BILL ANALYSIS                                                                                                                                                                                                    �



                                        

                         SENATE COMMITTEE ON EDUCATION
                                Carol Liu, Chair
                           2013-2014 Regular Session
                                        

          BILL NO:       AB 1068
          AUTHOR:        Bloom
          AMENDED:       April 1, 2013
          FISCAL COMM:   Yes            HEARING DATE:  June 26, 2013
          URGENCY:       No             CONSULTANT:Lynn Lorber

           SUBJECT  :  Pupil records.
          
           SUMMARY  

          This bill prohibits the release of directory information  
          for homeless pupils, and requires schools to permit access  
          to pupil records to a pupil who is at least 14 years old,  
          homeless and unaccompanied.

           BACKGROUND  

          The federal Family Educational Rights and Privacy Act  
          (FERPA) prohibits federal funds from being provided to any  
          educational agency or institution which has a policy or  
          practice of permitting the release of a pupil's educational  
          records to any individual, agency, or organization without  
          the written consent of the pupil's parents.  FERPA exempts  
          from the general parental consent requirement certain kinds  
          of disclosures, including disclosures to state and local  
          officials for the purposes of conducting truancy  
          proceedings, a criminal investigation, auditing or  
          evaluating an educational program, or in relation to the  
          application for financial aid.  (United States Code, Title  
          20, Section 1232g and Code of Federal Regulations, Title  
          34, Sections 99.31)

          Current state law prohibits a school district from  
          permitting access to pupil records to a person without  
          parental consent or under judicial order, with some  
          exceptions:

          1)   School districts are required to permit access to  
               records relevant to the legitimate educational  
               interests of specified requesters, including:

               a)        School officials and employees of the  







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                    districts, members of a school attendance review  
                    board and any volunteer aide (as specified),  
                    provided that the person has a legitimate  
                    educational interest to inspect a record.

               b)        Officials and employees of other public  
                    schools or school systems where the pupil intends  
                    to or is directed to enroll.

               c)        Other federal, state and local officials as  
                    specified.

               d)        Parents of a pupil 18 years of age or older  
                    who is a dependent.

               e)        A pupil 16 years of age or older or having  
                    completed the 10th grade who requests access.

               f)        A district attorney, judge or probation  
                    officer, in relation to truancy proceedings.

               g)        A district attorney's office for  
                    consideration against a parent for failure to  
                    comply with compulsory education laws.

               h)        A probation officer, district attorney, or  
                    counsel of record for a minor, in relation to a  
                    criminal investigation or in regard to declaring  
                    a person a ward of the court or involving a  
                    violation of a condition of probation.

               i)        A county placing agency when acting as an  
                    authorized representative of a state or local  
                    educational agency.  
                    (Education Code � 49076)

          2)   School districts are authorized to release information  
               from pupil records to the following:

               a)        Appropriate persons in connection with an  
                    emergency if the information is necessary to  
                    protect the health or safety of a pupil or other  
                    person.









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               b)        Agencies or organizations in connection with  
                    the application of a pupil for, or receipt of,  
                    financial aid.

               c)        The county elections official for the  
                    identification of pupils who are eligible to  
                    register to vote.

               d)        Accrediting associations in order to carry  
                    out accrediting functions.

               e)        Organizations conducting studies on behalf  
                    of educational agencies or institutions for the  
                    purpose of developing, validating or  
                    administering predictive tests, administering  
                    student aid programs, and improving instruction.

               f)        Officials and employees of private schools  
                    or school systems where the pupil is enrolled or  
                    intends to enroll.  

               g)        A contractor or consultant with a legitimate  
                    educational interest who has a formal written  
                    agreement or contract with the school district  
                    regarding the provision of outsourced  
                    institutional services or functions by the  
                    contractor or consultant.  (EC � 49076)




          Current law:

          1)   Requires school districts to adopt a policy  
               identifying categories of directory information that  
               may be released, and authorizes directory information  
               to be released according to the local policy.  School  
               districts are required to provide notice at least  
               annually of the categories of information that the  
               school plans to release and of the recipients.  The  
               release of directory information is prohibited if the  
               parent has notified the school district that the  
               information is not to be released.  (EC � 49073)









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          2)   Defines "directory information" as one or more of the  
               following: pupil's name, address, telephone number,  
               date of birth, email address, major field of study,  
               participation in officially recognized activities and  
               sports, weight and height of members of athletics  
               teams, dates of attendance, degrees and awards  
               received, and the most recent previous public or  
               private school attended by the pupil.  (EC � 49061)

          Current law requires school districts to notify parents in  
          writing of their rights, including the types of pupil  
          records kept by the district, the position of the official  
          responsible for the records, the policies for reviewing and  
          expunging records, and the criteria used by the district to  
          define "school officials and employees" and to determine  
          "legitimate educational interest."  (EC � 49063)

          Current law establishes the Caregiver's Authorization  
          Affidavit for the purpose of authorizing enrollment of a  
          minor in school and to authorize school-related medical  
          care.  This affidavit requests the name of the minor, the  
          minor's birthdate, the adult's name, and the adult's home  
          address at which he/she and the minor are living.  This  
          affidavit must also be signed by the adult attesting that  
          he/she is 18 years of age or older and that the named minor  
          lives in the adult's home.  The affidavit states that the  
          declaration does not affect the rights of the minor's  
          parents or legal guardian regarding the care, custody, and  
          control of the minor, and does not mean that the caregiver  
          has legal custody of the minor.  (Family Code � 6552)

          The federal McKinney-Vento Homeless Assistance Act defines  
          "homeless children and youths" as children and youths who  
          lack a fixed, regular, and adequate nighttime residence,  
          and includes children and youths who, among other  
          situations, are sharing the housing of other persons due to  
          loss of housing, economic hardship, or a similar reason;  
          are living in motels, hotels, trailer parks, or camping  
          grounds due to the lack of alternative adequate  
          accommodations.  Unaccompanied youth are considered  
          homeless pursuant to McKinney-Vento and who is not in the  
          physical custody of his/her parent or legal guardian.   
          (United States Code, Title 42, � 11431 et seq.)









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           ANALYSIS
           
          This bill prohibits the release of directory information  
          for homeless pupils, and requires schools to permit access  
          to pupil records to a pupil who is at least 14 years old,  
          homeless and unaccompanied.  Specifically,  this bill  :  
          1)   Prohibits the release of directory information  
               regarding a pupil identified as being homeless unless  
               a parent, or pupil with parental rights, has provided  
               written consent for such release.

          2)   Expands the existing requirement that school districts  
               permit access to pupil records relevant to the  
               legitimate educational interests of the requester, to  
               permit access to the following individuals:

                    a)             A pupil who is 14 years of age or  
                    older and is both a homeless child or youth and  
                    an unaccompanied youth as defined by the  
                    McKinney-Vento Homeless Assistance Act. 

                    b)             An individual who completes the  
                    Caregiver's Authorization Affidavit and signs the  
                    affidavit for the purpose of enrolling a minor in  
                    school.

           STAFF COMMENTS  

           1)   Need for the bill  .  According to the author,  
               "Unaccompanied homeless youth are youth experiencing  
               homelessness who are not in the physical custody of a  
               parent or guardian.  Most of these students have left  
               home due to severe family dysfunction, including abuse  
               and neglect.  Unaccompanied youth who have not yet  
               turned 18 are not considered 'eligible students' and  
               therefore cannot access their own educational records  
               and cannot give consent for the school to disclose  
               their records to advocates, community agencies, health  
               care providers, tutoring programs, or other agencies  
               or individuals that do not fall within one of Family  
               Educational Rights and Privacy Act exceptions."








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           2)   Opt-in vs. opt-out  .  Current law requires school  
               districts to adopt a policy identifying categories of  
               directory information that may be released, and  
               authorizes directory information to be released  
               according to the local policy.  School districts are  
               required to provide notice at least annually of the  
               categories of information that the school plans to  
               release and of the recipients.  The release of  
               directory information is prohibited if the parent has  
               notified the school district that the information is  
               not to be released.  This bill prohibits the release  
               of directory information regarding a pupil identified  
               as being homeless unless a parent, or pupil with  
               parental rights, has provided written consent for such  
               release.

           3)   Fiscal impact  .  According to the Assembly  
               Appropriations Committee, this bill imposes General  
               Fund (Proposition 98) state reimbursable mandated  
               costs, between $75,000 and $125,000, to school  
               districts.  These costs 
                
                are associated with staff time necessary to revise  
               directory and pupil record procedures and to ensure  
               proper documentation is received regarding the release  
               of pupil information. 

           4)   Related legislation  .  AB 643 (Stone) requires school  
               districts to allow access to school records to that  
               youth's social worker or probation officer, conforming  
               to the federal Uninterrupted Scholars Act.  SB 643 is  
               pending on the Senate Floor.

           SUPPORT  

          California Coalition for Youth
          California Federation of Teachers
          California Partnership to End Domestic Violence
          Children Now
          National Association for the Education of Homeless Children  
          and Youth

           OPPOSITION








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           None on file.