Expands the requirement for local educational agencies
(LEAs) to provide to parents "prior written notice" before
the LEA initiates or changes the identification,
assessment, or educational placement of a student by also
requiring prior written notice regarding any changes to the
planned type or level of individualized education program
(IEP) services.
9) Modifies the information required to be included in a prior
written notice by requiring a copy of the procedural
safeguards to be provided to a parent rather than providing
the means by which a copy can be obtained by the parent.
10) Expands the information required to be included in a prior
written notice by adding the contact information for all
family empowerment centers and parent training and
information centers in the special education local plan
area (SELPA) of which the LEA is a member.
11) Requires the LEA that is responsible for implementation of
a student's IEP to ensure that a copy of each prior written
notice given to the student's parents is included in the
student's records.
Notification to parents
12) Expands the situations in which LEAs are required to
provide parents with a copy of their rights and procedural
safeguards to include anytime that a parent receives a
"prior written notice" from an LEA, which occurs upon the
initial referral for assessment and before the LEA proposes
to initiate or change, or refuses to initiate or change,
the identification, assessment, or educational placement of
a student.
13) Requires each SELPA to establish additional written
policies and procedures that require each LEA to provide
informational materials, including but not limited to,
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student and parent rights and information regarding family
empowerment centers and parent training and information
centers in their community.
14) Requires the information to be provided in the three most
common languages used by parents served by the LEA and the
SELPA, and be made available for LEAs to provide to their
parents in the annual parent notification information.
STAFF COMMENTS
1) Need for the bill. According to the author, "In 2011, AB
114 was signed into law, which transferred the
responsibility of providing mental health services from
county mental health departments to LEAs. As a result,
LEAs are now responsible for ensuring that students receive
mental health services. Since the transition five years
ago, it has been difficult to determine if the shift in
services has actually benefited students due to three
glaring problems revealed by the California State Audit
report release in January of this year:
a) Insufficient record-keeping by the sampled local
educational agencies (LEAs) that could shed
information on student performance outcomes, making it
impossible to assess the effectiveness or lack thereof
regarding the mental health services that were
provided.
b) Lack of documentation on how funds were spent for
mental health services, including the total amount
spent and on what services.
c) Significant changes made in a students'
individualized education program (IEP) left
unexplained, specifically in some cases where the
school district made unilateral changes without
notifying the parent.
SB 884 is a response to the audit report and seeks to
address transparency and accountability issues within LEAs
delivering mental health services to K-12 students."
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2) Recent State audit. The Bureau of State Audits released a
report in January 2016, Student Mental Health Services:
Some Students' Services Were Affected by a New State Law,
and the State Needs to Analyze Student Outcomes and Track
Service Costs. The audit noted key points: the most
commonly offered types of mental health services and the
providers of those services generally did not change; the
number of students who received these mental health
services remained steady or grew; the provider of the most
common mental health services generally had already been,
and continues to be, the local educational agency; the
majority of changes to services were unrelated to AB 114.
However, the audit also noted that: local educational agencies
removed mental health services from student IEPs in the two
years after AB 114 took effect, yet some IEPs did not
include the rationale for such changes; LEAs and the
California Department of Education (CDE) do not know
whether student outcomes have been affected by AB 114; LEAs
could not determine their total costs to provide mental
health services; some have not spent all the funding they
received that is dedicated for mental health services.
This audit made several recommendations; those that are related
to provisions of this bill include:
a) Require LEAs to use six performance indicators to
perform analysis annually on the subset of students
receiving mental health services.
b) Require CDE to analyze and report on the outcomes
for students receiving mental health services,
including outcomes across six performance indicators,
in order to demonstrate whether those services are
effective.
c) Require CDE to report annually regarding outcomes
for students receiving mental health services in six
key areas.
d) Require California Department of Education (CDE)
to collect information about the frequency of the
provision of each service contained in all students'
individualized education programs (IEPs). Require CDE
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to annually review the frequency of mental health
services and follow up with special education local
plan areas (SELPAs) when it observes a significant
reduction in the frequency of services.
e) Require CDE to develop, and require all local
educational agencies (LEAs) to follow, an accounting
methodology to track and report expenditures related
to special education mental health services.
[ http://www.bsa.ca.gov/pdfs/reports/2015-112.pdf ]
This bill attempts to implement some of the recommendations
included in this audit, but does not include all the
recommendations in the audit. Further, this bill also
includes provisions that were not recommended by the audit.
3) How schools provide mental health services. Most of the
mental health services provided by schools are within the
context of meeting the requirements specified in a
student's IEP. Federal and state law requires the
instruction and related services detailed in an IEP to be
provided, irrespective of the internal capacity of the
school to provide the instruction and services. Schools
employ qualified staff directly as well as contract with
county mental health agencies or private providers.
Schools currently have the discretion to provide counseling and
mental health services, or refer to county and community
organizations, to students who do not have an IEP. These
services may be provided by a school counselor,
psychologist or social worker, or other qualified personnel
employed by an outside entity.
The CDE has issued guidance to LEAs on the transition of special
education and related services formerly provided by county
mental health agencies:
http://www.cde.ca.gov/sp/se/ac/ab114twg.asp .
4) How do schools pay for mental health services? Most of the
mental health services provided by schools are within the
context of meeting the requirements specified in a
student's IEP, and therefore schools use restricted mental
health funds or special education funds, or a combination
of those funds, and many also use unrestricted general
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funds.
Schools may be reimbursed for some costs through Medi-Cal (or
even private insurance) for providing some mental health
services to eligible students:
a) The Medi-Cal Local Billing Option allows schools
to access federal funding for health care services
(mostly used for services provided to students with
IEPs).
b) County mental health agencies are responsible for
administering the Early and Periodic Screening,
Diagnosis and Treatment (EPSDT) benefit for children
and youth from birth to age 21 who meet income
eligibility and the medical necessity criteria.
Schools are not currently authorized to seek
reimbursement for Early and Periodic Screening,
Diagnosis and
Treatment (EPSDT) benefits; schools may be reimbursed
with EPSDT
funds but only upon agreement with the county mental
health agency.
c) Covering the cost of individualized education
program (IEP)-based services via private insurance is
only an option if the parent consents, and the school
must provide prior notice to the parent about
potential implications of accessing private insurance,
such as how it might affect lifetime caps.
5) Consistent with audit recommendations.
Student outcomes. The audit found that local educational
agencies (LEAs) are unable to determine whether significant
changes to services negatively affected their students.
The audit recommended that LEAs use six performance
indicators to perform analysis annually on the subset of
the student receiving mental health services. Existing
federal law requires States to establish measurable and
rigorous targets, and report annually to the public on the
performance of each LEA on the targets in the state's
performance plan. The Special Education Annual Performance
Report Measures are a series of reports by the California
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Department of Education to disseminate educational data.
LEAs currently report to the California Department of
Education (CDE) data specific to 17 indicators, but do not
disaggregate data for the subset of students with IEPs who
receive mental health services. This bill requires LEAs to
annually provide data to document outcomes on 6 of the 17
indicators, as recommended by the recent audit. Will this
data provide any clear evidence that mental health services
are successfully meeting the needs of students?
Notwithstanding the question of the usefulness of this
data, staff recommends an amendment to clarify that LEAs
are to report this data to the CDE.
Frequency and duration. This bill requires LEAs to
annually report to the CDE, the actual frequency and
duration of each related service provided pursuant to a
student's IEP. This bill requires the CDE to monitor the
number and frequency of related services reported by LEAs,
and compare year-to-year changes for each LEA, and requires
the CDE to investigate if year-to-year services decline
significantly. LEAs are not currently required to document
the actual services that were provided, in contrast to what
is delineated in the IEP. This bill appears to require
LEAs to keep service logs to differentiate what the IEP
calls for versus what is actually provided. Further, this
bill requires LEAs to report on the provision of each
related service, not just mental health services.
Will data relative to actual frequency and duration provide
valuable information? Can the CDE extrapolate valid
conclusions using this data? Will this data allow for
consideration of other factors, such as placement into
foster care, in determining whether mental health services
are successfully meeting the needs of students?
Accounting. The recent State audit found that while local
educational agencies (LEAs) are required to report how much
of their mental health funding they spent, LEAs are not
required to track the total costs to provide mental health
services. This bill requires a school district or special
education local plan area (SELPA) to document and report to
the California Department of Education (CDE) all mental
health and special education services funding allocations
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and expenditures, and specify the dollar amount for each
service. This bill requires the CDE to align accounting
code systems to allow the CDE and LEAs to accurately
document the amount of funds expended for the provision of
mental health and special education services from each
funding source.
Staff recommends an amendment to strike reference to school
districts, thereby ensuring that the entity receiving the
funds (SELPAs) is the entity that reports allocations and
expenditures.
6) Related to the audit but not consistent with its
recommendations. The recent State audit found that some
LEAs had not established minimum qualifications for their
mental health staff to ensure staff were properly qualified
when hired. The audit also found that LEAs do not always
obtain and retain documentation of a contracted service
provider's qualifications. This bill expands the required
components of a student's individualized education program
(IEP) by requiring the IEP to document the type of provider
delivering each related service. According to the author's
office, the intent is to describe the job
classification/licensure of the professional who is to
provide the services (i.e. school psychologist, licensed
mental health provider). While it is likely that most IEPs
currently indicate which type of professional will provide
a related service, it is not clearly required by statute.
It is unclear if requiring the IEP to specify the type of
professional who will provide related services addresses
the concern raised in the audit.
Staff notes that this bill requires a student's IEP to document
the type of provider delivering each related service, not
just mental health services.
7) Provisions not specifically related to the audit.
Prior written notice. This bill expands the requirement to
provide parents with written notice prior to a LEA
initiating or changing the identification, assessment, or
educational placement by also requiring prior written
notice regarding any changes to the planned type or level
of IEP services. Any changes to the type or level of
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services constitute a change of placement, and therefore
prior written notice should already be provided.
This bill modifies the information required to be included in a
prior written notice by requiring a copy of the procedural
safeguards to be provided to a parent rather than providing
the means by which a copy can be obtained by the parent.
The procedural safeguards must be provided to parents under
several scenarios. Is it necessary to also provide a copy
of the procedural safeguards when given prior written
notice?
Existing law requires prior written notices to include,
among other things, sources for parents to contact to
obtain assistance in understanding laws. This bill expands
the information required to be included in a prior written
notice by adding the contact information for all family
empowerment centers and parent training and information
centers in the special education local plan area (SELPA) of
which the local educational agency (LEA) is a member.
There are a limited number of these federally funded and
mandated centers; it's possible that none exist within the
boundaries of a SELPA. Rather than requiring prior written
notice to include this information, staff recommends an
amendment to require prior written notice to include the
existing link to the California Department of Education's
(CDE's) website that provides contact information for all
centers, or upon the request of a parent, a printed copy of
the information on CDE's website.
Notice of rights and procedural safeguards. Existing law
requires LEAs to provide to parents their rights and
procedural safeguards only one time a school year, except
that a copy also must be given to the parents upon initial
referral or parental request for assessment, upon receipt
of the first state complaint in a school year, upon receipt
of the first due process hearing request in a school year,
when a decision is made to make a removal that constitutes
a change of placement because of a violation of a code of
student conduct, or upon request by a parent. Parents must
also be informed of the procedural safeguards at each
individualized education program (IEP) team meeting. This
bill expands the situations in which LEAs must provide to
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parents a copy of procedural safeguards to include anytime
that a parent receives a "prior written notice" from an
LEA. Parents may receive numerous prior written notices
each year. Is it necessary to provide a copy of procedural
safeguards to parents under additional scenarios?
This bill requires each SELPA to establish additional
written policies and procedures that require each LEA to
provide informational materials, including but not limited
to, student and parent rights and information regarding
family empowerment centers and parent training and
information centers in their community. It is unclear why
SELPAs need to establish additional policies and
procedures.
This bill requires the information to be provided in the
three most common languages used by parents served by the
LEA in the SELPA, and be made available for LEAs to provide
to their parents in the annual parent notification
information. Should SELPAs be responsible for translating
this information? Existing law requires, if 15% or more of
the enrolled students speak a single primary language other
than English, all notices, reports, statements, or records
sent to the parent by the school or school district shall,
in addition to being written in English, be written in the
primary language.
Information specific to procedural safeguards can be found
on the CDE's website:
http://www.cde.ca.gov/sp/se/qa/pseng.asp . Information
specific to parental rights can be found on the CDE's
website: http://www.cde.ca.gov/sp/se/qa/pssummary.asp .
Information specific to parent organizations can be found
on the California Department of Education's (CDE's)
website: http://www.cde.ca.gov/sp/se/qa/caprntorg.asp .
8) Recommended in the audit but not included in the bill. The
recent State audit includes a recommendation to require
local educational agencies (LEAs) to include directly in a
student's individualized education program (IEP) the
reasons for any changes to student placement or services.
Existing law requires LEAs to provide prior written notice
to parents in a reasonable time before the LEA proposes to
initiate a change, or refuses to initiate or change the
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identification, assessment, or educational placement of the
student, or the provisions of free appropriate public
education to the student. The notice must include an
explanation of why the LEA proposes or refuses to take the
action. A proposed reduction in, or elimination of,
services constitutes a change of placement. Therefore, a
parent should receive a written explanation including the
rationale for a proposed change; however, no such
requirement exists for such rationale to be documented in
the student's IEP. This bill does not propose to require a
student's IEP to document the rationale for changes in
placement or services. Should this bill be amended to
require such documentation, or document that such rationale
was provided via prior written notice pursuant to existing
law?
9) Mandates. This bill creates several unfunded mandates that
exceed the federal Individuals with Disabilities Education
Act.
10) Related legislation. SB 1113 (Beall) authorizes LEAs to
enter into partnerships, as specified, with county mental
health plans for the provision of Early and Periodic
Screening, Diagnosis, and Treatment mental health services
and to expand the allowable uses of specified mental health
funds, and requires the CDE to expand its reporting system
for mental health services to include academic performance
and other measures. SB 1113 is scheduled to be heard by
this Committee on April 6.
AB 1644 (Bonta), the School-Based Early Mental Health
Intervention and Prevention Services Support Program,
establishes a four-year pilot program to
encourage and support local decisions to provide funding
for the eligible support services. AB 1644 is pending in
the Assembly Education Committee.
11) Prior legislation. AB 1025 (Thurmond, 2015) required a
designated county office of education to establish a
three-year pilot program in school districts to encourage
inclusive practices that integrate mental health, special
education, and school climate interventions following a
multi-tiered framework. AB 1025 was held in the Senate
Appropriations Committee.
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SB 463 (Hancock, 2015) required the California Department of
Education (CDE), to the extent that funding is available in
the Budget Act of 2015, to designate a county office of
education to be the fiduciary agent for the Safe and
Supportive Schools Train the Trainer Program. SB 463 is
pending in the Assembly Education Committee.
AB 1133 (Achadjian, 2015) required the State Public Health
Officer to establish a four-year pilot program to, among
other things, provide free regional training and technical
assistance in support services that include intervention
and prevention services, use of trained staff to meet with
students on a short-term weekly basis in a one-on-one
setting, the potential for support services to help fulfill
state priorities described by the local control funding
formula and local goals described by local control and
accountability plans, and state resources available to
support student mental health and positive learning
environments. AB 1133 was held in the Assembly
Appropriations Committee.
AB 580 (O'Donnell, 2015) required the California Department of
Education (CDE) to develop model referral protocols for
voluntary use by schools to address the appropriate and
timely referral by school staff of students with mental
health concerns. AB 580 vetoed by the Governor, whose veto
message read:
California does not currently have specific model
referral protocols for addressing student mental
health as outlined by this bill. However, the
California Department of Education recently
received a grant from the federal Department of
Health and Human Services, Substance Abuse and
Mental Health Services Administration to identify
and address critical student and family mental
health needs. It's premature to impose an
additional and overly prescriptive requirement
until the current efforts are completed and we
can strategically target resources to best
address student mental health.
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AB 1018 (Cooper, 2015) required the CDE and the Department
of Health Care Services to convene a task force to examine
the delivery of mental health services through the Early
and Periodic Screening, Diagnosis, and Treatment services.
AB 1018 was held in the Senate Appropriations Committee.
SB 596 (Yee, 2014) required the CDE to establish a
three-year pilot program to encourage inclusive practices
that integrate mental health, special education, and school
climate interventions following a multi-tiered framework.
SB 596 was held at the Assembly Desk.
AB 174 (Bonta, 2014) required the Department of Public
Health to establish a pilot program in Alameda County, to
the extent that funding is made available, to provide
grants to eligible applicants for activities and services
that directly address the mental health and related needs
of students impacted by trauma. AB 174 was vetoed by the
Governor, whose veto message read:
I support the efforts of the bill but am
returning it without my signature, as Alameda
County can establish such a program without state
intervention and may even be able to use Mental
Health Services Act funding to do so. Waiting
for the state to act may cause unnecessary delays
in delivering valuable mental health services to
students. All counties - not just Alameda- should
explore all potential funding options, including
Mental Health Services Act funds, to tailor
programs that best meet local needs.
SUPPORT
California Alliance of Child and Family Services
Western Center on Law & Poverty
OPPOSITION
None received.
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SB 884 (Beall) Page 20
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