Testimony of Kristen Harper, Director for Policy Development
Pennsylvania Advisory Committee to the United States Commission on Civil Rights
Good morning, members of the Advisory Committee. My name is Kristen Harper, and I am director for policy development at Child Trends, a national, nonpartisan research institute devoted to improving the lives of children, youth, and their families through rigorous research, unbiased analyses, and clear communications to improve public policy and child-serving institutions. I’m honored to have the opportunity to share with this esteemed group the latest research and policy shifts related to school discipline practice, and to explain their implications for state and community efforts to address discipline disparities by race and discipline and dismantle what is known as the “school-to-prison” pipeline.
I will focus my remarks on the following main points:
Drawing on these points, Child Trends offers suggestions to improve school discipline practice in the state of Pennsylvania and to guide the work of the Advisory Committee in completing its findings and recommendations.
National trends in school discipline show decreasing annual rates of out-of-school suspension, but persistent disparities by race and disability. In recent years, the prevalence of school-reported out-of-school suspensions has been decreasing; however, disparities by race and disability persist. In 2018 and 2019, Child Trends published analyses of the federal Civil Rights Data Collection, examining trends from the 2011-2012 school year until the 2015-2016 school year.[1],[2] We found that schools were reporting decreases in overall rates of out-of-school suspension (from 5.6% to 4.7%), as well as decreases for White students (from 4.7% to 3.8%), Black students (from 9.7% to 8.0%), Hispanic students (from 5.0% to 3.5%), and students with disabilities (from 10.2% to 8.6%). However, Black students (8.0%) are still twice as likely to be suspended out of school as White students (3.8%), and students with disabilities (8.6%) are twice as likely to be suspended as their non-disabled peers (4.1%).
Child Trends also examined discipline data at the school level. We attempted to determine the proportion of schools with racial and ethnic disparities in discipline and explore how this proportion changed over time. Here are our findings:
Trends in Pennsylvania largely mirror what we see at the national level. The average Pennsylvania school suspended 5.7 percent of students out of school during the 2011-2012 school year and suspended 5.2 percent of students out of school during the 2015-2016 school year. The proportion of Pennsylvania schools with discipline disparities is somewhat similar to what we see at the national level:
While these data help to illuminate a child’s risk of experiencing suspension within a single school year, they heavily underestimate the risk of exposure over the entirety of a child’s school experience from preschool through the 12th grade. Based on Child Trends’ analyses of the Civil Rights Data Collection, an individual child’s risk of suspension in any one year is roughly 5 percent. However, other studies have found that 35 percent of students, and 67 percent of Black students, experience at least one suspension from kindergarten through 12th grade.[3]
New research continues to show the short- and long-term detrimental effects of suspension, including an increased likelihood of contact with the juvenile and criminal justice systems. Given the data showing widespread use of suspension, we should be alarmed when research indicates that suspension causes students harm.
Back in 2011, the Council of State Governments Justice Center released groundbreaking research that clearly conveyed the risks of suspension and expulsion.[4] This longitudinal study of 7 million Texas school children found widespread use of suspension and expulsion—31 percent of students experience at least one out-of-school suspension from 7th grade through 12th grade. Further, the study found that students who experienced a suspension or expulsion were at greater risk of drop-out, being retained in grade, and contact with the juvenile justice system.
Today, we have access to new research that elevates policymaker concerns regarding disciplinary exclusion. A quasi-experimental study featuring a nationally representative sample of students has shown that, 12 years after receiving an out-of-school suspension, disciplined students are less likely to earn a diploma or bachelor’s degree and more likely to have been arrested or incarcerated.[5]
Over the past decade, states and school districts have been responsive to research findings that the use of suspension runs counter to the goals of education equity and achievement. Legislatures, as well as state and local boards of education, have worked hard to shift school discipline practices through changes in statutes and regulations. Given this policy churn, and wide variation in state approaches, there is now an urgent need for research that identifies best practices in policy design and implementation.
States continue to pass school discipline policies restricting the use of out-of-school suspension, with recent efforts focusing on early childhood discipline. Child Trends and other organizations have been tracking shifts in school discipline policy. As of fall 2017, 31 states have laws limiting the use of suspension or expulsion, while 32 states have laws that encourage alternatives to disciplinary exclusion.[6] These new policies feature a wide array of approaches, including, but limited to, limitations on disciplinary exclusion for specific grade levels (e.g., preschool); limitations for specific types of offenses (e.g., willful defiance and insubordination); and requirements that exclusion be an option of last resort, absent threats to school safety.
Early studies examining discipline policy reform present a possibility of improved student outcomes, but with significant implementation challenges. Due to significant policy changes over the last decade, officials interested in advancing school discipline legislation or regulations have many templates from which to choose. However, there is precious little research available to help them determine which policy approaches have been most successful. What studies exist provide an early glimpse of the promise and challenge of using policy mandates and restrictions to shift discipline practice.
Two studies examine reforms in Philadelphia, which shifted its school discipline policy to mandate alternatives to suspension—such as school detention and parent notification—for low-level offenses. In the first study, which looked at elementary and middle schools, authors found that studied schools could be categorized into three groups with differing school climates: 1) under-resourced schools with limited staff and resources and low teacher morale (41%); 2) schools using punitive approaches to discipline, where teachers receive little support from administrators (28%), and 3) schools using collaborative and non-punitive approaches to school discipline, where teachers are supported by school administrators (31%).[7] The last type of school was more likely to serve communities with fewer low-income families and families of color. The study also found wide variation in how school administrators interpreted district communications regarding school discipline practice: Some administrators understood that suspensions should be used “as a last resort,” while others understood that suspensions should be used “only when necessary” and in accordance with policies and procedures.
In the second study, authors found wide differences in how schools complied with Philadelphia’s new discipline policies.[8] Of studied schools, 5 percent had no need to implement the new policies as they did not use suspensions, 18 percent fully complied with the new policies (eliminating all suspensions for low-level offenses), 60 percent only partially complied (reducing suspensions for low-level offenses), and 17 percent did not comply (and actually increased suspensions). Schools in this last category tended to be academically lower-achieving and had larger populations of students of color. While the authors found a temporary decrease in suspensions for low-level offenses, including a reduction for Black students, they also found that suspensions for serious offenses for Black students increased; these increases were found mostly in schools that did not comply or only partially complied with new discipline policies.
These two studies should give us pause, as they illustrate how differences in school climate and inequities in school capacity will heavily influence how shifts in policies fall on schools and students. They also suggest that, where initiatives to address school discipline address policy without addressing the underlying education inequity, we should not expect improved outcomes for children of color. Similarly, these studies make clear that policymakers must consider what implementation supports—for school leaders and teachers alike—should accompany shifts in discipline policy. At the same time, these are early studies that both examine policy and policy implementation within a single school district. While Philadelphia may not be unique among school districts, we do not know whether (or how) the school district’s policy context or particular approach to implementation may have influenced these findings.
A third study, focusing on a different type of policy change in Chicago, presents a different picture. Researchers examined the impact of school shifts in the use of suspensions for severe behaviors and found increases in academic achievement and attendance. While schools serving Latino students saw declines in school climate and student perceptions of safety, schools serving mostly Black students saw improvements in both measures.[9]
While state and local policy initiatives to restrict the use of suspension may be an important and necessary step to spur shifts in practice, these are unlikely to be sufficient. School discipline and school discipline disparities are manifestations of broader challenges our school systems contend with when responding to student behavior. To help schools develop the cultures, processes, and practices necessary to ensure fair and effective responses to student needs, policymakers must look beyond discipline policy.
Research on the prevalence, risks, and long-term implications of child adversity highlights the need to create school environments that emphasize support over exclusion. Child Trends has published state and national estimates of childhood exposure to adversity.[10] In 2016, 45 percent of children across the United States had experienced at least one of eight adverse childhood experiences, or ACEs.[11],[12] The picture is similar in Pennsylvania, where 46 percent of children have experienced at least one ACE, and 10 percent have experienced three or more ACEs. We also found that Black children (61%) and Hispanic children (51%) are more likely to experience ACEs than either White children (40%) or Asian children (23%).
While exposure to ACEs is generally associated with poorer education and adult employment outcomes, it is also associated with emotional and behavioral difficulties during the childhood years.[13] However, childhood responses to adversity can vary wildly. Supportive relationships with adults and caregivers and strong social and emotional skills can protect children from the negative effects of childhood adversity.[14],[15]
Where schools use suspension and expulsion as a measure of first resort—rather than the last—to respond to student behavior, they risk retraumatizing and alienating children that may struggle to cope with trauma and toxic stress.
Nationally, and within Pennsylvania, Black students are overrepresented within special education, especially among students identified with emotional disturbance, and face disparate rates of placement in separate settings. Nowhere do we see greater disparities in school responses to student behavior than at the intersection of race and disability—particularly for Black children in special education. In general, most referrals to special education are due to reading or behavior challenges.[16] This is particularly the case for high-incidence disabilities such as specific learning disabilities, intellectual disabilities, and emotional disturbance. The emotional disturbance category is most strongly associated with behavior challenges: Per the Individuals with Disabilities Education Act’s (IDEA) implementing regulations, children with emotional disturbance are those whose behaviors and inability to build interpersonal relationships (among other characteristics) adversely affect their educational performance.[17]
In 2016, Black students ages 6-21 were 40 percent more likely than all other racial and ethnic groups to receive special education services under IDEA.[18] Further, Black students in this age group were twice as likely as their peers to be identified with emotional disturbance. Research suggests that there are systems-level factors influencing these disparities, including biased educator beliefs and poor behavior management practices, among others.[19],[20] Two recent studies found a relationship between school segregation and disparities in disability identification: Schools serving mostly White students are more likely to identify Black students with disabilities, while schools serving mostly Black students are less likely to identify disabilities.[21],[22]
In recent years, there has been some debate as to whether the overrepresentation of Black students among students with disabilities is cause for alarm. However, one thing is certain: Given this degree of overrepresentation, IDEA’s protections and services for students with disabilities and guarantee of a free appropriate public education have proven inadequate for Black students. According to the Government Accountability Office, Black students with disabilities (23%) have among the highest rates of out-of-school suspension of any student subgroup (White students with disabilities face rates of 8%, and Black students without disabilities face rates of 13%).[23] Academic achievement level, as represented by the National Assessment of Educational Progress, presents an even bleaker picture. In 2015, only 18 percent of Black students with disabilities performed at or above basic for grade 12 reading, compared to 41 percent for White students with disabilities, 56 percent for Black students without disabilities, and 83 percent for White students without disabilities.[24]
While policymakers across the country have worked to improve school discipline practice, the policy and political contexts in which they pursue this goal are constantly shifting. As the public gains access to discipline data—and public accountability grows around discipline and discipline disparities—schools face numerous pressures to show improvement. Meanwhile, high-profile events such as active shooter incidents and bullying can leave parents and communities demanding action from policymakers to keep students safe.
Unintended shifts in discipline practice and reporting. Research highlighting the detrimental impacts of suspension—as well as shifts in federal, state, and local policy—make clear that school communities should seek ways to reduce their reliance on suspension. Stronger public and administrative accountability for school discipline, made possible by the federal Civil Rights Data Collection (which provides school-level discipline indicators) and the Every Student Succeeds Act (which requires states to publish report cards with indicators of school quality), has created a strong focus on discipline data to gauge whether schools are improving.
With such a strong focus on discipline data, particularly out-of-school suspension, one emerging challenge has been to ensure that shifts in discipline trends are actually indicative of intended shifts in practice. Ideally, reductions in reported suspensions would indicate a shift from punitive or exclusionary discipline toward more supportive alternatives. However, there are initial signs that some schools may be reducing the number of suspensions they report by changing record-keeping practices or swapping one type of punitive discipline for another type. In Washington state, officials have issued new regulations clarifying that informal disciplinary removals (e.g., sending children home with parents) must be recorded as suspensions.[25] In a preliminary study by Child Trends, we found that schools that reported decreases in out-of-school suspension from the 2011-2012 to 2015-2016 school years were more likely to also report increases in school-based arrests than schools reporting increases or no change in suspension.[26]
Pressures on policymakers to shift from prevention to school hardening and criminalization. In the aftermath of the Parkland shooting, policymakers have pursued a range of policy options in the hope of strengthening school safety, including new investments in school policing, active shooter drills, physical security features (e.g., metal detectors and cameras), and threat assessment. These approaches vary widely with respect to their grounding in the research, and some—like school policing and threat assessment—have the potential to aggravate challenges with disciplinary exclusion.[27] Research examining the potential for school policing to improve school safety has been mixed, and tragic active shooter incidents have taken place on school campuses where school police were present.[28],[29] However, the research does clearly indicate that greater use of school police is associated with increases in school arrests.[30] Threat assessment has stronger grounding in the research: Used well, this approach provides schools with a process to identify, assess, and intervene when a child may be considering violence.[31] However, used improperly and without oversight, threat assessment can become one more mechanism by which schools continue to exclude children improperly.[32]
This shift is particularly concerning given emerging narratives that malign children with disabilities and children with mental health needs as subgroups at higher risk of extreme violence. In fact, children and youth with mental health challenges are more likely than their peers to be victims of crime.[33]
Child Trends recommends that Pennsylvania pursue a comprehensive and integrated approach that goes beyond school discipline policy reform to address the following: 1) school capacity to support student health; 2) inequity within both general and special education; and 3) the availability of high-quality discipline data that allows state and local officials to monitor for improvement and identify inequity.
Recommendation 1: Improve coordination between education and health officials to create schools with the capacity, culture, and community partners they need to address students’ social, emotional, mental, and physical health needs. Pennsylvania has a strong foundation for starting this work with its longstanding focus on building community schools and implementing integrated student supports. As of 2017, Pennsylvania statutes and regulations addressed multiple dimensions of student and school health to a greater extent than other states, including counseling, psychological and social services, health services, physical environment (including school safety and security), and health education.[34] Still, there are areas of policy where Pennsylvania schools may face obstacles: As of 2018, Pennsylvania’s State Medicaid Plan only allowed schools to seek reimbursement for enrolled students with disabilities, limiting access to resources that could strengthen school health capacity.[35] Given its fairly robust policy infrastructure, Pennsylvania should focus its efforts on implementation support. This means working with school leaders and educators to create school climates and cultures that are supportive for children with a range of behavioral needs, including children with a history of adversity.
Recommendation 2: Advance a concerted effort to reduce resource inequity in general education and racial and ethnic disparities within special education. As the Pennsylvania studies showed, there are wide differences in school culture and capacity between schools serving communities, with children of color more often in schools with fewer resources and more punitive approaches to discipline. These inequities will complicate efforts to implement new school discipline policies, and must be addressed at their source. Further, Pennsylvania should address head-on disparities by race and ethnicity within its special education system, and should leverage new federal IDEA requirements to manage this process. Under Section 618(d) of IDEA, all states must identify school districts with “significant disproportionality”—large racial and ethnic disparities in the identification, placement, and discipline of students with disabilities. However, federal law leaves it to states to determine when disparity warrants state intervention. Historically, Pennsylvania has been among those states that has defined its threshold for “significant disproportionality” so high as to avoid any intervention.[36] This must change. During the 2013-2014 school year, Pennsylvania had 56 school districts that identified Black students with emotional disturbance at rates three times as high as all other students.[37]
Recommendation 3: Maintain an ongoing focus on data collection, with attention to improving data quality, examining discipline disparities, and capturing emerging practices. As of 2017, 27 states had laws requiring some form of monitoring for discipline disparities by either race or disability.[38] While continued attention to reducing discipline and discipline disparities necessitates ongoing access to data, investments in data collection and reporting should be matched with initiatives to ensure that the data accurately reflect school practice. This may entail clarifying for schools that suspensions include informal removals (such as shortened school days or asking parents to either pick up students early or keep them at home) and any time spent away from school pursuant to the decisions and deliberations of a threat assessment team. It would also include developing new strategies to audit school records and reporting practices for accuracy and completeness. Further, such a focus requires remaining vigilant for new formal practices—such as threat assessment—and ensuring regular data collection and reporting for such practices to help Pennsylvania communities assess whether students of color and students with disabilities are treated equitably.
[1] Harper, K., Ryberg, R., Temkin, D. (2018). Schools report fewer out-of-school suspensions, but gaps by race and disability persist. Bethesda, MD: Child Trends. Retrieved from: https://www.childtrends.org/schools-report-fewer-out-of-school-suspensions-but-gaps-by-race-and-disability-persist
[2] Harper, K., Ryberg, R., & Temkin, D. (2019). Black students and students with disabilities remain more likely to receive out-of-school suspensions, despite overall declines. Bethesda, MD: Child Trends. Retrieved from: https://www.childtrends.org/publications/black-students-disabilities-out-of-school-suspensions
[3] Shollenberger, T. (2015). Racial disparities in school suspension and subsequent outcomes: Evidence from the National Longitudinal Study of Youth. Closing the school discipline gap: Equitable remedies for excessive exclusion, New York, NY: Teachers College Press.
[4] Fabelo, T., Thompson, M. D., Plotkin, M., Carmichael, D., Marchbanks, M. P., & Booth, E. A. (2011). Breaking
schools’ rules: A statewide study of how school discipline relates to students’ success and juvenile justice involvement. New York: Council of State Governments Justice Center. Retrieved from https://csgjusticecenter.org/wpcontent/uploads/2012/08/Breaking_Schools_Rules_Report_Final.pdf
[5] Rosenbaum, J. (2019). Educational and criminal justice outcomes 12 years after school suspension. Youth and Society, 1-33.
[6] Chriqui, J., Stuart-Cassel, V., Piekarz-Porter, E., Temkin, D., Lao, K., Steed, H., Harper, K., Leider, J., Gabriel, A. (2019). Using state policy to create healthy schools: Coverage of the Whole School, Whole Community, Whole Child Framework in State Statutes and Regulations, School Year 2017-2018. Bethesda, MD: Child Trends. Retrieved from https://cms.childtrends.org/wp-content/uploads/2019/01/WSCCStatePolicyReportSY2017-18_ChildTrends_January2019.pdf
[7] Gray, A., Sirinides, P., Fink, R., Flack, A., DuBois, T., Morrison, K., and Hill, K. (2017). Discipline in Context: Suspension, Climate, and PBIS in the School District of Philadelphia. CPRE Research Reports. Retrieved from https://repository.upenn.edu/cpre_researchreports/106
[8] Steinberg, M., and Lacoe, J. (2017). The academic and behavioral consequences of discipline policy reform: Evidence from Philadelphia. Washington, DC. Thomas B. Fordham Institute.
[9] Hinze-Pifer, R. and Sartain, L. (2018). Rethinking Universal Suspension for Severe Student Behavior. Chicago, Illinois; University of Chicago Consortium on School Research. Retrieved at https://consortium.uchicago.edu/sites/default/files/2018-10/Rethinking%20Universal%20Suspension%20ES.pdf
[10] Sacks, V., Murphey, D. (2018). The prevalence of adverse childhood experiences, nationally, by state, and by race or ethnicity. Bethesda, MD: Child Trends. Retrieved from https://www.childtrends.org/publications/prevalence-adverse-childhood-experiences-nationally-state-race-ethnicity
[11] Metzler, M., Merrick, M. T., Klevens, J., Ports, K. A., & Ford, D. C. (2017). Adverse childhood experiences and life opportunities: shifting the narrative. Children and Youth Services Review, 72, 141-149. Retrieved from http://www.sciencedirect.com/science/article/pii/S0190740916303449
[12] Sacks and Murphey (2018) analyzed eight types of childhood adversity included in the National Survey for Children’s Health: parental or guardian divorce or separation; parental or guardian death; parental or guardian incarceration; living with anyone with mental illness; living with anyone with an alcohol or drug problem; witnessing domestic violence; witnessing or experiencing neighborhood violence; and economic hardship. These eight are generally referred to as “adverse childhood experiences” or ACEs. As ACEs are a subset of childhood adversities, and do not include other potentially traumatic experiences such as homelessness, bullying, forced displacement, and other events, the estimates of ACEs exposure should be considered a conservative estimate of exposure to childhood adversity.
[13] Bethell, C. D., Davis, MB, Gombojav, N, Stumbo, S, Powers, K. (2017). A national and across state profile on adverse childhood experiences among children and possibilities to heal and thrive. Retrieved from http://www.cahmi.org/projects/adverse-childhood-experiences-aces/
[14] Shonkoff, J., Boyce, W., Cameron, J., Duncan, G., Fox, N., Gunnar, M., & Thompson, R. (2005). Excessive stress disrupts the architecture of the developing brain. National Scientific Council on the Developing Child, Working Paper, 3, 2014. Retrieved from http://developingchild.harvard.edu/wp-content/uploads/2005/05/Stress_Disrupts_Architecture_Developing_Brain-1.pdf
[15] Bethell, C., Newacheck, P., Hawes, E., & Halfon, N. (2014). Adverse childhood experiences: assessing the impact on health and school engagement and the mitigating role of resilience. Health Affairs, 33(12), 2106-2115. Retrieved from https://www.healthaffairs.org/doi/abs/10.1377/hlthaff.2014.0914
[16] National Research Council. (2002). Minority Students in Special and Gifted Education. Washington, DC: The National Academies Press. Retrieved from https://doi.org/10.17226/10128.
[17] 300 C.F.R. § 300.8 (c) (4)
[18] U.S. Department of Education, Office of Special Education and Rehabilitative Services, Office of Special Education Programs. (2018). 40th Annual Report to Congress on the Implementation of the Individuals with Disabilities Education Act. Washington, D.C.
[19] Fergus, E. (2016). Social Reproduction Ideologies: Teacher Beliefs about Race and Culture. In D. Connor, B. Ferri., and S. Annamma (eds). DisCrit: Disability Studies and Critical Race Theory. New York: Teachers College Press.
[20] Milner, H. (2006). Classroom management in urban classrooms. In C.M. Evertson & C.S. Weinstein (Eds.), The handbook of classroom management: Research, practice & contemporary issues (pp. 491-522). Mahwah, NJ: Lawrence Erlbaum.
[21] Elder, T., Figlio, D., Imberman, S., & Persico, C. (2019). School Segregation and Racial Gaps in Special Education Identification (No. w25829). National Bureau of Economic Research.
[22] Fish, R. (2019). Standing Out and Sorting In: Exploring the Role of Racial Composition in Racial Disparities in Special Education. American Educational Research Journal, 1-36.
[23] United States Government Accountability Office. (2018). K-12 Education: Discipline Disparities for Black Students, Boys, and Students with Disabilities, GAO-18-258. Washington, DC. Retrieved at https://www.gao.gov/assets/700/690828.pdf
[24] U.S. Department of Education, Institute of Education Sciences, National Center for Education Statistics, National Assessment of Educational Progress (NAEP), 2015 Reading Assessment.
[25] Washington Office of the Superintendent of Public Instruction (2018). New Student Discipline Rules Questions & Answers: A Technical Guide. Retrieved from http://164.116.19.35/studentdiscipline/Rules/pubdocs/TechnicalGuide.pdf
[26] Harper, K., Ryberg, R., & Temkin, D. (2019). Black students and students with disabilities remain more likely to receive out-of-school suspensions, despite overall declines. Bethesda, MD: Child Trends. Retrieved from: https://www.childtrends.org/publications/black-students-disabilities-out-of-school-suspensions
[27] Harper, K., Temkin, D. (2018). New school safety bills could make schools less safe for kids. Bethesda, MD: Child Trends. Retrieved at https://www.gao.gov/assets/660/652437.pdf
[28] Jonson, C. (2017). Preventing School Shootings: The Effectiveness of Safety Measures, Victims & Offenders, 12(6), 956-973.
[29] Anderson, K. (2018). Does more policing make middle schools safer? Brown Center Chalkboard. Washington, DC: Brookings. Retrieved at https://www.brookings.edu/blog/brown-center-chalkboard/2018/11/08/does-more-policing-make-middle-schools-safer/
[30] James, N., McGallion, G. (2013). School Resource Officers: Law Enforcement Officers in Schools. Washington, DC: Congressional Research Services. Retrieved from https://fas.org/sgp/crs/misc/R43126.pdf
[31] Cornell, D. (2012). The Virginia Student Threat Assessment Guidelines: An Empirically Supported Violence Prevention Strategy. In: Böckler N., Seeger T., Sitzer P., Heitmeyer W. (eds) School Shootings. Springer, New York, NY
[32] Swetliz, I. (2019). Who’s the threat? Hundreds of special ed students ID’d as potential threats. Searchlight New Mexico. Retrieved at https://www.searchlightnm.org/whos-the-threat
[33] Turner, H., Finkelhor, D., Ormrod, R. (2010). Child mental health problems as risk factors for victimization, 15(2): 132-43. Retrieved at https://www.ncbi.nlm.nih.gov/pubmed/19812391
[34] Chriqui, J., Stuart-Cassel, V., Piekarz-Porter, E., Temkin, D., Lao, K., Steed, H., Harper, K., Leider, J., Gabriel, A. (2019). Using state policy to create healthy schools: Coverage of the Whole School, Whole Community, Whole Child Framework in State Statutes and Regulations, School Year 2017-2018. Bethesda, MD: Child Trends. Retrieved from https://cms.childtrends.org/wp-content/uploads/2019/01/WSCCStatePolicyReportSY2017-18_ChildTrends_January2019.pdf
[35] McCullough, F. (2015). Letter to Theodore Dallas, Acting Secretary of Human Services, Pennsylvania Department of Human Services. Philadelphia, PA: Centers for Medicare and Medicaid Services. Retrieved at https://www.medicaid.gov/State-resource-center/Medicaid-State-Plan-Amendments/Downloads/PA/PA-14-034.pdf
[36] Government Accountability Office. (2013). Individuals with Disabilities Education Act: Standards Needed to Improve Identification of Racial and Ethnic Overrepresentation in Special Education. Retrieved from https://www.gao.gov/assets/660/652437.pdf
[37] Office of Special Education and Rehabilitative Services, U.S. Department of Education. (2018). Racial and Ethnic Disparities in Special Education: A Multi-Year Disproportionality Analysis by State, Analysis Category, and Race/Ethnicity. Retrieved from https://www2.ed.gov/programs/osepidea/618-data/LEA-racial-ethnic-disparities-tables/disproportionality-analysis-by-state-analysis-category.pdf
[38] Chriqui, J., Stuart-Cassel, V., Piekarz-Porter, E., Temkin, D., Lao, K., Steed, H., Harper, K., Leider, J., Gabriel, A. (2019). Using state policy to create healthy schools: Coverage of the Whole School, Whole Community, Whole Child Framework in State Statutes and Regulations, School Year 2017-2018. Bethesda, MD: Child Trends. Retrieved from https://cms.childtrends.org/wp-content/uploads/2019/01/WSCCStatePolicyReportSY2017-18_ChildTrends_January2019.pdf
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