SCHOOL BULLYING

Extent of Legal 

Protections for 

Vulnerable Groups 

Needs to Be More 

Fully Assessed

Report to Congressional Requesters

May 2012

GAO-12-349

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-349, a report to 

congressional requesters

May 2012

SCHOOL BULLYING

Extent of Legal Protections for Vulnerable Groups 

Needs to Be More Fully Assessed

Why GAO Did This Study

Millions of youths are estimated to be 

subject to bullying in U.S. schools. 

GAO was asked to address (1) what is 

known about the prevalence of school 

bullying and its effects on victims, (2) 

approaches selected states and local 

school districts are taking to combat 

school bullying, (3) legal options 

federal and selected state 

governments have in place when 

bullying leads to allegations of 

discrimination, and (4) key federal 

agencies’ coordination efforts to 

combat school bullying. GAO reviewed 

research on the prevalence and effects 

on victims; analyzed state bullying 

laws, and school district bullying 

policies; and interviewed officials in 8 

states and 6 school districts. States 

were selected based on various 

characteristics, including student 

enrollment, and their definitions of 

bullying. Also, GAO reviewed selected 

relevant federal and state civil rights 

laws, and interviewed officials from 

Education, HHS, and Justice.

What GAO Recommends

GAO recommends that Education 

compile information about state civil 

rights laws and procedures that relate 

to bullying, and inform complainants 

about state legal options; Education, 

HHS, and Justice develop information 

about bullied demographic groups in 

their surveys; and assess whether 

legal protections are adequate for 

these groups. Education disagreed 

with our first recommendation and we 

clarified it to address some of their 

concerns. Education is considering our 

second recommendation, agreed with 

our third, and provided information on 

efforts related to the last. HHS agreed 

with our recommendations. Justice did 

not provide a written response. 

What GAO Found

School bullying is a serious problem, and research shows that it can have 

detrimental outcomes for victims, including adverse psychological and behavioral 

outcomes. According to four nationally representative surveys conducted from 

2005 to 2009, an estimated 20 to 28 percent of youth, primarily middle and high 

school-aged youths, reported they had been bullied during the survey periods. 

However, differences in definitions and questions posed to youth respondents 

make it difficult to discern trends and affected groups. For example, the surveys 

did not collect demographic information by sexual orientation or gender identity. 

The Departments of Education (Education) and Health and Human Services 

(HHS) are partially addressing the issue of inconsistent definitions by 

collaborating with other federal departments and subject matter experts to 

develop a uniform definition of bullying that can be used for research purposes. 

However, gaps in knowledge about the extent of bullying of youths in key 

demographic groups remain.

According to Education, as of April 2012, 49 states have adopted school bullying 

laws. The laws in the 8 states that GAO reviewed vary in who is covered and the 

requirements placed on state agencies and school districts. For example, 6 of the 

states cover a mix of different demographic groups, referred to as protected 

classes, such as race and sex or gender, in their bullying laws, while 2 states do 

not include any protected classes. With respect to school districts, each of the 6 

districts GAO studied adopted policies that, among other things, prohibit bullying 

and describe the potential consequences for engaging in the behavior. Also, 

school district officials told GAO that they developed approaches to prevent and 

respond to bullying. For example, several school officials said they implemented 

a prevention-oriented framework to promote positive school cultures. Both state 

and local officials expressed concerns about various issues, including how best 

to address incidents that occur outside of school. 

Federal civil rights laws can be used to provide protections against bullying in 

certain circumstances, but certain vulnerable groups are not covered and 

therefore have no recourse at the federal level. For example, federal agencies 

lack jurisdiction under civil rights statutes to pursue discrimination cases based 

solely on socioeconomic status or sexual orientation. While some state civil rights 

laws provide protections to victims of bullying that go beyond federal law, federal 

complainants whose cases are dismissed for lack of jurisdiction are not always 

informed about the possibility of pursuing claims at the state level.

Three federal departments—Education, HHS, and the Department of Justice 

(Justice)—have established coordinated efforts to carry out research and broadly 

disseminate information on bullying to the public, including establishment of a 

central website and an informational campaign to raise awareness about 

bullying. In addition to these efforts, Education has issued information about how 

federal civil rights laws can be used to address bullying of protected classes of 

youths and is conducting a comprehensive study of state bullying laws and how 

selected school districts are implementing them. However, no similar information 

is being gathered on state civil rights laws and procedures that could be helpful in 

assessing the adequacy of legal protections against school bullying.

View GAO-12-349. For more information, 

contact Linda Calbom at (206) 287-4809 or 

calboml@gao.gov.
Page i GAO-12-349 Bullying Prevention

Letter 1 

Background 3

Reported Levels of Bullying and Related Effects Are Significant 5

Selected State Legislatures and Educational Agencies Are Taking 

Various Approaches to Reduce Bullying 10

Federal and State Civil Rights Laws Offer Some Protections against 

Bullying, but Vulnerable Groups May Not Always Be Covered 16

Coordinated Federal Antibullying Efforts Are Under Way, but 

Assessment of Legal Remedies Is Incomplete 22

Conclusions 26

Recommendations for Executive Action 27

Agency Comments 28

Appendix I Objectives, Scope, and Methodology 31

Appendix II Comparison of the Definition and Measurement of Bullying in Four 

Nationally Representative Surveys 36

Appendix III Selected Data on National Prevalence of Youth Who Report Being 

Bullied in School 38

Appendix IV Selected Data on National Prevalence of Certain Types of Bullying 

Behaviors 40

Appendix V Coordination Practices of Key Interdepartmental Federal Efforts on 

Bullying 42

Appendix VI Additional Federal Programs and Services Are Available to Combat 

Bullying 46

Contents
Page ii GAO-12-349 Bullying Prevention

Appendix VII Comments from the Department of Education 48

Appendix VIII Comments from the Department of Health and Human Services 56

Appendix IX GAO Contacts and Staff Acknowledgments 58

Tables

Table 1: Coverage of Demographic Groups in Federal Surveys of 

Youth 7

Table 2: Examples of Provisions Commonly Required by State 

Bullying Laws 13

Table 3: Relevant Federal Civil Rights Laws, Protected Classes, and 

Agency Enforcement Authority 18

Table 4: Nationally Representative Surveys We Reviewed That Ask 

about Youths Being Bullied, among Other Topics 32

Table 5: Selected Aspects of the Definition and Measurement of 

Bullying in Four Nationally Representative Surveys 36

Table 6: Estimates of Youth Who Reported Being Bullied by Sex in 

Three National Surveys 38

Table 7: Estimates of Youth Who Reported Being Bullied by 

Race/Ethnicity in Three National Surveys 39

Table 8: NCVS SCS 2009: Estimates of Youth Who Reported Being 

Bullied for Certain Types of Bullying Behaviors 40

Table 9: HBSC 2005/2006: Estimates of Youth Who Reported Being 

Bullied for Certain Types of Bullying Behaviors 41

Table 10: NatSCEV 2008: Estimates of Youth Who Reported Being 

Bullied for Certain Types of Bullying Behaviors 41

Table 11: Practices for Key Coordinated Federal Efforts 

Specifically on Bullying 42

Table 12: Selected Services and Programs That Can Be Used to 

Support Bullying Prevention 46
Page iii GAO-12-349 Bullying Prevention

Abbreviations

ADA Americans with Disabilities Act

CCD Common Core of Data

CDC Centers for Disease Control and Prevention

CRT Civil Rights Division

CSN Children’s Safety Network 

ERIC Education Resources Information Center 

GLSEN Gay, Lesbian and Straight Education Network 

HBSC Health Behavior in School-Aged Children 

HHS Department of Health and Human Services

HRSA Health Resources and Services Administration 

NatSCEV National Survey of Children’s Exposure to Violence 

NCES National Center for Education Statistics 

NCVS National Crime Victimization Survey 

NIH National Institutes of Health

OCR Office for Civil Rights 

OJJDP Office of Juvenile Justice and Delinquency Prevention

PBIS Positive Behavioral Interventions and Supports 

SAMHSA Substance Abuse and Mental Health Services 

 Administration 

SCS School Crime Supplement 

SEA state educational agency

SS/HS Safe Schools/Healthy Students Initiative

YRBS National Youth Risk Behavior Survey

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Page 1 GAO-12-349 Bullying Prevention

United States Government Accountability Office

Washington, DC 20548

May 29, 2012

The Honorable Tom Harkin

Chairman

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable Robert P. Casey, Jr.

United States Senate

The Honorable Al Franken

United States Senate

The Honorable Mark Kirk

United States Senate

It is estimated that millions of American youths have been bullied by their 

peers, including physical, verbal, and electronic attacks.1 Some of these 

incidents, including some where bullying has been linked by the media to 

teen suicide, have received widespread attention, resulting in heightened 

awareness of bullying, as well as a wide range of actions at the federal, 

state, and local levels to address the behavior. Some of these incidents 

involved bullying based on personal characteristics, including race, 

religion, or sexual orientation, and have also raised questions about the 

role and availability of federal and state civil rights protections. Given the 

dynamic and rapidly changing nature of these efforts, governments at all 

levels, as well as the public, face a growing need for information about 

possible legal and practical approaches to combating bullying. In this 

context, you asked us to address the following questions:

 

1

For the purposes of this report, we use the term bullying to reflect behavior that is 

intended to inflict harm, repeated over time, and characterized by an imbalance of power 

between the perpetrator(s) and victim(s). Some sources refer to similar behavior as 

harassment, and may use the terms interchangeably.

 
 

Page 2 GAO-12-349 Bullying Prevention

1. What is known about the prevalence of school bullying and its effects 

on victims?

2. What approaches are selected states and local school districts taking 

to combat school bullying?

3. When bullying leads to allegations of discrimination, what legal 

options do federal and selected state governments have in place?

4. How are key federal agencies coordinating their efforts to combat 

school bullying?

To identify what is known about the prevalence of school bullying and its 

effects on victims, we interviewed knowledgeable federal officials, 

compared estimates and methodologies of four nationally representative 

surveys that captured information on bullying, and conducted a literature 

review of meta-analyses on the subject of the effects of bullying on 

victims.2

 

2

Meta-analyses are reviews that analyze other studies and synthesize their findings, 

usually through quantitative methods.

The four surveys focused primarily on middle and high schoolaged youths and were conducted by federal statistical agencies from 

2005 to 2009. The results of the meta-analyses are not generalizable, but 

represent a systematic approach to summarizing or analyzing findings 

across studies included in the meta-analyses. To describe approaches 

that selected states and local school districts are taking, we reviewed 

relevant state bullying laws, regulations, guidance, and documents from 

eight selected states and conducted interviews with state education 

officials. We selected eight states—Arkansas, California, Illinois, Iowa, 

Massachusetts, New Mexico, Vermont, and Virginia—based on the 

following criteria: Each has bullying laws or regulations, and they vary 

with respect to bullying definitions and enumeration of protected classes, 

geographic variation, and student enrollment. Further, we selected three 

states—New Mexico, Vermont, and Virginia, which vary on the 

characteristics listed above—to review policies and guidance of six local 

school districts, two in each state. School districts and schools were 

selected to reflect a range of size and urbanicity (urban, suburban, and 

rural), as well as racial and socioeconomic diversity. Participation in the 

National School Lunch Program is used as a proxy for socioeconomic 

status. In these school districts, we conducted interviews with central 

administrators, principals, school staff, and parents. To identify legal 
 

Page 3 GAO-12-349 Bullying Prevention

options that federal and selected state governments have in place when 

bullying leads to allegations of discrimination, we reviewed relevant 

federal anti-discrimination laws, as well as state anti-discrimination laws 

for the eight states included for review. We also conducted interviews with 

officials in the Departments of Education (Education) and Justice 

(Justice), as well as with state education and civil rights officials, on antidiscrimination laws and complaint processes. Last, to identify 

coordination of efforts of key federal agencies to combat school bullying, 

we conducted interviews and reviewed documents from three federal 

departments: Education, Justice, and the Department of Health and 

Human Services (HHS). We analyzed coordination of efforts based on 

our professional judgment and relevance of selected key practices that 

we have previously identified as effective coordination practices.3

We conducted this performance audit from April 2011 through May 2012 

in accordance with generally accepted government auditing standards. 

These standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. For more information on our 

scope and methodology, see appendix I.

Although definitions vary, including definitions used by federal agencies, 

many experts generally agree that bullying involves intent to cause harm, 

repetition, and an imbalance of power. The pioneering research of Dr. 

Dan Olweus in Norway has defined being bullied or victimized as when a 

student “is exposed, repeatedly and over time, to negative actions on the 

part of one or more other youths” with an intent to harm.4

 

3

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, 

Notably, 

bullying is distinct from general conflict or aggression, which can occur 

absent an imbalance of power or repetition. For example, a single fight 

between two youths of roughly equal power is a form of aggression, but 

may not be bullying. When bullying occurs it may take many forms that 

can also be associated with conflict or aggression, including physical 

GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

4

Dan Olweus, “Annotation: Bullying at School: Basic Facts and Effects of a School Based 

Intervention Program,” Journal of Child Psychology and Psychiatry, vol. 35, no. 7 (1994).

Background 
 

Page 4 GAO-12-349 Bullying Prevention

harm, such as hitting, shoving, or locking inside a school locker; verbal

name calling, taunts, or threats; relational attacks, such as spreading 

rumors or isolating victims from their peers; and the use of computers or 

cell phones to convey harmful words or images, also referred to as 

cyberbullying. Often bullying occurs without apparent provocation and 

may be based on the victim’s personal characteristics. For example, 

youth may be bullied based on the way they look, dress, speak, or act.

There are several federal efforts under way to bring together federal 

resources that can be used to identify and address bullying. In particular, 

given their focus on education, health, and safety issues, Education, 

HHS, and Justice, along with other federal agencies, have been involved 

in efforts to help coordinate federal resources to identify and address 

bullying. Additionally, several bills have been introduced in the 112th 

Congress that relate to bullying.5 Among the various issues addressed in 

these bills are bullying policies, the collection and reporting of bullying 

data, and the prohibition of discrimination on the basis of sexual 

orientation or gender identity. Some of the bills would authorize federal 

grants to states and school districts for antibullying-related purposes. 

Although there is not presently a federal law directly targeted to address 

school bullying, several federal civil rights laws that prohibit discrimination 

based on protected characteristics of individuals may, under certain 

circumstances, be used to address particular incidents of bullying.6

With respect to states’ efforts to address bullying, Education 

commissioned a two-part study that examines the elements of state 

bullying laws and the manner in which school districts are implementing 

the laws. The first part of Education’s study, issued in December 2011, 

included a review of all state bullying laws and model policies in effect as 

of April 2011, including those of the eight states we reviewed, as well as 

policies from 20 large school districts. The second part of Education’s 

study is scheduled for completion during fall 2012. It will include case 

 

5

See, for example, S. 506 and H.R. 1648, the Safe Schools Improvement Act of 2011; S. 

540 and H.R. 1048, the Tyler Clementi Higher Education Anti-Harassment Act of 2011; S. 

555 and H.R. 998, the Student Non-Discrimination Act of 2011; S. 919, the Successful, 

Safe, and Healthy Students Act of 2011; H.R. 83, the Bullying Prevention and Intervention 

Act of 2011; and H.R. 975, the Anti-Bullying and Harassment Act of 2011. 

6

Throughout this report we use the terms “civil rights laws” and “anti-discrimination laws” 

interchangeably.
 

Page 5 GAO-12-349 Bullying Prevention

studies of how 24 schools, selected from four states, implement their 

states’ bullying laws.

Being bullied is a serious problem, as evidenced by four federally 

sponsored nationally representative surveys conducted from 2005 to 

2009. Estimates of the national prevalence of bullying ranged from 

approximately 20 to 28 percent of youth reporting they had been bullied 

during the survey periods, which ranged from a couple of months to a 

year.7 However, differences in definitions and survey methods make it 

difficult to draw definitive conclusions regarding trends and affected 

demographic groups. Our analysis and similar work from HHS’s Centers 

for Disease Control and Prevention (CDC), one of the sponsors of two of 

the surveys, showed that the surveys vary in the way they pose questions 

about being bullied and how bullying is defined, if at all.8

While it is clear that bullying is a serious problem, it is unclear from the 

surveys the extent to which bullying affects certain groups of youths 

relative to other groups. Specifically, the surveys collected information on 

the percentage of youths bullied based on gender and race. However, the 

information showed varying results. For example, there was no significant 

difference in the percentage of boys and girls that reported being bullied, 

Officials at 

Education, the sponsor of one of the surveys, and HHS also told us that 

different survey questions and definitions of bullying lead to different 

results in estimates of prevalence.

 

7

These estimates have a 95 percent confidence interval of within plus or minus 2.1 

percentage points.

8

CDC officials have documented the differences in the four nationally representative 

surveys, including estimates of prevalence, definitions and questions about bullying, and 

other differences in how the four surveys measure bullying. CDC, as part of a federal 

interdepartmental coordinating committee on bullying and its subcommittee on research, 

developed an analysis for internal purposes comparing the four surveys. According to 

CDC officials, the agency plans to post relevant information based on this analysis on its 

public website in the next few months. They added that CDC currently posts and updates 

some prevalence information on its public website on a fact sheet about bullying.

Reported Levels of 

Bullying and Related 

Effects Are 

Significant 

Federal Survey Data
 

Page 6 GAO-12-349 Bullying Prevention

according to two surveys, while one noted that girls were bullied at a 

higher percentage. In two of the three surveys, white youths reported 

being bullied at a higher percentage than African-American youths, while 

one other survey found no significant difference.

In addition, the four national surveys we identified did not consistently 

collect information about other demographic characteristics, making it 

impossible to determine percentages of bullying for these groups.9 For 

example, none of the surveys collected demographic information for 

youths by sexual orientation or gender identity.10 Researchers noted 

various challenges to obtaining such information, such as some schools 

may not permit questions on sexual orientation or gender identity status, 

potentially resulting in a sample that would not be nationally 

representative. Also, questions about sexual orientation or gender identity 

may be sensitive for youth respondents to complete, and researchers 

noted that such questions may not yield accurate information. 

Additionally, the surveys varied in whether or not they collected 

demographic information to allow for analysis based on religion, disability, 

or socioeconomic status, and two of the surveys did not include any 

questions asking specifically if youths had been bullied based on specific 

demographic characteristics. (See table 1.)

 

9

The National Crime Victimization Survey, School Crime Supplement 2009, asks youths 

about hate-related words directed at students based on their sexual orientation.

10According to a 2011 publication of the National Academy of Sciences’ Institute of 

Medicine, gender identity refers to one’s sense of gender (such as male or female or 

another gender such as transgender), whether or not associated with a person’s sex at 

birth. 
 

Page 7 GAO-12-349 Bullying Prevention

Table 1: Coverage of Demographic Groups in Federal Surveys of Youth

 

National Youth 

Risk Behavior 

Survey (YRBS) 

2009

National Crime 

Victimization Survey 

(NCVS), School Crime 

Supplement (SCS) 

2009a

Health Behavior in 

School-aged 

Children (HBSC) 

2005/2006

National Survey of 

Children’s 

Exposure to 

Violence 

(NatSCEV) 2008

Survey collected demographic information that allows for analysis to determine if differences in bullying exist between different 

demographic groups.

Sex yes yes yes yes

Race/ethnicity yes yes yes yes

Religion no no no no

Disability nob no no yes

Sexual orientation nob no no no

Gender identity nob no no no

Socioeconomic status no yes yes yes

Survey included question(s) that specifically ask about bullying based on the following demographic characteristics

Sex no yes yes no

Race/ethnicity no yes yes no

Religion no yes yes no

Disability no yes no no

Sexual orientation no yes no no

Gender identity no no no no

Socioeconomic status no no no no

Source: GAO analysis of surveys.

Note: See appendixes I through IV for more information on the four surveys.

a

Includes “hate-related” speech as form of bullying.

b

The YRBS includes optional questions about disability, sexual identity, and sexual contacts that state 

and school districts may choose to use.

While federal agencies have not collected information on some 

demographic groups, other researchers have attempted to fill the void. 

For example, the Gay, Lesbian and Straight Education Network (GLSEN) 

conducted a survey in the 2008-2009 school year and received 

responses from more than 7,000 students between the ages of 13 and 21 
 

Page 8 GAO-12-349 Bullying Prevention

who self-reported as not heterosexual.11 Although not nationally 

representative, the results found, among other things, that 85 percent of 

students who responded to the survey said they were called names or 

threatened at some point in the past school year based on their sexual 

orientation, and 64 percent based on their gender expression; for 

example, for not acting “masculine enough” or “feminine enough”.12 Forty

percent of students who responded said they were pushed or shoved 

based on their sexual orientation, and 27 percent based on their gender 

expression.13

In addition to the fact that there are voids in information about 

demographic groups, Education and HHS officials said that researchers 

need a uniform definition to measure bullying. To better understand the 

prevalence of bullying, and given the different definitions used by bullying 

research instruments, CDC is leading an interdepartmental project to 

develop a uniform definition of bullying for research purposes. According 

to CDC officials, a report is expected to be issued in 2012 that contains a 

uniform definition along with information on other data elements to 

measure bullying, such as the frequency or types of bullying behavior. 

According to CDC, the project on the uniform definition is still under 

review, but may contain data elements for a number of demographic 

characteristics, including sex, race, ethnicity, disability status, religion, 

and sexual orientation.

Research, spanning more than a decade, has demonstrated that bullying 

is associated with a variety of negative outcomes for victims, including 

psychological, physical, academic, and behavioral issues.14

 

11GLSEN used two approaches to invite lesbian, gay, bisexual, and transgender (LGBT) 

students to participate in the survey: outreach through community-based groups serving 

LGBT youth and outreach via the Internet.

For example, 

12According to another publication by GLSEN, “gender expression” refers to how one 

appears and acts, which are socially defined as masculine or feminine.

13Joseph G. Kosciw et al., “The 2009 National School Climate Survey: The Experiences of 

Lesbian, Gay, Bisexual and Transgender Youth in Our Nation’s Schools.” Gay, Lesbian 

and Straight Education Network: 2010. Available at http://www.glsen.org/cgibin/iowa/all/library/record/2624.html?state=research&type=research, last accessed May 

22, 2012.

14Some of the meta-analyses may refer to peer victimization. According to Education and 

HHS officials, peer victimization has substantial overlap with bullying.

Negative Outcomes from 

Bullying 
 

Page 9 GAO-12-349 Bullying Prevention

a 2000 analysis of 23 bullying research studies found that youth who 

were bullied experienced higher levels of depression, loneliness, low selfesteem, and anxiety than their peers who had not been bullied.15

Similarly, a 2010 analysis of 18 research studies found that being bullied 

was linked to increased psychological issues later in life.16 A third 

analysis, of 20 studies, published in 2011, found that being bullied was 

associated with greater likelihood of being depressed later in life.17

A 2009 analysis of 11 research studies found that bullying victims had a 

higher risk for such physical health outcomes as headaches, backaches, 

sleeping problems, and bad appetite, as compared with their peers who 

had not been bullied.18 Additionally, a 2010 analysis of 33 research 

studies on bullying and academic achievement found that bullying is 

related to concurrent academic difficulties for victims. Academic 

achievement was assessed based on such measures as grade point 

averages, standardized test scores, or teacher ratings of academic 

achievement.19 Researchers have also linked bullying to increases in 

behavioral problems for victims over time, such as aggression, 

delinquency, and truancy.20

 

15David S. J. Hawker and Michael J. Boulton, “Twenty Years’ Research on Peer 

Victimization and Psychosocial Maladjustment: A Meta-analytic Review of Cross-sectional 

Studies.” Journal of Child Psychology and Psychiatry, vol. 41, no. 4 (2000).

16Albert Reijntjes et al., “Peer Victimization and Internalizing Problems in Children: A 

Meta-analysis of Longitudinal Studies.” International Journal of Child Abuse & Neglect, 

vol. 34 (2010).

17Maria M. Ttofi et al., “Do the Victims of School Bullies Tend to Become Depressed Later 

in Life? A Systematic Review and Meta-analysis of Longitudinal Studies.” Journal of 

Aggression, Conflict and Peace Research, vol. 3, no. 2 (2011).

18Gianluca Gini and Tiziana Pozzoli, “Association Between Bullying and Psychosomatic 

Problems: A Meta-analysis,” Pediatrics, vol. 123, no. 3 (2009).

19Jonathan Nakamoto and David Schwartz, “Is Peer Victimization Associated with 

Academic Achievement? A Meta-analytic Review.” Social Development, vol. 19, no. 2 

(2010).

20Albert Reijntjes et al., “Prospective Linkages Between Peer Victimization and 

Externalizing Problems in Children: A Meta-analysis,” Aggressive Behavior, vol. 37, no. 3 

(2011). According to the authors, “[p]eer victimization can take various forms, including 

teasing, deliberate exclusion, being the target of malicious gossip, and experiencing 

physical threats or violence.” 
 

Page 10 GAO-12-349 Bullying Prevention

While researchers point out that the causes of suicide and violence are 

varied and complex, bullying has been identified as one risk factor 

associated with violent actions against oneself and others. For example, 

one 2011 analysis of 18 studies found that gay, lesbian, and bisexual 

youth were more likely to be verbally harassed and teased or physically 

and sexually victimized than heterosexual youth, and more likely to 

experience detrimental outcomes, such as suicidal thoughts and 

attempts.21 According to a federally sponsored website on bullying, 

specific groups have an increased risk of suicide, including American 

Indian and Alaskan Native, Asian-American, lesbian, gay, bisexual, and 

transgender youths. Their risk of suicide can be increased further by 

bullying. Bullying has also been linked to acts of violence against others. 

For example, a 2002 study by Education and the Secret Service reviewed 

37 incidents of school attacks and shootings occurring between 1974 and 

the end of the 2000 school year, and reported out 10 key findings that 

could be used to develop strategies to address targeted school violence. 

One of those 10 findings was that nearly three-quarters of attackers were 

bullied, persecuted, or injured by others prior to the attack, and that in 

several cases the bullying was severe and long-standing.22

According to Education, 49 states had school bullying laws as of April 

2012, including the 8 states that we reviewed. These 8 states’ laws vary 

 

21Alicia L. Fedewa and Soyeon Ahn, “The Effects of Bullying and Peer Victimization on 

Sexual-Minority and Heterosexual Youths: A Quantitative Meta-Analysis of the Literature,” 

Journal of GLBT Family Studies, vol. 7, no. 4 (2011).

22United States Secret Service and United States Department of Education, “The Final 

Report and Findings of the Safe School Initiative: Implications for the Prevention of School 

Attacks in the United States” (Washington, D.C.: May 2002). 

Selected State 

Legislatures and 

Educational Agencies 

Are Taking Various 

Approaches to 

Reduce Bullying

State Laws Vary in How 

They Address Bullying
 

Page 11 GAO-12-349 Bullying Prevention

in several ways, including who is covered and the requirements placed on 

state agencies and school districts.23 For example, the 8 states’ laws that 

we reviewed vary in whether and the extent to which they cover specific 

demographic groups, referred to as protected classes. Five states—

Arkansas, Illinois, Iowa, New Mexico, and Vermont—identify race, color, 

sex or gender, national origin or nationality, disability, sexual orientation, 

gender identity, and religion as protected classes.24 California includes all 

of these groups, except for color. Some states also prohibit bullying of 

other protected classes. For example, Illinois also includes as protected 

classes ancestry, age, and marital status. Virginia and Massachusetts do 

not include protected classes in their state bullying laws. According to 

Massachusetts officials, protected classes were intentionally omitted from 

the state’s law to ensure that all youths were equally protected. Within 

Massachusetts’ state educational agency (SEA), a specific office is 

designated to receive complaints, including from youths who have been 

bullied for any reason, such as obesity or socioeconomic status. 

Additionally, four of the states that identify protected classes—Arkansas, 

Illinois, Iowa, and New Mexico—provide that the list of classes is not 

exhaustive, so protection can be afforded to youths with characteristics 

not explicitly listed. For example, Iowa prohibits bullying “based on any 

actual or perceived trait or characteristic of the student.”25

 

23For the sake of simplicity, we refer to bullying laws throughout this section of the report. 

Such references, unless specified otherwise, are meant to broadly encompass such state 

provisions, whether they are found in state laws or regulations, and whether the state uses 

the terms “bullying,” “harassment,” or both. Vermont officials stressed to us that much of 

our discussion of their bullying laws applies to the provisions using the term “harassment,” 

which specify protected categories of students, as opposed to provisions using the term 

“bullying,” which do not specify protected classes. The bullying laws we reviewed include 

the following (with the relevant state in parentheses): Ark. Code Ann. § 6-18-514 

(Arkansas); Cal. Educ. Code §§ 201, 234.1, 234.3, 32261, 32270, 32280, 32281, 32282, 

48900, and 48900.4, Cal. Code Regs. tit. 5, § 4910 (California); 105 Ill. Comp. Stat. 5/10-

20.14 and 5/27-23.7 (Illinois); Iowa Code §§ 280.12 and 280.28 (Iowa); Mass. Gen. Laws 

ch. 71, §§ 37H and 37O (Massachusetts); N.M. Stat. Ann. § 22-2-21, N.M. Admin. Code 

tit. 6, §§ 6.12.7.7 and 6.12.7.8 (New Mexico); Vt. Stat. Ann. tit. 16, §§ 11, 14, 164, 165, 

565, and 1161a (Vermont); Va. Code Ann. § 22.1-279.6 (Virginia). 

In contrast, 

California’s bullying law is more exclusive and limits protection to only 

those groups that are listed in the law.

24While New Mexico’s law does not explicitly include gender identity, it does include 

sexual orientation, and according to a state official, these concepts were intended to be 

closely aligned.

25Iowa Code § 280.28(2)(b).
 

Page 12 GAO-12-349 Bullying Prevention

We also found that state laws impose various requirements on SEAs. For 

example, laws in California, Massachusetts, Vermont, and Virginia require 

that SEAs develop model bullying policies as a resource for school 

districts.26 Also, we found that while SEAs in Arkansas, California, and 

Illinois are required by law to review or monitor school district’s bullying 

policies, the approach taken to do so is different from state to state.27

In each of the states we reviewed, the laws require school districts to

adopt bullying policies or plans, but the states differed in the specific 

requirements of what must be included in these policies or plans.

For 

example, officials in Arkansas reported that as part of a broader effort to 

ensure that school districts’ policies align with federal and state laws, they 

conduct on-site reviews every 4 years, and require school districts to 

forward information to the Department of Education for review every year, 

including information about discipline and bullying policies. Conversely, 

an Illinois official reported that little meaningful oversight is occurring, in 

part because of resource constraints.

28 For 

example, of the 8 states’ laws we reviewed, 6 states require school 

districts to set forth a process for receiving and investigating complaints,

and 2 do not. Similarly, we found that 6 states’ laws require district 

policies to identify the consequences for bullies, while 2 do not. Table 2 

provides information about commonly required school district provisions 

in state bullying laws.

 

26Model policies may be used by local school districts as a guide in developing their 

policies, and may include procedures for reporting and investigating bullying behavior. 

While not required to do so by law, SEAs in Iowa and New Mexico also make model 

bullying policies available to school districts.

27Massachusetts and Vermont officials reported that they also review district policies, 

although not required by law to do so. Iowa officials review district policies as part of the 

state’s school accreditation process. New Mexico officials checked to ensure that school 

districts had policies.

28More broadly, Education’s review of state bullying laws found that 39 states require 

school districts’ policies to contain clear prohibitions against bullying. 
 

Page 13 GAO-12-349 Bullying Prevention

Table 2: Examples of Provisions Commonly Required by State Bullying Laws

Notification of 

policy to 

parents and 

youths

Consequences for 

engaging in bullying 

behavior must be 

articulated

Require that school 

employees report 

incidents or that schools 

have reporting procedures

Process for 

receiving and 

investigating 

complaints

Complainant will 

be protected from 

retaliation or 

reprisal

Arkansas Xa X X X X 

California X X X 

Illinois X X 

Iowa X X X X X 

Massachusetts X X X X X 

New Mexico X X X X X 

Vermont X X X X X 

Virginia X X 

Source: GAO review of relevant state bullying laws and regulations for the 8 states included in our review.

a

School district policies must require notice of what constitutes bullying, that bullying is prohibited, and 

the consequences of bullying be provided. Ark. Code Ann. § 6-18-514(e)(2)(G).

States are also making changes to their bullying laws, as evidenced by 4 

of our 8 selected states amending or enacting bullying laws since we 

began our study in the spring of 2011.29 For example, Arkansas, among 

other things, amended its law to include protected classes based on 

actual or perceived characteristics. Vermont amended its law to include 

protections against cyberbullying and incidents that do not occur during 

the school day on school property, or at school-sponsored events.

The six school districts we reviewed in New Mexico, Virginia, and 

Vermont have all adopted policies, plans, or rules, and implemented a 

range of approaches, to combat bullying. Among other components of the 

bullying policies and rules, each prohibits bullying and describes potential 

consequences for the behavior. Also, the school districts in New Mexico 

and Vermont developed policies and procedures covering the reporting 

and investigation of bullying behavior.

School district officials explained that they have developed several 

approaches to prevent and respond to bullying. For example, in five of the 

six school districts we visited, central administrators or principals said 

 

29These states are Arkansas, California, New Mexico, and Vermont.

Selected School Districts’ 

Antibullying Policies and 

Programs
 

Page 14 GAO-12-349 Bullying Prevention

they conduct student surveys that include questions about bullying to 

determine the prevalence of the behavior, and two administrators said the 

surveys are used to develop strategies to address the behavior. Also, 

officials from four of the six school districts said that several or all of their 

schools utilize the prevention-oriented framework Positive Behavioral 

Interventions and Supports (PBIS) to improve overall behavior in schools 

(see text box).30 Additionally, several school districts and schools use 

curricula that help youths develop interpersonal skills and manage their 

emotions, such as Second Step, a classroom-based social skills program 

for youths 4 to 14 years of age, and Steps to Respect, a bullying 

prevention program developed for grades three through six. Several 

central administrators and principals mentioned that antibullying-focused 

events have been held at their schools, such as Rachel’s Challenge and 

Ryan’s Story. Rachel’s Challenge is a program that seeks to create a 

positive culture change in schools and communities and begins with 

video/audio footage of Rachel Scott, the first person killed during the 

1999 Columbine High School incident. Ryan’s Story is a presentation that 

recounts the factors that led to the 2003 suicide of Ryan Halligan, a victim 

of both bullying and cyberbullying.

 

30PBIS is used by educators to improve overall school environments. PBIS’ focus on 

improving behavior, teaching social skills, and supporting academic achievement can help 

reduce bullying behavior. 
 

Page 15 GAO-12-349 Bullying Prevention

The Positive Behavioral Interventions and Supports framework utilizes evidence-based, 

prevention-oriented practices and systems to promote positive and effective classroom 

and school social cultures. According to Education’s Office of Special Education 

Programs, PBIS steps to addressing bullying behavior at school include the following:

• examining discipline data to determine, for example, the frequency, location, and 

timing of specific bullying behaviors;

• examining the extent to which staff members have, for example, actively and 

positively supervised all students across all school settings, had high rates of 

positive interactions and contact with all students, and arranged their instruction so 

all students are actively engaged, successful, and challenged ; and

• teaching students and staff common strategies for preventing and responding to 

bullying behavior, such as intervening and responding early and quickly to interrupt 

bullying behavior, removing what triggers and maintains bullying behavior, and 

reporting and recording when a bullying behavior incident occurs.

Students whose bullying behavior does not improve are considered for additional 

supports. For example, on the basis of the function of a student’s behavior, students 

would (1) begin the day with a check-in or reminder about the daily expectations; (2) be 

more overtly and actively supervised; (3) receive more frequent, regular, and positive 

performance feedback each day; and (4) conclude each day with a checkout or 

debriefing with an adult.

Source: National Technical Assistance Center on Positive Behavioral Interventions & Supports. 

In addition to mentioning efforts focused on youths, several central 

administrators and principals said that teachers receive some bullying 

prevention guidance or training. Information about bullying prevention is 

also shared with parents during workshops and forums. For example, one 

official mentioned that Rachel’s Challenge includes a session with 

parents and community leaders. A parent said that his school district 

hosted a national speaker to share information with parents about 

bullying.

Both state and local officials expressed concerns about various issues 

associated with implementing state bullying laws, regulations, and local 

policies and codes of conduct. For example, administrators and principals 

reported that determining how to respond to out-of-school incidents, such 

as cyberbullying, is challenging. Administrators and principals said that 

sometimes they are not informed of incidents in a timely manner, resulting 

in a delayed response. Additionally, some parents discourage school 

officials’ involvement in out-of-school incidents. However, administrators 

and principals agreed that when out-of-school incidents affect school 

climate, the behavior has to be addressed.

Another issue of concern for both state and local officials is that parents 

and youths can confuse conflict with bullying. According to the state and 

local officials that we spoke with, they spend a lot of time on nonbullying 

State and Local Officials 

Cited Concerns That 

Hinder Antibullying Efforts
 

Page 16 GAO-12-349 Bullying Prevention

behavior and more could be done to educate parents and youths on the 

distinction between bullying behavior and other forms of conflict. On a 

related matter, state and local officials said that it is important to train 

teachers and staff to prevent, identify, and respond to bullying behavior. 

However, according to these officials, because of state budget cuts and 

the elimination of some federal funding that could be used for bullying 

prevention activities, there is little funding available for training. State 

officials specifically cited the loss of funding from Title IV, Part A of the 

Elementary and Secondary Education Act of 1965, as amended, which 

among other things could be used to prevent violence in and around 

schools. According to federal officials, funding for this program was 

eliminated in 2009.

When bullying rises to the level of discrimination, federal civil rights laws 

may be used to provide redress to individuals in legally protected groups. 

Federal civil rights laws protect against discrimination based on sex, race, 

color, national origin, religion, or disability. However, federal agencies 

generally lack jurisdiction to address discrimination based on 

classifications not protected under federal civil rights statutes. For 

example, federal agencies lack authority to pursue discrimination cases 

based solely on sexual orientation.

Additionally, federal civil rights laws do not cover all youths in all 

educational settings, and as a result, where a student goes to school 

could affect the student’s ability to file a claim of discrimination with the 

federal government. For example, Title IV of the Civil Rights Act of 1964 

Federal and State 

Civil Rights Laws 

Offer Some 

Protections against 

Bullying, but 

Vulnerable Groups 

May Not Always Be 

Covered 

Federal Civil Rights 

Protections 
 

Page 17 GAO-12-349 Bullying Prevention

(Title IV) prohibits discrimination in public schools and institutions of 

higher learning.

31 Since Title IV is the only federal civil rights law 

addressing religious discrimination in educational settings, only youths at 

public schools and public institutions of higher learning, where Title IV 

applies, could file such a claim. Youths who attend public schools or other 

schools receiving federal education funding and who belong to other 

federally protected classes may have the option to file a complaint with 

Education, Justice, or both departments, depending on which agency has 

enforcement authority.32 See table 3 for the relevant federal civil rights 

laws, protected classes, and agency enforcement authority.

 

3142 U.S.C. §§ 2000c, 2000c-6.

32Persons in protected classes who have been bullied or harassed and believe they are 

victims of discrimination may be able to file a complaint with Education or Justice. 

According to Education officials, their department investigates all complaints it receives for 

which it has jurisdiction. Justice officials stated that because they have far fewer staff than 

Education, they must use their available resources in a targeted way. According to Justice

officials, the department is not statutorily required to investigate every complaint and thus 

evaluates complaints they receive to identify those that involve pressing matters or novel 

legal questions requiring government involvement. When either an Education or Justice 

investigation determines that civil rights violations have occurred, they first try to work with 

the institution to develop a voluntary resolution—Education through resolution agreements 

and Justice through negotiated settlements. When Justice enters into a settlement 

agreement, it can do so in conjunction with or following the filing of a complaint in federal 

court, or the settlement can be entered into out of court. Resolution agreements and 

settlements may require that, among other things, school districts revise their policies and 

publicize them to schools and communities, conduct training of staff and students, and/or 

collect and report data. In instances where resolution agreements and settlements are not 

reached or complaints are not otherwise resolved, Justice could engage in litigation in 

federal court. According to Education officials, since they have a high level of voluntary 

compliance, they generally do not need to refer complaints to Justice for litigation. As an 

alternative to initiating litigation, Justice may also intervene in a private lawsuit or file 

amicus briefs on behalf of the United States.
 

Page 18 GAO-12-349 Bullying Prevention

Table 3: Relevant Federal Civil Rights Laws, Protected Classes, and Agency Enforcement Authority

Protected 

class Applicable federal law Settings where discrimination is prohibited

Agency with 

enforcement 

authority

Sex Title IX of the Education Amendments of 

1972 (Title IX)a Education programs and activities receiving 

federal financial assistance. 

Education and Justice

Title IV of the Civil Rights Act of 1964 (Title 

IV)b Public schools and public institutions of higher learning.

Justice

Race, color, or 

national origin

Title VI of the Civil Rights Act of 1964 (Title 

VI)c Programs and activities receiving federal 

financial assistance. 

Education and Justice

Title IV of the Civil Rights Act of 1964 (Title 

IV)b Public schools and public institutions of higher 

learning.

Justice

Religion Title IV of the Civil Rights Act of 1964 (Title 

IV)b Public schools and public institutions of higher learning.

Justice

Disability Section 504 of the Rehabilitation Act of 

1973 (section 504)d Programs and activities receiving federal 

financial assistance or conducted by an 

executive agency (such as Education). 

Education and Justice

Titles II and III of the Americans with 

Disabilities Act of 1990 (ADA)e 

Title II prohibits discrimination by public entities, 

including public schools. Title III prohibits 

discrimination by places of public 

accommodation, including private schools. 

Education (Title II) 

and Justice (Titles II 

and III)

Source: GAO analysis of relevant federal laws and information from Education and Justice.

a

20.U.S.C. § 1681 et seq.

b

42 U.S.C. § 2000c et seq.

c

42 U.S.C. § 2000d et seq.

d

29 U.S.C. § 794.

e

Title II: 42 U.S.C. § 12131 et seq.; Title III: 42 U.S.C. § 12181 et seq.

In addition to those groups explicitly enumerated in federal civil rights 

laws, protections have been applied to other classes of youth in some 

situations. For example, Titles IV and IX, which prohibit discrimination 

based on sex, have been interpreted, in certain circumstances, to apply to 

discrimination based on gender identity. However, Titles IV and IX have 

not been used to address discrimination based solely on sexual 

orientation. Justice officials explained that youths who are discriminated 

against based on gender identity are generally protected under Titles IV 

and IX, as discrimination based on gender identity is a form of sex 

discrimination. They explained that sexual orientation, on the other hand, 

is not covered under Titles IV or IX. According to Education and Justice 

officials and some court decisions, however, youths bullied on the basis 

of actual or perceived sexual orientation may have some protection under 
 

Page 19 GAO-12-349 Bullying Prevention

Titles IV and IX if there is overlapping gender-based discrimination.33 For 

example, in Montgomery v. Independent School District No. 709, the U.S. 

District Court for the District of Minnesota addressed the issue of sexual 

orientation discrimination in the Title IX context.34 In Montgomery, a male 

student claimed that he was verbally and physically abused by other 

youths because he did not meet their stereotyped expectations of 

masculinity and because they perceived him to be gay. The court held 

that the student’s claim of sexual orientation discrimination was not 

actionable under Title IX because sexual orientation is not a protected 

characteristic under Title IX.35 On the other hand, however, the court 

found that a discrimination claim based on a failure to meet gender 

stereotypes was permissible under Title IX.36

Little is known about the extent to which students belonging to various 

demographic groups not covered by federal civil rights laws are being 

discriminated against because they either do not file claims or, when they 

file claims, information about those claims is not routinely collected or 

tracked. Victims of bullying who are members of a protected class and 

feel that they have been discriminated against can generally file a 

complaint with Education or Justice. According to Education’s guidance, 

individuals must generally file complaints with Education within 180 days 

of the latest incident, whereas no time limitations apply for filing 

complaints with Justice.37

 

33According to Justice officials, all students, including LGBT students, are protected from 

gender-based discrimination, including discrimination based on gender stereotypes.

Education and Justice differ in their approaches 

to processing complaints and levels of staff resources to investigate 

complaints of discrimination. In general, Education resolves complaints 

through a formal administrative process, and while both Education and 

Justice investigate complaints, Justice negotiates and, if necessary, 

litigates in federal courts. According to Education and Justice officials, an 

important difference in their approaches to handling discrimination 

34109 F. Supp. 2d 1081 (2000).

35Id. at 1090.

36Id. at 1092.

37According to OCR’s case processing manual, a complaint must be filed within 180 

calendar days of the date of the alleged discrimination, unless the time for filing is 

extended by Education’s Office for Civil Rights for good cause shown under certain 

circumstances.
 

Page 20 GAO-12-349 Bullying Prevention

complaints is partly due to Education’s greater staff resources. 

Education’s Office for Civil Rights has roughly 400 staff, and Justice’s 

Civil Rights Division, Educational Opportunities Section, has about 20 

attorneys. According to departmental officials, Education investigates all 

complaints it receives for which it has jurisdiction. Conversely, Justice 

selects a limited number of complaints to review based on such factors as 

the severity of the complaint and whether the federal government has a 

special interest in the case. Additionally, officials from Education and 

Justice told us that they collaborate closely. Generally, Justice and 

Education share information about complaints because they may have 

overlapping jurisdiction, and try to coordinate efforts where feasible.

Education and Justice do not currently have a systematic approach for 

tracking information about the number of cases related to various 

demographic groups that they do not have jurisdiction to address. The 

U.S. Commission on Civil Rights, in a 2011 report on the protections of 

federal anti-discrimination laws relating to school bullying, recommended 

that Justice and Education, among other things, track dismissed civil 

rights claims by various demographic characteristics. However, Education 

and Justice officials told us that as part of their complaint review 

processes, they focus on collecting information to establish federal 

jurisdiction, and as a result neither department collects information in a 

way that would allow them to routinely assess the demographic 

characteristics of cases where they lack jurisdiction. Thus, they do not 

plan to address the commission’s recommendation. Additionally, 

according to officials from both departments, attempting to track such 

information would be problematic because of difficulties in ascertaining 

demographic information. They also believe the information could be 

misleading. According to Justice officials, they dedicate significant 

resources to outreach designed to educate communities on their 

jurisdiction, and this may impact the number of complaints they receive 

from demographic groups that fall outside of their jurisdiction.

We found that some states’ civil rights laws extend beyond the 

protections afforded at the federal level, but information about the 

possibility of pursuing claims at the state level was not always provided to 

federal complainants. For all eight states we reviewed, state antidiscrimination laws, like federal civil rights laws, provide protections for 

individuals who are discriminated against on the basis of sex, race, 

State Civil Rights 

Protections 
 

Page 21 GAO-12-349 Bullying Prevention

national origin, religion, and disability, and in all but Arkansas, color.38

The majority of the eight states that we reviewed include in their antidiscrimination laws protections for various groups of people who are not 

explicitly covered at the federal level. For example, six of the eight states 

we reviewed prohibit discrimination on the basis of sexual orientation,

Thus, in these eight states, for these protected classes, legal action can 

generally be taken at the federal, state, or both levels.

39

and five of the eight states prohibit discrimination on the basis of gender 

identity.40 Beyond these protected classes, most states we reviewed also 

prohibit discrimination on the basis of other personal characteristics, such 

as marital status. California is unique among the states in our review in 

that its anti-discrimination laws explicitly protect individuals on the basis of 

citizenship, gender-related appearance and behavior, and individuals who 

are associated with a person with (or perceived to have) a protected 

characteristic.41

Education officials told us they sometimes provide information on state 

civil rights laws to complainants on an informal basis, but not as a matter 

of routine. For example, these officials said that a federal complainant 

However, because some characteristics are not explicitly 

protected under anti-discrimination laws at either the federal level or in 

the states we reviewed, youths in these states who are bullied on the 

basis of one of these characteristics would have no recourse under civil 

rights law at either level. For example, state education and civil rights 

officials mentioned that anti-discrimination laws generally do not apply to 

youths who were bullied based on their socioeconomic status or obesity.

 

38The state civil rights laws we reviewed include the following (with the relevant state in 

parentheses): Ark. Code Ann. §§ 16-123-101 through 16-123-108 (Arkansas); Cal. Educ. 

Code §§ 200 et seq., 210 et seq., 220 et seq., and 260 et seq. (California); 775 Ill. Comp. 

Stat. 5/5-102, 5/5A-102, and 5/1-103 (Illinois); Iowa Code § 216.9 (Iowa); Mass. Gen. 

Laws ch. 76, § 5, ch. 71B, § 2 (Massachusetts); N.M. Stat. Ann. § 28-1-1 et seq. (New 

Mexico); Vt. Stat. Ann. tit. 9, §§ 4500-4507 (Vermont); Va. Code Ann. § 2.2-3900 et seq. 

(Virginia). In some of the states these laws apply only in the education context, while in 

others they apply more broadly. We only analyzed these laws in the education context, 

and make no assessment of how they might apply in other areas.

39The six states are California, Illinois, Iowa, Massachusetts, New Mexico, and Vermont. 

40The five states are California, Illinois, Iowa, New Mexico, and Vermont. In addition, 

Massachusetts recently passed a law prohibiting discrimination based on gender identity, 

and that law will take effect in July 2012.

41Cal. Ed. Code §§ 210 et seq., 220.
 

Page 22 GAO-12-349 Bullying Prevention

who withdraws his or her complaint may be informed in a phone 

discussion about legal options at the state level. Also, officials said that if 

a complaint reaches the stage of a dismissal, Education’s letter to the 

complainant sometimes suggests that the claimant might have a claim 

under state civil rights law, along with the name and address of the 

relevant state agency. However, according to Education officials, when 

the agency lacks jurisdiction, it does not presently notify complainants 

about the availability of possible recourse under state law on a routine 

basis. As a result, individuals who file complaints with Education may not 

be fully aware of their legal options. On the other hand, according to 

Justice officials, department officials routinely share with complainants 

that they may have legal options available to them through their state’s 

civil rights laws. While not specific to particular states and their laws, 

Justice provides a general notification in letters to complainants for 

complaints they do not pursue.

Education, HHS, and Justice have established coordinated efforts to carry 

out research and broadly disseminate information on bullying. Education 

has also provided key information about how federal civil rights laws can 

be used to address bullying and is conducting a study of state bullying 

laws and how selected school districts are addressing bullying. Three 

federal efforts, in particular—formation of a coordinating committee, 

establishment of a central website, and an informational campaign—have 

provided the public with a range of information about bullying, through a 

variety of media.

The Federal Partners in Bullying Prevention Steering Committee serves 

as a forum for federal agencies to develop and share information with 

each other and the public. The committee was created in 2009 and is 

composed of the Departments of Education, HHS, Justice, Agriculture, 

Coordinated Federal 

Antibullying Efforts 

Are Under Way, but 

Assessment of Legal 

Remedies Is 

Incomplete 

Federal Coordination 

Efforts 

Coordinating Committee to 

Promote Collaboration on 

Bullying across the Federal 

Government
 

Page 23 GAO-12-349 Bullying Prevention

Defense, and Interior, along with the Federal Trade Commission, the 

National Council on Disability, and the White House Initiative on Asian 

Americans and Pacific Islanders. Among other activities, the coordinating 

committee helped to plan a conference on bullying in March 2011 hosted 

by the White House, as well as annual conferences of the coordinating 

committee in August 2010 and September 2011. Following each annual 

conference, the committee has developed priorities and formed 

subcommittees to address those priorities. For example, after identifying 

a need for better coordination of bullying research, a research 

subcommittee was created after the August 2010 conference. Following 

the September 2011 conference, this subcommittee’s activities in the 

upcoming year will also include identifying best practices for training 

teachers as well as drawing attention to programs that could help youths 

develop interpersonal skills and manage their emotions.

The three federal departments, along with the White House, established a 

central federal website (www.stopbullying.gov, last accessed May 22, 

2012), launched in March 2011 at the White House conference on 

bullying. The central website sought to consolidate the content of different 

federal sites into one location to provide free materials for the public. 

Hosted by HHS, with content and technical support from the Health 

Resources and Services Administration (HRSA), the website aims to 

present a consistent federal message and features content arranged by 

target audience, such as teens, along with sections on special topics such 

as cyberbullying.

HHS through HRSA launched the informational campaign called Stop 

Bullying Now! in 2004. Federal departments outside HHS that assist with 

the campaign include the Departments of Education, Justice, Agriculture, 

Defense, and Interior. The campaign is designed for youth and adults to 

raise awareness, foster partnerships, and disseminate evidence-based 

findings to help prevent and intervene in instances of bullying. The 

informational campaign offers a variety of free materials, including a DVD 

with 14 cartoon episodes, 30 tip sheets based on research and evidencebased practices, public service announcements, posters, brochures, 

comic books, and kits for youth leaders and adults. According to data 

from HRSA as of August 2011, recipients of materials in mass mailings 

included, among others, all 66,000 public elementary and middle schools 

in the country, 17,000 libraries, relevant state health and education 

agencies, offices serving Indian and military youth, 4,000 Boys and Girls 

Clubs, relevant state health and education agencies, schools on military 

bases worldwide, and offices serving American Indian youth. (See app. V 

for more information on the campaign.) However, according to HHS 

Central Website to Provide 

Consistent Federal Information 

to the Public

Informational Campaign to 

Raise Awareness about 

Bullying
 

Page 24 GAO-12-349 Bullying Prevention

officials, the campaign and its online content are currently in a period of 

transition, as they adapt to the new interdepartmental website and its 

governance.

While these efforts are still evolving, we found that they are consistent 

with key practices that we determined can help or sustain coordination 

efforts across federal agencies.42

In addition to these collaborative agency efforts to share information 

about bullying, Education has disseminated information about federal civil 

rights laws that can be used to address bullying, and key components of 

state bullying laws. In October 2010, Education sent a letter to state and 

local education officials outlining how federal civil rights laws can be 

applied to bullying. The letter stated that student misconduct may trigger 

school responsibilities under federal civil rights laws and provided 

examples of behavior that may meet the threshold for violating the laws. 

In December 2010, the department issued another letter that summarized 

several key components of state bullying laws, such as specifying 

prohibited behavior, development and implementation of school district 

policies, and training and preventive education. As previously discussed, 

following up on this letter, the department commissioned a study of state 

bullying laws to determine the extent to which states and school districts 

incorporate the key components into their laws and policies. In December 

2011, Education issued the first part of this two-part study on state 

bullying laws.

Specifically, we found that in each of 

these three efforts that key agencies reached agreement on roles and 

responsibilities. For example, the roles and responsibilities of the federal 

agencies responsible for stopbullying.gov are spelled out in a governance 

document, and the lead agency, HHS, for this website has executed 

agreements to provide funding for the maintenance and operation of the 

website. Similarly, we found that these agencies worked to establish 

compatible policies and procedures, and to develop mechanisms to 

monitor progress for these coordinated efforts. Appendix V provides more 

information on federal coordination efforts on bullying.

43

 

42GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

43U.S. Department of Education, Office of Planning, Evaluation and Policy Development, 

Policy and Program Studies Service. Analysis of State Bullying Laws and Policies

(Washington, D.C.: 2011). 
 

Page 25 GAO-12-349 Bullying Prevention

While Education, HHS, and Justice have initiated several efforts to better 

inform the public about how to utilize federal, state, and other resources 

to better address bullying, none of these efforts include an assessment of 

state civil rights laws and procedures for filing complaints. Since some 

states’ civil rights laws provide protection for groups not named in 

applicable federal civil rights laws, collection and dissemination of such 

information could assist in better understanding how these laws vary in 

coverage and in the procedures states have in place for filing complaints. 

For example, five states in our review—California, Illinois, Iowa, 

Massachusetts, and Vermont—have established processes and 

procedures for resolving civil rights complaints, and have empowered a 

statewide organization with the authority to hold schools and school 

districts accountable when discrimination is found, according to state 

officials. Specifically, according to a state official, California’s Uniform 

Complaint Process empowers its Department of Education’s Office of 

Equal Opportunity to ensure compliance with state and federal civil rights 

laws. California’s state code also requires uniform complaint procedures 

that each school district within the state must follow when addressing 

complaints of discrimination against protected groups, according to a 

state official. The complaint process allows up to 60 days for an 

investigation and decision to be rendered at the district level, unless a 

child is directly in harm’s way and the school district is unresponsive, in 

which case a complaint can be filed directly with the state. In Vermont, 

the state’s Human Rights Commission acts as an independent agency 

focused solely on the protection of civil rights, and if its investigation 

determines unlawful discrimination occurred, the agency assists the 

parties in negotiating a settlement. Human Rights Commission officials 

told us if a settlement cannot be reached, the agency may choose to take 

the case to court. However, they said that this usually does not happen 

because cases are generally settled. The Massachusetts Department of 

Elementary and Secondary Education has a formal process called the 

Problem Resolution System that handles complaints that allege a school 

or a district is not meeting legal requirements for education, including 

complaints of discrimination. In each of the five states with established 

processes and procedures for resolving civil rights complaints, the SEAs 

include information on their websites about the civil rights complaint 

process, including where to file, required information, and time frames.

According to their respective state officials, Arkansas and New Mexico 

offer only limited legal options for protected classes with complaints of 

discrimination based on school bullying because they lack a state entity 

with the authority to investigate and hold school districts accountable for 

such complaints. Although Arkansas has an Equity Assistance Center 

No Assessment of State 

Civil Rights Laws and 

Procedures Has Been 

Performed
 

Page 26 GAO-12-349 Bullying Prevention

within its Department of Education that can serve as an intermediary 

between the complainant and the school district, its decisions lack the 

authority to discipline a school district, according to state officials. New 

Mexico has a human rights commission that receives and investigates 

complaints of discrimination based on protected classes, but the 

commission is focused on employment issues and does not address 

discrimination complaints related to education. As a result, the state lacks 

formal processes and procedures to address complaints of discrimination 

stemming from instances of bullying, according to state officials. 

Therefore, according to state officials from these two states, if an 

individual cannot afford an attorney to file a private right of action related 

to complaints of discrimination because of school bullying, the individual’s 

only legal option is to file a federal complaint.

By not incorporating an assessment of state civil rights laws and 

procedures into their various bullying prevention efforts, federal agencies 

are overlooking a potentially important source of information. Building on 

information from Education’s study of state bullying laws and the letters 

they issued on federal civil rights laws, information on state civil rights 

laws and procedures would provide a broader and more complete 

perspective of the overall coverage of federal and state efforts to prevent 

and address bullying.

Students who are bullied may seek recourse through a number of 

avenues—local and state educational policies, state bullying laws, state 

civil rights laws, or federal civil rights laws. However, the nature and 

extent of protections available to them depend on the laws and policies of 

where they live or go to school. Education and Justice have taken 

important steps in assessing how federal civil rights laws can be used to 

help combat certain instances of bullying of protected classes of youth for 

which they have jurisdiction. And Education has completed a study of 

state bullying laws and is conducting another study looking at how school 

districts are implementing these laws. However, neither Education nor 

Justice has assessed state civil rights laws and procedures as they may 

relate to bullying. Many of the states’ civil rights laws we reviewed extend 

protections to classes of individuals beyond the groups protected at the 

federal level, but states vary in the groups that are explicitly protected; 

therefore, whether bullying victims have any recourse through civil rights 

laws can depend on the state in which they live or go to school. Also, 

states vary in their procedures for pursuing civil rights claims, which could 

also affect the ability to pursue a bullying-related discrimination claim.

State civil rights laws, just like federal civil rights laws and state bullying 

Conclusions 
 

Page 27 GAO-12-349 Bullying Prevention

laws, can play an important role in addressing this important issue. More 

information about state civil rights laws and procedures is a key missing 

link and is needed by administration officials and decision makers alike, to 

understand the potential overall legal protections available to students 

who have been bullied.

Federal claimants would also benefit from knowing that options may be 

available to them at the state level. This is particularly key when cases 

are dismissed at the federal level because of a lack of jurisdiction. While 

Justice routinely informs individuals when their complaints are dismissed 

because of a lack of jurisdiction of possible recourse under their state civil 

rights laws, Education does not. Routinely making this basic information 

available would be another key step in helping ensure that bullying 

victims are aware of some of the legal options available to them.

Multiple efforts to collect information about bullying have been under way 

for several years; however, the prevalence of bullying of youths in certain 

vulnerable demographic groups is not known. A greater effort by key 

federal agencies to develop more information about the extent to which a 

broader range of demographic groups are subject to bullying and bullyingrelated discrimination would better inform federal efforts to prevent and 

remedy bullying. Understanding the prevalence of bullying by 

demographic groups would help administration officials develop additional 

actions targeted at the greatest areas of need. This information, together 

with an assessment of federal and state legal protections, could also aid 

policymakers in determining whether additional actions are needed to 

protect vulnerable groups of youths who are subjected to bullying.

To allow for a more comprehensive assessment of federal and state 

efforts to prevent and address bullying, we recommend the Secretary of 

Education, in consultation with the Attorney General, as appropriate,

compile information in a one-time study—similar to its study of state 

bullying laws—about state civil rights laws and procedures, as they may 

pertain to bullying.

In order to better ensure that individuals are aware of their options to seek 

legal redress, especially in cases where their complaints to Education are 

not pursued because of a lack of jurisdiction, we recommend that the 

Secretary of Education develop procedures to routinely inform individuals 

who file complaints of discrimination stemming from bullying about the 

potential availability of legal options under their state’s anti-discrimination 

laws.

Recommendations for 

Executive Action
 

Page 28 GAO-12-349 Bullying Prevention

To address gaps in knowledge about targets of bullying and 

discrimination, we recommend that the Secretaries of Education and HHS 

and the Attorney General work together to develop information in their 

future surveys of youths’ health and safety issues on the extent to which 

youths in various vulnerable demographic groups are bullied.

To aid policymakers and program administrators at the federal and state 

levels in understanding more comprehensively what is being done to 

address bullying and discrimination, we recommend that the Secretaries 

of Education and HHS and the Attorney General, in conjunction with the 

Federal Partners in Bullying Prevention Steering Committee, assess the 

extent to which legal protections against bullying exist for vulnerable

demographic groups. Such an assessment, to be comprehensive, should 

make use of information federal agencies have already compiled on state 

bullying laws and federal civil rights laws together with information from 

our recommendations above to compile information on state civil rights 

laws and collect more information on demographic groups in federal 

surveys of youth health and safety issues.

We provided Education, HHS, and Justice an opportunity to comment on 

a draft of this report. Education and HHS provided written responses, 

which appear in appendixes VII and VIII, respectively. Each of the 

agencies provided technical comments, which we incorporated as 

appropriate. Justice chose not to provide a written response.

Education disagreed with our recommendation that it compile information 

about state civil rights laws and procedures as they pertain to bullying.

Specifically, Education noted that it does not have jurisdiction over state 

civil rights laws, nor the appropriate expertise, to interpret and advise on 

these laws. The department stressed that its previous analysis of state 

bullying laws was limited to compiling a list of statutes or regulations and 

identifying key components of statutes and regulations. Further, 

Education suggested that compiling information about state civil rights 

laws and procedures would only be useful if kept current, and that 

undergoing such a time-intensive and costly survey and review of state’s 

civil rights laws would not be an appropriate use of the department’s 

limited resources.

We continue to believe that a one-time compilation of state civil rights 

laws and procedures would be beneficial, and provide a basis, along with 

other information, for analyzing the overall legal protections that are 

available for vulnerable demographic groups. Such an assessment would 

Agency Comments
 

Page 29 GAO-12-349 Bullying Prevention

help determine the extent to which states are positioned to respond to 

these types of civil rights complaints and to identify those instances where 

certain students are left with little recourse to pursue discrimination claims 

simply because of the state in which they reside or go to school. While we 

appreciate the work involved in any analysis of state laws, we believe that 

Education can develop a methodological approach that would limit the 

scope of their work and hone in on those aspects of civil rights laws that 

come into play when bullying leads to allegations of discrimination. For 

example, this review could be limited to compiling basic information about 

state civil rights laws, such as which protected classes are included and 

whether they apply in educational settings, and may not require an 

extensive analysis of state case law. In implementing a study of this type, 

Education may consider approaches similar to those they used in their 

previous work on state bullying laws. Alternatively, Education officials 

could choose to rely on the knowledge and expertise of cognizant state 

officials by conducting a survey or otherwise soliciting pertinent 

information, rather than undertaking the bulk of this work themselves. We 

acknowledge Education’s concerns regarding keeping the information on 

state civil rights laws updated and have modified language in the report 

and our recommendation to clarify that this is meant to be a onetime 

effort.

Regarding our second recommendation, Education indicated that they are 

considering whether to develop procedures that would inform 

complainants whose complaints are dismissed for lack of jurisdiction that 

they may have possible recourse under state or local laws. We 

encourage Education to review the language that Justice currently 

includes in similar notification letters. As Education suggested, more 

detailed guidance regarding rights and procedures for seeking redress 

may then be provided by state and local agencies.

Both HHS and Education agreed with our recommendation that they 

develop additional information in their surveys about youths in various 

vulnerable groups who are bullied.

In response to our recommendation that Education, HHS, and the 

Attorney General assess the extent to which protections exist for various 

demographic groups likely to be the target of bullies, HHS agreed with the 

recommendation and Education cited many of its ongoing efforts to this 

end. We commend Education on its current efforts as well as other efforts 

we have discussed in our report. However, as we point out in our 

previous recommendations, more information is needed on state civil 

rights laws as well as about how various demographic groups are 
 

Page 30 GAO-12-349 Bullying Prevention

affected by bullying. Utilizing all of the information at their disposal, 

including information we recommend be collected, Education, HHS, and 

Justice could work together to assess how well the available laws and 

resources address areas of need and identify measures that could be 

taken to help prevent bullying. We believe that it is an important step to 

assimilate information on resources and laws with research about areas 

of need in order to assist federal policy makers and agency officials in 

their efforts to address this important issue. Based on questions we 

received during discussions with Justice on our report, we modified this 

recommendation to clarify that such an assessment should make use of 

information from our previous recommendations in this report, as well as 

information that federal agencies have already gathered, and that the 

three agencies in our review could work through the Federal Partners in 

Bullying Prevention Steering Committee to conduct such an assessment.

As agreed with your offices, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the

report date. At that time, we will send copies to the Secretaries of 

Education, and Health and Human Services, and the Attorney General; 

relevant congressional committees; and other interested parties. In 

addition, the report will be available on GAO’s website at 

http://www.gao.gov. 

If you or your staff have any questions about the report, please contact 

me at (206) 287-4809 or calboml@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff that made major contributions to this report 

are listed in appendix IX.

Linda M. Calbom

Western Regional Director 
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-12-349 Bullying Prevention

To obtain information on the prevalence of school bullying of victims in 

the United States, we primarily compared estimates and methodologies of 

available data on being bullied in four nationally representative surveys by 

federal statistical agencies conducted from 2005 to 2009. Specifically, we 

compared data on being victims of bullying from the Youth Risk Behavior 

Survey, the School Crime Supplement to the National Crime Victimization 

Survey, the Health Behavior in School-aged Children Survey, and the 

National Survey of Children’s Exposure to Violence (see table 4). We 

selected these surveys based on interviews with officials at the 

Departments of Education (Education), Health and Human Services 

(HHS), and Justice (Justice), as well as the similar work of the Centers for 

Disease Control and Prevention (CDC) on this topic that compared the 

four surveys. We evaluated these federal surveys for methodological 

rigor, as well as to determine the extent to which the data could be used 

to offer a national perspective on bullying in schools. This included 

interviews with researchers, as appropriate. We determined that the data 

were sufficiently reliable for our purposes. Because the survey data were 

collected using generalizable probability samples, this sample is only one 

of a large number of samples that might have been selected. Since each 

sample could provide different estimates, we have used 95 percent 

confidence intervals to show the precision of our results. All percentage 

estimates used in this report have 95 percent confidence intervals of 

within plus or minus 2.1 percentage points, unless otherwise noted. In 

addition to sampling error, surveys are subject to nonsampling error, such 

as how respondents interpret questions, including any biases or 

tendencies to provide desirable answers or false answers. Although 

respondents self-reported being bullied in the surveys, this approach to 

measure the prevalence of bullying is viewed as valid and robust, 

according to some previous research on bullying. We also reviewed 

certain other relevant research as appropriate. Finally, we conducted 

interviews with officials at Education and HHS to obtain information about 

how different surveys and research define bullying and their efforts to 

develop a uniform definition of bullying for research purposes.

Appendix I: Objectives, Scope, and 

Methodology 

Analysis of Surveys 

and Literature Review
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-12-349 Bullying Prevention

Table 4: Nationally Representative Surveys We Reviewed That Ask about Youths Being Bullied, among Other Topics

Survey Sponsoring federal agency Purpose

Age/grade of 

youth surveyed 

Youth Risk Behavior Survey 

(YRBS)a HHS’s CDC To monitor priority health risk behaviors that contribute to the leading causes of 

death, disability, and social problems 

among youth and adults in this country

Grades 9-12

National Crime Victimization 

Survey’s (NCVS) School Crime 

Supplement (SCS) 

Education’s National Center for 

Education Statistics and Justice’s 

Bureau of Justice Statistics

To collect additional information about 

school-related victimizations on a national 

level

Ages 12-18

Health Behavior in School-aged 

Children (HBSC)b 

HHS’s National Institutes of Health To better understand the health behaviors 

of youths and their social context during 

early adolescence

Grades 6-10

National Survey of Children’s 

Exposure to Violence 

(NatSCEV) 

Justice’s Office of Juvenile Justice 

and Delinquency Prevention and 

HHS’s CDC

To examine past-year and lifetime 

exposure to violence of children age 17 

and younger across several categories of 

violence

Ages birth-17

Source: GAO analysis and information from CDC.

a

We reviewed the national YRBS rather than associated state and local surveys.

b

HBSC is an international survey. For the purposes of our work, we reviewed the sample used for the 

national survey rather than the sample used for the international data.

To describe the effects of school bullying on victims, we conducted a 

literature review. To identify studies on the effects of bullying on victims, 

we searched numerous databases—including MEDLINE, Embase, 

Education Resources Information Center (ERIC), ProQuest, PsycINFO, 

Sociological Abstracts, Social Services Abstracts, and WorldCat. We also 

consulted with officials at Education, HHS, and Justice to identify relevant 

studies. Because of the extensive available literature, we limited our 

review to meta-analyses, which analyze other studies and synthesize 

their findings. Additionally, we limited our review to articles published in 

peer-reviewed journals. Our literature search covered studies published 

from 2001 through July 2011. Subsequently, new meta-analyses were 

brought to our attention by agency officials, and we reviewed them to the 

extent they were consistent with our search criteria. We identified seven 

relevant studies. We reviewed the methodologies of these studies to 

ensure that they were sound and determined that they were sufficiently 

reliable. The meta-analyses synthesized the findings of studies of schoolaged children in a variety of countries, including the United States. They 

were not designed to establish causal relationships, nor are the results of 

the meta-analyses generalizable.
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-12-349 Bullying Prevention

To describe approaches that selected states and local school districts are 

taking, we reviewed relevant state bullying laws and regulations, as well 

as guidance and other documents from eight selected states and 

conducted interviews with state education officials. We selected eight 

states—Arkansas, California, Illinois, Iowa, Massachusetts, New Mexico, 

Vermont, and Virginia—based on the following criteria: Each has bullying 

laws or regulations, and they vary with respect to bullying definitions and 

enumeration of protected classes, geographic variation, and student 

enrollment. Further, we selected three of these states (New Mexico, 

Vermont, and Virginia), which vary on the characteristics listed above, to 

review policies and guidance of local school districts and conduct 

interviews with school officials. We selected a total of six school districts, 

two in each state—Albuquerque Public Schools, Rio Rancho Public 

Schools, Fairfax County Public Schools, Warren County Public Schools, 

Windham Southeast Supervisory Union, and Windham Southwest 

Supervisory Union. The six school districts were selected from the 

National Center for Education Statistics (NCES) Common Core of Data 

Public Elementary/Secondary School Universe Survey: School Year 

2008–09. The Common Core of Data (CCD) nonfiscal surveys consist of 

data submitted annually to NCES by state educational agencies (SEA). 

School districts and schools were selected to reflect a range of size, and 

urbanicity (urban, suburban, or rural), as well as racial and socioeconomic 

diversity. Participation in the National School Lunch Program was used as 

a proxy for socioeconomic status. We held interviews with central 

administrators, principals, school staff, and parents. In several instances, 

multiple individuals attended an interview; for example six parents 

attended one parent interview. During the interviews, we asked about 

measures taken to prevent bullying, school officials’ response to bullying 

behavior, and lessons learned. We analyzed narrative responses 

thematically.

To identify legal options that federal and selected state governments have 

in place when bullying leads to allegations of discrimination, we reviewed 

relevant federal and state anti-discrimination laws and regulations, 

selected federal court decisions, as well as guidance and other 

documents of the federal government and the eight states selected for 

review.1

 

1

State court decisions were beyond the scope of our review, so we did not review such 

decisions.

We also conducted interviews with federal officials in the 

States and Local School 

District Interviews and 

Document Review

Review of Laws and 

Discrimination Complaint 

Processes
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-12-349 Bullying Prevention

Department of Education’s Office for Civil Rights (OCR) and the 

Department of Justice’s Civil Rights Division (CRT), Educational 

Opportunities Section, as well as with state officials. State officials were 

from various departments, including state educational agencies and 

human rights or civil rights commissions or departments.2 During the 

interviews with federal and state officials, we asked about provisions, 

discrimination complaint processes, complaint resolutions, and legal 

mechanisms available to individuals who are not members of a protected 

class. 

To address how key federal agencies are coordinating their efforts to 

combat school bullying, we interviewed officials from Education, HHS, 

and Justice and reviewed relevant documents. These departments were 

represented with officials from many component agencies. For Education, 

we spoke to officials from the Office of Safe and Healthy Students 

(formerly the Office of Safe and Drug-Free Schools), OCR, and Office of 

Special Education Programs. For HHS, we spoke to officials from the 

Office of the Assistant Secretary for Public Affairs, Office of the Assistant 

Secretary for Planning and Evaluation, CDC, Health Resources and 

Services Administration (HRSA), National Institutes of Health, and 

Substance Abuse and Mental Health Services Administration (SAMHSA). 

For Justice, we spoke to officials from the Office of Community Oriented 

Policing Services, CRT, and Office of Justice Programs. We focused on 

these three departments, given their leadership roles on an 

interdepartmental coordinating committee and website 

(www.stopbullying.gov, last accessed May 22, 2012) on bullying. We 

analyzed coordination of efforts based on key practices that GAO has 

previously identified as effective coordination practices.3

 

2

Officials from the state of Virginia declined to speak with us about this component of our 

review.

For example, in 

our interviews and analysis, we asked questions about such effective 

coordination practices as agreeing on roles and responsibilities or 

establishing compatible policies, procedures, or other means to operate 

across agency boundaries. We focused on these practices, among those 

GAO has identified, based on our professional judgment and relevance 

3

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

Interviews with Federal 

Officials and Document 

Review
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-12-349 Bullying Prevention

for the coordinated federal efforts regarding bullying.4

We conducted this performance audit from April 2011 through May 2012 

in accordance with generally accepted government auditing standards. 

These standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Related documents 

that we reviewed included plans, meeting agendas, conference materials, 

interagency agreements, and educational materials provided to the 

public. We also attended the second annual bullying prevention 

conference of the interdepartmental coordinating committee. In addition, 

we conducted interviews with Education, HHS, and Justice officials about 

efforts within their departments to combat bullying. We also reviewed 

relevant documents and agency websites.

 

4

As we have previously reported in GAO-06-15, we recognize that there is a wide range of 

situations and circumstances in which agencies work together and that not all practices 

may be necessary or be as relevant for particular coordinated efforts. For example, during 

the course of our audit work, we determined that certain other practices that may promote 

coordination were not as applicable in this particular context, given competing priorities of 

departments or the new nature of the coordination.
Appendix II: Comparison of the Definition and 

Measurement of Bullying in Four Nationally 

Representative Surveys

Page 36 GAO-12-349 Bullying Prevention

Table 5 compares how four nationally representative surveys define and 

measure bullying.

Table 5: Selected Aspects of the Definition and Measurement of Bullying in Four Nationally Representative Surveys 

 

National Youth Risk 

Behavior Survey 

(YRBS) 2009 

National Crime 

Victimization Survey 

(NCVS), School Crime 

Supplement (SCS) 2009 

Health Behavior in 

School-aged Children 

(HBSC) 2005/06 

National Survey of 

Children’s Exposure 

to Violence 

(NatSCEV) 2008 

Definition of bullying, if 

any 

“When 1 or more 

students tease, 

threaten, spread 

rumors about, hit, 

shove, or hurt another 

student over and over 

again. It is not bullying 

when 2 students of 

about the same 

strength or power 

argue or fight or tease 

each other in a friendly 

way.”

“What students do at school 

that make you feel bad or are 

hurtful to you”

“When another student, or 

a group of students, say or 

do nasty and unpleasant 

things to him or her. It is 

also bullying when a 

student is teased 

repeatedly in a way he or 

she does not like or when 

he or she is deliberately left 

out of things. But it is NOT 

BULLYING when two 

students of about the same 

strength or power argue or 

fight. It is also not bullying 

when a student is teased in 

a friendly and playful way.”

No explicit definition is 

presented

Use of a question on 

overall prevalence

Yes, but no questions 

about types of bullyinga No, but overall prevalence is 

calculated based on 

affirmative answers to one or 

more types of bullying

Yes, and questions follow 

about types of bullyingb No, but there are questions about three 

types of bullying. 

Use of questions about 

gender and 

race/ethnicity

(see app. III for 

estimates)c

Yes Yes Yes Yes

Use of questions about 

frequency of being 

bullied in the past year 

or couple of months

No Yes Yes No

Age/grade of youth 

surveyed

Grades 9-12 Ages 12-18 Grades 6-10 Ages birth-17d

Time period for 

question about being 

bullied

During past 12 months During this school year In the past couple of 

months

In the past year, over 

a lifetime.

Frequency of survey Every 2 years Every 2 years Every 4 yearse Periodic 

Appendix II: Comparison of the Definition 

and Measurement of Bullying in Four 

Nationally Representative Surveys
Appendix II: Comparison of the Definition and 

Measurement of Bullying in Four Nationally 

Representative Surveys

Page 37 GAO-12-349 Bullying Prevention

 

National Youth Risk 

Behavior Survey 

(YRBS) 2009 

National Crime 

Victimization Survey 

(NCVS), School Crime 

Supplement (SCS) 2009 

Health Behavior in 

School-aged Children 

(HBSC) 2005/06 

National Survey of 

Children’s Exposure 

to Violence 

(NatSCEV) 2008 

Purpose of survey To monitor priority 

health risk behaviors 

that contribute to the 

leading causes of 

death, disability, and 

social problems among 

youth and adults in this 

countryf

 

To collect additional 

information about schoolrelated victimizations on a 

national level

To better understand the 

health behaviors of children 

and their social context 

during early adolescenceg

To examine past-year 

and lifetime exposure 

to violence of children 

age 17 and younger 

across several 

categories of violence 

Source: GAO analysis and information from CDC.

a

YRBS did not ask about types of bullying in the 2009 survey, but the 2011 survey included a 

question on cyberbullying.

b

Thus, it is possible for the overall prevalence to appear less than the prevalence for certain types of 

bullying behaviors. According to one researcher at the National Institutes of Health (NIH) involved in 

the HBSC, respondents may be more inclined to respond affirmatively to a specific type of behavior 

rather than an overall, or general, question on bullying.

c

We did not include estimates for NatSCEV in appendix III, as this survey did not provide an overall 

estimate but reported estimates of prevalence for certain types of behaviors in the past year. 

Estimates are for youth aged 0-17. They include school and nonschool settings and being victimized 

by a peer or sibling. See, for example, David Finkelhor et al., “Violence, Abuse, and Crime Exposure 

in a National Sample of Children and Youth.” Pediatrics, vol. 124, no. 5 (2009).

d

For NatSCEV, youth aged 10 and older were interviewed, while adult caregivers of youth under 10 

were interviewed.

e

According to NIH officials involved in the HBSC, the future of the HBSC is uncertain, partly because 

of budget constraints.

f

We reviewed the national YRBS rather than associated state and local surveys.

g

HBSC is an international survey. For the purposes of our work, we reviewed the sample used for the 

national survey rather than the sample used for the international data.
Appendix III: Selected Data on National 

Prevalence of Youth Who Report Being Bullied 

in School

Page 38 GAO-12-349 Bullying Prevention

This appendix provides estimates of the overall prevalence of youth who 

reported being bullied by sex and by race/ethnicity. Three of the four 

federal surveys that we reviewed present an estimate of overall 

prevalence of being bullied, and for these three surveys, the results of 

each are shown separately by sex and by race/ethnicity. Unless 

otherwise noted, all estimates in these tables have 95 percent confidence 

intervals of within plus or minus 2.1 percentage points.

The difference between boys and girls reporting that they were bullied 

was statistically significant in one survey (YRBS), with girls reporting a 

higher percentage of bullying, but was not statistically significant in the 

other two surveys (SCS and HBSC). See table 6.

Table 6: Estimates of Youth Who Reported Being Bullied by Sex in Three National 

Surveys

Sex YRBS 2009 NCVS SCS 2009 HBSC 2005/2006

Male 18.7 26.6 28.0a

Female 21.2 29.5 26.1

Source: GAO analysis of YRBS 2009, NCVS SCS 2009, HBSC 2005/2006.

a

This estimate has a 95 percent confidence interval of within plus or minus 2.4 percentage points.

White youth reported being bullied at higher percentages than AfricanAmerican youth in two of the three surveys (YRBS and HBSC), while the 

other survey found no difference. In two of the three surveys (YRBS and 

HBSC), differences between the overall prevalence for white compared 

with Hispanic youth and for African-American youth compared with 

Hispanic youth were not statistically significant.1 In the other survey, 

Hispanics reported a lower percentage of bullying than whites or AfricanAmericans. Asian-American youths reported a lower percentage of 

bullying in the one survey (NCVS) that captured information for that 

demographic group. See table 7.

 

1

We tested for differences using a significance level of 0.05.

Appendix III: Selected Data on National 

Prevalence of Youth Who Report Being 

Bullied in School
Appendix III: Selected Data on National 

Prevalence of Youth Who Report Being Bullied 

in School

Page 39 GAO-12-349 Bullying Prevention

Table 7: Estimates of Youth Who Reported Being Bullied by Race/Ethnicity in Three 

National Surveys

Race/ethnicity YRBS 2009 NCVS SCS 2009 HBSC 2005/2006 

White non-Hispanic 21.6 29.3a 28.6b,c

Black non-Hispanic 13.7 29.1a,d 22.7b,c

Hispanic 18.5 25.5a,d 26.4b,c

Asian, not Hispanic or Latino not applicablee 17.3d not applicablee

Other not applicablee 26.7d 28.6c

Source: GAO analysis of YRBS 2009, NCVS SCS 2009, HBSC 2005/2006.

a

In the SCS, these three racial or ethnic groups were labeled as (1) white, not Hispanic or Latino; (2) 

black, not Hispanic or Latino; and (3) Hispanic or Latino, respectively.

b

In the HBSC, these three racial or ethnic groups were labeled as (1) Caucasian, (2) AfricanAmerican, and (3) Hispanic, respectively.

c

These estimates have 95 percent confidence intervals of within plus or minus 4.7 percentage points.

d

These estimates have 95 percent confidence intervals of within plus or minus 9.0 percentage points.

e

Data were not collected in this survey in this category.
Appendix IV: Selected Data on National 

Prevalence of Certain Types of Bullying 

Behaviors

Page 40 GAO-12-349 Bullying Prevention

This appendix provides estimates of the prevalence of being bullied for 

certain types of bullying behaviors. Three of the four federal surveys that 

we reviewed provide estimates of the prevalence of being bullied for 

certain types of behaviors, and the results of each are shown separately. 

Unless otherwise noted, all estimates in these tables have 95 percent 

confidence intervals of within plus or minus 2.1 percentage points.

These surveys also found that boys may be subject to somewhat different 

types of bullying than girls. For example, estimates from SCS and HBSC 

showed that a higher percentage of boys were bullied physically than 

girls, while girls were more commonly bullied than boys with rumors or 

social exclusion, which are examples of relational bullying, or bullying 

using interpersonal relationships.

Table 8: NCVS SCS 2009: Estimates of Youth Who Reported Being Bullied for 

Certain Types of Bullying Behaviors 

Type of bullying

Estimate (percentage) for this 

school year

Overall prevalence of being bullieda 28.0%

Made fun of, called names, or insulted 18.8

Spread rumors 16.5

Pushed, shoved, tripped, or spit on 9.0

Cyberbullied 6.0

Threatened with harm 5.7

Excluded from activities on purpose 4.7

Tried to make do things they did not want to do 3.6

Property destroyed on purpose 3.3

Source: GAO analysis of NCVS SCS 2009.

a

A separate question on this survey asks about being cyberbullied. This estimate of overall 

prevalence therefore does not include being cyberbullied.

Appendix IV: Selected Data on National 

Prevalence of Certain Types of Bullying 

Behaviors
Appendix IV: Selected Data on National 

Prevalence of Certain Types of Bullying 

Behaviors

Page 41 GAO-12-349 Bullying Prevention

Table 9: HBSC 2005/2006: Estimates of Youth Who Reported Being Bullied for 

Certain Types of Bullying Behaviors

Type of bullying

Estimate (percentage) for the past 

couple of months

Overall prevalence of being bullieda 27.0

Spreading rumor: told lies or spread false 

rumors 31.9

Called mean names, was made fun of, or 

teased in a hurtful way 31.5

Social isolation: excluded from a group of 

friends or was ignored 25.6

Bullied with mean names and comments 

about race or color 13.1

Hit, kicked, pushed, shoved around, or 

locked indoors 12.8

Bullied with mean names and comments 

about religion 8.5

Bullied using a computer or e-mail 

messages or pictures 8.1

Bullied using a cell phone 5.7

Source: GAO analysis of HBSC 2005/2006.

a

As separate HBSC survey questions ask about the overall prevalence and the prevalence of specific 

types of bullying behaviors, it is possible for the overall prevalence to appear less than the prevalence 

for certain types of bullying behaviors. According to one researcher at NIH involved in the HBSC, 

respondents may be more inclined to respond affirmatively to a specific type of behavior rather than 

an overall, or general, question on bullying.

Table 10: NatSCEV 2008: Estimates of Youth Who Reported Being Bullied for 

Certain Types of Bullying Behaviors

Type of bullying Estimate (percentage) for the past year

Overall prevalence of being bullied N/A

Teasing or emotional bullying 19.7 

Physical bullying or intimidation 13.2

Internet harassment 1.8

Source: GAO analysis of NatSCEV 2008.

Note: For NatSCEV, youth aged 10 and older were interviewed, while adult caregivers of youth under 

10 were interviewed.
Appendix V: Coordination Practices of Key 

Interdepartmental Federal Efforts on Bullying

Page 42 GAO-12-349 Bullying Prevention

In table 11 are selected coordination practices that we have previously 

found help to enhance and sustain coordination across federal agencies, 

as well as the ways that key interdepartmental activities against bullying 

reflect those coordination practices.

Table 11: Practices for Key Coordinated Federal Efforts Specifically on Bullying

Selected coordination 

practices

Federal Partners in Bullying 

Prevention Steering Committee

Central website 

(stopbullying.gov)

Stop Bullying Now! 

campaign

Agree on roles and 

responsibilities

Education through its Office of Safe 

and Healthy Students has agreed 

to serve as chair. HHS through 

HRSA served as cochair until 

October 2011.a On the one hand, 

these agencies have not developed 

a formal document that sets their 

overall roles and responsibilities, 

given the fluid nature and rapid 

evolution of the committee and its 

external environment.

On the other hand, despite the 

committee’s evolving organization, 

agencies can and in some cases 

have formally agreed on roles and 

responsibilities for particular 

projects. For example, the project 

to develop a uniform definition of 

bullying for research purposes 

features an interagency agreement 

between Education and CDC 

signed in 2011.

The roles and responsibilities of 

federal agencies are outlined in a 

governance document that serves 

as the framework for coordination 

across agencies and departments. 

For example, the participating 

federal agencies serve on the two 

governing bodies of the website: 

(1) the editorial board, which 

reviews and develops content for 

the website, and (2) the steering 

committee, which makes 

managerial decisions for higherlevel planning and resources.b

HHS’s lead agency, the Office of 

the Assistant Secretary for Public 

Affairs, executed agreements in 

summer 2011 with Education, 

HHS’s Office of the Assistant 

Secretary for Planning and 

Evaluation, HRSA, and SAMHSA 

that provide funding to maintain 

and operate the website.

HRSA has collaborated and 

received funding from 

Education from the start of 

the campaign until fiscal year 

2010. Unlike in prior years, 

in fiscal year 2011, 

Education and HRSA were 

unable to execute an 

interagency agreement 

because of time constraints. 

Instead, HHS’s SAMHSA 

provided funding to reprint 

and disseminate 

informational materials for 

the campaign.

Appendix V: Coordination Practices of Key 

Interdepartmental Federal Efforts on 

Bullying 
Appendix V: Coordination Practices of Key 

Interdepartmental Federal Efforts on Bullying

Page 43 GAO-12-349 Bullying Prevention

Selected coordination 

practices

Federal Partners in Bullying 

Prevention Steering Committee

Central website 

(stopbullying.gov)

Stop Bullying Now! 

campaign

Establish compatible policies, 

procedures, and other means 

to operate across agency 

boundaries, including 

frequent communication

Education and CDC signed an 

interagency agreement for the 

project on the uniform definition of 

bullying for research purposes.

The committee so far has used 

regular phone meetings, along with 

its conferences, to share 

information among federal 

agencies and potentially with the 

public. According to Education 

officials, monthly or even biweekly 

phone meetings as well as 

correspondence by e-mail have 

facilitated preparations for the three 

conferences in 2010 and 2011. 

Such internal communication, 

including electronic Listservs, has 

also promoted sharing information 

among federal agencies on 

upcoming opportunities that may 

be relevant to bullying, such as 

upcoming webinars, grant 

announcements, or recent research 

publications.

Four agreements provide for the 

maintenance and operation of the 

website.

The governing bodies have so far 

operated with frequent 

communication. According to HHS 

officials, the editorial board meets 

approximately every 2 to 4 weeks 

and corresponds by e-mail, and 

the steering committee meets 

quarterly and as needed.

An agreement between 

HRSA and Education (more 

recently SAMHSA) has 

provided for the 

development, publication, 

and dissemination of 

informational materials of the 

campaign.

HRSA has communicated 

across six federal 

departments. The campaign 

also relies on its more than 

140 partner organizations to 

help disseminate materials, 

such as chapters of the 

American Academy of 

Pediatrics or Boys and Girls 

Clubs of America. One way 

that these government and 

nongovernment partners 

may communicate and 

provide input to HRSA’s 

communications contractor 

is seven external work 

groups that have provided 

expertise and reviewed 

materials, especially when 

the campaign was designed. 
Appendix V: Coordination Practices of Key 

Interdepartmental Federal Efforts on Bullying

Page 44 GAO-12-349 Bullying Prevention

Selected coordination 

practices

Federal Partners in Bullying 

Prevention Steering Committee

Central website 

(stopbullying.gov)

Stop Bullying Now! 

campaign

Develop mechanisms to 

monitor, evaluate, and report 

results

The committee as a whole does not 

have formal mechanisms to 

monitor results.

Specific projects within the 

committee, such as the project of 

the research subcommittee on the 

uniform definition of bullying, may 

have formal time frames and 

deliverable products. This project 

may help other efforts to monitor 

the extent of bullying and evaluate 

programs.

Besides the uniform definition, 

another way that the committee 

and its research subcommittee are 

helping others to monitor and 

evaluate antibullying efforts is by 

sharing information on evaluation 

research. Because of funding 

constraints and stipulations, the 

research subcommittee has mainly 

focused its activities about 

evaluation research on participating 

in local conferences, understanding 

existing publications, and obtaining 

information from researchers, 

including any suggestions for 

additional research.

HHS and Education officials said 

they monitor metrics about the 

use of the website, such as the 

number of visits. From its launch 

in March 2011 to the end of 

December 2011, the website 

received more than 1.1 million 

visits, according to HHS data.

HHS officials said that they plan to 

add a qualitative feature for 

feedback from users and conduct 

additional usability testing of the 

website as it continues to evolve 

in its second phase.

HRSA and its 

communications contractor 

track the distribution of the 

campaign’s materials. 

According to data from 

HRSA as of August 2011, 

recipients of the materials in 

mass mailings included, 

among others, all 66,000 

public elementary and 

middle schools in the 

country, 17,000 libraries, 

relevant state health and 

education agencies, schools 

on military bases worldwide, 

and offices serving American 

Indian youth. 

Nongovernment and 

government partners 

distributed roughly 92,000 

additional materials from 

July 2007 to August 2011 

through a variety of 

organizations.

HRSA has received 

feedback on the materials 

from its government and 

nongovernment partners 

through the seven 

implementation working 

groups through e-mail and 

occasional phone outreach. 

Also, in structured 

discussions held with partner 

organizations three times 

since 2003, many 

organizations reported using 

the campaign’s materials to 

raise awareness about the 

problem of bullying.

HRSA officials said that the 

campaign’s impact has not 

been formally evaluated 

because of funding 

constraints such that funding 

for an evaluation could divert 

resources from delivery of 

the campaign.

Source: GAO analysis of information from Education, HHS, and Justice officials.
Appendix V: Coordination Practices of Key 

Interdepartmental Federal Efforts on Bullying

Page 45 GAO-12-349 Bullying Prevention

a

Prior to September 2011, the Office of Safe and Healthy Students within the Office of Elementary 

and Secondary Education was a separate office, the Office of Safe and Drug-Free Schools. The 

organizational change followed funding reductions to the separate Office of Safe and Drug-Free 

Schools, including reductions to its grant programs.

b

The first phase of www.stopbullying.gov relied on three governing bodies, which the governance 

document reflects. HHS officials said that, for the second phase, federal officials decided to eliminate 

one of the three bodies to streamline the management of the website.
Appendix VI: Additional Federal Programs and 

Services Are Available to Combat Bullying

Page 46 GAO-12-349 Bullying Prevention

In addition to supporting antibullying activities, the Departments of 

Education, HHS, and Justice support more broadly focused services and 

programs that may be used for bullying prevention. Generally, bullying 

prevention represents one of many allowable activities within these 

services and programs. Within each agency, officials identified a range of 

services and programs, including technical assistance, funding 

opportunities, information sharing, and research, that may include bullying 

prevention. For example, HHS provides funding for the Children’s Safety 

Network (CSN), a national resource center for the prevention of childhood 

injuries and violence. See table 12.

Table 12: Selected Services and Programs That Can Be Used to Support Bullying Prevention 

Program or service Description

HHS

15+ Make Time to Listen–Take Time to 

Talk

An initiative to promote healthy child development and to prevent youth and school-based 

violence.

Safe Schools/Healthy Students Initiativea Grants support school districts in the development of communitywide approaches to 

creating safe and drug-free schools and promoting healthy childhood development.

Children’s Safety Network A national resource center for the prevention of childhood injuries and violence that, 

among other things, provides technical assistance on injury prevention planning, 

promotes child and adolescent health and safety, and disseminates injury prevention 

research.

Maternal and Child Health Services Block 

Grant

Provides funds to all 50 states, the District of Columbia, and 6 territories to promote the 

health of mothers and children.

Education

Safe and Supportive Schools grants Grants to states to measure school safety and to help intervene in those schools with the 

greatest safety needs.

Positive Behavioral Interventions and 

Support Technical Assistance Center

A national technical assistance center focused on improving student behavior to foster 

academic instruction.

Justice

National Training and Technical 

Assistance Center

Provides technical assistance to individuals in the juvenile justice field on a range of 

topics, including webinars on bullying intervention and civil rights.

Secure Our Schools grants Provides funding to state, local, or tribal governments to assist with the development of 

school safety resources.

Office of Juvenile Justice and Delinquency 

Prevention (OJJDP) bulletins

Describes statistics, research, training, technical assistance, and programs funded 

through OJJDP grants and contracts, and includes the Bullying in School series.

Source: Agency program information.

Note: Agency officials reported that it would be difficult to obtain specific spending information on 

bullying for these services and programs. Furthermore, it could be misleading to include total service 

or program amounts because it would misrepresent funding for bullying activities.

a

The Safe Schools/Healthy Students Initiative (SS/HS) is a collaborative program supported by three 

federal agencies—HHS, Education, and Justice.

Appendix VI: Additional Federal Programs 

and Services Are Available to Combat 

Bullying 
Appendix VI: Additional Federal Programs and 

Services Are Available to Combat Bullying

Page 47 GAO-12-349 Bullying Prevention

While these programs and services generally support a broader range of 

activities than just bullying, several of them have been used to directly 

address bullying. For example, several grantees have used Safe 

Schools/Healthy Students funding to implement bullying prevention 

programs. Also, in fiscal year 2010, 2 of the 11 SEAs awarded Safe and 

Supportive Schools grants devoted resources to bullying prevention. 

While these services and programs do not always exclusively focus on 

bullying prevention, officials across the three federal agencies—

Education, HHS, and Justice—agreed that their emphasis on violence 

reduction and healthy behaviors can help prevent and reduce bullying 

behavior, even if the funds are not used specifically to address bullying.
Appendix VII: Comments from the Department 

of Education

Page 48 GAO-12-349 Bullying Prevention

Appendix VII: Comments from the 

Department of Education
Appendix VII: Comments from the Department 

of Education

Page 49 GAO-12-349 Bullying Prevention
Appendix VII: Comments from the Department 

of Education

Page 50 GAO-12-349 Bullying Prevention
Appendix VII: Comments from the Department 

of Education

Page 51 GAO-12-349 Bullying Prevention
Appendix VII: Comments from the Department 

of Education

Page 52 GAO-12-349 Bullying Prevention
Appendix VII: Comments from the Department 

of Education

Page 53 GAO-12-349 Bullying Prevention
Appendix VII: Comments from the Department 

of Education

Page 54 GAO-12-349 Bullying Prevention
Appendix VII: Comments from the Department 

of Education

Page 55 GAO-12-349 Bullying Prevention
Appendix VIII: Comments from the Department 

of Health and Human Services

Page 56 GAO-12-349 Bullying Prevention

Appendix VIII: Comments from the 

Department of Health and Human Services
Appendix VIII: Comments from the Department 

of Health and Human Services

Page 57 GAO-12-349 Bullying Prevention
Appendix IX: GAO Contacts and Staff 

Acknowledgments

Page 58 GAO-12-349 Bullying Prevention

Linda M. Calbom, (206) 287-4809 or calboml@gao.gov

Bryon Gordon (Assistant Director), Ramona L. Burton (Analyst-inCharge), Susannah Compton, Alex Galuten, Avani Locke, Ashley McCall, 

Sheila McCoy, Jean McSween, Mimi Nguyen, Karen O’Conor, Kate 

O’Dea, Michael Pahr, Rebecca Rose, Regina Santucci, Matthew 

Saradjian, Ronni Schwartz, and John Townes made significant 

contributions to all aspects of this report.

Appendix IX: GAO Contacts and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(131076)
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