Presented to the

PRESIDENT OF THE UNITED STATES

December 18, 2018

FINAL REPORT OF THE FEDERAL COMMISSION ON 

School Safety
2 Federal Commission on School Safety: Prevent

Disclaimer 

Since the horrific February 14, 2018 

shooting at Marjory Stoneman 

Douglas High School, the Trump 

Administration has devoted considerable time, resources, and 

effort to studying ways to keep 

our students safe and our schools 

secure. The Federal Commission on 

School Safety was designed to both 

research and recommend solutions 

to advance the safety of our schools. 

The Commission’s observations and 

recommendations are contained in 

this report.

The Commission recognizes that 

the problem of school violence is 

long-standing and complex and that 

there are certain limits to what the 

federal government can do. This 

Commission was not established 

to provide a single solution to this 

problem, nor did the Commissioners 

set out to mandate uniform policy 

to every community. In fact, it is 

our considered belief that doing so 

would prove counterproductive. 

There can be no “one-size-fits-all” 

approach for an issue this complex.

The shooting in Parkland, FL, was 

not the first of its kind, nor is it likely 

to be the last. This does not mean we 

should give up on doing all we can to 

minimize the chances that something like that could happen again. 

In the pages that follow, the Commission makes recommendations 

that address multiple aspects of 

school safety. It does so based on the 

insights, experiences, and expertise 

of a wide range of individuals. The 

recommendations are predicated 

on the policies already working in 

state and local communities. They 

outline steps we all can take—families, communities, schools, houses of 

worship, law enforcement, medical 

professionals, government, and 

others. 

Each of us has a role to play in 

improving the safety of our students 

and the security of our schools. Only 

by working together can we help 

prevent future tragedies and, when 

those incidents do occur, mitigate 

their effects and continue to learn 

from them. 

The U.S. Departments of Education, 

Justice, Homeland Security, and Health 

and Human Services do not mandate 

or prescribe practices, models, or other 

activities in this document. This report 

contains examples of, adaptations of, and 

links to resources created and maintained 

by other public and private organizations. 

This information, informed by research 

and gathered in part from practitioners, is 

provided for the reader’s convenience and 

is included here to offer examples of the 

many resources that educators, parents, 

advocates, administrators, and other concerned parties may find helpful and use at 

their discretion. The Departments do not 

control or guarantee the accuracy, relevance, timeliness, or completeness of this 

outside information. Further, the inclusion 

of links to items and examples does not 

reflect their importance, nor are they 

intended to represent or be an endorsement by the Commission or any of its 

members, any federal agency or department, or the U.S. Government of any views 

expressed, or materials provided. 

This document has no force or effect of 

law and does not create any additional 

requirements for the public beyond those 

included in applicable laws and regulations; nor does it create any additional 

rights for any person, entity, or organization. Implementation of the practices 

identified in this guide is purely voluntary, 

and no federal agency will take any action 

against schools that do not adopt them.
Letter of Transmittal

December 18, 2018

The President

The White House

Washington, D.C. 20500

Dear Mr. President:

Our nation’s schools must be safe places to learn. Sadly, incidents of school violence are too common in the 

United States, and far too many families and communities have suffered. 

Following the school shooting in Parkland, FL, you established the Federal Commission on School Safety. You 

tasked the Commission with producing a report of policy recommendations in an effort to help prevent future 

tragedies. 

Our work included field visits, listening sessions, and meetings with anyone and everyone who is focused on 

identifying and elevating solutions. After learning from students, parents, teachers, school safety personnel, law enforcement officers, mental health professionals, and others who play a role in keeping students 

safe, we have developed recommendations for leaders at the local, state, and federal levels. Our key observations and recommendations are included in this report. Our goal has been to identify local, state, and federal 

policy for lawmakers and local officials to consider. The report’s recommendations can assist states and local 

communities in preventing school violence and improving recovery efforts following an incident.

There is no universal school safety plan that will work for every school across the country. Such 

a prescriptive approach by the federal government would be inappropriate, imprudent, and ineffective. We 

focused instead on learning more about, and then raising awareness of, ideas that are already working for 

communities across the country. That is why the Commission’s work and recommendations focus on a variety 

of school sizes, structures, and geographic locations. 

The federal government can play a role in enhancing safety in schools. However, state legislators should work 

with local school leaders, teachers, parents, and students themselves to address their own unique challenges and 

develop their own specific solutions. What may work in one community may or may not be the right approach in 

another. Each local problem needs local solutions. Rather than mandate what schools must do, this report serves 

to identify options that policymakers should explore. 

Ultimately, ensuring the safety of our children begins within ourselves, at the kitchen table, in houses of worship, 

and in community centers. The recommendations within this report do not and cannot supplant the role families 

have in our culture and in the lives of children. Our country’s moral fabric needs more threads of love, empathy, 

and connection. 

Together with states, local communities, and families, we can all continue working to uphold our promise 

to keep students safe as they pursue their futures at school.

Sincerely,

Betsy DeVos, Secretary

U.S. Department of Education

Chair, Federal Commission on School Safety

Kirstjen M. Nielsen, Secretary

U.S. Department of Homeland Security

Matthew Whitaker, Acting Attorney General

U.S. Department of Justice

Alex M. Azar II, Secretary

U.S. Department of Health and Human Services
2 Federal Commission on School Safety

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Federal Commission on School Safety 3

Table of Contents

Background .................................................................................................................................................................. 5

Executive Summary .................................................................................................................................................. 13

Section 1: Prevent

1. Character Development and a Culture of Connectedness ........................................................................ 17

2. Cyberbullying and School Safety................................................................................................................ 23

3. Curating a Healthier and Safer Approach: Issues of Mental Health and Counseling for Our Young........ 27

4. Integrating Mental Health, Primary Care, Family Services, and Court-Ordered Treatment .................... 37

5. Using Suspicious Activity Reporting and Threat Assessments to Enhance School Safety ...................... 49

6. Effects of Press Coverage of Mass Shootings ............................................................................................. 59

7. Violent Entertainment and Rating Systems ............................................................................................... 63

8. The Obama Administration’s “Rethink School Discipline” Guidance ....................................................... 67

9. The Effectiveness and Appropriateness of Psychotropic Medication for Treatment of Troubled Youth .. 75

10. The Efficacy of Age Restrictions for Firearm Purchases............................................................................. 85

11. Extreme Risk Protection Order Laws .......................................................................................................... 89

12. Improvements to the FBI’s Public Access Line ........................................................................................... 97

Section 2: Protect and Mitigate

13. Training School Personnel to Help Ensure Student Safety...................................................................... 101

14. Emergency and Crisis Training for Law Enforcement.............................................................................. 109

15. The Transition of Military Veterans and Retired Law Enforcement Officers into 

New Careers in Education ......................................................................................................................... 113

16. Best Practices for School Building Security ............................................................................................. 119

17. The Family Educational Rights and Privacy Act and Other Statutory and 

Regulatory Privacy Protections ................................................................................................................ 129

18. The Health Insurance Portability and Accountability Act and Other Statutory 

and Regulatory Privacy Protections ......................................................................................................... 135

Section 3: Respond and Recover

19. Active Shooter Preparedness and Mitigation........................................................................................... 141

Conclusion................................................................................................................................................................ 155

Appendix A................................................................................................................................................................ 157

Appendix B................................................................................................................................................................ 177
4 Federal Commission on School Safety

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Federal Commission on School Safety 5

Background

Decades of Problems

On February 14, 2018, a former student walked into 

Marjory Stoneman Douglas High School in Parkland, 

FL, and began firing. He murdered 17 people, and 

wounded many more. 

Three months later, a shooter at Santa Fe High School 

in Texas murdered 10 people. These successive school 

shootings are two tragedies on a ledger that now 

spans decades. 

School violence has been a persistent problem in the 

United States. For example, on January 29, 1979, a 

16-year-old opened fire on Grover Cleveland Elementary School in San Diego, CA. She killed two adults and 

wounded eight students and one police officer, for 

seemingly no reason at all.

In each decade since, we have experienced tragedies 

of this kind. In the 1980s, communities across the 

country suffered from school killings—in Alabama and 

Nevada, in Missouri and Kansas, in Washington, North 

Carolina, Michigan, and Virginia. 

The incidents continued during the 1990s. The decade 

culminated in a shooting in Littleton, CO—now known 

as the Columbine High School Massacre. On April 

20, 1999, two shooters killed 13 fellow students and 

wounded 21 before taking their own lives. Virginia 

Tech came eight years later, with the death toll at 32. 

At Sandy Hook Elementary School in December 2012, 

a shooter claimed 26 lives. 

These are not just numbers. These are lives that were 

tragically cut short.

A Tragic Chronology

The following list of school violence incidents is not 

intended to be exhaustive, but rather to illustrate the 

breadth of the problem. 

January 29, 1979 Grover Cleveland Elementary School in San Diego, CA—two adults killed, eight students and one police 

officer wounded

October 31, 1980 Hueytown High School in Hueytown, AL—one student wounded, shooter takes his own life

March 19, 1982 Valley High School in Las Vegas, NV—one teacher killed, two students wounded

January 20, 1983 Parkway South Junior High in St. Louis, MO—one student killed, one wounded, shooter takes his own life 

January 21, 1985 Goddard Junior High School in Goddard, KS—school principal killed, two teachers and one student wounded

November 27, 1985 Spanaway Junior High School in Spanaway, WA—two students killed, shooter takes her own life

May 9, 1986 Pine Forest High School in Fayetteville, NC—three students wounded, one critically

April 17, 1987 Murray Wright High School in Detroit, MI—one student killed, two wounded

December 16, 1988 Atlantic Shores Christian School in Virginia Beach, VA—two teachers shot, one fatally

January 17, 1989 Cleveland Elementary School in Stockton, CA—five students killed, 29 others wounded, shooter takes 

his own life

February 2, 1996 Frontier Middle School in Moses Lake, WA—one teacher and two students killed, another student wounded 

October 1, 1997 Pearl High School in Pearl, MS—shooter kills his mother then kills two classmates and injures seven others 

December 1, 1997 Heath High School in West Paducah, KY—three students killed and five others wounded

March 24, 1998 Westside Middle School in Jonesboro, AR—four students and one teacher killed, 11 others wounded
6 Federal Commission on School Safety

Establishment and Operation of the 

Federal Commission on School Safety

On March 12, 2018, President Donald Trump established the Federal Commission on School Safety to 

review safety practices and make meaningful and 

actionable recommendations of best practices to keep 

students safe. Members of the Commission include 

Secretary Betsy DeVos of the U.S. Department of 

Education (“ED”), Acting Attorney General Matthew 

Whitaker of the U.S. Department of Justice (“DOJ”) 

(succeeding former Attorney General Jeff Sessions), 

Secretary Alex Azar II of the U.S. Department of Health 

and Human Services (“HHS”), and Secretary Kirstjen 

Nielsen of the U.S. Department of Homeland Security 

(“DHS”). 

To inform its work the Commission held a series of 

meetings, field visits, and listening sessions. Commission meetings provided a forum to hear from key 

stakeholders such as school safety experts, educators, 

and other concerned citizens. Field visits involved 

travel to schools by Commission members and staff to 

observe and learn firsthand about current practices in 

school safety. Listening sessions occurred around the 

country and provided the opportunity for the Commission to receive input directly from members of the 

general public. Parents, students, teachers, counselors, psychologists, administrators, and many others 

presented statements at these sessions. In addition 

to hearing from the public, most listening sessions 

included one or two separate roundtable discussions 

with state and local officials including Governors, 

State School Chiefs, law enforcement leadership, 

mental health representatives, and others. 

The Commission held an organizational meeting on 

March 28, 2018. On May 17, 2018, the Department of 

Education hosted several families directly impacted 

by past school shootings, as well as authors of key 

reports. Full Commission meetings, field visits, and listening sessions began on May 31, 2018, and ended on 

August 28, 2018. (See page 7 for details of Commission 

events.) The Commission held four formal meetings, 

four field visits, and four listening sessions. Responsibilities for planning and carrying out the meetings 

and field visits were shared by each of the four departApril 20, 1999 Columbine High School in Littleton, CO—13 students killed and 21 wounded, shooters take their own lives 

March 25, 2001 Santana High School in Santee, CA—two students killed and 13 wounded

December 5, 2001 Springfield High School in Springfield, MA—school counselor killed 

April 14, 2003 John McDonogh Senior High School in New Orleans, LA—one student killed and three wounded 

September 24, 2003 Rocori High School in Cold Spring, MN—two students killed

March 21, 2005 Red Lake High School in Red Lake, MN—after killing his grandparents, shooter kills five students, a teacher, 

and an unarmed security guard

April 16, 2007 Virginia Polytechnic Institute and State University in Blacksburg, VA—shooter kills 32 people, takes his 

own life

February 27, 2012 Chardon High School in Chardon, OH—three students killed and two wounded 

December 14, 2012 Sandy Hook Elementary School in Newton, CT—shooter kills his mother, 20 students, and six adults before 

taking his own life

October 21, 2013 Sparks Middle School in Sparks, NV—shooter kills a teacher, wounds two classmates, and takes his own life

December 13, 2013 Arapahoe High School in Centennial, CO—one student killed, shooter takes his own life

May 27, 2014 University of California Santa Barbara, CA—six students killed, 14 wounded, shooter takes his own life

June 10, 2014 Reynolds High School in Troutdale, OR—one student killed, one teacher wounded, shooter takes his own life

October 24, 2014 Marysville-Pilchuck High School in Marysville, WA—four students killed and a fifth critically wounded

April 10, 2017 North Park Elementary School in San Bernardino, CA—one teacher and one student killed, one student 

wounded, shooter takes his own life 

January 23, 2018 Marshall County High School in Benton, KY—two students killed, 18 other people wounded 

February 14, 2018 Marjory Stoneman Douglas High School in Parkland, FL—14 students and three teachers killed

May 18, 2018 Santa Fe High School in Santa Fe, TX—eight students and two teachers killed, 10 others wounded
Federal Commission on School Safety 7

ments, while the listening sessions were organized by 

ED, in consultation with the other departments. 

The Commission’s meetings, field visits, and listening 

sessions were livestreamed and preceded by media 

advisories. In addition, Commission meetings and 

listening sessions were transcribed. All of the Commission events are posted to the Commission’s website, 

http://www.ed.gov/school-safety/. Speakers’ written 

statements at Commission meetings as well as other 

useful information are also posted to this website. 

In addition to the Commission meetings, field visits, and listening sessions, various Commission and 

agency staff members have met regularly with others 

in the school safety community. The Commission has 

repeatedly encouraged all who have an interest in 

school safety to submit their recommendations and 

views at safety@ed.gov for consideration by the Commission. Learning from students, parents, teachers, 

administrators, school safety personnel, school counselors, mental health professionals, law enforcement 

officers, security professionals, and others through the 

above-noted means has been critical to the work of 

the Commission. The Commission reviewed information received from each of these fora.

Organizational Meeting. On March 28, 2018, Secretary 

DeVos convened an organizational meeting of the 

Commission at the Lyndon B. Johnson Department of 

Education Building (LBJ). The Commission discussed 

the scope of work, staffing, coordination with state 

and local partners, the timeline for future meetings 

with stakeholders, and how best to incorporate 

stakeholder input on the areas of focus that President 

Trump directed the Commission to study.

Discussion with Families and Authors. On May 17, 

2018, Secretary DeVos hosted a discussion at LBJ to 

learn from survivors and family members affected by 

the mass shootings at Columbine High School, Virginia 

Tech, Sandy Hook Elementary School, and Marjory 

Stoneman Douglas High School. The discussion 

session also included authors of official after-action 

reports as well as others knowledgeable on school 

safety. 

ED-led Field Visit in Hanover, MD. The first field visit 

occurred on May 31, 2018, at Frank Hebron-Harman 

Elementary School in Hanover, MD. The Commission 

toured the school and hosted a roundtable discussion 

with administrators, principals, teachers, students, 

and a national expert on Positive Behavioral Interventions and Supports, which is a framework designed to 

improve social, emotional, behavioral, and academic 

outcomes for all students. 

ED-led Listening Session in Washington, D.C. On June 

6, 2018, the Commission hosted a public listening session at LBJ. The open session included stakeholders, 

students, experts, and others who offered recommendations on how best to improve school safety. 

ED-led Commission Meeting in Washington, D.C. On 

June 21, 2018, the Commission held a Commission 

meeting at the Eisenhower Executive Office Building 

(EEOB) titled, “Ecology of Schools: Fostering a Culture 

of Human Flourishing and Developing Character.” 

Commissioners heard from three panels of experts 

who focused on the effects of entertainment, media, 

cyberbullying, and social media upon violence and 

student safety. 

ED-led Listening Session in Lexington, KY. On June 

26, 2018, the Commission hosted two roundtable discussions and its second listening session in Lexington, 

KY. The discussion included state and local officials, 

including the Governor of Kentucky, the First Lady of 

Wisconsin, a State Commissioner of Education, a State 

Commissioner of Safety and Homeland Security, a 

State Commissioner of Mental Health and Substance 

Abuse Services, a Chairman of a State Board of Education, a Commissioner of State Police, and law enforcement officers. This session focused on how schools, 

districts, colleges and universities, and other state and 

local government agencies can improve school safety. 

As with the earlier listening session, this occasion 

provided an opportunity for members of the public to 

provide their recommendations.

HHS-led Commission Meeting in Washington, D.C. On 

July 11, 2018, the Commission hosted its second meeting at the EEOB titled “Curating a Healthier and Safer 

Approach: Issues of Mental Health and Counseling for 
8 Federal Commission on School Safety

our Young.” Commissioners heard from three panels of 

experts who focused on mental health, psychotropic 

medications, and data and student records confidentiality issues. 

HHS-led Field Visit in Adams County, WI. On July 24, 

2018, the Commission held its second field visit at 

Adams Friendship Middle School in Adams County, 

WI. During this visit, the Commission learned about a 

rural middle school’s implementation of a statewide 

mental health framework and how the framework 

transformed the school’s ability to meet the behavioral health needs of its students. The visit included a 

roundtable discussion with state officials and mental 

health professionals. Commissioners also heard from 

a panel consisting of parents, students, administrators, law enforcement officers, and others, who shared 

details about integrated behavioral health, home visits 

and community navigation, cross-agency collaboration, and crisis response.

DOJ-led Commission Meeting in Washington, D.C. 

On July 26, 2018, the Commission hosted its third 

meeting at the EEOB titled “Proactively Protecting Our 

Schools.” This meeting focused on the importance of 

information sharing between schools and law enforcement, as well as the role of school resource officers 

(SROs).

DOJ-led Field Visit in Pearcy, AR. On August 1, 2018, 

the Commission held its third field visit at the Lake 

Hamilton School District in Pearcy, AR. The Commission heard from state-level elected leaders, legislators, local superintendents, a teacher, state and local 

education board members, and parents about the 

challenges faced by rural school districts as well as 

the strategies they have adopted in an effort to meet 

them. In particular, the Commission learned about the 

school district’s Commissioned School Security Officer 

program, which was developed with the community’s 

guidance and in cooperation with law enforcement to 

improve the armed response time to active shooter 

situations. 

ED-led Listening Session in Cheyenne, WY. On August 

7, 2018, the Commission hosted two roundtable discussions and its third listening session in Cheyenne, 

WY. The discussion included state and local officials, 

including two State Superintendents, a State Attorney 

General, State Board of Education members, a State 

Commissioner of Public Safety, local district officials, 

law enforcement officers, and SROs. In addition, 

members of the general public from Wyoming and 

surrounding states presented statements to Commission representatives. This session focused on the 

particular concerns of rural districts and the distances 

law enforcement and SROs must travel from school to 

school. 

DHS-led Commission Meeting in Washington, D.C. 

On August 16, 2018, the Commission hosted its fourth 

meeting at the EEOB titled, “Creating a Citadel of 

Learning: New Tools to Secure Our Schools, Inside 

and Out.” This meeting focused on best practices for 

school building security, active shooter training for 

schools, and school-based threat assessments.

DHS-led Field Visit in Las Vegas, NV. On August 23, 

2018, the Commission held its fourth field visit at the 

Miley Achievement Center in Las Vegas, NV. The Commission heard from local school leaders, law enforcement officers, security professionals, and architects 

about what schools can do to enhance their security 

through various preventive and protective activities.

ED-led Listening Session in Montgomery, AL. On 

August 28, 2018, the Commission hosted two roundtable discussions and its fourth listening session in 

Montgomery, AL. The discussion included state and 

local officials, including the Governor of Alabama, 

state legislators, a State Superintendent of Education, 

a State Law Enforcement Secretary, a State Commissioner of Public Safety, higher education leaders, a 

member of the State Board of Education, and law 

enforcement officers. In addition, members of the 

general public from Alabama and surrounding states 

presented statements to Commission representatives. 

This session focused on physical security and school 

design, information sharing among community partners, providing mental health services in schools, and 

the unique challenges and potential solutions for rural 

communities.

Federal Commission on School Safety: 

Accomplishments

At the direction of the President following the shooting in Parkland, FL, the Administration and specifically 

the Departments of Education (ED), Justice (DOJ), 

Homeland Security (DHS), and Health and Human 

Services (HHS) immediately began taking steps to support state and local efforts to improve school safety.
Federal Commission on School Safety 9

Immediate Actions to Secure Our Schools

On March 12, 2018, President Trump called for immediate action on a range of policies designed to protect 

schools and students.1 The Trump Administration 

worked to build a bipartisan coalition to garner passage and enactment of two bills: HR 4909, Students, 

Teachers, and Officers Preventing (STOP) School 

Violence Act of 20182 and S. 2135, Fix NICS (National 

Instant Criminal Background Check System) Act.3

The STOP School Violence Act helps school personnel 

and law enforcement identify and prevent violence 

in schools. The law authorizes more than $1 billion in 

grant funding through Fiscal Year 2028, administered 

by the DOJ, to support evidence-based violence-prevention programs in schools throughout the country. 

These grants will support a range of proactive strategies for identifying and preventing school violence, 

including evidence-based training, anonymous reporting systems, threat assessments, intervention teams, 

and increased coordination between schools and local 

law enforcement. The first grants were announced 

in October 2018, when DOJ awarded more than $70 

million in grant funding to support school safety.4

The Fix NICS Act strengthens the federal firearms 

background check system. Federal agencies are 

required by law to share critical information with the 

NICS, which can help determine whether a person is 

legally prohibited from buying or possessing firearms. The Fix NICS Act reinforces those obligations by 

requiring federal agencies to submit to the Attorney 

General semi-annual certifications on a number of 

reporting metrics, as well as to submit four-year plans 

for improving reporting. The Attorney General must 

publish the names of those agencies that fail to comply with these requirements, and political appointees 

from non-complying agencies may not receive bonus 

pay. In addition, the DOJ is in the midst of working 

with states and tribal governments to develop plans 

to improve record sharing with the NICS, as required 

by the act. Finally, through grant preferences, the law 

incentivizes states and tribal governments to provide 

accurate and timely submissions, including through 

the Domestic Abuse and Violence Prevention Initiative, an effort designed to strengthen their ability to 

identify and submit to the NICS all felony conviction 

and domestic violence records. 

President Trump also called for immediate action to 

“encourage States’ Attorneys General to audit school 

district compliance with State emergency preparedness activities.”5

 In response, the Commission sent a 

letter to Governors, State Attorneys General, and Chief 

State School Officers encouraging them to take such 

action.6

Additional Action from Federal Agencies 

and States

Following the October 1, 2017 massacre in Las Vegas, 

NV, the Trump Administration commenced the process 

to produce a new regulation that would ban bump 

stocks. Following consideration of public comments 

on the proposed rule, a final rule implementing the 

ban is expected to be announced soon. 

In addition, HHS and ED have begun initial planning 

for the Safe School and Citizenship Education demonstration program (referenced in the Joint Explanatory 

Statement of the Consolidated Appropriations Act, 

2018).7 With the goal of providing and expanding 

mental health services in low-income public elementary schools and secondary schools, the program is 

designed to test and evaluate innovative partnerships 

between institutions of higher education and states or 

high-need local educational agencies to train qualified 

school-based mental health service professionals. 

In June 2018, the Federal Bureau of Investigation 

(FBI) convened a School Safety Summit that brought 

together state and local law enforcement partners to 

provide a forum for sharing information and discussing best practices in school safety. The topics 

discussed included how to identify troubled students; 

threat assessments; anonymous reporting systems; 

school resource officers and other law enforcement 

coordination; information sharing; hardening of 

schools; and grants and technical assistance.
10 Federal Commission on School Safety

Efforts at ED include awarding new grants related to 

school safety and the delivery of technical assistance 

to states and school districts, as well as a commitment to regular evaluations of programs. In FY 2018, 

the Department awarded 11 grants to state education 

agencies to expand their capacity to support local 

schools in creating and implementing high quality 

emergency management plans.8 ED has also awarded 

14 School Climate Transformation Grants to state education agencies to implement multi-tiered behavioral 

frameworks to improve school safety and well-being.9

ED continues to evaluate programs authorized under 

the Elementary and Secondary Education Act of 1965 

(ESEA) to understand how states and local schools are 

using funds provided under the ESEA to ensure that 

students are safe in schools.  For example, ED published the report Collaboration for Safe and Healthy 

Schools: Study of Coordination Between School 

Climate Transformation Grants and Project AWARE

in 2018.10  The Department is also developing studies 

under the Title IV, Part A program to further understand how funds are being used to support school 

safety, as well as to examine how it can best support 

schools in maximizing the use of these funds. 

In addition to funding, ED has placed an increased 

emphasis on improving technical assistance related 

to school safety including readiness and emergency 

management, safe and supportive learning, and social 

and emotional learning.11  

DHS has continued to engage students, teachers, 

school administrators, law enforcement officers, and 

other members of the K–12 school community on how 

to better prepare for and protect our schools from 

active shooters and other emergencies. Since the 

Parkland shooting, DHS Protective Security Advisors and the Transportation Security Administration 

have participated in hundreds of school security 

engagements with K–12 administrators, conducting 

assessments, sharing best practices, and facilitating 

exercises. During this period, the U.S. Secret Service 

National Threat Assessment Center provided guidance and training to approximately 2,000 school 

personnel, law enforcement, legislators, and other 

government representatives on the prevention of 

school violence. In August 2018, DHS held a two-day 

roundtable discussion with members of the K–12 

school community to collect insight and feedback on 

how to improve school safety and security. That same 

month DHS announced a grant opportunity to support 

the development of mass casualty trauma training 

for high school students.12 DHS also recently released 

a number of new school safety resources, including 

an operational guide that describes the steps schools 

can take to create a comprehensive targeted violence 

prevention plan,13 a separate guide and self-assessment tool to assist schools in conducting their own 

security risk assessments,14 and K–12 Active Shooter 

Exercise Starter Kits, which provide a package of 

exercise design, conduct, and evaluation templates to 

assist schools and school districts in conducting their 

own tabletop exercises focused on an active shooter 

incident. 

With respect to HHS, the Substance Abuse and Mental 

Health Services Administration (SAMHSA) established 

Mental Health Technology Transfer Centers.15 SAMHSA 

also awarded grants to a privacy technical assistance 

center to provide training to individuals, families, and 

practitioners on the implementation of privacy rules 

such as the Health Insurance Portability and Accountability Act (HIPAA), 42 CFR Part 2, and the intersection 

of these rules and FERPA in addressing the needs 

of school-aged children. SAMHSA has developed a 

free online interactive guide titled the “Safe Schools 

Framework Implementation Toolkit” to help schools 

and communities plan, implement, evaluate, and sustain a comprehensive and coordinated approach to 

school safety, prevention of youth violence, and activities that promote good mental health.16 Efforts are 

underway between SAMHSA and the Centers for Medicare and Medicaid Services (CMS) to provide states 

and school systems with guidance on school-based 

funding approaches to address mental and substance 

use issues.17 SAMHSA has also awarded more than 

160 grants at a total of approximately $57.5 million to 

communities across the country.18 The Administration 

is also implementing mental health programs authorized in the 21st Century Cures Act.19

In addition, individual states have taken on enhanced 

leadership roles in school safety by forming state-level 

commissions, passing state legislation, and supporting new resources (such as school safety centers).20

Together, this Administration and the states have 

made significant near-term progress in strengthening 

our schools and ensuring educators have the necessary resources to keep our students safe.
Federal Commission on School Safety 11

Background Endnotes

1 President Donald J. Trump is Taking Immediate Actions to Secure Our 

Schools (March 12, 2018). https://www.whitehouse.gov/briefings-statements/president-donald-j-trump-taking-immediate-actions-secure-schools/

2 STOP School Violence Act, Title V, Division S, the Consolidated Appropriations Act, Pub. L. No. 115-141 (March 23, 2018). 

3 Fix NICS Act, Title VI, Division S, the Consolidated Appropriations Act, 

Pub. L. No. 115-141 (March 23, 2018). 

4 https://www.justice.gov/opa/pr/department-justice-announces-more70-million-support-school-safety-and-64-million-improve

5 https://www.whitehouse.gov/briefings-statements/president-donald-j-trump-taking-immediate-actions-secure-schools/

6 https://www2.ed.gov/documents/school-safety/letter-review-emergency-operations-plans.

7 Pub. L. No. 115-141 (March 23, 2018) and Joint Explanatory Statement 

at https://docs.house.gov/billsthisweek/20180924/Joint%20%20Statement.pdf.

8 For additional information about these grants, see https://www2.

ed.gov/programs/schlemergmgt-sea/index.html.

9 For additional information about these grants, see https://www2.

ed.gov/programs/schoolclimatesea/contacts.html.

10 For a copy of the report, see https://www2.ed.gov/rschstat/eval/schoolsafety/school-climate-transformation-grants-aware-full-report.pdf.

11 The Readiness and Emergency Management for Schools (REMS) Technical Assistance Center provides a comprehensive cadre of free resources 

to assist States, local educational agencies, schools, and institutes 

of higher education with comprehensive emergency management 

planning. More information can be found at https://rems.ed.gov. The 

National Center for Safe and Supportive Learning Environments offers 

information and technical assistance to States, districts, schools, 

institutions of higher learning, and communities focused on improving 

student supports and academic enrichment including but not limited 

to school conditions. More information can be found at https://safesupportivelearning.ed.gov. The Administration has also supported the 

funding of the Center to Improve Social and Emotional Learning and 

School Safety to provide technical assistance to States and districts in 

the implementation of evidence-based programs and practices in social 

and emotional learning. More information can be found at https://www.

federalregister.gov/documents/2018/05/16/2018-10474/applicationsfor-new-award-center-to-improve-social-and-emotional-learning-andschool. Also, in September 2018, ED awarded funding for the National 

Center on Positive Behavioral Interventions and Supports. The new 

investment expands funding and services to include enhanced services 

to students with disabilities with intensive behavioral needs, expanded 

support to state and local educational agencies for activities to improve 

student safety and activities to improve student achievement by 

improving conditions for learning. 

12 https://www.grants.gov/web/grants/view-opportunity.html?oppId=307563

13 U.S. Secret Service National Threat Assessment Center. (July 2018). 

Enhancing school safety using a threat assessment model: An operational 

guide for preventing targeted school violence. https://www.secretservice.

gov/data/protection/ntac/USSS_NTAC_Enhancing_School_Safety_

Guide_7.11.18.pdf. 

14 Department of Homeland Security. (2018). K–12 school security: A guide 

for preventing and protecting against gun violence, Second Edition, at p. 

6. https://www.dhs.gov/sites/default/files/publications/K12-School-Security-Guide-2nd-Edition-508.pdf. 

15 These MHTTCs include a Network Coordinating Center, 10 Regional 

Centers, a Tribal Affairs Center and a Hispanic/Latino Center that will 

support resource development and dissemination, training and technical assistance and workforce development to the mental health field, 

including a focus in each Center on addressing school-based mental 

health. 

16 This toolkit can be accessed at https://healthysafechildren.org/

safe-schools-healthy-students-framework-implementation-toolkit. 

FAQs about the toolkit can also be found at https://healthysafechildren.

org/sites/default/files/FIT-FAQ-508.pdf. 

17 Given funding challenges faced by many states and local school systems 

in seeking to provide comprehensive support and services to students, 

this SAMHSA-CMS document will: 1) examine practices that states are 

using to support school-based mental health and substance-related 

services, and 2) present options that states and school systems may 

pursue to expand and finance school-based services.

18 The purpose of these grants is to increase education and training of 

school personnel, including teachers and student support personnel (as 

well as other adults that interact with and work with youth including 

family members, first responders, and law enforcement/juvenile justice 

personnel) around mental health issues on the identification and connection to school-based and other community resources for youth and 

families in need of treatment; and to decrease youth violence.

https://www.samhsa.gov/grants/awards/SM-18-006

https://www.samhsa.gov/grants/awards/SM-18-009

19 For more information about the 21st Century Cures Act, see https://

www.fda.gov/regulatoryinformation/lawsenforcedbyfda/significantamendmentstothefdcact/21stcenturycuresact/default.html.

20 Select Homeland Security Initiatives on School Safety in 2018. (October 

11, 2018). https://www.nga.org/wp-content/uploads/2018/10/10-10-18-

HSPS-GHSAC-Quarterly-Memo-on-School-School-Safety.pdf.
12 Federal Commission on School Safety

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Federal Commission on School Safety 13

Executive Summary

The efforts of the Federal Commission on School 

Safety have been guided by the need to promote state 

and local solutions to school violence. To that end, the 

Commission conducted field visits, listening sessions, 

and meetings with hundreds of Americans all across 

the country. The input of these individuals—state and 

local policymakers, administrators, principals and 

teachers, law enforcement and healthcare professionals, students and their families—was critical in 

identifying best practices and the recommendations 

contained in this Report. 

As set forth in the pages that follow, the work of the 

Commission falls into three broad categories:

a) Prevent—preventing school violence; 

b Protect and Mitigate—protecting students and 

teachers and mitigating the effects of violence; and

c) Respond and Recover—responding to and 

recovering from attacks. 

The Commission’s work is summarized below. 

Prevent

Character education and creation of a positive 

school climate: Character education and a positive 

school climate can help students feel connected to, 

rather than isolated from, teachers and fellow students. They can also help combat cyberbullying, an 

area where states, districts, and schools are developing and evaluating promising new approaches. 

Student-led efforts are critical to addressing cyberbullying. Firm and prompt responses to cyberbullying by 

staff are necessary as well as having suitable systems 

for the reporting of incidents. 

Mental health: Improving access to school-based 

mental health and counseling for young people is 

an important aspect of prevention. So, too, is community involvement and support, including the faith 

community. Prescribing psychotropic medications for 

complex mental health needs should only be part of a 

broader treatment plan. 

Integrating mental health, substance misuse, and 

other supportive services into school and pediatric 

settings can help early identification of needs and 

access to treatment. Testimony and information gathered from Commission listening sessions, site visits, 

and meetings noted a lack of school-based or easily 

accessible mental health professionals. Telephonic 

and telepsychiatry consultations have the potential to 

dramatically expand and enhance care.

Threat assessment: Beyond the school building 

and campus, informed and alert communities play 

a critical role in keeping our schools safe. Prior to 

most attacks, other students had concerns about 

the attacker, yet most did not report what they 

knew to a parent or other responsible adult. Outreach campaigns such as “If You See Something, Say 

Something®” and similar state-specific programs are 

essential to encouraging and facilitating the reporting 

of suspicious activities or other concerning behaviors. 

There are significant opportunities to customize or 

expand such efforts. 

Suspicious activity reporting programs must incorporate appropriate privacy protections to ensure 

compliance with the Family Educational Rights and 

Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act (HIPAA). However, confusion 

remains in some localities about whether and when 

student records can legally be shared during a health 

or safety emergency. Reducing this confusion can lead 

to greater compliance and appropriate reporting of 

threats to the safety of students and schools. 

Press coverage: For optimal engagement with the 

media after a school safety incident, state and local 

authorities should develop a media plan as part of 

their broader crisis preparedness, response, and 

recovery plan. The “No Notoriety Campaign” (i.e., not 

using shooters’ names or photos, but instead focusing 

on facts and victims) is a policy that media outlets and 

communities across the country should consider. 

Violent entertainment and rating systems: The role 

of the family is central to controlling violent entertainment. State and local educational agencies should 

collaborate with parents to strengthen internet safety 

measures to curb access to inappropriate content. 
14 Federal Commission on School Safety

In addition, the entertainment industry should ensure 

its rating systems provide parents with the full complement of information needed to make informed 

decisions about entertainment for their children.

School discipline: Maintaining order in the classroom 

is a key to keeping schools safe. Teachers are best 

positioned to identify and address disorderly conduct. 

However, guidance issued by the prior Administration 

advocated a federal solution that undercut the ability 

of local officials to address the impact of disciplinary 

matters on school safety. The guidance also relies on 

a dubious reading of federal law. The guidance should 

be rescinded and information about resources and 

best practices for improving school climate and learning outcomes should be developed for schools and 

school districts. 

Law enforcement: The available research does not 

support the conclusion that age restrictions for 

firearms purchases are effective in reducing homicides, suicides, or unintentional deaths. Most school 

shooters obtain their weapons from family members 

or friends rather than by purchasing them. States 

should consider offering training or other resources to 

promote safe storage of firearms. 

Other recommendations include encouraging states 

to adopt laws permitting “extreme risk protection 

orders” (ERPOs), which can prevent individuals who 

pose a threat to themselves or others from possessing 

or purchasing firearms. The Federal Bureau of Investigation’s Public Access Line—a critical component of 

the FBI’s efforts to keep Americans safe—has undergone changes to improve the process for receiving and 

evaluating tips from the public. 

Protect and Mitigate 

Training: All school personnel play a role in school 

safety and should take part in school safety training. 

Those best positioned to respond to acts of violence 

are those with specialized training such as school 

resource officers (SROs) who are generally sworn law 

enforcement officers. With respect to training and 

other related aspects of school safety, states and 

local policies and approaches should reflect their own 

unique circumstances and needs. 

When a school shooting occurs, law enforcement officers are the ones who rush to the scene, neutralize the 

shooter, assist victims, and secure the site. The federal 

government provides a wide array of emergency and 

crisis training resources to state, local, and tribal law 

enforcement agencies to help prevent, plan for, and 

respond to such incidents. 

Troops to Teachers: Military veterans and retired law 

enforcement officers often possess the leadership, 

experience, and essential training to help ensure the 

safety and security of our nation’s schools. As the 

Troops to Teachers program attests, veterans and 

retired law enforcement officers can also serve as 

highly effective educators where there are reduced 

barriers to certification and appropriate incentives are 

in place.

Building and campus security: Every school in 

America is different, and the appropriate protective 

measures will vary based on the characteristics of the 

site, location, resources, and personnel available. A 

risk assessment can identify vulnerabilities and enable 

the development of a strategy to address any security 

gaps. 

Effective security plans use a layered approach across 

all three areas of a school: entry points, the building 

envelope (e.g., walls, roofs, windows, doors), and the 

classroom. An effective security plan can be especially valuable in rural areas, where law enforcement 

response times may be significantly longer than in 

more urban jurisdictions. 

Respond and Recover 

Active shooter preparedness: Reports prepared in the 

aftermath of school shootings have universally recognized the value of preparing for a potential active 

shooter incident through training, planning, and 

related strategies. According to some reports, total 

casualties could have been higher in Parkland, FL, had 

the school not provided active shooter preparedness 

training to staff (the latest training coming just six 

weeks before the shooting incident). 
Federal Commission on School Safety 15

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16 Federal Commission on School Safety: Prevent

SECTION 1

Prevent
Federal Commission on School Safety: Prevent 17

CHAPTER 1

Character Development and a Culture of Connectedness 

School shooters don’t simply “snap.”1 The circumstances that lead to violence are complex and far 

ranging, often the culmination of months and years of 

individual experiences. Accordingly, improving school 

safety cannot focus solely on mitigating incidents of 

violence. Successful efforts must improve the culture 

in which students live and learn. This includes developing students of strong character who are connected 

in meaningful ways to their peers, educators, and 

communities.

Character development naturally and properly begins 

in the home. Since the founding of our nation, a clear 

consensus has recognized that character development 

is key to a successful society.2 There must be intentional efforts to foster both the academic advancement and the moral, ethical, and social-emotional 

development of students.

Character development is essential for a healthy 

school climate. The promotion of core ethical values 

such as fairness, respect, and personal responsibility 

can create a caring community that fosters students’ 

self-motivation and positive interactions.3

Fostering a culture of connectedness is another 

important aspect of school safety. In the aftermath of 

the Parkland shooting, multiple reports indicated the 

alleged shooter experienced feelings of isolation and 

depression in the years leading up to the shooting. His 

inability to connect with classmates increased his feelings of detachment and withdrawal, and his isolation 

only exacerbated other factors that led to violence.4

Perpetrators of previous school shootings shared 

that sense of detachment. For example, one Columbine shooter was characterized as depressed and 

reclusive. In a journal entry he expressed his sense of 

loneliness and isolation: “I want to die really bad right 

now...no girls (friends or girlfriends), no other friends 

except a few, nobody accepting me...I feel so lonely 

w/o a friend.”5

In a similar fashion, family members and acquaintances of the Virginia Tech shooter said that, as his 

isolation grew during his senior year, his “attention to 

schoolwork and class time dropped.” By the end, he 

had done all he could to exclude himself from Virginia 

Tech’s campus community.6

The same was true at Sandy Hook. In the months prior 

to the tragedy, the shooter isolated himself in his bedroom. He covered his windows with black trash bags 

and, even though he and his mother lived on the same 

floor of the home, insisted on communicating with her 

through email.7

Both the Bush Administration’s 2007 Report to the 

President on Issues Raised by the Virginia Tech Tragedy and the Obama Administration’s 2013 Now is the 

Time report issued recommendations on character 

education. The Bush Report encouraged teachers 

to increase connectedness in their classrooms and 

states to develop school cultures that promote safety, 

trust, respect, and open communication.8 The Obama 

Report proposed a $50 million initiative to help 8,000 

schools train teachers and other school staff to implement strategies that would improve school climate.9

The U.S. Department of Education has awarded grant 

funds through the School Climate Transformation 

Grant program to support schools implementing an 

evidence-based multi-tiered behavioral framework for 

improving behavioral outcomes and learning conditions for all students.10 The Department has invested 

$226.5 million in School Climate Transformation 

Grants.11 Since 2014, these grants have promoted state 
18 Federal Commission on School Safety: Prevent

and district efforts to develop and enhance schoolwide positive behavioral interventions and supports 

(PBIS) frameworks to improve school climate and 

promote positive school behavior.12

In addition, the Department’s Office of Special Education Programs and the Office of Elementary and 

Secondary Education jointly fund a Technical Assistance Center on PBIS that supports schools, districts, 

and states in their implementation of a multi-tiered 

approach to social, emotional, and behavioral support.13 The multiple tiers of PBIS include core instruction, supplemental instruction, and more intensive 

intervention and supports.

Commission Observations

Character education programs may work best when 

the whole school integrates character education into 

the day-to-day work of the students. School leaders 

can establish character development as a priority by 

supporting both classroom-level and school-level 

practices, as well as collaborating with families and 

community organizations. 

Commission members witnessed such an approach 

when they visited Frank Hebron-Harman Elementary 

School in Anne Arundel County, MD, to learn about 

the PBIS framework. The school program seeks to 

develop a positive school culture by helping educators 

to develop trusting relationships with their students, 

who in turn experience schools as a safe and responsive environment supporting their diverse needs, 

strengths, and learning.14

Along with character education programs, fostering 

social and emotional learning can help prevent school 

violence and improve safety. At a May 17, 2018 information session, Secretary DeVos heard from Scarlett 

Lewis, who founded the Jesse Lewis Choose Love 

Foundation after her son was killed at Sandy Hook 

Elementary School. Lewis applauded First Lady Melania Trump’s “Be Best” initiative for endorsing social 

and emotional learning, acknowledging the positive 

force of social and emotional skills to improve school 

safety.15

Social emotional learning (SEL) and character education are distinct aspects of human development. 

Research suggests that SEL builds the skills that allow 

youth to put into practice the knowledge they receive 

through character education.16

Researchers have developed different frameworks 

to define skills that support character development. 

One well-accepted framework was developed by the 

Collaborative for Academic, Social, and Emotional 

Learning (CASEL).17 Based on its experience working 

with researchers, school administrators, teachers, and 

others, CASEL encourages the development of five 

core skills: self-awareness, self-management, social 

awareness, relationship skills, and responsible decision-making. 

Positive Behavioral Interventions 

and Supports (PBIS) 

The PBIS framework supports local flexibility in the 

selection and implementation of practices in each 

site, based on unique needs and resources. It has 

included a variety of programs addressing classroom management, bullying, discipline, character 

development, social emotional development, and 

general school climate. For example, a teacher at 

Hebron-Harman rearranges her classroom seating 

every two weeks. But before doing so, she asks 

students to write down the names of five classmates 

they would like to sit close to and five they think 

would like to sit near them. Through this simple but 

effective practice, she can identify which students 

lack connections with their classmates. 

Research suggests that social emotional learning 

(SEL) builds the skills that allow youth to put into 

practice the knowledge they receive through character education.
Federal Commission on School Safety: Prevent 19

Youth who learn these core skills are able to “manage their emotions and interactions in ways that 

benefit themselves and others.”18 Most importantly, 

recent research suggests that the development of 

social and emotional skills can lead to improved outcomes for educational attainment, employment, and 

earnings. It can also lead to a significant decrease in 

the likelihood of crime and delinquency, substance 

use, antisocial behavioral conditions, aggression, 

and violent behavior.19

In addition, the Commissioners heard testimony that 

34 percent of high schoolers in America are cyberbullied, and 80 percent of students who are cyberbullied 

are also bullied at school. Research has tied experience with bullying and cyberbullying to low-self-esteem, depression, anxiety, family problems, academic difficulties, delinquency, school violence, and 

suicidal thoughts and attempts. Dr. Sameer Hinduja, 

Professor in the School of Criminology and Criminal 

Justice at Florida Atlantic University and Co-Director 

of the Cyberbullying Research Center, told Commissioners that students who cultivate characteristics 

such as social intelligence, resilience, and confidence 

are less likely to be bullied or to bully others. Hinduja 

also cited recent studies that found significantly less 

bullying in schools where students perceived a better 

or more positive school climate. 20

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¤ STATES & LOCAL COMMUNITIES 

1. States should provide resources for their schools to help create a positive school climate where 

students feel connected to, rather than isolated from, their teachers and fellow students. 

2. States should support character education programs and expand those already in existence using 

various federal21 or state funds.22

• When considering the character education programs, states might use a framework researchers 

have summarized using the acronym PRIMED: Prioritization, Relationships, Intrinsic Motivation, 

Modeling, Empowerment, and Developmental Pedagogy.23

‒ Prioritization to ensure character education is an authentic priority for the school by developing shared language, values, and active support from leadership that affirms character as an 

integral part of a school’s mission. 

‒ Relationship building among staff, youth, families, and communities (including teachers) 

emphasizing cooperative learning and teaching interpersonal skills. 

‒ Intrinsic motivation to help youth internalize ethical and performance values. Effective programs 

focus on integrating activities that promote self-growth, such as personal goal setting. 

‒ Modeling ethical and performance values for fostering character development. Youth learn from 

their older peers as well as adults (e.g., teachers can demonstrate respect in how they speak to 

students). 

‒ Empowerment results from youth having opportunities for leadership responsibility and a voice 

in the classroom. 

‒ Developmental pedagogy identifies explicit teaching, setting high expectations for youth and 

practicing identified skills as hallmarks of effective character development programs.
20 Federal Commission on School Safety: Prevent

• The U.S. Department of Education’s What Works Clearinghouse completed a systematic review of 

character education interventions and identified nine that had positive or potentially positive effects 

on one or more of the following: students’ behavior; academic achievement; and students’ knowledge, attitudes, and values.24

3. Schools and districts should adopt effective social and emotional learning (SEL) strategies.

• SEL programs might include the following: a curriculum to teach specific SEL skills; a modification to 

school or classroom climate through teacher practices or school-wide changes to rules and expectations; and practices to help students develop a growth mindset (i.e., the belief that they can develop 

most basic abilities through dedication and hard work).25

• A recent review of state and district resources for implementing SEL programs highlights the importance of leadership, resources, and legislative support from states and school districts.26

4. Schools and districts should use a variety of data sources, including school climate surveys, to guide 

the selection of evidence-based interventions tailored to their specific needs. 

• To assist districts in measuring school climate, the U.S. Department of Education developed school 

climate surveys that school leaders can download and administer on a web-based platform at no 

cost. The Department also developed resources for district leaders to use as they interpret their 

school climate data.27 Using these resources, once a district identifies needs related to school 

climate, it can then select and implement an evidence-based intervention and then examine and 

reflect on the outcomes of the intervention.28

5. Schools and districts should adopt tiered social, emotional, and behavioral supports to establish a 

climate that appropriately supports and responds to student behavior. 

• The Pennsylvania State University and the Robert Wood Johnson Foundation issued a joint briefing 

paper that discusses school climate, SEL, and blended models that have positive effects on school 

climate and social and emotional competence. This paper illustrates six key elements for nurturing 

a healthy school climate and building students’ emotional competence: supportive relationships, 

engagement, safety, cultural responsiveness, academic challenge, and high expectations.29

• Research illustrates the potential of a comprehensive tiered system of support for academics, 

behavior, and SEL.30

• The U.S. Department of Education’s Office of Safe and Healthy Students (OSHS), a part of the Office 

of Elementary and Secondary Education (OESE), administers the Readiness and Emergency Management for Schools (REMS) Technical Assistance Center. The Center helps school districts assess the 

safety, security, accessibility, and emergency preparedness of school buildings and grounds. It also 

offers tips to help guide school officials in using multi-tiered interventions and supports to improve 

school climate.31
Federal Commission on School Safety: Prevent 21

Chapter 1 Endnotes

1 Statement from Dr. Marisa Reddy Randazzo to the Federal Commission 

on School Safety (May 17, 2018). https://www2.ed.gov/documents/

press-releases/federal-commission-school-safety-marisa-reddy-randazzo.pdf. 

2 See Benjamin Franklin’s statement of 1750: “...nothing is of more 

importance for the public weal, than to form and train up youth 

in wisdom and virtue. Wise and good men are, in my opinion, the 

strength of a state...” https://founders.archives.gov/documents/Franklin/01-04-02-0009. See also the words of John Quincy Adams: “Public 

Virtue cannot exist in a Nation without private, and public Virtue is the 

only Foundation of Republics. There must be a positive Passion for the 

public good, the public Interest, Honour, Power, and Glory, established 

in the Minds of the People, or there can be no Republican Government, nor any real Liberty.” https://founders.archives.gov/documents/

Adams/06-04-02-0044; and “Human nature with all its infirmities and 

depravation is still capable of great things. It is capable of attaining to 

degrees of wisdom and of goodness, which, we have reason to believe, 

appear respectable in the estimation of superior intelligences. Education makes a greater difference between man and man, than nature has 

made between man and brute. The virtues and powers to which men 

may be trained, by early education and constant discipline, are truly 

sublime and astonishing.” https://founders.archives.gov/documents/

Adams/04-01-02-0209. 

3 Character.org. (n.d.). Retrieved from http://character.org/.

4 Viglucci, A., Rabin, C., Nehamas, N., & Blaskey, S. (October 31, 2018). 

“Filled with rage”: How a scrawny misfit turned into Florida’s worst 

school shooter. Retrieved from Tampa Bay Times: https://www.tampabay.com/news/publicsafety/-Filled-with-rage-How-a-scrawny-misfitturned-into-Florida-s-worst-school-shooter_165830512.

5 Hong, J.S., Cho, H., Allen-Meares, P., & Espelage, D.L. (2010). The social 

ecology of the Columbine High School shootings. Children and Youth 

Services Review. Retrieved from http://wp.vcu.edu/hsep/wp-content/

uploads/sites/3338/2013/06/columbine-risk-factors.pdf.

6 Gardner, A., & Cho, D. (May 6, 2007). Isolation defined Cho’s senior year. 

Retrieved from Washington Post: http://www.washingtonpost.com/

wp-dyn/content/article/2007/05/05/AR2007050501221.html.

7 Flegenheimer, M. (December 27, 2013). Final report on Sandy Hook 

killings sheds new light on gunman’s isolation. Retrieved from New York 

Times: https://www.nytimes.com/2013/12/28/nyregion/with-release-offinal-sandy-hook-shooting-report-investigation-is-said-to-be-over.html.

8 U.S. Departments of Justice, Health and Human Services, and Education. (2007). Report to the President: On issues raised by the Virginia Tech 

tragedy. Retrieved from https://www.justice.gov/archive/opa/pr/2007/

June/vt_report_061307.pdf.

9 Obama Administration. (2013). Now is the time. Retrieved from https://

obamawhitehouse.archives.gov/issues/preventing-gun-violence.

10 U.S. Department of Education. (n.d.). Programs: School Climate Transformation Grant – Local Educational Agency Grants. Retrieved from https://

www2.ed.gov/programs/schoolclimatelea/index.html.

11 The $226.5 million represents the total of such grants from 2014 through 

2018 based on U.S. Department of Education data. 

12 Positive Behavioral Interventions and Support: OSEP Technical Assistance Center. (n.d.). Implementation blueprint. Retrieved from https://

www.pbis.org/blueprint/implementation-blueprint.

13 Positive Behavioral Interventions and Support: OSEP Technical Assistance Center. (n.d.). Retrieved from https://www.pbis.org/.

14 Positive Behavioral Interventions and Support: OSEP Technical Assistance Center. (n.d.). Briefs. Retrieved from https://www.pbis.org/blueprintguidestools/briefs.

15 Statement of Scarlett Lewis before the Federal Commission on School 

Safety (May 17, 2018). https://www2.ed.gov/documents/press-releases/

federal-commission-school-safety-scarlett-lewis.pdf.

16 Moroney, D., & Devaney, E. (2017). How the out-of-school time workforce 

can support character development through social and emotional 

learning: A review of literature and future directions. Journal of Character Education, 13(1), 67–89.

17 CASEL is a voluntary association formed more than 20 years ago, with 

the express goal of establishing high-quality, evidence-based SEL as an 

essential part of preschool through high school education. 

18 Jones, S.M., & Doolittle, E.J. (2017). Social and emotional learning: 

Introducing the issue. The Future of Children, Vol. 27, No.1, 3–11.

19 Jones, D.E., Karoly, L.A., Crowley, D.M., & Greenberg, M.T. (2015). 

Considering valuation of noncognitive skills in benefit-cost analysis 

of programs for children. Journal of Benefit-Cost Analysis, 6, 471–507. 

DOI:10.1017/ bca.2015.53.

20 Statement of Sameer Hinduja, Ph.D., before the Federal Commission 

on School Safety (June 21, 2018). https://www.ed.gov/news/press-releases/readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety.

21 A variety of federally-funded programs may be used, in part, for character education, school climate, culturally responsive teaching strategies, 

and similar programs so long as they meet program requirements. This 

might include: Title I Grants to Local Educational Agencies (https://

www2.ed.gov/programs/titleiparta/index.html), Student Support and 

Academic Enrichment Grants (https://www2.ed.gov/programs/ssae/

index.html), 21st Century Community Learning Centers (https://www2.

ed.gov/programs/21stcclc/index.html), Rural Education Achievement 

Program (https://www2.ed.gov/nclb/freedom/local/reap.html), Indian 

Education Grants to Local Educational Agencies (https://www2.ed.gov/

programs/indianformula/index.html), Demonstration Grants for Indian 

Children (https://www2.ed.gov/programs/indiandemo/index.html), 

Education Innovation and Research (https://innovation.ed.gov/whatwe-do/innovation/education-innovation-and-research-eir/), and Special 

Education Technical Assistance and Dissemination (https://www2.

ed.gov/programs/oseptad/index.html).

22 Since 2000, Arizona has supported character education through 

legislative actions as well as voter initiatives providing funding to teach 

character education in schools. Currently, the state incentivizes a focus 

on character education through a state-sponsored Character Education 

Matching Grant; any public (including charter) school that teaches a 

character education curriculum aligned to the state’s definition, codified in law, is eligible to apply. Additionally, the state allows individuals 

to claim an extracurricular activity (ECA) tax credit for making contributions to public schools in Arizona for supporting character education 

programs as well as other activities that supplement the school’s 

educational program. For more information, visit http://www.character.

org/wp-content/uploads/What-States-Are-Doing.pdf and http://www.

azed.gov/character-education/.

23 Berkowitz, M.W., Bier, M.C., & McCauley, B. (2017). Toward a science of 

character education: Frameworks for identifying and implementing 

effective practices. Journal of Character Education, 13(1) 33–51. National 

Academies of Sciences, Engineering, and Medicine. Approaches to the 

development of character: Proceedings of a workshop. Washington, DC: 

The National Academies Press.

24 U.S. Department of Education, Institute of Education Sciences. (2007). 

What works clearinghouse: Character education. Washington, DC: 

Author. Accessed June 25, 2018, from https://files.eric.ed.gov/fulltext/

ED497054.pdf. The What Works Clearinghouse defines “potentially positive effects” as evidence of a positive effect with no overriding contrary 

evidence. “Positive effects” are defined as strong evidence of a positive 

effect with no overriding contrary evidence.

25 Jones and Doolittle. (2017).

26 O’Conner, R., De Feyter, J., Carr, A., Luo, J. L., & Romm, H. (2017). A 

review of the literature on social and emotional learning for students ages 

3–8: Implementation strategies and state and district support policies

(part 2 of 4) (REL 2017–246). Washington, DC: U.S. Department of Education, Institute of Education Sciences, National Center for Education 

Evaluation and Regional Assistance, Regional Educational Laboratory 

Mid-Atlantic. Retrieved from https://ies.ed.gov/ncee/edlabs/regions/

midatlantic/pdf/REL_2017246.pdf.

27 For more information on the U.S. Department of Education’s School 

Climate Surveys, see https://safesupportivelearning.ed.gov/edscls. Note 

that the U.S. Department of Education will not have access to any data 

that districts create with this tool.

28 U.S. Department of Education. (2016). Non-regulatory guidance: Using 

evidence to strengthen education investments. Retrieved from https://

www2.ed.gov/policy/elsec/leg/essa/guidanceuseseinvestment.pdf.
22 Federal Commission on School Safety: Prevent

29 Penn State and Robert Wood Johnson Foundation (2018). School 

climate and social and emotional learning: The integration of two 

approaches. Retrieved from http://prevention.psu.edu/uploads/files/

rwjf443059.pdf.

30 Maras, M.A., Thompson, A.M., Lewis, C., Thornburg, K., & Hawks, J. 

(2015). Developing a tiered response model for social-emotional 

learning through interdisciplinary collaboration. Journal of Educational 

and Psychological Consultation, 198–223. Retrieved from https://www.

tandfonline.com/doi/full/10.1080/10474412.2014.929954?scroll=top

&needAccess=true.

31 U.S. Department of Education, Office of Safe and Healthy Students, 

REMS TA Center. (n.d.). School climate and emergencies. Retrieved from 

https://rems.ed.gov/K12SchoolClimateAndEmerg.aspx.
Federal Commission on School Safety: Prevent 23

CHAPTER 2

Cyberbullying and School Safety 

Social media can help students access information, 

connect with family and friends, and provide a means 

of communication for those who feel isolated or disconnected in the offline world. However, social media 

can also provide a platform for unfortunate interactions with others,1

 such as cyberbullying.2 Educators 

are equally aware that some online conduct, although 

perceived as bullying, may be protected by the First 

Amendment.

Based on lessons learned from the shooting in Parkland, the Broward County League of Cities indicated a 

need for proactive social media monitoring protocols 

to identify threats and at-risk behaviors.3 The role of 

schools in intervening in cyberbullying can be challenging, as students access technology using school 

and personal internet services, during and outside of 

school hours, and on and off school grounds. Most 

schools are limited in their ability to identify and 

address behavior that occurs off school grounds. 

In spite of this, there are many examples of school 

efforts to address cyberbullying. Since 2010, the Federal Partners in Bullying Prevention have developed 

and disseminated key resources via StopBullying.gov 

and hosted a biannual bullying prevention summit.4

First Lady Melania Trump recently launched the “Be 

Best” initiative, which focuses, in part, on addressing 

cyberbullying.5 Various federal programs may, among 

other purposes, support efforts to address cyberbullying, such as improving school climate and anti-bullying interventions.6

Commission Observations

In recent surveys, 34 percent of youth reported being 

cyberbullied in their lifetime, and bullying has been 

cited as a contributing factor in cases of extreme retaliation, including school shootings.7

The Commission heard about the importance of 

engaging the broader community in cyberbullying 

prevention efforts and of empowering students to lead 

such initiatives. Presenters characterized cyberbullying as a behavioral issue that is not distinct from more 

traditional in-person forms of bullying. They emphasized the importance of not blaming technology or 

restricting access as the means to address cyberbullying. Instead, the presenters suggested focusing on 

improving overall school climate and changing social 

norms on how technology is used.

At the June 21 Commission meeting, Dr. Sameer Hinduja, Professor in the School of Criminology and Criminal Justice at Florida Atlantic University and Co-Director of the Cyberbullying Research Center, made the 

point that cyberbullying is not a technology issue, but 

rather a social issue. He recommended efforts to build 

school climate, normalize pro-social behaviors (i.e., 

responsible digital citizenship), support student-led 

initiatives, and facilitate student resilience. Hinduja 

also stressed the importance of students having an 

adult to turn to if they are dealing with an issue such 

as cyberbullying.8 This reinforces recent findings 

about the key role educators play in empowering students to inform them of cyberbullying and the need to 

break the “code of silence.”9

Dr. Paul Gausman, Superintendent of the Sioux City 

Community School District, shared with the Commission some successful strategies in his district for 

addressing cyberbullying. The district collaborates 

with a company to scan potential social media threats 

and receive actionable alerts. (Recommendations 

following the Parkland shooting similarly included the 

need for proactive social media monitoring protocols to identify threats and at-risk behaviors.10) Sioux 

City also has an online reporting tool for parents and 

community members to raise concerns. This serves as 

a significant tool given that a lot of bullying, including 

cyberbullying, goes unreported and that cyberbullying 

is a community-based problem. In addition, Gausman 

✔ FAST FACTS

In recent surveys, 34 percent of youth reported being 

cyberbullied in their lifetime, and bullying has been 

cited as a contributing factor in cases of extreme 

retaliation, including school shootings.
24 Federal Commission on School Safety: Prevent

spoke about his district’s digital citizenship courses for 

freshmen and reward systems that encourage appropriate social media use.11

With respect to state and local laws, a handful of 

states and localities have begun to enact laws with 

criminal penalties for cyberbullying. Key components 

of state-enacted laws may include specification of 

prohibited conduct and development and implementation of district procedures for reporting, investigating, and responding to bullying.12

Many schools are using programs designed to intervene in both bullying and cyberbullying behaviors, 

given their inherent linkages. However, program 

outcomes have largely been inconsistent in the United 

States. Many have not led to a significant reduction 

in bullying (even those programs with demonstrated 

results in other countries).13 On the other hand, developing a positive school climate is consistently associated with lower rates of bullying and cyberbullying 

behaviors.14

Considerations for parents

Parents can alert school staff if they become aware 

that their child may be engaging in, or a target of, 

cyberbullying. Schools and districts can coordinate 

with parents to clarify protocols for how parents, students, and members of the community can report this 

information. 

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. The appropriate federal agencies should assist states and school districts in leveraging support from 

existing programs that help reduce cyberbullying.

• StopBullying.gov provides information from various government agencies on what bullying is, 

what cyberbullying is, who is at risk, and how people can prevent and respond to bullying. The 

site provides helpful research and resources about bullying-prevention training, state laws and 

policies, what schools and students can do to prevent bullying, and more.15

• The U.S. Department of Education’s Office of Safe and Healthy Students administers the Readiness 

and Emergency Management for Schools (REMS) Technical Assistance Center. The Center offers 

tips to help guide school officials in considering the use of social media in school behavioral threat 

assessments.16

• The U.S. Department of Health and Human Services’ website MedlinePlus provides resources that 

inform users of the warning signs of bullying, prevention and risk factors, and how to help children 

deal with bullying.17 It also discusses existing laws and policies regarding bullying. 

¤ STATES & LOCAL COMMUNITIES 

1. Many states, districts, and schools are creating their own, innovative approaches to cyberbullying. 

These practices, many of which are still in the process of being evaluated, could show promise for 

Districts and schools approach cyberbullying in 

a variety of ways, including: 

• Implementing strategies to improve school 

climate using feedback gathered from school 

climate surveys that measure perceptions of 

bullying and cyberbullying; 

• Providing direct programing for social and 

emotional learning or digital citizenship; 

• Providing students access to mental health 

services; and 

• Updating discipline policies to include 

cyberbullying. 
Federal Commission on School Safety: Prevent 25

preventing and/or addressing cyberbullying. States should adopt similar and effective practices or 

develop their own. Some examples include:

• Sioux City, IA: As shared by Dr. Paul Gausman during the June 21 Commission meeting, Sioux 

City Community School District is investing in a multifaceted approach to tackling bullying and 

cyberbullying. Efforts include empowering and training school staff to take an active role in 

responding to bullying incidents. They also involve creating a positive school climate; implementing evidence-based social and emotional learning, character education, and mentor programs for 

students; and enacting clear anti-bullying policies.

• Seattle, WA: Seattle Public Schools is partnering with a nonprofit organization that serves as 

an intermediary between the district and social media companies to identify and negotiate the 

removal of cyberbullying content.18

• Deer Park, TX: The Deer Park Independent School District is using a computer-and smartphone-based anonymous reporting application to receive reports of concerning student behavior 

(such as bullying, cyberbullying, suicidal behaviors, and cheating) from students and parents. The 

school not only receives these reports but can connect students to school-based resources such as 

school counselors.19

• Poughkeepsie, NY: Poughkeepsie High School and other schools across the state teamed with 

students from Sienna College to host peer-to-peer learning sessions to create an “upstander” 

culture around cyberbullying. The goal of the trainings was to build students’ digital responsibility 

and identify student leaders to become ambassadors for their school.20

• Pennsylvania: The state convened a workgroup of key stakeholders to explore its current capacity 

to prevent bullying, including cyberbullying, and identify potential facilitators and barriers to creating safer and more supportive learning environments. The workgroup, consisting of youth-serving agencies, health providers, educators, and researchers, provided recommendations that form 

the basis of a statewide plan to address bullying.21

2. States, districts, and schools should adopt policies to help prevent cyberbullying, such as school 

climate initiatives and support for digital citizenship and character development. Because of the 

importance of peer influence, schools can consider ways to have these efforts led by students.

3. States, districts, and schools should use appropriate systems to monitor social media and mechanisms for reporting cyberbullying incidents.22 Examples include:

• Michigan’s OK2SAY program allows students to confidentially report tips on potential harm or 

criminal activities directed at schools, students, or school employees. It uses a comprehensive 

communication system to facilitate tip sharing—about harmful behaviors that threaten to disrupt 

the learning environment—among parents, school personnel, students, community mental health 

service programs, the Michigan Department of Health and Human Services, and law enforcement 

officers. OK2SAY also has a free mobile app that allows users to submit real-time confidential tips.23

• Colorado’s Safe2Tell program provides an anonymous way for students, parents, school staff, 

and community members to report concerns regarding their safety or the safety of others. It also 

provides resources to educate the community on the importance of breaking the code of silence as 

well as technical assistance to schools and communities before and after tragic events. A Safe2Tell 

mobile app for reporting threatening behaviors and safety concerns in Colorado is available for 

students, parents, and community members.24
26 Federal Commission on School Safety: Prevent

Chapter 2 Endnotes

1 Shapiro, L.A.S., & Margolin, G. (2014). Growing up wired: Social networking sites and adolescent psychosocial development. Clinical Child and 

Family Psychology Review, 17(1), 1–18.

2 Cyberbullying is defined as bullying behavior that takes place through 

electronic technology including social media platforms, text messages, 

video game platforms, and other internet and mobile applications. 

Cyberbullying is not considered a distinct form of bullying; rather, 

electronic technology and social media are contexts in which multiple 

forms of bullying can occur. According to the Centers for Disease Control 

and Prevention’s uniform definition, bullying is aggressive behavior 

between school aged youth in the context of a real or perceived power 

imbalance that is repeated, or has the potential to be repeated, over 

time. The definition stresses that because messages shared online often 

are viewed by multiple people, and therefore the harm is repeated, 

even a single incident can be considered bullying under this definition. 

(See Gladden, R.M., et al. (2014). Bullying surveillance among youths: 

Uniform definitions for public health and recommended data elements. 

Version 1.0. Centers for Disease Control and Prevention.) Some incidents, however, while perceived as bullying, may be protected speech 

under the First Amendment.

3 Broward League of Cities and Engage One Broward. (June 4, 2018). The 

Broward County League of Cities’ School and Community Public Safety 

Task Force initial report and recommendations. Broward County, FL. 

Retrieved from http://browardleague.org/wp-cnt/uploads/2018/06/

BLOC_PUBLICSAFETY_TASKFORCE_FINAL_RR_6_2_18_PM1.pdf.

4 www.stopbullying.gov.

5 https://www.whitehouse.gov/bebest/.

6 Consistent with program requirements, Title I grants to local educational agencies (https://www2.ed.gov/programs/titleiparta/index.html) 

may support school districts in improving conditions for student learning in Title I schoolwide program schools, including through reducing 

incidences of bullying and harassment. Student Support and Academic 

Enrichment grants (https://www2.ed.gov/programs/ssae/index.html) 

and grants under both Rural Education Achievement Programs (REAP) 

(the Small, Rural School Achievement (SRSA) and Rural, Low-Income 

Schools (RLIS) programs (https://www2.ed.gov/nclb/freedom/local/

reap.html)) may be used for activities to support safe and healthy 

students, which may include interventions and supports to help prevent 

or respond to bullying and harassment. In addition, 21st Century 

Community Learning Centers (https://www2.ed.gov/programs/21stcclc/

index.html) are used for before- or after-school activities, some of which 

could support anti-bullying efforts. Indian Education Grants to Local 

Educational Agencies (https://www2.ed.gov/programs/indianformula/

index.html) can include activities to educate individuals so as to prevent 

violence, suicide, and substance abuse.

7 Hinduja, S., & Patchin, J. (2016). New national bullying and cyberbullying data. Cyberbullying Research Center. Retrieved from https://cyberbullying.org/new-national-bullying-cyberbullying-data.

8 Statement of Dr. Sameer Hinduja before the Federal Commission on 

School Safety (June 21, 2018). https://www2.ed.gov/documents/schoolsafety/transcript-06-21-2018.pdf. 

9 U.S. Secret Service and U.S. Department of Education. (July 2004). The 

final report and findings of the safe school initiative: Implications for the 

prevention of school attacks in the United States. Washington. DC: U.S. 

Secret Service and U.S. Department of Education. 

Threat assessment in schools: A guide to managing threatening situations and to creating safe school climates. Washington, DC.

10 Broward League of Cities and Engage One Broward. (June 4, 2018). The 

Broward County League of Cities’ School and Community Public Safety 

Task Force initial report and recommendations. Broward County, FL. 

Retrieved from http://browardleague.org/wp-cnt/uploads/2018/06/

BLOC_PUBLICSAFETY_TASKFORCE_FINAL_RR_6_2_18_PM1.pdf.

11 Statement of Dr. Paul Gausman, Superintendent of Sioux City Community School District, before the Federal Commission on School Safety 

(June 21, 2018). https://www2.ed.gov/documents/school-safety/transcript-06-21-2018.pdf.

12 U.S. Department of Health and Human Services. (n.d.). Key components 

in state anti-bullying laws. Retrieved from https://www.stopbullying.

gov/laws/key-components/index.html.

13 Ttofi, M.M., & Farrington, D.P. (2011). Effectiveness of school-based 

programs to reduce bullying: A systematic and meta-analytic review. 

Journal of Experimental Criminology, 7(1), 27–56. Retrieved from http://

njbullying.org/documents/ttofifarrington2011.pdf.

14 Lessne, D., Yanez, C., & Sinclair, M. (2018). Measuring school climate 

using the 2015 School Crime Supplement. (NCES 2018-098). U.S. Department of Education, Institute of Education Sciences, National Center for 

Education Statistics. Also, Bradshaw, C.P., Sawyer, A.L., & O’Brennan, 

L.M. (2009). A social disorganization perspective on bullying-related 

attitudes and behaviors: The influence of school context. American Journal of Community Psychology, 43(3–4), 204–220. Retrieved from https://

www.ncbi.nlm.nih.gov/pubmed/19333749. Also, Swearer, S.M., Espelage, D.L., Vaillancourt, T., & Hymel, S. (2010). What can be done about 

school bullying? Linking research to educational practice. Educational 

Researcher, 39(1), 38–47. DOI:10.3102/0013189X09357622.

15 U.S. Department of Health and Human Services. (n.d.). Stopbullying.gov. 

Retrieved from https://www.stopbullying.gov/.

16 U.S. Department of Education, Office of Safe and Healthy Students, 

REMS TA Center. (n.d.). Use of social media in school behavioral threat 

assessments. Retrieved from https://rems.ed.gov/SocialMediaThreatAssessment2016Webinar.aspx.

17 U.S. National Library of Medicine. (n.d.). MedlinePlus: Bullying. Retrieved 

from https://medlineplus.gov/bullying.html.

18 Seattle Public Schools. (n.d.). District partners to stop bullying on social 

media. Retrieved from https://www.seattleschools.org/district/calendars/news/what_s_new/district_partners_to_stop_bullying_on_social_

media.

19 Deer Park Independent School District. (n.d.). Anonymous alerts. 

Retrieved from https://www.anonymousalerts.com/deerparkisd/.

20 Schutzmann, N. Poughkeepsie students learn tips to fight cyberbullying. 

Retrieved from Poughkeepsie Journal: https://www.poughkeepsiejournal.com/story/news/education/2017/11/03/students-learn-tips-fight-cyberbullying/829235001/.

21 Pennsylvania Department of Education. (August 2015). Pennsylvania 

bullying prevention support plan. Harrisburg, PA. Retrieved from https://

www.education.pa.gov/Documents/K-12/Safe%20Schools/Bullying%20

Prevention%20-%20Intro%20and%20Background%20FINAL.pdf.

22 U.S. Department of Health and Human Services. (n.d.). Key components 

in state anti-bullying laws. Retrieved from https://www.stopbullying.

gov/laws/key-components/index.html.

23 For more information visit, https://www.michigan.gov/

ok2say/0,5413,7-366-86296---,00.html.

24 For more information, visit https://safe2tell.org/?q=about-us.
Federal Commission on School Safety: Prevent 27

A consistent theme throughout Commission listening sessions, site visits, and meetings was the lack of 

mental health professionals in schools or centers that 

students and schools can easily access. 

Individuals who commit mass shootings may or may 

not have a serious mental illness (SMI). There is little 

population-level evidence to support the notion that 

those diagnosed with mental illness are more likely 

than anyone else to commit gun crimes. Researchers 

have concluded that less than 3–5 percent of U.S. 

crimes involve people with mental illness, and the percentages of crimes that involve guns are lower than 

the national average for persons not diagnosed with 

mental illness.1 Databases that track gun homicides 

(such as the National Center for Health Statistics) 

similarly show that less than 5 percent of the 120,000 

gun-related killings in the United States between 2001 

and 2010 were perpetrated by people diagnosed with 

mental illness.2

A U.S. Department of Education and U.S. Secret 

Service analysis found that as many as a quarter of 

individuals who committed mass shootings had been 

in treatment for mental illnesses, and more than 

three-quarters had symptoms of a mental illness 

prior to the time of the shooting.3 Earlier research 

suggests that such individuals often feel aggrieved 

and extremely angry, and nurture fantasies of violent 

revenge. They typically do not voluntarily seek out 

mental health treatment.4

Although the presence of a mental illness may not be 

directly correlated to violence, trends with respect 

to youth mental illness are of great concern. Rates of 

youth depression, anxiety, self-harm, and most tragically, suicide are climbing.5,6,7,8

 Approximately one in 

10 children and youth in the United States experience 

a serious emotional disturbance (SED), yet only 20 

percent of them receive the help they need.9,10,11 The 

reasons for this include failure to recognize problems, 

fear of negative attitudes and discrimination, and lack 

of resources.12

Many of these children perform poorly in school and 

have difficulties at home and in the community. For 

example, according to the Centers for Disease Control 

and Prevention (CDC), between 2007 and 2015 suicide 

rates increased by 31 percent for males aged 15–19 

(from 10.8 to 14.2 per 100,000 population) and by 40 

percent for females aged 15–19 (from 2.4 to 5.1 per 

100,000).13 Trauma, social isolation, and bullying are 

highly correlated with the development of SED.14,15,16

Transition-age youth (16–25 years) are a population 

of particular concern given their high rates of SED and 

low rates of seeking help. 

Similar factors and signs existed in the case of the 

Parkland shooting, which was allegedly committed 

by a transition-aged youth. The alleged shooter had 

experienced numerous instances of difficulties in the 

community and with his family, including violence 

against animals and toward his mother and others. 

The aforementioned social isolation also appeared to 

be a factor in the Parkland case. The alleged shooter 

was reported to be lonely, ostracized, and volatile. 

A growing number of studies suggests that greater 

mental, emotional, and behavioral health impacts 

might be achieved by enhancing protective factors 

and reducing risk factors that place children and 

adolescents at risk for adverse health and educational 

outcomes. These efforts also might buffer children 

and adolescents from the potentially harmful effects 

of negative situations and events, such as exposure to 

violence.17

Unfortunately, past experience demonstrates that 

these trends are not new. The US has seen alarming 

school shootings which previous Administrations 

CHAPTER 3

Curating a Healthier and Safer Approach: 

Issues of Mental Health and Counseling for Our Young 

Approximately one in 10 children and youth in 

the United States experience a serious emotional 

disturbance, yet only 20 percent of them receive 

the help they need.
28 Federal Commission on School Safety: Prevent

have aimed to address. An examination of recommendations from previous Administrations reveals 

that many did not focus specifically on mental illness identification or service provision. For example, 

recommendations following the Columbine shooting focused largely on improving law enforcement’s 

response to these types of events. Recommendations 

from subsequent reports, such as following the Virginia Tech shooting, did address access to the mental 

healthcare system; however, the recommendations 

centered on a very narrow and specific component of 

the mental healthcare delivery system. The Now is the 

Time response following the tragedy at Sandy Hook 

demonstrated an evolving understanding of the need 

to address mental health issues through comprehensive recommendations on mental healthcare reform. 

A review of the Parkland shooting indicates that we 

need to be more specific and comprehensive with 

these recommendations.

There is an urgent need to reduce risk for youth mental, emotional, and behavioral difficulties through the 

implementation of efficacious and effective prevention interventions, as well as identify youth at risk 

for mental illness in schools and connect them with 

needed treatment and services.18 This includes efforts 

to increase basic mental health literacy, particularly for those working with young people. Research 

has shown that early identification and treatment 

improves outcomes. Thus, intervening early is critical 

given that half of all lifetime cases of mental illness 

begin by age 14 and three-quarters by age 24.19 

Most communities and schools lack high-quality treatment for children and adolescents, however.20 Many 

areas of the nation are without psychiatrists, psychologists, and other professionals (especially those with 

experience in treating children) to meet the growing 

needs. Navigating complex systems to seek care is 

often challenging for families and involves long wait 

times, few services, and poor insurance coverage.

Commission Observations

Schools have the potential to play a key role in 

preventing youth mental, emotional, and behavioral 

difficulties, identifying and supporting students with 

mental health problems and reducing youth violence. 

Yet up to 79 percent of school-age youth have unmet 

mental health needs.21 The Individuals with Disabilities Education Act (IDEA) makes available a free 

appropriate public education to eligible children with 

disabilities throughout the nation and ensures special 

education and related services for them. The IDEA 

governs how states and public agencies provide early 

intervention, special education, and related services 

to more than 6.5 million eligible infants, toddlers, 

children, and youth with disabilities. 

Unfortunately, many schools lack the capacity to identify and adequately treat mental illness. School principals report that student mental health needs are one 

of their biggest challenges.22 Integrating mental health 

prevention and treatment services and supports into 

schools can provide many benefits, including reducing 

risk for mental health disorders and increasing access 

to care for those who need treatment while reducing 

the stigma of seeking help. It can also help provide 

early identification, intervention, and a full continuum 

of services while using a multidisciplinary approach. 

This involves engaging teachers, parents, and community providers as partners in promoting social, emotional, and academic learning for all students. The 

continuum of services includes violence prevention 

programs along with social and emotional development efforts, such as the evidence-based model of the 

Positive Behavioral Interventions and Supports (PBIS) 

framework.23 Bringing these efforts to scale across 

the nation and sustaining them are important steps 

in improving student mental health and preventing 

adverse outcomes, including aggression and bullying. 

Healthcare providers can also play an important 

role in identifying children at risk. For example, at a 

school-based health center in Ashland, OR, a family 

nurse practitioner addresses a range of behavioral 

health concerns, including depression, threats of 

violence, and suicide, for students as well as their 

families.24 Additionally, some schools have embedded health clinics that may play an important role in 

identifying and treating children and adolescents with 

certain behavioral health conditions. 

✔ FAST FACTS

Half of all lifetime cases of mental illness begin 

by age 14 and three-quarters by age 24.
Federal Commission on School Safety: Prevent 29

Comprehensive school-based mental health systems 

(CSMHS) are school-community partnerships that provide a continuum of mental health services (such as 

prevention, early identification, and treatment) that 

support students, families, and the school community. They seek to improve the school climate and can 

decrease social isolation and marginalization, including bullying.25,26 Key aspects include evidence-based 

universal prevention; training for school and community members to identify and respond to early warning signs of mental health difficulties; and targeted 

prevention and treatment intervention programs and 

services supporting the mental health of students. 

Mental health care delivery is integrated within school 

settings. 

Several states are implementing CSMHS, including 

Pennsylvania, Maryland, Wisconsin, New Hampshire, 

Tennessee, and Alaska. The cost of implementing a 

comprehensive system varies depending on factors 

such as student needs, evidence-based practices used, 

and reimbursement for certain services by public and 

private insurance. Multiple streams of funding, including public and private insurance, are used to finance 

CSMHS. Currently, federal grants provide support for 

20 states to develop CSMHS at up to $1.8 million per 

year, per state.27

The following approaches have been effective in 

addressing the mental health needs of youth. 

Prevention of mental, emotional, and behavioral 

difficulties in youth

There is a body of research showing that there are 

efficacious and effective developmentally focused 

prevention intervention from prenatal through adolescence that decrease risk for mental, emotional, and 

behavioral difficulties, and there are examples of them 

being implemented at scale in communities.28

Violence prevention

Reducing Youth Violence: Addressing youth violence requires a comprehensive approach. The Safe 

Schools/Healthy Students (SS/HS) Framework was 

developed by the Substance Abuse and Mental Health 

Services Administration (SAMHSA) in response to the 

Columbine School shooting. It provides schools and 

communities with a template for implementing best 

practices to prevent youth violence.29,30 These practices include:

1. collaboration and partnership with juvenile justice, 

law enforcement, and other related agencies; 

2. enhanced technology to identify patterns and 

trends; 

3. policy change and development, including diversion intervention plans to keep students out of 

juvenile justice systems; 

4. capacity building; and 

5. systemic change and integration. 

More than 350 school districts have implemented the 

SS/HS Framework. Over 30,000 mental health professionals, teachers, and administrators have been 

trained in prevention and other mental health–related 

practices and activities as well as in the provision of 

specific parent and caregiver training and support. 

State SS/HS successes include a 50 percent reduction 

in suspensions and expulsions in Connecticut, a 51 

percent reduction in risks associated with depression 

in Pennsylvania, and a 37 percent decrease in the 

number of students who reported staying home from 

school due to feeling unsafe in Nevada.31

SS/HS programs can also use enhanced technology to 

develop a comprehensive data-collection system to 

track student behavior, providing an interactive online 

map to depict disciplinary data and identify patterns 

and trends. The integrated database identifies the 

time of day and location of disciplinary incidents 

so that staff can respond to “hot spots” and use the 

data to make decisions about how to best allocate 

resources. The estimated cost is approximately $1–3 

million to implement at the school district level. 

Another valuable resource available to the public is 

the CDC’s A Comprehensive Technical Package for 

the Prevention of Youth Violence and Associated Risk 

Behaviors. This represents a select group of strategies 

based on the best available evidence to help commuTable 3-1

Safe Schools/Healthy Students Results

State Result

CT 50% reduction in suspensions and expulsions

PA 51% reduction in risks associated with depression

NV

37% decrease in the number of students who 

reported staying home from school due to 

feeling unsafe
30 Federal Commission on School Safety: Prevent

nities and states sharpen their focus on prevention 

activities with the greatest potential to prevent youth 

violence and its consequences.32

Access to treatment for mental illness

Starting Early in Life: Training adults to appropriately 

identify and respond to concerning behavioral health 

problems allows children to stay in supportive environments and optimizes their potential for successful 

development.33 The training and education of parents 

and families is equally important and a critical part of 

these efforts.34

Work is underway across 32 states, tribes, and territories to implement Project Launch, an evidence-based 

SAMHSA program, by training staff in childcare, Head 

Start, home visiting, and other settings.35 These efforts 

help improve children’s social skills and emotional 

functioning, promote healthy relationships, reduce 

challenging behaviors, reduce the number of suspensions and expulsions, improve classroom quality, 

and reduce provider and teacher stress, burnout, and 

turnover.36,37

In addition, the Health Resources and Services Administration (HRSA), Maternal and Child Health Bureau, 

in collaboration with the Administration for Children 

and Families, administers the Maternal, Infant, and 

Early Childhood Home Visiting (MIECHV) Program. The 

MIECHV Program gives pregnant women and families, particularly those considered at-risk, necessary 

resources and skills to raise children who are physically, socially, and emotionally healthy and ready to 

succeed. Awardees select from a list of evidence-based 

service delivery models.

Helping Children and Families with the Highest 

Needs: Children with high needs may have serious 

mental health diagnoses, such as major depressive 

disorder, bipolar disorder, and Attention Deficit Hyperactivity Disorder (ADHD). Mental illness significantly 

affects their ability to function at home, in school, or 

in the community. Affected children and their families 

may have complex medical, behavioral health, and 

social needs that require a more in-depth and broader 

array of assistance. 

The Commission meeting “Curating a Healthier and 

Safer Approach: Issues of Mental Health and Counseling of Our Young” comprised experts who testified to 

the importance of including access to mental health 

service provision in schools and/or providing robust 

systems of referrals and linkages to such services. One 

witness testified that “by providing these services in 

schools, we have an opportunity to decrease stigma 

associated with seeking mental healthcare, and we can 

also decrease many of the barriers to getting students 

help when they need it.”38 

Ensuring High Quality of Integrated Care: The quality 

of community mental healthcare across the nation 

varies greatly. Very few communities provide comprehensive, coordinated, evidence-based care for children 

and adults with SMI and SED. The Certified Community 

Behavioral Health Clinic demonstration and expansion program provides comprehensive, high-quality, 

integrated care in a “one stop shop” model. It includes 

access to crisis care, evidence-based treatment for 

mental and substance use disorders, recovery support 

services, and linkages with primary healthcare. 

Addressing Childhood Trauma: In many instances, 

children with a mental illness have experienced 

trauma and need treatment. SAMHSA supports the 

National Child Traumatic Stress Initiative and the 

National Children Traumatic Stress Network (NCTSN), 

which improves access to treatment and services for 

children and adolescents who have experienced or 

witnessed traumatic events and has identified more 

than 30 evidence-based interventions to support such 

children and their families. 

These interventions include screening and assessment 

practices as well as training curricula implemented 

in approximately one-third of schools of social work. 

They also include resources targeted to parents, 

families, and caregivers who play an essential role in 

understanding and supporting children and teenagers 
Federal Commission on School Safety: Prevent 31

who have experienced traumatic events.39 NCTSN has 

engaged more than 10,000 local and state partnerships 

integrating trauma-informed services into a range of 

child-serving systems. 

NCTSN supports efforts in 44 states and D.C. Outcomes 

from this work show that the percentage of children 

who reported positive functioning in everyday life (e.g., 

dealing effectively with daily problems, crises, social 

situations, school/work) increased by 61 percent from 

baseline to the most recent assessment.40

Caring for Transition-Age Youth: Evidence-based 

interventions, such as the Transition to Independence 

Process (TIP), can help improve treatment engagement and functioning for youth and young adults 

aged 16–25 with or at-risk for SED/SMI. Specifically, 

TIP involves youth and young adults in a process 

that facilitates greater self-sufficiency and successful 

attainment of adult roles and responsibilities. It does 

so by engaging them and, as appropriate, their families 

in their own future planning process while providing 

developmentally appropriate and appealing services 

and supports. 

TIP has been shown to improve the lives of young people in the areas of employment and career, education, 

living situation, personal effectiveness and well-being, 

and community-life functioning. Currently, 15 states 

and D.C. are implementing this approach. Findings 

from these efforts indicate significant decreases in 

psychological distress, improvements in physical 

health, decreases in homelessness, and increases in 

employment.41

Treating First Episode Psychosis: Each year approximately 100,000 individuals, primarily youth, experience a First Episode of Psychosis (FEP). Coordinated 

Specialty Care (CSC) is a demonstrated effective 

model for them.42 Research shows that individuals 

with early psychosis who receive CSC achieved significant improvements in education and employment as 

well as a decrease in hospitalization rate.43

CSC is a coordinated care approach that provides 

treatment, family education and engagement, and 

recovery support services delivered by an integrated, 

multidisciplinary care team. A set-aside in the SAMHSA 

Mental Health Block Grant supports states to implement this practice nationwide. For example, Kentucky 

has developed a data infrastructure to track outcomes 

and improve the eight CSC programs its set-aside 

funding supports. Approximately 250 CSC programs 

are currently in place across the country to reduce the 

duration of untreated psychosis, improve outcomes, 

and promote recovery.44

Identifying and Supporting At-Risk Youth: A growing 

evidence base supports approaches to identifying 

youth at risk for psychosis and providing early interventions that could have an impact on the trajectory 

of this serious condition.45 On average, there is a 

more than 50 percent reduction in risk of an individual actually having a first episode of psychosis after 

demonstrating early phases of a psychotic disorder for 

those receiving psychosocial treatment services, such 

as cognitive behavioral therapy.46,47

Research also demonstrates the association of early 

intervention services with engagement in treatment, 

improved involvement in school, and improvement in 

symptom severity.48 SAMHSA is working with communities to better understand and address the needs 

of youth and young adults in the earliest stages of 

psychosis. 

Building Mental Health Literacy: Raising awareness 

and literacy around mental health issues is a critical 

component of improving school-based mental health. 

Mental Health First Aid and Youth Mental Health First 

Aid are examples of mental health literacy curricula 

designed to provide a basic understanding of common 

mental health issues and how to refer people in mental health crises appropriately. 

These trainings are widely available to school personnel, parents and families, first responders, law 

enforcement, and others, with more than one million 

people across the nation already trained. Research 

has indicated that gains in mental health knowledge 

over the course of the training were associated with 

increased help-seeking intentions, suggesting that 

mental health literacy may facilitate treatment utilization. Instructor training costs between $1,500 and 

$2,000, while individual course training varies, with an 

average cost of $119. 

During the Commission’s visit to Adams Friendship 

Middle School in Wisconsin, it was noted that the Mental Health First Aid model was an essential element 

to changing school climate and ultimately increasing access to care. Crisis Intervention Team training 

provides specific training to law enforcement and 

other first responders in safely responding to people 
32 Federal Commission on School Safety: Prevent

with mental illness or addiction who are in crisis. Most 

states have implemented such mental health literacy 

efforts.49,50

Financing School-Based Mental Health: States have 

been using a variety of strategies for school-based 

mental healthcare, including the use of Medicaid and 

other resources. According to the 2015 CMS (Centers 

for Medicare and Medicaid Services) Medicaid Financial Management Report, the total computable expenditure for “school-based services” was more than $3.1 

billion. The state share was about $1.4 billion. 2016 

Financial Management Data indicates expenditure of 

$3.3 billion. 

The 2015 report indicates that 44 states offer reimbursement.51 Examples include Louisiana, which 

authorized the use of school nurses to deliver Medicaid-funded mental health services to students with 

Individualized Education Plans, and Arkansas, which 

developed administrative procedures to finance 

school-based mental health programs. During the 

Commission’s Wisconsin site visit, the Adams Friendship School District shared its innovative approach 

to braiding federal funding streams. This approach 

enabled the development and implementation of 

a school-climate culture change to foster access to 

treatment and provision of services. 

Workforce

Behavioral Health Workforce Shortages: A consistent 

theme throughout the Commission’s listening sessions, site visits, and meetings was the lack of mental 

health professionals in schools or in centers that 

students and schools can easily access. Clinical, peer, 

and family support is critical to help youth and their 

families with SED engage in and navigate complex 

systems of care. 

High turnover rates, an aging workforce, and low compensation all contribute to workforce shortages across 

the mental health arena. Unfortunately, this shortage 

is all too apparent in the school system. Clinical, peer, 

and family support providers may enhance the workforce efforts by developing trust and effective relationships through similar lived experiences.52,53 They 

help to address critical caregiver supports and have 

been shown to improve quality of life, engagement, 

and satisfaction with services and supports. They also 

help improve overall health and reduce overall cost of 

services.54

Training the Workforce: It is important to support 

clinicians and others in providing high-quality care to 

ensure broad use and appropriate implementation of 

best practices. Several new efforts have recently been 

initiated to accomplish this, including:

1. the Clinical Support System for Serious Mental 

Illness, to support the implementation of evidence-based practices in the treatment and recovery of individuals with SMI;

2. 12 Mental Health Technology Transfer Centers, 

which provide regionally focused assistance to 

clinicians and others;

3. a 90-minute Specialized Educational Tool on 

Assessing and Addressing Risk of Youth Violence, 

developed in partnership with the U.S. Department 

of Education and made available at no cost to 

teachers, first responders, parents, and students; 

and 

4. mental health literacy training, such as Mental 

Health First Aid and Crisis Intervention Training. 

In addition, HRSA supports several training programs 

that include the training of future child and adolescent behavioral health professionals. Within HRSA’s 

Maternal and Child Health Bureau, the Developmental 

Behavioral Pediatrics Program supports the advanced 

postdoctoral fellowship training of pediatricians to 

enhance the behavioral, psychosocial, and developmental components of pediatric care. 

Establishing Counseling, Psychological, and Social 

Services (CPSS) Coordinators: Coordination can have 

a positive impact on the quality and delivery of mental 

health and other related services.55 CPSS Coordinators can bring together various providers within and 

outside of schools to meet students’ needs.56 This 

can also result in a clear mission, goals, and objectives that promote the integration of procedures and 

programs.57 Integration of services within the larger 

school environment helps secure resources, such as 

confidential space for providing services, and helps 

minimize lost class time for students seeking services. 

A recent survey of school districts revealed that 79.5 

percent of them had staff to oversee CPSS.58

Using Technology to Address Workforce Issues: 

Technology can play a significant role in enhancing 

the workforce. “Telemental health” is the use of video-conferencing to conduct real-time mental health 
Federal Commission on School Safety: Prevent 33

treatment between a clinician and patient. This can 

provide needed treatment to people who otherwise 

may not have access to mental healthcare, including 

those in underserved or rural areas. 

The use of telemental health services in both rural 

and urban environments, including schools, has been 

effective and cost efficient, and has met with high 

ratings of satisfaction by students. The cost of implementing telemental health services can vary. The purchase of equipment can be between $500 and $10,000, 

with each encounter costing approximately $78.

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. SAMHSA and CMS should provide information to states on available financing options for comprehensive school-based mental health care services, enabling states to develop innovative solutions 

within current requirements. 

2. All appropriate federal agencies should increase awareness of mental health issues among students 

and ways to seek needed care. Often, stigma is associated with the lack of seeking help for a mental 

health condition. As discussed during the July 11 Commission meeting, stigma is often the reason 

that individuals needing help choose not to seek treatment. 

3. The U.S. Department of Health and Human Services (HHS) Health Resources and Services Administration should continue to support the mental health workforce response to children’s needs 

through existing programs such as the National Health Services Corps Loan Repayment Program. 

¤ STATES & LOCAL COMMUNITIES 

1. All appropriate state and local agencies should continue to increase awareness of mental health 

issues among students and ways to seek needed care. Often, stigma is associated with the lack of 

seeking help for a mental health condition. As discussed during the July 11 Commission meeting, 

stigma is often the reason that individuals needing help choose not to seek treatment. 

2. Schools and local behavioral health agencies should increase training of adults who interact with 

children (e.g., caregivers, preschool staff) to recognize signs and symptoms of mental illness. This is 

an imperative step in enhancing school-based mental health services. The Early Childhood Mental 

Health Consultation model trains such adults to identify early signs of mental health conditions and 

to respond appropriately.59

Additionally, training can be enhanced through the development of a network of national and 

regional technical assistance centers for children, adolescent and youth school-based mental disorder prevention and treatment. The network should assist states and localities in adopting mental 

health promotion activities, including suicide prevention and clinical treatment provision. It would 

work in collaboration with the SAMHSA-established national network of Technology Transfer Centers in Prevention, Addiction, and Serious Mental Illness. 

Trainings to increase mental health literacy to recognize signs and symptoms of mental illness, such 

as Mental Health First Aid, also provide key resources for individuals working with children. Distribution of tools and resources, including the SAMHSA-developed PowerPoint “Assessing and Addressing Risk of Violence in Youth,” to all school districts and college campuses, could also be considered. 
34 Federal Commission on School Safety: Prevent

3. State and local school districts in collaboration with social service, faith based, primary care and law 

enforcement agencies should develop and implement comprehensive and coordinated approaches 

that are inclusive of all systems involved in service provision. This is a critical factor in addressing 

school-based mental health in the most efficient way possible. The systems of care (SOC) framework is an approach that explicitly includes all systems that are involved with providing services to 

children and is a proven best practice in providing comprehensive, community-based mental health 

prevention, treatment, and support services to youth with SED or SMI and their parents and families. 

Examples of the types of systems in an SOC approach are social services, education, and juvenile 

justice. Youth and transition-aged youth receiving services in SOC programs may include those 

experiencing an FEP, those with SED, or those with SMI. Recipients of SOC services have demonstrated significant improvements in behavioral and emotional functioning; significant reductions in 

thoughts of suicide and suicide attempts; significant reductions in unlawful activities; and significant cost reductions due to decreases in hospitalizations and arrests.60 

4. State and local behavioral health agencies should increase the availability of high-quality community-based services such as Certified Community Behavioral Health Clinics and crisis/acute care services (e.g., mobile teams, inpatient care), as needed. These services could include evidence-based 

practices, trauma-informed services, multidisciplinary team-based approaches, recovery supports, 

and medication-assisted treatment, where indicated. 

5. State and local school districts should engage and activate natural supports in communities. It 

is not enough simply to engage law enforcement, healthcare, and schools. Other supports, such 

as the faith community, can help identify and support youth with SED and refer them to needed 

treatment. Although the school system plays an integral role in ensuring the sound mental health of 

its students, a holistic community approach is needed. Community partnerships contribute to the 

success of the expansion of school-based mental health. 

6. State and local school districts should increase the use of technology, including telemental health 

infrastructure, to increase access to services for individuals in underserved or rural areas. Telehealth 

service provision and care extension strategies include collaborative models of medical education 

and support to manage patients with complex conditions such as the Extension for Community 

Healthcare Outcomes (ECHO) type model. These models have been very effective in serving hard-toreach populations and areas. Telehealth provides a means to treatment access for those who might 

otherwise not be able to access it. 
Federal Commission on School Safety: Prevent 35

Chapter 3 Endnotes

1 Appelbaum, P.S. (2006). Violence and mental disorders: data and public 

policy. American Journal of Psychiatry, 163(8):1319–1321. https://www.

ncbi.nlm.nih.gov/pubmed/16877640. 

2 Centers for Disease Control and Prevention. (February 19, 201). Leading 

causes of death reports. National and regional 1999–2010. Available at 

http://webappa.cdc.gov/sasweb/ncipc/leadcaus10_us.html. Accessed 

July 23, 2014.

3 Vossekuil, B., Fein, R., Reddy, M., Borum, R., & Modzeleski, W. (2002). 

The final report and findings of the safe school initiative: Implications for 

the prevention of school attacks in the United States. Washington, DC: 

U.S. Department of Education, Office of Elementary and Secondary 

Education, Safe and Drug-Free Schools Program and U.S. Secret Service, 

National Threat Assessment Center.

4 Knoll, J.L., & Annas, G.D. (2016).

5 Center for Behavioral Health Statistics and Quality. (2015). 

6 American Foundation for Suicide Prevention. (2018).

7 Bitsko, R.H, Holbrool J.R., Ghandour R.M., Blumberg, S.J., Visser, S.N., 

Periu, R., & Walkup J.T. (2018). Epidemiology and impact of health care 

provider-diagnosed anxiety and depression among US children. Journal 

of Developmental and Behavioral Pediatrics. 0: 1–9.

8 Mojtabai, R., Olfson, M., & Han, B. (2016). National trends in the prevalence and treatment of depression in adolescents and young adults. 

Pediatrics, DOI: 10.1542/peds.2016-1878.

9 Williams, N.J., Scott, L., & Aarons, G.A. (January 2018). Prevalence of 

serious emotional disturbance among U.S. children: A meta-analysis. 

Psychiatric Services, 69(1):32-40. DOI: 10.1176/appi.ps.201700145. 

Epubh 2017. 

10 David-Ferdon, C., Vivolo-Kantor, A.M., Dahlberg, L.L., Marshall, K.J., 

Rainford, N., & Hall, J.E. (2016). A comprehensive technical package for 

the prevention of youth violence and associated risk behaviors. Atlanta, 

GA: National Center for Injury Prevention and Control, Centers for 

Disease Control and Prevention. Georgetown University, Center for 

Child and Human Development. Retrieved from https://gucchdtacenter.

georgetown.edu/publications/ECMHCStudy_Report.pdf. 

11 Centers for Disease Control and Prevention. Improving access to children’s mental health care. https://www.cdc.gov/childrensmentalhealth/

access.html. 

12 Cowell, J.M. (2013). Mental health services in schools: Issues from implementation. Journal of School Nursing, 29(6). 406. 

13 QuickStats. (2017). Suicide rates for teens aged 15–19 years, by sex—

United States, 1975–2015. Morbidity and Mortality Weekly Report, 66:816. 

DOI: http://dx.doi.org/10.15585/mmwr.mm6630a6.

14 World Health Organization. (August 2012). Risks to mental health: An 

overview of vulnerabilities and risk factors. http://www.who.int/mental_health/mhgap/risks_to_mental_health_EN_27_08_12.pdf.

15 Bannink, R., Broeren, S., van de Looij-Jansen, P.M., de Waart, F.G., & 

Raat, H. (2014). Cyber and traditional bullying victimization as a risk 

factor for mental health problems and suicidal ideation in adolescents. 

PLoS One. 9(4): e94026.Published online April 9, 2014. DOI: 10.1371/

journal.pone.0094026.

16 HHS Stop Bullying Now campaign. https://www.stopbullying.gov/. 

17 https://www.cdc.gov/healthyyouth/protective/pdf/connectedness.pdf.

18 Interdepartmental Serious Mental Illness Coordinating Committee. 

(December 13, 2017). The way forward: Federal action for a system that 

works for all people living with SMI and SED and their families and caregivers. 

19 Kessler, R.C., et al. (2005). Prevalence, Severity, and Comorbidity of 

12-Month DSM-IV Disorders in the National Comorbitity Survey Replication. Archives of General Psychiatry, 62(6), 593–602. http://archpsyc.

jamanetwork.com/article.aspx?articleid=208671.

20 National Research Council and Institute of Medicine. (2009).

21 Kataoka, S.H., Zhang, L., & Wells, K.B. (2002). Unmet need for mental 

health care among U.S. children: Variation by ethnicity and insurance 

status. American Journal of Psychiatry, 159, 1548–1555. 

22 Iachini, A.L., Brown, E.L., Ball, A.B., Gibson, J.E, & Lize, S.E. (2015). 

School mental health early interventions and academic outcomes for 

at-risk high school students: A meta-analysis. Advances in School Mental 

Health Promotion, Vol. 8, Issue 3, 156–175. https://doi.org/10.1080/1754

730X.2015.1044252. 

23 Hoover S., & Lever, N. (September 7, 2017). State of school mental 

health, briefing document. SAMHSA/HHS Expert Panel on School Mental 

Health. http://csmh.umaryland.edu/media/SOM/Microsites/CSMH/

docs/Reports/State-of-School-Mental-Health-Initial-Briefing-Document-

--September-2017-9.5.17.pdf.

24 http://www.sbh4all.org/school-health-care/our-stories/.

25 Center for School Mental Health. (2015).

26 Comprehensive school mental health services: Why and what? https://

healthysafechildren.org/sites/default/files/Comprehensive_SMH_Webinar_PowerPoint.pdf. 

27 NITT TA Center—Distance learning—Using an interconnected systems 

framework in NITT, Project AWARE—Part 1: The “what and why” of ISF. 

https://www.youtube.com/watch?v=cgWlm7p4zC0&feature=youtu.be.

28 National Research Council and Institute of Medicine. (2009). Preventing Mental, Emotional, and Behavioral Disorders Among Young People: 

Progress and Possibilities. Committee on the Prevention of Mental Disorders and Substance Abuse Among Children, Youth, and Young Adults: 

Research Advances and Promising Interventions. Mary Ellen O’Connell, 

Thomas Boat, and Kenneth E. Warner, Editors. Board on Children, Youth, 

and Families, Division of Behavioral and Social Sciences and Education. 

Washington, DC: The National Academies Press.

29 https://healthysafechildren.org/sshs-framework.

30 https://knowledge.samhsa.gov/ta-centers/promoteprevent.

31 https://healthysafechildren.org/sites/default/files/SS-HS_infographic.

PDF.

32 David-Ferdon, C., Vivolo-Kantor, A.M., Dahlberg, L.L., Marshall, K.J., 

Rainford, N., & Hall, J. E. (2016). A comprehensive technical package for 

the prevention of youth violence and associated risk behaviors. Atlanta, 

GA: National Center for Injury Prevention and Control, Centers for Disease Control and Prevention. https://www.cdc.gov/violenceprevention/

pdf/yv-technicalpackage.pdf. 

33 Duran, F., Hepburn, K., Irvine, M., Kaufman, R., Anthony, B., Horen, N., & 

Perry, D. (2009). What works? A study of effective early childhood mental 

health consultation programs. 

34 https://healthysafechildren.org/topics/family-strengthening-and-parent-skills-training.

35 https://healthysafechildren.org/grantee/project-launch.

36 https://www.samhsa.gov/iecmhc.

37 Gilliam, W.S., & Shahar, G. (2006). Preschool and child care expulsion 

and suspension: Rates and predictors in one state. Infants & Young 

Children, 19, 228–245.

38 Sheryl Kataoka, MD, MSHS, statement to the Federal Commission 

on School Safety (July 11, 2018). https://www2.ed.gov/documents/

press-releases/20180711-sheryl-kataoka-testimony.pdf.

39 https://www.nctsn.org/audiences/families-and-caregivers.

40 Analysis of data from SAMHSA’s Performance Accountability and Reporting System (SPARS).

41 U.S. Department of Health and Human Services, Substance Abuse and 

Mental Health Services Administration. (2017). The healthy transitions 

national evaluation preliminary findings report, 2017. Rockville, MD.

42 National Institutes of Mental Health. (August 2015). Fact sheet: First 

episode psychosis. Retrieved from https://www.nimh.nih.gov/health/

topics/schizophrenia/raise/fact-sheet-first-episode-psychosis.shtml.

43 Nossel, I., et al. (2018). Results of a coordinated specialty care program 

for early psychosis and predictors of outcomes. Psychiatric Services. 

https://doi.org/10.1176/appi.ps.201700436.

44 https://www.nimh.nih.gov/health/topics/schizophrenia/raise/

what-is-coordinated-specialty-care-csc.shtml. 
36 Federal Commission on School Safety: Prevent

45 Schultze-Lutter, F., Michel, C., Ruhrmann, S., & Schimmelmann, B. 

(2017). Prevalence and clinical relevance of interview-assessed psychosis-risk symptoms in the young adult community. Psychological 

Medicine, 1–15. 

46 Hutton, P., & Taylor, P. (2014). Cognitive behavioral therapy for psychosis 

prevention: A systematic review and meta-analysis. Psychological Medicine, 44(3), 449-468.

47 van der Gaag, M., Smit, F., Bechdolf, A., French, P., Linszen, D.H., Yung, 

A.R., McGorry, P., & Cuijpers P. (2013). Preventing a first episode of psychosis: Meta-analysis of randomized controlled prevention trials of 12 

month and longer-term follow-ups. Schizophrenia Research, 149 (1–3), 

56–62.

48 Correll, C.U., et al. (2018). Comparison of early intervention services 

vs treatment as usual for early-phase psychosis: A systematic review, 

meta-analysis, and meta-regression. JAMA Psychiatry, DOI: 10.1001/

jamapsychiatry.2018.0623. Published online May 2, 2018.

49 Cournoyer, C. Governments discover need for mental health first aid. 

http://www.governing.com/topics/health-human-services/gov-governments-discover-mental-health-first-aid.html.

50 U.S. Department of Health and Human Services, Substance Abuse and 

Mental Health Services Administration. (2017). Funding and characteristics of single state agencies for Substance Abuse Services and State 

Mental Health Agencies, 2015. Rockville, MD. https://store.samhsa.gov/

shin/content/SMA17-5029/SMA17-5029.pdf.

51 https://www.medicaid.gov/medicaid/finance/state-expenditure-reporting/expenditure-reports/index.html. https://data.medicaid.gov/

Uncategorized/FY-2016-Financial-Management-Data-National-Totals/27my-s6bh.

52 Mead, S. (2003). Defining peer support. Retrieved from http://parecovery.org/documents/DefiningPeerSupport_Mead.pdf. 

53 Solomon, P. (2004). Peer support/peer provided services underlying 

processes, benefits, and critical ingredients. Psychiatric Rehabilitation 

Journal, 27, 392–401. http://dx.doi.org/10.2975/27.2004.392.401. 

54 Obrochta, C., Anthony, B., Armstrong, M., Kalil, J., Hust, J., & Kernan, 

J. (2011). Issue brief: Family-to-family peer support: Models and evaluation. Atlanta, GA: ICF Macro, Outcomes Roundtable for Children and 

Families. Retrieved from https://www.ffcmh.org/sites/default/files/Issue 

Brief - Family to Family Peer Support Outcomes Roundtable 2011.pdf.

55 Brener, N.B., & Demissie, Z. (2018). Counseling, psychological, and social 

services staffing: Policies in U.S. school districts. American Journal of 

Preventive Medicine, 54(6S3):S21.–S219. 

56 AAP Committee on School Health. (2004). School-based mental 

health services. Pediatrics, 113(6):1839–1845. https://doi.org/10.1542/

peds.113.6.1839. 

57 Freeman E.V. (2011). School mental health sustainability: Funding strategies to build sustainable school mental health programs. Washington DC: 

Technical Assistance Partnership for Child and Family Mental Health. 

58 Brener et al. (2018).

59 https://www.samhsa.gov/iecmhc.

60 U.S. Department of Health and Human Services, Substance Abuse and 

Mental Health Services Administration. (2016). The comprehensive 

community mental health services for children with serious emotional 

disturbances program: Report to Congress. Retrieved from https://store.

samhsa.gov/shin/content//PEP18-CMHI2016/PEP18-CMHI2016.pdf.
Federal Commission on School Safety: Prevent 37

CHAPTER 4

Integrating Mental Health, Primary Care, 

Family Services, and Court-Ordered Treatment

Students often come to school with multiple complex health, mental health, and social service needs. 

Schools can play an important role in curating healthy 

environments that seek to prevent and mitigate the 

onset of health and mental health conditions. Developing and promoting models in which mental health 

and substance use screening, treatment, and support 

services are integrated into school and pediatric 

settings can help to ensure that children, youth, and 

adolescents with needs (along with their families) are 

identified earlier and gain access to treatment and 

other support services. 

Research has shown that less than half of children and 

adolescents with a mental disorder receive the treatment they need. Of those who received treatment, 

24 percent were in school-based settings, 23 percent 

in specialty mental health settings (such as community-based mental health centers), and 10 percent in 

primary care.1 Ensuring there are services and systems 

available and accessible that support positive social 

and emotional development early in a child’s life is 

more effective than working to address problems later 

in life.2 Therefore, it is important to provide an array of 

services that are evidence-based and address a child’s 

overall health, including mental health.3

Given the amount of time children spend there, 

schools are a natural environment in which to provide 

these services.4 Studies show that the way to integrate 

services and shift the overall school culture to support 

these services is to develop and implement a plan that 

works with other important school issues and supports the goals of education.5,6,7,8

 In general, the most 

successful integration programs also include buy-in 

from committed and dedicated leaders, and exhibit 

effective communication and collaboration among the 

integrated care team.9,10 There is solid evidence in support of the impact that school mental health programs 

can have on academics.11 Embedded school-based 

mental health services make the services accessible 

and acceptable to both students and families.12,13 A 

significant amount of research demonstrates that 

treatment is much more likely to be effective and completed when services are school based.14

Another approach in which mental and physical 

health services can be integrated is by providing 

mental and substance use healthcare services in a 

pediatric primary care setting. Twenty-five percent of 

children and adolescents seen in primary care settings 

and about half of all pediatric office visits involve 

behavioral, emotional, developmental, psychosocial, 

and/or educational concerns in children and adolescents. It is important to note that psychiatric disorders 

in children and adolescents are often evaluated and 

treated in the pediatrician’s office.15 Research has 

demonstrated that, in some communities, seeing 

a pediatrician for a mental health concern may be 

associated with significantly less stigma than seeing a 

mental health provider.16

There is an increasing trend toward addressing 

children’s and adolescents’ “whole health” (i.e., 

both physical and mental health needs) in primary 

care settings. Evidence suggests that mental health 

conditions are correlated with adverse physical health 

conditions, and approximately 75 percent of physical 

Figure 8-1

24% were in schoolbased settings

23% were in specialty 

mental health settings

10% were in 

primary care

Less than half of children and adolescents with a mental 

disorder receive the treatment they need. Of those who 

received treatment...

Figure 4-1
38 Federal Commission on School Safety: Prevent

health outcomes in conditions like asthma, obesity, and diabetes are correlated with mental health 

problems.17,18,19 When mental health outcomes are 

addressed, physical health outcomes also improve.20

Multiple efforts have been made to integrate pediatric 

primary care and behavioral health.21 The patient-centered medical home model (PCMH), which originated 

in pediatrics, has at its core the idea of attending to 

both the individual’s physical and mental health.22

The integration of mental health services into pediatric primary care settings has shown effectiveness in 

several approaches from consultation models (e.g., 

telephonic consultation with child and adolescent 

psychiatrists as described in sections of this report), 

co-location of mental health providers, and care coordination.23

Often included in the integration of primary care 

and mental health services is care coordination. This 

involves referring and linking to resources and sharing 

information among all participants involved with an 

individual’s care to achieve better health outcomes. 

Care coordination links youth and their families to 

services such as specialty healthcare, mental healthcare, and social services programs. As one study puts 

it, “Coordination of care across settings premits an 

integration of services that is centered on the comprehensive needs of the individual and their family, 

leading to decreased healthcare costs, reduction in 

fragmented care, and improvement in the individual/

family experience of care.”24

Care coordination is a key part of the SAMHSA (Substance Abuse and Mental Health Services Administration) Systems of Care model. This is a recommended 

approach for working with children and their parents/

caregivers as they navigate complex multisystem 

agencies and services. Involving the family in the care 

of their children and adolescents by including them 

in the services and supports provided in schools or in 

pediatric primary care settings is an essential part of 

providing integrated care. Parents and the family play 

a key role in supporting any interventions. Not only do 

parents make treatment decisions for their children, 

they are also critical in facilitating treatment. In addition, parents and caregivers of children with complex 

needs often need support and services themselves. 

Families should be engaged in the development and 

implementation of treatment services in a meaningful way. Equal partnerships with child, family, and 

system need to be developed to produce positive 

outcomes.25,26

Shared decision-making is an emerging best practice 

in mental and physical health. It is one way to assist 

people in treatment and recovery and help their families engage in informed, meaningful, and collaborative 

discussions with providers about their healthcare 

services. The American Academy of Pediatrics has also 

acknowledged the critical role of families in improving children’s health outcomes (and outcomes for the 

family as a whole) and improving the pediatrician’s 

ability to provide high-quality care.27,28

Prevention and early intervention programs to 

divert youth from the Justice System

Prevention services that address mental health 

conditions and divert youth from the juvenile justice 

system are an essential part of an effective continuum 

of services. Prevention strategies include: education 

for both the family and the youth on key issues such 

as substance use, social skill development, support 

for academic achievement, connection to family and 

other adults, and close and positive relationships with 

peers, as well as services and supports for the family, 

among other interventions. These approaches can 

lead to the lessening or prevention of future risk.29

Research has shown that there are a number of strategies and interventions that reduce youth violence 

victimization and perpetration and associated risk 

factors.30,31

In general, persons receiving mental disorder treatment would benefit from treatments that are provided 

in the least restrictive and most integrated setting possible. It is known that early interventions that support 

healthy social and emotional development do make a 

Involving the family in the care of their children 

and adolescents by including them in the services 

and supports provided in schools or in pediatric 

primary care settings is an essential part of providing integrated care.

Prevention services that address mental health 

conditions and divert youth from the juvenile 

justice system are an essential part of an effective 

continuum of services.
Federal Commission on School Safety: Prevent 39

difference in longer-term outcomes, particularly with 

regard to children at risk for involvement with juvenile 

justice. The prevention adage “you can pay now, or 

you can pay later” is an important foundation for all 

prevention and early intervention services. This is particularly so when considering interventions that would 

prevent children from entering into juvenile justice 

systems that often are very hard for them to get out of 

once they have a criminal record. 

Students with disabilities, including those with mental 

and substance use disorders, are more likely to be 

involved in disciplinary actions at school and are more 

often suspended or expelled.32 These actions can have 

a significant negative impact on a young person and 

may result in social disconnectedness as well as law 

enforcement and/or juvenile justice involvement. 

Once a youth becomes involved in the juvenile justice 

system, receiving needed treatment is challenging. 

The prevalence of mental disorders among justice-involved youth ranges from 50 to 75 percent, with about 

25 percent having significant impairment.33,34 Recidivism studies indicate that the rates of re-arrest for 

juvenile offenders who have returned from residential 

treatment and/or juvenile correctional settings range 

from 40 percent to 85 percent.35,36,37 These findings 

tend to suggest that when juvenile justice-involved 

youth are released to the community, there is a higher 

likelihood that they will reoffend and end up back in 

the juvenile justice system. 

Ensuring that at-risk youth receive timely and appropriate prevention and early intervention services is 

highly recommended as a best practice.38,39 States and 

localities have implemented programs to divert youth 

as early in the process as possible as a way to address 

their mental health needs and keep them out of the 

juvenile justice system. To increase participation in 

treatment, they have also provided less formal, community-based alternatives to the justice system.40,41

Court-ordered or emergency treatment

There are multiple avenues for children and adolescents to receive treatment through emergency mental 

health services and/or court orders. The following four 

areas summarize these possibilities. 

Emergency Mental Health Treatment: Pediatric 

primary care settings and pediatric emergency departments are now seeing increasing numbers of children 

and adolescents with mental health conditions. 

These visits account for 25–50 percent of primary care 

and 5 percent of pediatric emergency department

 visits.42,43,44,45,46,47 As children’s legal guardians, parents are generally able to make medical treatment 

decisions for their children, although specific details 

around mental health and substance use may vary by 

state. When safety is jeopardized as a result of a mental health condition, parents or guardians can usually 

facilitate and consent to treatment. In such situations, 

court involvement is generally not needed. 

Emergency Petitions to Access Treatment: For the 

most part, parents have the authority to consent for 

medical and psychiatric treatment for their minor 

children (even over youth objections) for most conditions up to the age of majority, which is usually 18.48,49

In some states, a youth may consent to treatment 

without parent knowledge; likewise, a youth may have 

the right to refuse mental health or substance use care 

even when the parent consents to it.50 At times, parents may have to petition the court for an emergency 

hold or temporary detention order to access diagnosis 

and treatment and to keep their child—and others—

safe. Generally, older adolescents enjoy greater legal 

rights to consent to their own treatment, and a cutoff 

age is often 14 or 16 years of age. 

In some instances, a provider or court may opine that 

a child’s well-being or safety is in conflict with the 

wishes of the parent. In circumstances of extreme 

safety risk in some states, a physician may detain a 

child or adolescent even if the parent objects. A parent 

still may need to consent to treatment given (such as 

medication), even if the child or adolescent is legally 

committed to a hospital over the objection of the 

parent. In some jurisdictions, this process would occur 

through a court-appointed emergency guardian for 

the child or adolescent. These details vary from state 

to state. 

While involuntary treatment is a tool that can be used, 

it may lead to a child’s or family’s distrust of a service 

system that initiated this kind of intervention. In these 

situations, parents may find themselves responsible 

for payment of treatment and transportation costs 

that they were not expecting.51 If a community has 

a comprehensive array of services, including care 

coordination and other more intensive services, the 

need for involuntary treatment can be reduced.52
40 Federal Commission on School Safety: Prevent

When possible, decision-making in behavioral healthcare should be made jointly by family, caregivers, and 

youth. Partnerships between child, family, and system 

facilitate positive outcomes.53

Child Welfare: The state may become involved in 

treatment decisions if the child or adolescent is in 

the custody of the state. Child abuse and neglect are 

defined by state laws, and child protective agencies 

can become involved in situations of abuse or neglect. 

“Medical neglect” is a term that can trigger the 

involvement of the child welfare system if the parent 

is not agreeing to needed treatment for the child or 

adolescent or is not following through with treatment 

determined necessary to treat a serious condition.54

A temporary or permanent court-appointed guardian 

may be required to consent to treatment on behalf of 

the child or adolescent. 

Child in Need of Services (CHINS): A child or youth’s 

behavior can be so challenging that parents cannot 

manage it. In these situations, the family can enter 

into a “child in need of services” or “child in need 

of supervision” arrangement. This is a legal process 

whereby courts can mandate treatment compliance 

and/or school attendance. The CHINS process varies 

by state. In Maryland, for example, it begins when 

someone makes a referral to the Department of Juvenile Services (DJS). The DJS officer may elect to file a 

petition that results in a hearing to determine if the 

child or youth should be placed under formal supervision by DJS. 

Additional measures can be considered for some 

transition-age youth and young adults who exhibit 

ongoing serious and significant mental health needs 

and who may be at risk of violence. According to one 

study, “Homicide is the third leading cause of death 

for young people between the ages of 10 and 24,55 and 

nationwide, 15.7 percent of students carried a weapon 

(e.g., gun, knife, or club) on at least one day in the past 

month.”56 Interventions can mitigate the risk of violent 

behavior.57

Commission Observations

Mental health conditions are a leading cause of 

health-related disability and often go unidentified and 

untreated. Screening that identifies emotional and 

behavioral problems is a first step in promoting early 

intervention and, if necessary, referral to treatment. 

Schools are a viable setting for screening, which could 

be incorporated just like visual and hearing screening. 

During the July 11 Commission meeting, one expert 

testified that providing services in schools could 

reduce stigma and increase access to needed care. 

Primary healthcare providers, parents, caregivers, and 

other community agencies could also identify signs of 

mental health and substance use issues. This position 

is endorsed by the American Academy of Pediatrics58

and (for depression in youth over age 11) by the 

United States Preventive Services Task Force.59

Unfortunately, the alleged Parkland shooter was not 

able to access mental health or counseling services 

within his school. (This is the case with many students 

with mental health conditions.)

In view of his apparent emotional problems, it was 

recommended that he attend an alternative school 

in which services would have been provided. But 

because he was 18, he had the right to refuse such 

services and stay in the mainstream school that did 

not provide services. 

Through its work, the Commission has identified the 

following integrated models and approaches that 

have been successful. 

Whole School, Whole Community, Whole Child: The 

WSCC model includes and expands on previously 

developed frameworks focusing on the “greater alignment, integration, and collaboration between education and health to improve each child’s cognitive, 

physical, social, and emotional development.”60

“Homicide is the third leading cause of 

death for young people between the ages 

of 10 and 24, and nationwide, 

15.7 percent of students carried a weapon 

(e.g., gun, knife, or club) on at least 

one day in the past month.”

Primary healthcare providers, parents, caregivers, 

and other community agencies could also 

identify signs of mental health and substance 

use issues.
Federal Commission on School Safety: Prevent 41

This model builds on the Centers for Disease Control 

and Prevention’s (CDC) coordinated school health 

approach, which has been the blueprint for integrating health-promoting practices in school settings, recognizing the relationship between educational attainment and health.61,62 The WSCC model prioritizes the 

child and the development of a school-wide approach, 

and supports learning, health, and the school as being 

a part of the local community.63 Colorado, Arkansas, 

Kentucky, and Maine have implemented aspects of 

this model at the state and local levels.64

Interconnected Systems Framework: Another program that integrates behavioral health services into 

schools is the Interconnected Systems Framework 

(ISF). This program uses a Multi-tiered System of Supports (MTSS) approach of academic and behavioral 

support in schools. The Positive Behavioral Intervention and Supports (PBIS) is an example of an MTSS. 

The MTSS approach involves three levels, or tiers: 

a) a universal tier that provides basic interventions 

for all students; 

b) selective tier for some students at risk; and 

c) tertiary intervention for those students in need 

of diagnosis and treatment for a mental health 

condition. 

This provides the appropriate level of care for each 

student.65,66

SAMHSA’s Project AWARE (Advancing Wellness and 

Resilience in Education) currently supports 20 states 

in developing quality comprehensive school mental 

health systems that seek to meet the needs of all 

students, especially those at high risk for violence 

perpetration and suicide.67 Findings from this program 

show improved ability to identify and refer children 

and youth with mental health problems to appropriate treatment.

School-Based Health Centers: SBHCs are one more 

model of providing behavioral health services. These 

centers include “primary medical care; mental/behavioral healthcare; dental/oral care; and health education and promotion.”68 SBHCs operate in a variety of 

ways and can be managed through healthcare providers employed by the school or in partnership with 

other healthcare agencies. Currently, there are more 

than 2,300 SBHCs in 49 states and Washington D.C. 

Some 94 percent of them are in or on school property, 

and 67 percent include behavioral health providers on 

staff.69

SBHCs increase access and improve health, mental 

health, and educational outcomes for youth and 

families.70,71 Funding for them comes from multiple 

sources, such as local, state, and federal government, 

private foundations, and public and commercial 

health insurers. Examples of federal programs that 

support school-based services include: the Health 

Resources and Services Administration (HRSA) SBHC 

Capital Program, Federally Qualified Health Center 

funding (Section 330 of the Public Health Service Act), 

and Title X of the Public Health Service Act.72 Services 

may also be reimbursed by Medicaid if the services are 

Medicaid coverable and delivered by qualified Medicaid practitioners to eligible and enrolled Medicaid 

children. 

Coordinated Specialty Care: CSC is an evidencebased, recovery-oriented, and team-based treatment 

program for transition-aged youth experiencing a 

first episode psychosis (FEP). The young person and a 

defined team of professionals work together to make 

treatment decisions. Family members and school or 

employment coaches are essential elements of the 

treatment intervention.73
42 Federal Commission on School Safety: Prevent

Integration of mental healthcare and pediatric 

primary care

The Chronic Care Model: The Chronic Care Model was 

developed to assist primary care settings to more 

effectively manage long-term conditions. It served as 

the foundation for the patient-centered medical home 

and is recommended by the American Academy of 

Pediatrics as a practice model for children with mental health problems.74 The Chronic Care Model was 

developed more than 20 years ago and includes care 

coordination staff as a key element.75 The National Initiative for Children’s Healthcare Quality describes this 

program in detail.76 The Chronic Care Model has been 

widely adopted in modern healthcare settings.77

The System of Care Approach: The System of Care 

approach begins with recognition that youth with 

complex conditions and their families must interact 

with multiple different systems. When these systems 

are not coordinated, the direction and support given 

to a family can be confusing, unclear, and overwhelming.78 The System of Care model builds a team 

around a family so that interventions and efforts are 

aligned and staged in a way that families can better 

manage implementation.79 It is effective in improving 

outcomes for children, including functioning, school 

attendance, reduced depression levels, improved 

chronic physical health conditions, and several other 

positive indicators.80

The Massachusetts Child Psychiatry Access 

Project: MCPAP is a statewide system in Massachusetts 

that uses regional consultation teams focused solely 

on children’s mental health. It supports a telephone 

consultation service wherein primary care physicians 

and providers can consult directly with specialty child 

mental health professionals on-demand. Services 

include care coordination and follow up, as well as 

psychopharmacology and psychotherapy consultations.81

MCPAP also trains primary care providers on how to 

respond to mental health needs and increases their 

competency to provide mental healthcare. Primary 

care providers are often able to address the needs of 

youth with mild to moderate mental health concerns, 

while the consultation teams triage and direct to mental health providers those children with more complicated, serious mental health conditions.82

Care4Kids: Care4Kids is a Wisconsin program that 

addresses individualized needs by providing a comprehensive care coordination healthcare model for 

children in out-of-home care (OHC). To ensure access 

to quality services in a timely manner, Care4Kids provides children with access to primary care physicians 

trained in the needs of children in OHC by establishing 

a healthcare coordination team that manages the care 

for the child. 

Facilitated by a healthcare coordinator, the team 

comprises a variety of key stakeholders, such as child 

welfare staff, healthcare professionals, foster parents, 

the child’s family, and other important partners as 

needed. These stakeholders work closely together to 

ensure that children in the program receive individualized and developmentally appropriate care in a timely 

way by medical staff trained in trauma-informed care 

practice. This approach to healthcare is designed to 

improve physical and mental health outcomes for children, as well as to promote improved resiliency and 

create stronger natural support systems for children.83

Programs to support diversion of children 

and youth into mental health treatment and 

services from juvenile justice systems 

Developing strong partnerships between the juvenile 

justice system and community organizations (such as 

mental health agencies, primary care settings, and 

schools) can help prevent or mitigate an individual’s 

involvement with the juvenile justice system. The goal 

of this partnership is to provide needed treatment 

services and supports to keep the individual functioning effectively in the community and to divert him or 

her from law enforcement or juvenile justice involvement where appropriate. 

Diversion programs can be very effective in improving behavioral health outcomes and reducing future 

delinquency.84,85 The Community Preventive Services 

Task Force’s systematic review of the transfer of juvenile offenders to adult criminal courts showed this 

strategy resulted in a 34 percent increase in rearrests 

for violent crimes. Clearly, alternative approaches are 

important.86

School-Based Diversion Models: Keeping students 

with mental disorders out of the juvenile justice system where appropriate and getting them the care they 

need is an integral component of addressing mental 
Federal Commission on School Safety: Prevent 43

health. School-based diversion models are designed 

to fill this critical function. 

Multi-Systemic Therapy: Multi-Systemic Therapy 

(MST) is an intensive family- and community-centered 

program for youth at risk of incarceration and/or outof-home placement due to problematic behavior. MST 

is an evidence-based treatment program that provides 

time-limited, flexible, individualized interventions that 

address specific issues and needs. 

Therapeutic Foster Care for Delinquent Juveniles: 

Therapeutic Foster Care service for young people 

who have had ongoing interactions with the juvenile justice system has been shown to have positive 

outcomes, including the reduction of violent crime. 

The service involves placing at-risk youth with foster 

families who have received several months of specialized training in how to provide the young person with 

intensive services in a structured environment. The 

U.S. Department of Health and Human Services (HHS) 

Community Prevention Services Task Force reviewed 

this approach and found it to reduce violent crime 

by 71.9 percent among participants when compared 

with youths in standard group residential treatment 

facilities and to have net benefits of $20,351 to $81,664 

per youth.87

Court-Ordered Treatments for Adults : Civil commitment processes can mandate treatment for transition-aged youth and young adults over the age of 18 

when the individual refuses treatment that would be 

helpful for the mental illness present. The process 

usually begins with a temporary hold or petition that 

seeks to allow time for a diagnostic assessment and 

determination of the best level of care. 

When there is insufficient time to make an accurate 

diagnosis and treatment recommendation, persons 

may be subject to unnecessary civil commitment to 

inpatient treatment or premature release without 

adequate time to secure appropriate and available 

outpatient treatment. State laws vary widely regarding the time holds allowed and the process involved. 

Assisted Outpatient Treatment (AOT) is a civil commitment law available in 46 states. It allows a court to 

mandate participation in outpatient treatment and 

services. Criteria for participation in AOT differ across 

states, but eligibility may include: posing a threat of 

substantial harm to oneself or others; having a history 

of relapsing serious mental illness and/or deterioration of mental status with demonstrated impairment; 

experiencing multiple hospitalizations or incarcerations related to a mental disorder; a documented history of non-adherence with prescribed treatment; and 

impaired judgment that is interfering with the ability 

to make informed decisions about treatment. 

Currently, there is wide variability within most states 

regarding the extent to which AOT laws are utilized. 

They are almost always used for outpatient stepdown after a psychiatric admission and not as a legal 

intervention that could prevent clinical deterioration. 

North Carolina is one example of a state with an AOT 

law that can mandate participation in outpatient 

treatment designed to stabilize the person and his or 

her situation so that hospitalization can be avoided. 

AOT has produced positive outcomes in adults. This 

is particularly so in the case of AOT ordered in the 

context of services that include psychiatric care with 

attention to medication adherence, counseling, community support services, and medical care. Positive 

outcomes include increased participation and engagement in treatment and other services, increased 

adherence to prescribed medication, improved community and social functioning, and reduced incidence 

of harmful behaviors to self or others.88 But current 

laws make it difficult to place individuals into AOT 

because the legal standard is high—imminent danger 

of violent behavior toward self or others.
44 Federal Commission on School Safety: Prevent

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. SAMHSA and CMS should provide guidance and technical assistance to states on how to utilize 

federal funding sources to support mental healthcare for children and youth. 

2. All appropriate federal agencies should support the implementation of evidence-based diversion 

models, including development and dissemination of clear, step-by-step guidance for schools on 

how to build an approach that best meets the mental health, developmental, and educational 

needs of children and youth in their systems. 

One such model is the School Responder Model, where the young person’s mental health and substance abuse needs are assessed and then linked to needed community services, including mental 

health treatment. An effective responder initiative should identify youth with behavioral health 

needs, reduce their disproportionate referral to the juvenile justice system, and increase their 

connection to appropriate services that have been shown to improve mental health outcomes and 

decrease interactions with the justice system. Key components of this model are 1) cross-systems 

collaboration teams; 2) family and youth engagement; 3) implementation of a behavioral health 

response (e.g., screening, assessment and services); and 4) creation of formal structures. 

3. The U.S. Department of Health and Human Services (HHS) should develop guidance for service providers, justice officials, first responders, and school systems, on model state involuntary treatment 

legislation such as AOT. Clinical programs with outreach to individuals are often a necessary companion to AOT laws. An example of this style of service is Assertive Community Treatment teams, 

which provide psychiatric and medical care, assure adherence to prescribed medications, and 

provide counseling and assistance with obtaining community supports. 

¤ STATES & LOCAL COMMUNITIES

1. State and local school districts and state and local behavioral health and health agencies should 

work together to promote screening and early intervention for mental/substance use disorders in all 

settings by increasing education and awareness of the importance of these services; by supporting 

the use of evidence-based screening tools and instruments; and by supporting increases in funding 

for behavioral health professionals in all settings.

2. State and local school districts and state and local behavioral health and health agencies should 

work together to support evidence-based care coordination models that ensure a thorough assessment and provide referral, follow up, communication, and ongoing collaboration among and 

between agencies and providers by working with all public and private payers to provide coverage 

for these services. 

3. State and local school districts should expand the implementation of tiered models that intentionally focus on school climate and incorporate social and emotional learning and prevention, as well 

as access to specialty treatment for the minority of children who require it. WSCC, MTSS, and PBIS 

are examples of these systematic models. 
Federal Commission on School Safety: Prevent 45

4. Law enforcement agencies in collaboration with state and local school districts and state and local 

behavioral health agencies should develop clear guidance for law enforcement, courts, juvenile 

justice systems, and jails around developing supportive partnerships with schools to implement 

effective diversion programs, identifying individuals who could benefit from participation in such 

programs, and implementing proper procedures for identifying mental and substance use disorders. This guidance can identify specific mechanisms and related practices for diversion at various 

stages (or intercepts) in the criminal and juvenile justice systems, including pre-arrest, pre-booking, 

arraignment, and juvenile court. 

5. State and local behavioral health agencies in collaboration with state and local school districts 

should expand Multi-Systemic Therapy and other evidence-based treatment modalities to most 

effectively treat youth at risk of incarceration. Multiple controlled trials of MST report significant 

reductions in rates of recidivism and conduct problems. 

6. State policymakers should examine AOT laws in states with attention to consideration of lowering 

the commitment threshold for AOT in youth with untreated and unstable mental illness. This is so 

that an appropriate level of care can be mandated (a) for youth with mental health conditions who 

would clearly benefit from treatment for a mental illness but have a pattern of not engaging with 

treatment; and (b) where that treatment would improve the overall condition and reduce the risk of 

harm to themselves or those around them. 

7. State policymakers should consider redefining specific terms currently used in most civil commitment state statutes. For the involuntary commitment of an individual due to suicidality, homicidality, 

or grave disability, the terms “gravely disabled” and/or “imminent danger” are currently used. States 

should consider whether statutory modifications to incorporate language such as “mental status 

reasonably foreseeable to be likely to be associated with suicidality, homicidality, or grave disability” would lead to better public policy outcomes. Such a standard, for example, may help secure 

the involuntary hospitalization and treatment of individuals before they act on thoughts of harm to 

themselves or others—or the occurrence of other behaviors resulting from impairment produced by 

untreated mental illness likely to lead to incarceration or other adverse events. 
46 Federal Commission on School Safety: Prevent

Chapter 4 Endnotes

1 Costello, E.J., He, J.P., Sampson, N.A., Kessler, R.C., & Merikangas, K.R. 

(2014). Services for adolescents with psychiatric disorders: 12-month 

data from the National Comorbidity Survey–Adolescent. Psychiatric 

Services, 65(3), 359–366.

2 https://www.cdc.gov/healthyschools/wscc/index.html.

3 Ibid.

4 Atkins, M.S., Hoagwood, K.E., Kutash, K., & Seidman, E. (March 2010). 

Toward the integration of education and mental health in schools. Adm 

Policy Ment Health, 37(1-2): 40–47. DOI: 10.1007/s10488-010-0299-7.

5 Atkins, M, Frazier, S., Birman, D., Adil, J., Jackson, M., Graczyk, P., et al. 

(2006). School-based mental health services for children living in high 

poverty urban communities. Administration and Policy in Mental Health 

and Mental Health Services Research, 33:146–159. 

6 Atkins, M.S., Hoagwood, K.E., Kutash, K., & Seidman, E. (March 2010). 

Toward the integration of education and mental health in schools. Adm 

Policy Ment Health, 37(1-2): 40–47. DOI: 10.1007/s10488-010-0299-7.

7 Kratochwill, T.R. (2007). Preparing psychologists for evidence-based 

practice: Lessons learned and challenges ahead. American Psychologist, 

2007;62:826–843.

8 Kratochwill, T.R., Clements, M.A., & Kalymon, K.M. Response to intervention: Conceptual and methodological issues in implementation. In Jimmerson, S.R, Burns, M.K., & VanDerHeyeden, A.M, editors. The handbook 

of response to intervention: The science and practice of assessment and 

intervention. New York: Springer, pp. 25–52.

9 SAMHSA Center for Integrated Health Solutions. (2018). 

10 Rasberry, C.N., Slade S., Lohrmann, D.K., & Valois, R.F. (2015). Lessons learned from the whole child and coordinated school health 

approaches. Journal of School Health, 85: 759-765.

11 Kase et al. (July 2017). Educational outcomes associated with school 

behavioral health interventions: A review of the literature. Journal of 

School Health.

12 Fazel et al. (October 2014). Mental health interventions in schools 1: 

Mental health interventions in schools in high-income countries. Lancet

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13 American Psychological Association. (2009). Schools expand mental 

health care, Vol. 40, No.1. http://www.apa.org/monitor/2009/01/

school-clinics.aspx. 

14 Kataoka, S., Jaycox, L.H., Wong, M., Nadeem, E., Langley, A., Tang L., & 

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S1-71-77.

15 American Academy of Child and Adolescent Psychiatry. (2012). Best principles for integrating behavioral health services in to the pediatric health 

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16 Gabel, S. (2010). The integration of mental health into pediatric practice: 

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17 Goodwin, R.D., Robinson, M., Mkeague, I.W., Susser, E.S., Zubrick, S.R., 

Stanley, F.J., & Mattes, E. (2013) Severity and persistence of asthma and 

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18 Russell-Mayhew, S., McVey, G., Bardick, A., & Ireland, A. (2012). Mental 

health, wellness, and child overweight/obesity. Journal of Obesity. 

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19 Ducat, L., Rubenstein, A., Philipson, L.H., & Anderson, B.J. (2015). A 

review of the mental health issues of diabetes conference. Diabetes 

Care, 38(2): 333–338. 

20 Suryavanshi, M.S., & Yang Y. Clinical and economic burden of mental disorders among children with chronic physical conditions, United States, 

2008–2013. Preventing Chronic Disease, 13:150535. DOI: http://dx.doi.

org/10.5888/pcd13.150535.

21 U.S. Department of Health and Human Services, National Institute 

of Mental Health. https://www.nimh.nih.gov/health/topics/integrated-care/index.shtml. Accessed June 13, 2018.

22 American Academy of Pediatrics. AAP agenda for children: Medical home. 

https://www.aap.org/en-us/about-the-aap/aap-facts/AAP-Agenda-forChildren-Strategic-Plan/Pages/AAP-Agenda-for-Children-Strategic-PlanMedical-Home.aspx. Accessed December 16, 2016.

23 Asarnow, J.R., Rozenman, M., Wiblin, J., & Zeltzer, L. (2015). Integrated 

medical-behavioral care compared with usual primary care for child 

and adolescent behavioral health: A meta-analysis. JAMA Pediatrics. 

169(10): 929–937. Also, for more detailed information on integration of 

behavioral health services in pediatric primary care, Johns Hopkins’ 

Center for Mental Health Services in Pediatric Primary Care has a number of resources: http://web.jhu.edu/pedmentalhealth/index.html. 

24 http://pediatrics.aappublications.org/content/133/5/e1451. 

25 Weist, M.D., Garbacz, S.A., Lane, K.L., & Kincaid, D. (2017). Aligning and 

integrating family engagement in Positive Behavioral Interventions and 

Supports (PBIS): Concepts and strategies for families and schools in key 

contexts. Center for Positive Behavioral Interventions and Supports 

(funded by the Office of Special Education Programs, U.S. Department 

of Education). Eugene, Oregon: University of Oregon Press.

26 https://www.pbis.org/family/family-partnership.

27 American Academy of Pediatrics, Institute for Family-Centered Care. 

(September 2003). Policy Statement: Family-centered care and the 

pediatrician’s role. Pediatrics, Vol. 112, No. 3. http://pediatrics.aappublications.org/content/pediatrics/112/3/691.full.pdf. 

28 American Academy of Pediatrics. Engaging patients and families: What 

is youth and family-centered care? https://www.aap.org/en-us/professional-resources/practice-transformation/managing-patients/Pages/

youth-family-centered-care.aspx. 

29 https://www.cdc.gov/violenceprevention/pdf/yv-technicalpackage.pdf. 

30 David-Ferdon, C., & Simon, T.R. (2014). Preventing youth violence: 

Opportunities for action. Atlanta, GA: Centers for Disease Control and 

Prevention. Retrieved from http://www.cdc.gov/violenceprevention/

youthviolence/opportunities-for-action.html. 

31 U.S. Department of Health and Human Services. (2001). Youth violence: 

A report of the surgeon general. Rockville, MD: U.S. Department of Health 

and Human Services, Centers for Disease Control and Prevention, 

National Center for Injury Prevention and Control; Substance Abuse and 

Mental Health Services Administration, Center for Mental Health Services; National Institutes of Health, National Institute of Mental Health.

32 U.S. Gov’t Accountability Office, GAO-18-258, K-12 Education: Discipline

Disparities for Black Students, Boys, and Students With Disabilities (2018).

33 Wasserman, G.A., McReynolds, L.S., Ko, S.J., Katz, L.M., Cauffman, E., 

Haxton, W., & Lucas, C.P. (2004). Screening for emergent risk and service 

needs among incarcerated youth: Comparing MAYSI-2 and Voice DISC-IV. 

Journal of the American Academy of Child and Adolescent Psychiatry, 

43(5), 629–639. 

34 Shufelt, J.L., & Cocozza J.J. (2006). Youth with mental health disorders in 

the juvenile justice system: Results from a multi-state prevalence study. 

Delmar, NY: National Center for Mental Health and Juvenile Justice. 

35 Taylor J., Kemper, T.S., Loney, B.R., & Kistner J.A. (2009). Recidivism in 

subgroups of severe male juvenile offenders. Psychology, Crime and 

Law, 15(5), 395–408.

36 Benda, B.B., Corwyn, R.F., & Toombs, N.J. (2001). Recidivism among 

adolescent serious offenders: Prediction of entry into the correctional 

system for adults. Criminal Justice and Behavior, 28(5), 588-613.

37 Trulson, C.R., Marquart, J.W., Mullings, J.L., & Caeti, T.J. (2005). In 

between adolescence and adulthood: Recidivism outcomes of a cohort 

of state delinquents. Youth Violence and Juvenile Justice, 3(4), 355–387.

38 National Center for Mental Health and Juvenile Justice. (2013). 

Improving diversion policies and programs for justice-involved youth with 

co-occurring mental and substance use disorders. https://www.ncmhjj.

com/wp-content/uploads/2013/10/improvingdiversionstrategies.pdf. 

39 Kamradt, B., & Goldfarb, P. (2015). Demonstrating effectiveness of the 

wraparound model with juvenile justice youth through measuring and 

achieving lower recidivism. Baltimore, MD: The Technical Assistance 

Network for Children’s Behavioral Health.
Federal Commission on School Safety: Prevent 47

40 Skowyra, K., & Powell, S. (2006). Juvenile diversion: Programs for 

justice-involved youth with mental health disorders. Albany, NY: National 

Center for Mental Health and Juvenile Justice.

41 Grisso, T., Vincent, G., & Seagrave, D. (Eds.). (2005). Mental health screening and assessment in juvenile justice. New York: Guilford. 

See also Vincent, G., Paiva-Salisbury, M., Cook, N., Guy, L., & Perrault, R. 

(2012). Impact of risk/needs assessment on juvenile probation officers’ 

decision-making: Importance of implementation. Psychology, Public 

Policy, and Law, 18, 549–576.

42 Grupp-Phelan J., Harman, J.S., Kelleher, K.J. (2007). Trends in mental 

health and chronic condition visits by children presenting for care 

at U.S. emergency departments. Public Health Report, 122(1):55–61. 

Epub 2007/01/24. PubMed PMID: 17236609; PubMed Central PMCID: 

PMC1802106.

43 Kessler, R.C., Demler, O., Frank, R.G., et al. (2005). Prevalence and 

treatment of mental disorders, 1990 to 2003. The New England 

Journal of Medicine, 352(24):2515–23. Epub 2005/06/17. DOI: 10.1056/

NEJMsa043266. PubMed PMID: 15958807; PubMed Central PMCID: 

PMC2847367.

44 Lewis, M. (1978). Child psychiatric consultation in pediatrics. Pediatrics, 

62(3):359–64. Epub 1978/09/01. PubMed PMID: 704211.

45 Sills, M.R., & Bland, S.D. (2002). Summary statistics for pediatric 

psychiatric visits to US emergency departments, 1993–1999. Pediatrics, 

110(4):e40. Epub 2002/10/03. PubMed PMID: 12359813.

46 Wang, P.S., Demler, O., Olfson, M., et al. (2006). Changing profiles of 

service sectors used for mental health care in the United States. The 

American Journal of Psychiatry, 163(7):1187–98. Epub 2006/07/04. DOI: 

10.1176/appi.ajp.163.7.1187. PubMed PMID: 16816223; PubMed Central 

PMCID: PMC1941780.

47 Cooper, S., Valleley, R.J., Polaha, J., et al. (2006). Running out of time: 

physician management of behavioral health concerns in rural pediatric 

primary care. Pediatrics, 118(1):e132–8. Epub 2006/07/05. DOI: 10.1542/

peds.2005-2612. PubMed PMID: 16818528.

48 Committee on Bioethics. (1995). Informed consent, parental permission, 

and assent in pediatric practice. Pediatrics, 95:314–317 (reconfirmed in 

2007).

49 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4393016/#FN2. 

50 Adleman, H.S., Kaser-Boyd, N., & Taylor, L. (1984). Children’s participation in consent for psychotherapy and their subsequent response to 

treatment. Journal of Clinical Child Psychology, 13:170–178.

51 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5654888/. 

52 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5654888/#b28-

wjem-18-1159. 

53 Weist, M.D., Garbacz, S.A., Lane, K.L., & Kincaid, D. (2017). Aligning and 

integrating family engagement in Positive Behavioral Interventions and 

Supports (PBIS): Concepts and strategies for families and schools in key 

contexts. Center for Positive Behavioral Interventions and Supports 

(funded by the Office of Special Education Programs, U.S. Department 

of Education). Eugene, Oregon: University of Oregon Press.

54 Child Welfare Information Gateway. (2016). Definitions of child abuse 

and neglect. Washington, DC: U.S. Department of Health and Human 

Services, Children’s Bureau.

55 Centers for Disease Control and Prevention, National Center for Injury 

Prevention and Control. Web-based Injury Statistics Query and Reporting System (WISQARS) [online] 2016; [cited 2018 Aug 6] Available from 

www.cdc.gov/injury

56 https://www.cdc.gov/healthyyouth/data/yrbs/pdf/2017/ss6708.pdf

57 U.S. Surgeon General report on youth violence, 2001.

58 AAP Schedule of Screenings and Assessments for Well-Child Assessments

(February 24, 2014). https://www.aap.org/en-us/about-the-aap/aappress-room/pages/AAP-Updates-Schedule-of-Screening-and-Assessments-for-Well-Child-Visits.aspx. 

59 PSPSTF Depression in Children and Adolescents: Screening (February 

2016). http://www.uspreventiveservicestaskforce.org/Page/Document/

UpdateSummaryFinal/depression-in-children-and-adolescents-screening1. 

60 ASCD and CDC. Whole school, whole community, whole child: A collaborative approach to learning and health. https://www.cdc.gov/healthyschools/wscc/WSCCmodel_update_508tagged.pdf.

61 U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention. Whole school, whole community, whole child: 

Model fact sheet. https://www.cdc.gov/healthyyouth/wscc/pdf/wscc_

fact_sheet_508c.pdf. 

62 Michael, S.L., Merlo, C.L., Basch, C.E., Wentzel, K.R., & Wechsler, H. 

(2015). Critical connections: Health and academics. Journal of School 

Health, 85: 740–758.

63 U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention. Whole school, whole community, whole child

website. https://www.cdc.gov/healthyyouth/wscc/.

64 Chiang, R.J., Meagher, W., & Slade, S. (2015). How the whole school, 

whole community, whole child model works: Creating greater alignment, integration, and collaboration between health and education. 

Journal of School Health, 85: 775–784.

65 Fazel et al. (October 2014). Mental health interventions in schools 1: 

Mental health interventions in schools in high-income countries. Lancet

Psychiatry, 1(5): 377–387. DOI: 10.1016/S2215-0366(14)70312-8.

66 https://www.pbis.org/school/mtss. 

67 NITT TA Center—Distance Learning—Using an interconnected systems 

framework in NITT, Project AWARE—Part 1: The “what and why” of ISF. 

https://www.youtube.com/watch?v=cgWlm7p4zC0&feature=youtu.be.

68 HRSA. https://www.hrsa.gov/our-stories/school-health-centers/index.

html.

69 School-based Health Alliance, National Census of School-based Health 

Centers. http://censusreport.sbh4all.org/ and http://www.sbh4all.org/

wp-content/uploads/2015/02/2013-14-Census-Data-and-Methods.pdf.

70 http://www.sbh4all.org/school-health-care/health-and-learning/mental-health/. 

71 Lai, K., Guo, S., Ijadi-Maghsoodi, R., Puffer, M., & Kataoka, S.H. (2016). 

Bringing wellness to schools: Opportunities for and challenges to 

mental health integration in school-based health centers. Psychiatric 

Services, 67:1328–1333; DOI: 10.1176/appi.ps.201500401. 

72 School-based Health Alliance, National Census of School-based Health 

Centers. http://censusreport.sbh4all.org/.

73 https://www.nimh.nih.gov/health/topics/schizophrenia/raise/

what-is-coordinated-specialty-care-csc.shtml. 

74 The chronic care model: Model elements (n.d.). Retrieved from www.

improvingchroniccare.org/index.php?p=Model_Elements&s=18.

75 National Initiative for Children’s Healthcare Quality. (2011). Care model 

for child health. Retrieved from www.nichq.org/how_we_work/care_

model_for_child_health.html.

76 McDowell, M., & Klepper, K. (2000). A “chronic disorder” health-care 

model for children with complex developmental disorders. Journal of 

Paediatrics and Child Health, 36(6): 563–8. 

77 The chronic care model (n.d.). Retrieved from www.improvingchroniccare.org/index.php?p=The_Chronic_Care_Model&s=2. 

78 Pires, S. (2002). Building systems of care: A primer. National Technical 

Assistance Center for Children’s Mental Health. Retrieved from https://

gucchd.georgetown.edu/products/PRIMER_CompleteBook.pdf. 

79 Stroul, B., Blau, G., & Friedman, R. (2010). Updating the system of care 

concept and philosophy. Washington, DC: Georgetown University Center 

for Child and Human Development, National Technical Assistance 

Center for Children’s Mental Health. Retrieved from http://thefamilygateway.net/wp-content/uploads/Updating-the-System-of- Care-Concept-and-Philosophy.pdf. 

80 U.S. Department of Health and Human Services. (2009). The comprehensive community mental health services for children and their families 

program, evaluation findings: Report to Congress. Retrieved from http://

store.samhsa.gov/shin/content//PEP12-CMHI2009/PEP12-CMHI2009.

pdf. 

81 http://www.mcpap.com/About/ReportsNPublications.aspx. 

82 https://www.mcpap.com/. 
48 Federal Commission on School Safety: Prevent

83 https://www.chw.org/childrens-and-the-community/

healthy-kids-healthy-communities/health-insurance/care4kids. 

84 Wilson, H.A., & Hoge, R.D. (2012). The effect of youth diversion programs 

on recidivism: A meta-analytic review. Criminal Justice and Behavior, 

Vol. 40, Issue 5, at pp. 497–518. First Published October 15, 2012. https://

doi.org/10.1177/0093854812451089. 

85 Kretschmar, J.M., Butcher, F., Flannery, D.J., & Singer, M.I. (2014). 

Diverting juvenile justice-involved youth with behavioral health issues 

from detention: Preliminary findings from Ohio’s Behavioral Health 

Juvenile Justice (BHJJ) Initiative. Criminal Justice Policy Review, Vol. 27, 

Issue 3, at pp. 302–325. First Published December 17, 2014. https://doi.

org/10.1177/0887403414560885. 

86 https://www.thecommunityguide.org/findings/violence-policies-facilitating-transfer-juveniles-adult-justice-systems.

87 https://www.thecommunityguide.org/findings/violence-therapeutic-foster-care-chronically-delinquent-juveniles.

88 New York State Office of Mental Health. Kendra’s Law: Final report on the 

status of Assisted Outpatient Treatment outcomes for recipients during 

the first six months of AOT. https://www.omh.ny.gov/omhweb/kendra_

web/finalreport/outcomes.htm. 
Federal Commission on School Safety: Prevent 49

Informed, alert communities play a critical role in 

keeping our nation safe. By reporting suspicious activities, individuals may be providing the information 

authorities need to stop an attack before it occurs. This 

is especially true in relation to school attacks. Studies 

have shown that, prior to the incident, most attackers 

engaged in behavior that caused others concern and 

that others knew about the attacker’s ideas or plan to 

attack.1 Indeed, before the Parkland shooting, multiple 

reports were allegedly received about the shooter’s 

concerning behavior.2 How they were processed, evaluated, and acted upon remains under review. What 

is certain is that effective programs addressing suspicious activity reporting and threat assessment can 

significantly reduce—or prevent—violence.

Following the shooting at Columbine High School in 

1999, the U.S. Secret Service partnered with the U.S. 

Department of Education to study school violence. 

Completed in 2002, the Safe School Initiative examined 37 incidents of targeted violence that occurred 

at elementary and secondary schools (i.e., K–12).3 The 

study sought to analyze the thinking and behavior of 

students who committed these acts from an operational perspective. Its key findings include:

• Incidents of targeted violence at K–12 schools were 

rarely sudden or impulsive acts.

• Prior to most incidents, other people knew about 

the attacker’s idea and/or plan to attack.

• There is no accurate or useful “profile” of students 

who engaged in targeted school violence.

• Most attackers engaged in some behavior prior to 

the incident that caused others concern or indicated a need for help.

• Most attackers had difficulty coping with significant 

losses or personal failures. Moreover, many had 

considered or attempted suicide.

• Many attackers felt bullied, persecuted, or injured 

by others prior to the attack.

• In many cases, other students were involved in 

some capacity.

One of the study’s most significant findings was 

that, prior to most attacks, other students knew of 

the attackers’ plans, yet most did not report it to an 

adult. This finding led the two agencies to conduct a 

follow-on effort titled the Bystander Study,

4

 which was 

released in 2008. The study explored barriers that may 

prevent someone from coming forward in advance. 

A series of in-depth interviews were conducted with 

persons who did not come forward before an attack 

took place, as well as those who did come forward 

and thereby helped to avert a potential school-based 

attack. The study concluded:

• The relationships between the bystanders and 

the attackers, and when and how the bystanders 

came upon information about the planned attacks, 

varied.

• Bystanders’ willingness to share information 

ranged from those who took no action to those 

who actively conveyed their concerns.

• School climate affected whether students came 

forward.

• Some students did not come forward because they 

disbelieved that the attacks would occur or they 

misjudged the likelihood and immediacy of the 

planned attack.

• In some situations, parents and parental figures 

influenced whether the bystander reported the 

information to school staff or other adults in positions of authority.

CHAPTER 5

Using Suspicious Activity Reporting and Threat Assessments 

to Enhance School Safety

Informed, alert communities play a critical role in 

keeping our nation safe. By reporting suspicious 

activities, individuals may be providing the information authorities need to stop an attack before 

it occurs.
50 Federal Commission on School Safety: Prevent

Based on the above, it is clear that there exists an 

opportunity to customize or expand the framework 

of suspicious activity reporting to include the identification and reporting of student behaviors of concern. 

Outreach campaigns, such as the U.S. Department 

of Homeland Security’s (DHS) “If You See Something, 

Say Something®” campaign, and similar state-specific 

programs, are essential to both encouraging and facilitating the reporting of suspicious activities or other 

concerning behavior. They not only remind individuals 

that it is important to stay vigilant and report things 

that appear out of the ordinary, they also provide 

guidance on both what should be considered concerning and how and to whom to report it. 

Reporting suspicious or concerning behavior on its 

own, however, will not prevent a violent act from 

occurring. The reported information must be appropriately evaluated and, if determined to indicate a 

legitimate potential threat or concern, properly acted 

upon. This typically means the conducting of a threat 

assessment. 

The school threat assessment process essentially 

involves a three-step model in which a team identifies

students of concern, gathers information about their 

behavior and circumstances to assess whether they 

pose a risk of harm to themselves or the school community, and develops a management plan to mitigate 

that risk. Threat assessment does not definitively predict whether someone will commit an act of violence. 

Rather, its goal is to evaluate the risk an individual 

may pose and implement intervention strategies to 

address concerns.

Research has shown that threat assessment programs 

are beneficial, including in preventing mass casualty 

shootings. For instance, a 2008 field study examined 

209 student cases from 103 schools that were referred 

to a centralized threat assessment team because the 

student had communicated a threat to commit a violent act resulting in a long-term suspension. For each 

case, the threat assessment team conducted interviews, assessed the threat, and developed a written 

report containing findings and recommendations. The 

results of the threat assessment concluded that all but 

five students should be returned to school, and none 

of the alleged threats were carried out.5

A 2009 study examined data gathered from Virginia’s 

2007 annual school safety audit. It showed that 95 

schools had adopted the Virginia threat assessment 

guidelines, 131 schools used locally developed threat 

assessment procedures, and 54 reported not using a 

threat assessment approach. Students were randomly 

selected from these 280 schools and administered a 

school climate survey. The schools that used a threat 

assessment approach had lower rates of bullying and 

fewer long-term suspensions. Further, students had 

a greater willingness to seek help for bullying and 

threats of violence, and had a more positive perception of their school climate.6

The importance of suspicious activity reporting and 

the establishment of threat assessments has been a 

common theme identified in the wake of past school 

shootings. The Virginia Tech Commission’s report recommended that states “[e]ducate and train parents, 

teachers, and students to recognize warning signs 

and known indicators of violence and mental illness 

and to alert those who can provide for safety and 

treatment” and to “[e]stablish and publicize widely a 

mechanism to report and respond to reported threats 

of violence.”7 The report also noted that creating interdisciplinary teams to evaluate information reported 

by students and staff, assess the degree of threat, 

and intervene to preempt the threat was an effective practice.8

 It recommended that federal agencies 

work together and with other appropriate partners 

to share information on and best practices in behavioral analysis, threat assessments, and emergency 

preparedness.9 The Obama Administration’s plan also 

discussed suspicious activity reporting, and proposed 

clarifying that no federal law prevents healthcare 

providers from warning law enforcement authorities 

about threats of violence.10

The Columbine Review Commission report stressed 

the need for school officials to overcome the “code of 

silence” that often prevented the reporting of concerning behavior. It recommended all schools establish 

and encourage students to use an anonymous telephone line or other mechanism to report statements 

or behavior that they found concerning.11 The report 

also recognized the value of threat assessment teams, 

recommending that they “should be established at 

School Threat Assessment Process 

Figure 5-1
Federal Commission on School Safety: Prevent 51

every Colorado high school and middle school.”12 The 

Sandy Hook Advisory Commission report discussed 

how schools can be designed in a way to facilitate the 

observation of changes in behavior that may be of 

concern and should be reported.13

Various states and districts have implemented suspicious activity reporting and related threat assessment 

programs. For instance, in 2004 under Governor Bill 

Owens, the State of Colorado created Safe2Tell to 

deliver a statewide anonymous 24-hour reporting tool 

where parents, students, teachers, school administrators, law enforcement, and others can report a perceived threat to their safety or the safety of others.14

The reporting tool can be accessed from the Safe2Tell 

website, calling into the hotline, or through an application on a mobile phone. When imminent action is 

needed on a report, Safe2Tell passes along the information to local school officials and law enforcement. 

Also, an accountability component was developed to 

confirm that every report that comes in is investigated 

by school and law enforcement agencies, that action 

was taken, and that the outcome was tracked. In May 

2014, Colorado incorporated Safe2Tell under the Colorado Office of the Attorney General to ensure reporting 

avenues, trainings, and education and awareness 

efforts are available across the entire state.15 Similarly, in 2013, Virginia was the first state to pass a law 

requiring every school in the state to establish a threat 

assessment team.16

Commission Observations

Suspicious activity reporting 

The Nationwide Suspicious Activity Reporting Initiative has issued a publication that provides an overview of some of the key characteristics of an effective 

suspicious activity reporting program.17 These include 

the timely vetting of reports received, educating the 

community on the reporting process, complementary 

training for staff, and privacy protections.18

Outreach Campaigns: During the August 16 Commission meeting, Officer Chris Fraley, Region 2 Director for 

the National Association of School Resource Officers, 

told Commission members: “students are a source of 

valuable information through social media and talk 

amongst their peers of potential threats or incidents 

that are being planned. Security in the school building 

also involves the promotion of see something, say 

something wherein the students and staff report crime 

or suspicious activity.”19

Visible public awareness messaging campaigns 

increase vigilance and reporting of suspicious behavior. Successful campaigns, such as the “If You See 

Something, Say Something®” campaign, typically 

perform outreach through multiple means, both physically and online. This includes posters, factsheets, 

infographics, websites, audio and video public service 

announcements, and public events.20 Simple messaging focused on what suspicious activity or concerning 

behavior looks like and how to report are the hallmarks of many of the major campaigns.

Colorado’s Safe2Tell program similarly uses a variety 

of methods to raise awareness, including age-appropriate videos, posters, direct messaging, and classroom discussions.21 By combining direct messaging 

along with relevant promotional materials, Safe2Tell 

effectively spreads its message and tip line number 

to thousands of students each year.22 Data shows that 

more Safe2Tell tip reports come from schools that 

incorporate the Safe2Tell solution in all practices.23

Many campaign organizers also encourage partnering 

with other organizations to help expand the reach of 

the messaging. For example, in the execution of the 

“If You See Something, Say Something®” campaign, 

Visible public awareness messaging campaigns increase vigilance and 

reporting of suspicious behavior. Successful campaigns, such as the “If You 

See Something, Say Something®” campaign, typically perform outreach 

through multiple means, both physically and online. This includes posters, 

factsheets, infographics, websites, audio and video public service announcements, and public events.
52 Federal Commission on School Safety: Prevent

DHS partners with states, cities, and counties; airports 

and mass transit entities; sports leagues and teams; 

major sports events and entertainment venues; colleges and universities; fairs and festivals; private sector businesses; and media outlets. Partners typically 

work together to tailor campaign messages and distribution mechanisms to their specific stakeholder community. All school districts are encouraged to work 

with DHS to obtain official “If You See Something, Say 

Something®” materials that increase awareness of the 

importance of reporting suspicious activity or concerning behavior within their school community.24

Anonymous Reporting: As early as the Columbine 

Commission Report, experts have recognized the 

importance of providing a mechanism for anonymous 

reporting.25 Numerous witnesses at various Commission events concurred, including Chris Harms, Director of the Colorado School Safety Resource Center; 

Marguerite Herman, Federal Legislative Chair of the 

Wyoming Parent Teacher Association; and Trisha Daniel, Nationally Certified School Psychologist from the 

Alabama Association of School Psychologists.26 Anonymous reporting can be done through various means 

(e.g., mobile applications, online, email, and phone). It 

is now a commonplace part of many statewide safety 

tip lines, such as Michigan’s OK2SAY,27 Wyoming’s 

Safe2Tell Wyoming,28 Utah’s SafeUT,29 and Nevada’s 

SafeVoice.30

Anonymous reporting is not without its challenges. 

For example, it sometimes can make it more difficult 

to evaluate the veracity of a tip and may increase the 

likelihood of an individual using a reporting system as 

a means for harassment or false accusations. However, these challenges are considered infrequent and 

far outweighed by the benefits of allowing anonymous 

reporting. Further, they can be greatly mitigated 

through the incorporation of protocols to ensure that 

all reports are properly evaluated by trained staff and 

handled with appropriate discretion.

Complementary Training: Training individuals on how 

to implement a program is critical to its continued 

success. As Safe2Tell founder Susan Payne pointedly 

stated in her testimony to the Commission, “we do 

not rise to the level of expectation in a crisis, we fall 

to our level of training.”31 In acknowledgement of this, 

the National Suspicious Activity Reporting Initiative 

calls training one of the 10 key elements to successfully integrating suspicious activity reporting into an 

organization’s operations.32 In the case of suspicious 

activity reporting and “If You See Something, Say 

Something®” campaigns, this includes training the 

intended audience on how to identify and report 

suspicious behavior as well as training the recipients 

of the suspicious activity reporting on how to manage 

and respond to incoming reports. 

In her testimony, Payne provided an overview of the 

many ways in which Safe2Tell raises education and 

awareness of the program. Its methods include:

• Train the Trainer Certifications and Staff Trainings. Safe2Tell developed a training program that 

certifies individuals and leaders to present Safe2Tell information, materials, and classroom discussion materials to their communities and schools. 

• Conversation Jumpstarts. Safe2Tell developed 

educational lessons to provide school staff a tangible tool to lead guided classroom discussions. 

Available Conversation Jumpstart topics include 

bullying, cyberbullying, dating, sexting, weapons, 

depression, and substance abuse. While discussing issues, trainers talk about the code of silence, 

when it is appropriate to make a report, and what 

happens when a report is made.

As part of its “See, Say, Do Something” campaign, in 

May 2018 the Dallas (TX) Independent School District 

(Dallas ISD) brought thousands of its students to the 

city’s American Airlines Center to talk about how to 

prevent and respond to gun violence in schools. At the 

event (which was planned with help from the International Association of Venue Managers), representatives 

of the DHS, the Federal Bureau of Investigation, Dallas 

ISD police, and other officials spoke with students 

about the importance of being vigilant in observing 

and reporting classmates’ behavior. This event is a 

potential model for high-impact community outreach 

and training.33

Another example of a successful approach to suspicious activity reporting training is the Transportation 

Security Administration’s (TSA’s) First Observer PlusTM 

Program,34 which TSA offers as a complement to the 

As early as the Columbine Commission Report, 

experts have recognized the importance of providing a mechanism for anonymous reporting.
Federal Commission on School Safety: Prevent 53

“If You See Something, Say Something®” campaign. 

The First Observer PlusTM Program is a security awareness and training program meant to deliver a simple 

message to surface transportation professionals to 

“Observe, Assess, and Report” suspicious activity. 

Through online and in-person training, the program 

provides transportation professionals tools to recognize suspicious activity possibly related to terrorism, 

guidance in assessing what they see, and a method for 

reporting those observations. Training participants are 

instructed not to intervene or engage suspicious persons or items, but to follow their organization’s policy 

for reporting information to local law enforcement 

and, when possible, to TSA by calling 1-844-TSA-FRST. 

The TSA First Observer PlusTM Program is available to 

school transportation frontline employees. Over the 

past few years, TSA employees have conducted more 

than 1,000 online school bus training registrations as 

well as in-person training for more than 200 school 

bus professionals. 

Privacy Protections: As John Verdi, Vice-President of 

Policy at the Future of Privacy Forum, stated during 

the July 11 Commission meeting: “trust between 

students and adults is crucial to ensure that children reach out for help when they need it and report 

concerns about other students when they have them. 

Maintaining appropriate safeguards for students’ privacy helps create and maintain that trust.”35

During the design and execution of any suspicious 

activity reporting program it is important to incorporate appropriate privacy protections and to comply 

with privacy laws. This can raise additional complexities in the school environment where privacy rights 

embedded in both the Family Educational Rights and 

Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act (HIPAA) may apply. As multiple witnesses noted during the July 11 Commission 

meeting, there often is some confusion regarding what 

information legally can be shared and with whom 

when it involves the behavior or mental health history 

of a student.36

The Guide for Developing High-Quality School Emergency Operations Plans, which was issued by the U.S. 

Departments of Justice, Health and Human Services, 

Homeland Security, and Education in 2013, provides 

guidance on how FERPA and HIPAA affect the ability 

to share and act upon suspicious behavior reported in 

a school environment.37 Additionally, the Nationwide 

Suspicious Activity Reporting Initiative has issued a 

Privacy Fact Sheet with some general tips on how to 

incorporate privacy into suspicious activity reporting 

efforts.38 For additional information on FERPA and 

HIPAA, see Chapters 17 and 18 of this Report.

Threat assessment teams and comprehensive 

targeted violence prevention programs

In July 2018, the U.S. Secret Service National Threat 

Assessment Center published Enhancing School Safety 

Using a Threat Assessment Model: An Operational 

Guide for Preventing Targeted School Violence. It notes 

the following: “[e]nsuring the safety of our schools 

involves multiple components, including physical 

security, emergency management, and violence 

prevention efforts in the form of a threat assessment 

process. This process begins with establishing a 

comprehensive targeted violence prevention plan.”39

Numerous witnesses stressed the importance of threat 

assessment teams during Commission meetings, 

including Donna Michaelis, Manager for the Virginia 

Center for School and Campus Safety; Kathy Martinez-Prather, Director of the Texas School Safety Center; and Dr. Kathy Murphy, Superintendent of Hoover 

(AL) City Schools.40

In its Operational Guide for Preventing Targeted School 

Violence, the U.S. Secret Service enumerated the 

following eight steps for creating a comprehensive 

targeted violence prevention plan.
54 Federal Commission on School Safety: Prevent

8 Steps for Creating a Comprehensive Targeted Violence Prevention Plan

STEP 1: Establish a multi-disciplinary threat assessment team. Threat assessments are best performed by 

multi-disciplinary teams that include highly trained professionals from a variety of different disciplines (e.g., 

teachers, administrators, school resource officers, school psychologists, guidance counselors). The team will 

conduct the threat assessments, implement crisis prevention when needed, assess the student’s potential for 

violence, and develop intervention and management strategies to mitigate that risk.

STEP 2: Define behaviors to include those that are prohibitive and concerning. Prohibited behaviors should 

trigger immediate intervention. These behaviors can include, but are not limited to, intimidation, threats, 

harassment, bullying, and carrying weapons on school property. Concerning behaviors may indicate the need 

for a threat assessment. These behaviors can vary in nature, but may include sudden or dramatic changes in 

mood and appearance or a decline in school performance. There should be a low threshold of concern so that 

the plan addresses a continuum of concerning behaviors, not just direct threats or behaviors indicative of planning for an attack.

STEP 3: Establish and provide training on a central reporting system. This can include an online form on 

the school website, email address, phone number, smartphone application, or other mechanism. It is also 

important to ensure the reporting tool is continually monitored, each report is followed up, and that it allows 

individuals to report anonymously. Programs and policies must be put into place that promote a climate that 

ensures those reporting feel safe in their concern and break down the code of silence.

STEP 4: Determine the threshold for law enforcement intervention. Although the majority of cases will 

be handled using school or community resources (e.g., mentoring, counseling, tutoring, and social or family 

services), some will require law enforcement, especially if there is a safety risk. 

STEP 5: Establish replicable threat assessment procedures. These procedures include practices for maintaining documentation, identifying sources of information, reviewing records, and conducting interviews with 

an emphasis on rapport building. Procedures should include the following investigative themes to guide the 

assessment process: Motive, Communications (unusual or concerning), Inappropriate Interests, Weapons Access, 

Stressors, Emotional and Developmental Issues, Desperation or Despair, Violence as an Option, Concerned Others, 

Capacity to Organize an Attack, Pre-Attack Planning Behaviors, Consistency Between Students’ Actions and Statements, and Protective Factors.

STEP 6: Develop risk management options. Threat assessment teams should develop a set of risk management options that can be implemented once an assessment is complete. Based on the information developed 

by the team, an individualized management plan can be created to mitigate any identified risks. Other components of management include notifying law enforcement if an attack is imminent, ensuring the safety of 

potential targets, creating a situation less prone to violence, and reducing the effect of stressors.

STEP 7: Create and promote a safe school climate. School climates should facilitate a culture of safety, 

respect, trust, and emotional support, where open communication is encouraged, school staff intervene in 

conflicts and bullying, and students feel empowered to share their concerns.

STEP 8: Provide training for all stakeholders. As Donna Michaelis stated at the August 16 Commission meeting, “Training is absolutely vital to the success of a threat assessment program.”41 Recipients of the training 

should include faculty, staff, and administrators; students; parents; and school resource officers and local law 

enforcement. Topics covered by the training might include how to recognize and report concerning behavior, 

suicide prevention, conflict resolution, and de-escalation techniques.
Federal Commission on School Safety: Prevent 55

As more and more states, localities, school districts, 

and schools begin implementing threat assessment 

and targeted violence prevention programs, they 

are developing new approaches. Thus far, three 

states—Virginia, Florida, and Maryland—have legally 

mandated the use of threat assessment teams in all 

public K–12 schools or school systems. Under these 

laws, the local or district school board must adopt 

policies for the establishment of threat assessment 

teams that can assess and intervene against individuals whose behavior may pose a threat to the safety 

of school staff or students.42 The policies must include 

procedures for referrals to approved community 

service boards, healthcare providers, or mental health 

services, when appropriate.43

Funded under California’s Mental Health Services Act, 

the Los Angeles Police Department created a School 

Threat Assessment Response Team (START) program 

to address the need for comprehensive threat prevention and management. In collaboration with the Los 

Angeles Police Department, START works to address 

school violence by providing training to communities 

on risk/threat assessment and developing multi-disciplinary Crisis or Threat Management Teams. The 

program also assists educational institutions with 

case consultations, conducting threat assessments, 

and implementing intervention response and case 

management plans. It has fielded more than 8,000 

calls since its establishment in 2009.44
56 Federal Commission on School Safety: Prevent

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. The federal government should develop options to support the creation (in conjunction with federal 

and state partners) of guidance for state and local jurisdictions to implement a comprehensive early 

warning and reporting system modeled on programs like “If You See Something, Say Something®” 

and Safe2Tell.

2. As numerous witnesses noted to the Commission, students themselves must be part of the solution 

and often can help identify the best ways to communicate to and educate their peers. In recognition of that, the U.S. Department of Homeland Security (DHS) and the U.S. Department of Education should explore sponsoring a Peer-to-Peer Competition Challenge for high school students to 

develop school security campaigns.

3. To assist schools and school districts in establishing threat assessment teams and targeted violence 

prevention programs, DHS, as warranted, should periodically update its Enhancing School Safety 

Using a Threat Assessment Model: An Operational Guide for Preventing Targeted School Violence. 

Additionally, DHS should develop options for supporting the development of a train-the-trainer 

program to facilitate consistent application of the recommended practices contained in the Guide. 

¤ STATES & LOCAL COMMUNITIES

1. States, school districts, and individual schools should establish and provide training on a central 

suspicious activity reporting system that is continually monitored, allows anonymous reporting, 

and has procedures in place to ensure proper action is taken on each report.

Funds may be available through the STOP School Violence Act of 2018 to assist in developing these 

systems. The reporting system could be supplemented by an education and awareness campaign 

that encourages students, teachers, and other members of the school community to report their 

concerns, provides guidance on what types of activities should be reported, and provides instructions on the various options for submitting a report. 

2. School districts and individual schools should establish threat assessment teams and develop 

comprehensive targeted violence prevention programs. States and localities should consider 

encouraging and supporting this activity in whatever manner they determine to be the most appropriate. This may include the enactment of legislation mandating that school districts or schools 

take these actions, the establishment of state or local teams to provide training to school administrators and staff on these activities, and/or the provision of grants or other funds to schools to 

support these activities. 

3. School districts and individual schools should establish comprehensive targeted violence prevention 

programs supported by multi-disciplinary threat assessment teams as outlined in the U.S. Secret 

Service guide Enhancing School Safety Using a Threat Assessment Model: An Operational Guide for 

Preventing Targeted School Violence. Schools may be able to receive funds through the STOP School 

Violence Act of 2018 to assist in establishing these programs. To establish a comprehensive violence 

prevention program, it is recommended that schools/school districts perform the following steps: 
Federal Commission on School Safety: Prevent 57

• Establish a multi-disciplinary threat assessment team consisting of highly trained school professionals from a variety of different disciplines (e.g., teachers, administrators, school resource 

officers, school psychologists, guidance counselors) who, among other things, will conduct threat 

assessments, assess a student’s potential for violence, and develop intervention and management 

strategies to mitigate that risk.

• Define concerning behaviors that initiate the need for a threat assessment (e.g., sudden or dramatic changes in mood, appearance, or behavior) and prohibited behaviors (e.g., harassment, 

bullying, carrying a weapon on school property) that initiate immediate intervention. There should 

be a low threshold for defining concerning behaviors so that protocols address a continuum of 

behaviors, not just direct threats or behaviors indicative of planning for an attack.

• Establish and provide training on a central reporting system.

• Determine the threshold for law enforcement intervention. 

• Establish replicable threat assessment procedures to include practices for maintaining documentation, identifying sources of information, reviewing records, and conducting interviews with an 

emphasis on rapport building. 

• Develop risk management options to enact once an assessment is complete and individualized 

management plans to mitigate identified risks and enhance positive outcomes for students of 

concern.

• Create and promote a safe school climate.

• Provide training for all stakeholders.

4. As numerous witnesses noted to the Commission, students themselves must be part of the solution 

and often can help identify the best ways to communicate with and educate their peers. In recognition of that, school districts and schools should empower students by increasing engagement with 

students in the development of school security campaigns.

Chapter 5 Endnotes

1 See, e.g., Pollack, W., Modzeleski, W., & Rooney, G. (May 2008). Prior 

knowledge of potential school-based violence: Information students 

learn may prevent a targeted attack. United States Secret Service and 

United States Department of Education. https://rems.ed.gov/docs/

DOE_BystanderStudy.pdf.

2 See, e.g., Haag, M., & Kovaleski, S. (February 14, 2018). Nikolas Cruz, 

Florida shooting suspect, described as a “troubled kid.” New York Times; 

Wallman, B., & McMahon, P. (August 3, 2018). Here’s what Broward 

Schools knew about Parkland shooter—details revealed by mistake. 

South Florida Sun Sentinel.

3 Vossekuil, B., Fein, R., Reddy, M., Borum, R., & Modzeleski, W. (June 

2004). The final report and findings of the safe school initiative: Implications for the prevention of school attacks in the United States. United 

States Secret Service and United States Department of Education. The 

U.S. Secret Service is in the process of updating this study based on 

more recent incidents of targeted school violence (2008–2017).

4 Pollack, W., Modzeleski, W., & Rooney, G. (May 2008). Prior knowledge of 

potential school-based violence: Information students learn may prevent 

a targeted attack. United States Secret Service and United States 

Department of Education. https://rems.ed.gov/docs/DOE_BystanderStudy.pdf. 

5 Strong, K., & Cornell, D. (2008). Student threat assessment in Memphis 

City Schools: A descriptive report. Behavioral disorders, Vol. 34, at pp. 

42–54.

6 Cornell, D., Sheras, P., Gregory, A., & Fan, X. (2009). A retrospective study 

of school safety conditions in high schools using the Virginia Threat 

Assessment Guidelines versus alternative approaches. School Psychology Quarterly, Vol. 24, at pp. 119–129.

7 Departments of Education, Justice, and Health and Human Services. 

(June 13, 2007). Report to the President on issues raised by the Virginia 

Tech tragedy, at p. 12.

8 Ibid.

9 Ibid at p. 9.

10 Now is the time: The President’s plan to protect our children and our 

communities by reducing gun violence. (January 16, 2013), at p. 9.

11 The report of Governor Bill Owens’ Columbine Review Commission. (May 

2001), at pp. xv–xvi.

12 Ibid at p. xvii.

13 Final report of the Sandy Hook Advisory Commission. (March 6, 2015), at 

pp. 25–27. 

14 To learn more, visit: https://safe2tell.org.

15 Many other states have enacted similar programs, to include Michigan’s 

OK2SAY (https://www.michigan.gov/ok2say/), launched in September 

2014 under Governor Rick Snyder; Utah’s SafeUT (https://healthcare.

utah.edu/uni/programs/safe-ut-smartphone-app/), launched in 

January 2016 under Governor Gary Herbert; Wyoming’s Safe2Tell 

Wyoming (http://safe2tellwy.org/), launched in October 2016 under 

Governor Matt Mead; Oregon’s SafeOregon (https://www.safeoregon.

com/), launched in January 2017 under Governor Kate Brown; Nevada’s 

SafeVoice (http://safevoicenv.org/), launched in January 2018 under 
58 Federal Commission on School Safety: Prevent

Governor Brian Sandoval; and Iowa’s Say Something Iowa (https://www.

saysomething.iowa.gov/), launched in February 2018 under Governor 

Kim Reynolds. 

16 Va. Code. Ann. § 22.1-79.4

17 Nationwide Suspicious Activity Reporting Initiative. (January 2017). 

Suspicious activity reporting process implementation checklist. https://

nsi.ncirc.gov/documents/sar_implementation_checklist.pdf.

18 Ibid.

19 Officer Chris Fraley Statement to the Federal Commission on School 

Safety Meeting (August 16, 2018), Creating a citadel of learning: New 

tools to secure our schools, inside and out. https://www2.ed.gov/documents/school-safety/transcript-08-16-2018.pdf

20 “If You See Something, Say Something®” campaign materials can be 

found at https://www.dhs.gov/see-something-say-something/campaign-materials.

21 Susan Payne Statement to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out. https://www2.ed.gov/documents/

school-safety/transcript-08-16-2018.pdf

22 Ibid.

23 Ibid.

24 For more information on partnering with DHS on an “If You See Something, Say Something®” campaign, visit https://www.dhs.gov/see-something-say-something/become-partner.

25 The report of Governor Bill Owens’ Columbine Review Commission. (May 

2001). At pp. xv–xvi; testimony of Susan Payne to the Federal Commission on School Safety Meeting (August 16, 2018), Creating a citadel of 

learning: New tools to secure our schools, inside and out; Pollack, W., 

Modzeleski, W., & Rooney, G. (May 2008). Prior knowledge of potential 

school-based violence: Information students learn may prevent a targeted 

attack. United States Secret Service and United States Department of 

Education, at p. 9. https://rems.ed.gov/docs/DOE_BystanderStudy.pdf.

26 Testimony of Chris Harms to the Federal Commission on School Safety 

Roundtable (August 7, 2018); testimony of Marguerite Herman to the 

Federal Commission on School Safety Listening Session (August 28, 

2018); and testimony of Trisha Daniel to the Federal Commission on 

School Safety Listening Session (August 28, 2018).

27 https://www.michigan.gov/ok2say/.

28 http://safe2tellwy.org/.

29 https://healthcare.utah.edu/uni/programs/safe-ut-smartphone-app/.

30 http://safevoicenv.org/.

31 Susan Payne Statement to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out. https://www2.ed.gov/documents/

school-safety/transcript-08-16-2018.pdf.

32 Nationwide Suspicious Activity Reporting Initiative. 10 ways to integrate 

suspicious activity reporting into your agency’s operations. https://nsi.

ncirc.gov/documents/10_Ways_to_Integrate_Suspicious_Activity_

Reporting_Into_Your_Agencys_Operations.pdf.

33 For additional information about how the Dallas ISD is addressing gun 

violence in schools, visit https://thehub.dallasisd.org.

34 www.TSA.gov/firstobserver.

35 Testimony of John Verdi to the Federal Commission on School Safety 

Meeting (July 11, 2018), Curating a healthier and safer approach: Issues 

of mental health and counseling for our young.

36 See, e.g., testimony of Jennifer Mathis to the Federal Commission on 

School Safety Meeting (July 11, 2018), Curating a healthier and safer 

approach: Issues of mental health and counseling for our young; and 

testimony of Doris Fuller to the Federal Commission on School Safety 

Meeting (July 11, 2018), Curating a healthier and safer approach: Issues 

of mental health and counseling for our young.

37 Department of Education, Department of Justice, Department of Health 

and Human Services, Department of Homeland Security, Federal 

Emergency Management Agency, and Federal Bureau of Investigation. 

(2013). Guide for developing high-quality school emergency operations 

plans. https://www.dhs.gov/sites/default/files/publications/REMS%20

K-12%20Guide%20508_0.pdf. 

38 Nationwide Suspicious Activity Reporting Initiative. Privacy fact sheet. 

https://nsi.ncirc.gov/documents/SAR_Privacy_Fact_Sheet.pdf.

39 U.S. Secret Service National Threat Assessment Center. (July 2018). 

Enhancing school safety using a threat assessment model: An operational guide for preventing targeted school violence, at p. 2. https://

www.secretservice.gov/data/protection/ntac/USSS_NTAC_Enhancing_School_Safety_Guide_7.11.18.pdf.

40 Donna Michaelis Statement to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out. https://www2.ed.gov/documents/

school-safety/transcript-08-16-2018.pdf; Kathy Martinez-Prather Statement to the Federal Commission on School Safety Listening Session 

(August 28, 2018); and Dr. Kathy Murphy Statement to the Federal Commission on School Safety Listening Session (August 28, 2018). https://

www2.ed.gov/documents/school-safety/transcript-08-28-2018.pdf.

41 Donna Michaelis Statement to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out. https://www2.ed.gov/documents/

school-safety/transcript-08-16-2018.pdf

42 Va. Code Ann. § 22.1-79.4 (2013); Fla. Stat. Ann. § 1006.07 (2018); Md. Code

Ann. § 7-1507 (2018).

43 Ibid.

44 To learn more, visit http://file.lacounty.gov/SDSInter/dmh/186285_EOB.

pdf.
Federal Commission on School Safety: Prevent 59

CHAPTER 6

Effects of Press Coverage of Mass Shootings

Press coverage of school shootings is often sensational, which can exacerbate the trauma of those 

directly and indirectly affected and potentially incite 

successive events. Wall-to-wall cable television coverage, front-page images, and overloaded social media 

feeds make it nearly inevitable that most people will 

learn about what transpired, including the names, 

faces, and personal stories of those who perpetrated 

the acts of violence.

Reports indicate that the alleged Parkland shooter 

received letters of encouragement, greeting cards, and 

even money in prison.1 The Broward County Public 

Defender finds this deeply disturbing: “The letters 

shake me up because they are written by regular, 

everyday teenage girls from across the nation.”2

The extensive correspondence as well as the Facebook 

communities defending the accused have left many 

to wonder how a mass shooter became a national 

celebrity. Indeed, achieving celebrity may have been 

his very intent. The Sun Sentinel reported that the 

accused, via a social network, recorded a video bragging about how the massacre he planned would make 

him notorious: “when you see me on the news you’ll 

all know who I am.”3

Researchers have found that most shooters desire 

fame and wish to emulate other mass shooters.4 In 

several recent surveys, approximately 80 percent of 

the general public agreed that media coverage of 

mass shootings can make offenders famous, and 70 

percent agreed that this coverage can lead to subsequent attacks.5

 Analyses of media coverage following 

violent incidents provide strong evidence for a “contagion effect,”6

 which holds that media coverage can 

increase the probability of future violent incidents. 

Social media only amplifies this problem. In the 

absence of traditional journalistic tools—like editorial 

discretion—social media allows for the wide dissemination of information, where nearly every individual can be a contributor and a consumer (including 

would-be shooters). It is increasingly difficult for all 

involved to strike an appropriate balance between 

informing the public about school shootings—especially in the context of active security events, where 

parents and educators need immediate and accurate 

information—and the real danger that saturated coverage of mass killings may instigate future violence.

In the wake of Parkland, several national news outlets 

released profiles of the alleged shooter, and media 

sites reported widely on his YouTube and Instagram 

posts. In May 2018, news outlets released to the 

public the videos the accused made. Several Parkland 

survivors strongly opposed the release of the videos 

on Twitter, one of them claiming that doing so “only 

gives him what he wants.”7 In response, several media 

outlets, including the Orlando Sentinel, removed the 

videos from their webpages. 

This is the first federal report to examine the issue of 

media coverage as it relates to the perpetuation of 

violence. Given the dramatic growth of social media, 

understanding this new dynamic (including the 

significantly different ways in which citizens consume 

information) remains an ongoing challenge. According 

to a recent poll by the Pew Research Center, “fully 95% 

of teens have access to a smartphone, and 45% say 

they are online ‘almost constantly.’”8

Commission Observations

The American Psychological Association released a 

study in 2016 that concluded that “the prevalence 

of mass shootings has risen in relation to the mass 

media coverage of them and the proliferation of social 

media sites that tend to glorify the shooters and 

downplay the victims.”9

Senior administrators from the Santa Fe, TX, School 

District shared with Commission leaders how the 

Does media coverage of mass shootings make offenders famous?

Does media coverage lead to subsequent attacks?

NO YES

80%

70%

Figure 6-1
60 Federal Commission on School Safety: Prevent

district intentionally worked with media to focus 

coverage on the victims, on the heroic actions of the 

students, teachers, and school resources officers, and 

on the community’s efforts to come together (rather 

than on the perpetrator). 

A 2015 Arizona State University research paper highlighted data indicating that mass shootings often 

occur in bunches.10 Likening mass shooting events 

to the spread of an infectious contagion, researchers 

found “significant evidence that mass killings involving firearms are incented by similar events in the 

immediate past.”11 Researchers further hypothesize 

that television, radio, and other media exposure of 

one mass shooting could infect the next perpetrator.12

The Commission received testimony and written submissions on the material impact that press coverage 

can have on schools and communities. For instance, 

Ben Fernandez, Chair of the National Association of 

School Psychologists (NASP) School Safety and Crisis 

Response Committee, testified about not only the contagion effect that press coverage can create but also 

the effect it can have on children and youth, such as 

an increase in anxiety levels or substance abuse. Governments, he said, can provide “education, guidance, 

and technical assistance to help schools better understand the best practices around media engagement 

following a school crisis to both gather information, 

disseminate verified facts, and connect with members 

of the school community.”13

Dr. Jennifer Johnston, Assistant Professor, Psychology, 

Western New Mexico University, shared with the Commission that the Parkland shooting had a contagion 

effect as far as the Los Angeles Unified School District, 

which had 63 threats that required investigation.14

Johnston also noted that some in the media have 

adopted the “Don’t Name Them, Don’t Show Them” 

(similar to “No Notoriety”15) voluntary policy in an 

effort to reduce the appeal of mass shootings by those 

who may be susceptible to external influence. Started 

in response to the Aurora, CO, movie theater shootings 

in 2012, the “No Notoriety” campaign emphasizes that 

media outlets should not use names or display photos 

of killers.

The Society of Professional Journalists’ Code of Ethics 

suggests a “heightened sensitivity” when it comes to 

the coverage of crime victims and families. It recommends that journalists “balance the public’s need for 

information against potential harm.”16 Survivors of the 

Parkland shooting have encouraged more journalists 

to adhere to this code.17

“significant evidence that mass killings 

involving firearms are incented by similar 

events in the immediate past.”
Federal Commission on School Safety: Prevent 61

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. The White House and all federal departments and agencies should adopt the principles of the “No 

Notoriety” campaign. This helps keep the focus on the facts and the victims and does not mention 

the names or publish photos of perpetrators once they are apprehended.

¤ STATES & LOCAL COMMUNITIES

1. State, local, and school leaders play a critical role in developing any crisis preparedness, response, 

and recovery plan. They should include a media plan as well. Those who have already done so 

should continually review and revise their plans.18

The media portion of these plans can cover a number of issues, including:

• who will talk to the press after a tragedy, 

• what information should be released (including considerations for the level of detail, existing 

safety measures, and details about any forthcoming notifications to families), 

• how to communicate through a variety of media vehicles (e.g., press conference, press release, 

social media), and 

• when designated individuals should talk to the media, including if families should be contacted 

first and when media are permitted to enter school grounds. 

2. As they examine their media plans, schools should coordinate with local law enforcement and other 

community leaders on a regular basis to ensure consistent messaging and clear lines of authority. 

States and local communities can take advantage of support that the U.S. Department of Education’s 

Office of Safe and Healthy Students administers from the Readiness and Emergency Management 

for Schools (REMS) Technical Assistance Center. It provides some tools that school districts can use 

to assess the safety, security, accessibility, and emergency preparedness of school buildings and 

grounds. The Center also offers tips to help guide school officials in preparing, developing, and ultimately implementing high-quality school emergency operations plans along with other actionable 

resources. The Center’s website (https://rems.ed.gov/) is updated frequently.

3. National and local media outlets should consider adopting the “No Notoriety” campaign. State and 

local authorities should consider employing the principles of “No Notoriety” when communicating 

the facts of a school safety incident to media outlets. 
62 Federal Commission on School Safety: Prevent

Chapter 6 Endnotes

1 Rosenberg, E. (March 29, 2018). The Parkland shooting suspect has 

fans, and they’re sending him letters and money. Retrieved from 

Washington Post: https://www.washingtonpost.com/news/post-nation/

wp/2018/03/28/the-parkland-shooter-has-fans-and-theyre-sendinghim-letters-and-money/?utm_term=.0f4a282519e7.

2 Rosenberg, E. (March 29, 2018). The Parkland shooting suspect has 

fans, and they’re sending him letters and money. Retrieved from 

Washington Post: https://www.washingtonpost.com/news/post-nation/

wp/2018/03/28/the-parkland-shooter-has-fans-and-theyre-sendinghim-letters-and-money/?utm_term=.0f4a282519e7.

3 Olmeda, R. (May 3, 2018). Parkland shooter Nikolas Cruz brags on 

cellphone videos, “I’m going to be the next school shooter.” Retrieved 

from Washington Post: http://www.sun-sentinel.com/local/broward/

parkland/florida-school-shooting/fl-reg-florida-school-shooting-phonevideo-release-20180530-story.html.

4 Lankford, A. (2014). Précis of the myth of martyrdom: What really drives 

suicide bombers, rampage shooters, and other self-destructive killers. 

Behavioral and Brain Sciences, 37(04), 351–362.

Hoffmann, J., Meloy, J.R., & Sheridan, L. (2013). Contemporary research 

on stalking, threatening, and attacking public figures. International 

Handbook of Threat Assessment, 160–177.

5 Schildkraut, J., & McHale, R. (2018, February). Covering rampage: News 

consumers’ perceptions about mass shootings in the media. Paper presented at the meeting of the Academy of Criminal Justice Sciences, New 

Orleans, LA as referenced in Lankford, A., & Madfis, E. (2018). Media coverage of mass killers: Content, consequences, and solutions. American 

Behavioral Scientist, DOI: https://doi.org/10.1177/0002764218763476.

6 Lankford, A., & Madfis, E. (2018). Media coverage of mass killers: Content, consequences, and solutions. American Behavioral Scientist, DOI: 

https://doi.org/10.1177/0002764218763476. For additional information 

on the emergence of this concept, refer to the following: Phillips, D.P. 

(1983). The impact of mass media violence on US homicides. American 

Sociological Review, 48(4), 560–568.

7 James, M. (May 30, 2018). Parkland’s Nikolas Cruz made chilling videos 

before shooting: “You’re all going to die.” Retrieved from USA Today: 

https://www.usatoday.com/story/news/2018/05/30/parkland-killer-video-im-going-next-school-shooter/657774002/.

8 Anderson, M., & Jiang, J. (May 31, 2018). Teens, social media & technology 2018. Retrieved from Pew Research Center: http://www.pewinternet.org/2018/05/31/teens-social-media-technology-2018/.

9 American Psychological Association. (August 4, 2016). “Media contagion” is factor in mass shootings, study says. Retrieved from http://

www.apa.org/news/press/releases/2016/08/media-contagion.aspx.

10 Towers, S., Gomez-Lievano, A., Khan, M., Mubayi, A., & Castillo-Chavez, 

C. (July 2, 2015). Contagion in mass killings and school shootings. PLoS 

ONE, 10(7): e0117259. Retrieved from https://doi.org/10.1371/journal.

pone.0117259.

11 https://www.ncbi.nlm.nih.gov/pubmed/26135941. 

12 Arizona State University. (October 5, 2015). Q&A: Sherry Towers on the 

contagion effect of mass shootings. Retrieved from https://asunow.asu.

edu/20151005-contagion-effect-mass-shootings.

13 Statement from Ben Fernandez to the Federal Commission on School 

Safety (June 21, 2018). https://www.ed.gov/news/press-releases/

readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety; and Ben 

Fernandez’s recommended guidance doc Responsible media coverage of 

crisis events impacting children and youth. https://www.nasponline.org/

about-school-psychology/media-room/press-releases/responsible-media-coverage-of-crisis-events-impacting-children-and-youth.

14 Jennifer Johnston, Ph.D., statement to the Federal Commission on 

School Safety (June 21, 2018). https://www.ed.gov/news/press-releases/readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety.

15 https://nonotoriety.com/. 

16 Jennifer Johnston, Ph.D., statement to the Federal Commission on 

School Safety (June 21, 2018). https://www.ed.gov/news/press-releases/readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety.

Society of Professional Journalists. (September 6, 2014). SPJ code of 

ethics. Retrieved from https://www.spj.org/ethicscode.asp. 

17 Jennifer Johnston, Ph.D., statement to the Federal Commission on 

School Safety (June 21, 2018). https://www.ed.gov/news/press-releases/readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety.

18 The following source makes a similar suggestion that the Commission is 

recommending: Musu-Gillette, L., Zhang, A., Wang, K., Zhang, J., Kemp, 

J., Diliberti, M., & Oudekerk, B.A. (2018). Also, Indicators of School Crime 

and Safety (2017) (NCES 2018-036/NCJ 251413). National Center for 

Education Statistics, U.S. Department of Education, and Bureau of Justice Statistics, Office of Justice Programs, U.S. Department of Justice. 

Washington, DC. Retrieved from https://nces.ed.gov/pubs2018/2018036.

pdf.
Federal Commission on School Safety: Prevent 63

CHAPTER 7

Violent Entertainment and Rating Systems

Children have 24/7 access to multiple forms of entertainment at their fingertips. Their exposure to violent 

entertainment is of particular concern—in television, 

video games, social media, music, movies, graphic 

novels, and books. Violent content is ubiquitous 

across these platforms and continues to grow.1

Neighbors of the alleged Parkland shooter, for 

instance, told reporters that he often played violent 

video games for up to 15 hours a day. According to 

one, “It was kill, kill, blow up something, and kill some 

more, all day.”2

The Bush Administration did not directly address 

this issue in its 2007 Report to the President on Issues 

Raised by the Virginia Tech Tragedy. Following Sandy 

Hook, the Obama Administration’s Now is the Time

report called on Congress to provide, among other 

things, $10 million for the Centers for Disease Control 

and Prevention (CDC) to conduct further research 

on the relationship between video games, media 

images, and violence.3 President Obama also issued 

a presidential memorandum that directed the CDC 

to research the causes and prevention of violence, 

including links between violent entertainment and 

aggression.4

Commission Observations

It is estimated that depictions of violence are present 

in 90 percent of movies, 68 percent of video games, 

60 percent of television shows, and 15 percent of 

music videos.5 While no single factor causes someone 

to engage in an act of violence, some scholars argue 

that children who regularly consume violent images 

are more prone to social isolation and aggressive 

behavior.6

Dr. Rowell Huesmann, Professor of Psychology at the 

University of Michigan, explained to the Commission 

that exposure to violence creates “violent behavior 

scripts” that are a predisposing factor in a child’s 

developing mind. When behavior scripts are activated 

under certain environmental conditions, they could 

lead to a child acting aggressively and violently.7

In addition, research has found a relationship between 

the amount of time children spend viewing violent 

entertainment and the amount of time they spend 

with friends. One correlational study found that children who view more violent programs spend less time 

interacting with other children, which could be an 

indicator for social isolation.8

Others argue that exposure to media violence is not 

predictive of violent actions. Some studies show that 

violent entertainment can help to reduce violent 

behavior,9 and their authors contend that most studies in this area find only weak correlational results and 

not causal results of the potentially negative effects 

of violent entertainment. Dr. Christopher Ferguson, 

a Professor of Psychology at Stetson University, 

reported to the Commission that studies that purport 

to link video games and violence are often not replicable. Because research on the negative effects of 

violent entertainment has produced mixed results, 

he believes debate about the possible role of violent 

entertainment after a mass shooting is a distraction 

from other factors.10

Even though scholars and researchers disagree about 

the effect of exposure to violent entertainment, some 

advocate that rating systems can play an important 

role in informing parents about what their children are 

watching and playing. 

A landmark Supreme Court case, Brown v. Entertainment Merchants Association, established video games 

as protected speech under the First Amendment.11

As a result, the entertainment industry continues to 

✔ FAST FACTS

It is estimated that depictions of violence are 

present in 90 percent of movies, 68 percent of video 

games, 60 percent of television shows, and 15 

percent of music videos.
64 Federal Commission on School Safety: Prevent

establish voluntary rating systems in the United States 

for motion pictures, software, television programs, 

and music. 

A variety of rating systems exist to inform the public 

of entertainment content. The Motion Picture Association of America (MPAA) film rating system was 

established in 1968 to provide “parents, guardians, 

and teachers the tools they need to make informed 

decisions about what children watch.”12 Ratings are 

determined by the Classification and Ratings Administration (CARA), an independent division of the MPAA, 

via a board comprised of an independent group of 

parents.13 In addition to film ratings, CARA provides 

parent resources such as movie reviews and online 

sources for movie information. 

Some criticize the MPAA rating system for not providing enough information for parents and viewers 

beyond the simple designation of movies into the categories “G,” “PG,” “PG-13,” and “R.” Additionally, some 

say the overuse of the “PG-13” rating has resulted in 

confusion regarding what kind of content is actually 

included in these movies.14

The television industry designed the TV Parental 

Guidelines ratings system to give parents more information about the content and age-appropriateness 

of television programs.15 The TV Parental Guidelines 

Monitoring Board is responsible for ensuring uniformity and consistency in applying the Guidelines. It is 

comprised of experts from the television industry and 

public interest advocates. 

With respect to music, the Recording Industry Association of America and its member companies created 

the Parental Advisory Label (PAL) program to help 

parents determine what may be inappropriate for 

children.16 This rating system helps parents recognize 

music releases containing explicit lyrics, including 

explicit depictions of violence and sex.17

The Entertainment Software Ratings Board (ESRB) 

provides guidance about video games and applications to help consumers make informed choices about 

what is suitable for their families. As the video game 

industry’s self-regulatory body, the ESRB is responsible for enforcing its rating system. It requires complete 

disclosure of content during the rating process and 

proper display of rating information on packaging 

and wherever the game is marketed or sold. This is to 

comply with “industry-adopted advertising and marketing guidelines intended to ensure that video games 

are not marketed to audiences for whom they are not 

intended.”18

According to a 2016 survey, 86 percent of parents with 

children who play video games know about the ESRB’s 

rating system, and 73 percent say they check a computer or video game’s rating before buying it for their 

children.19 The ESRB rating system has gained high 

levels of trust among parents, who regularly report 

being satisfied with the level of information as they 

choose which games to select for children.

Considerations for parents

Parents are best positioned to determine which forms 

of entertainment are appropriate for their children. 

While rating systems can be helpful tools, they are not 

a substitute for conversations with children about the 

content children consume. Parents can consider having direct discussions with their children about such 

common things as:

• Movies and television programs their children are 

watching;

• Video games and apps their children are playing or 

using;

• Music their children are listening to;

• Standards the family has set regarding what is 

appropriate; and,

• Limits and rules on what can be watched and 

played.

In addition to rating systems, parents can consider 

other resources to better understand what entertainment media may be appropriate for their children. 

For example, Common Sense Media is a source for 

users to search for specific movies, books, television 

shows, games, applications, and websites by a range 

of considerations, including age appropriateness. The 

site includes user reviews from both the parent’s and 

the child’s perspective.20

Another resource is the Parents’ Choice Foundation, 

which provides information about children’s media 

and toys through its Parents’ Choice Awards. Awards 

focus on design and function, learning value, longterm play value, and the benefits to a child’s social 

and emotional growth and well-being. Products that 

contain violent content are not eligible for awards.21
Federal Commission on School Safety: Prevent 65

The Federal Trade Commission’s website includes 

a page on Consumer Information on Kids, Parents, 

and Video Games provides guidance for parents on 

how they may talk to their kids about entertainment 

choices. It also provides information and resources for 

parents regarding video game ratings, mobile game 

apps, and web-based games.22

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¤ STATES & LOCAL COMMUNITIES

1. State education agencies (SEAs) and local educational agencies (LEAs) should ensure adequate 

internet safety measures are in place to curb access to potentially inappropriate content. For example, the Narragansett School System in Rhode Island made rigorous filtering decisions to prevent 

students from accessing inappropriate content.23

2. School and district leaders should partner with parents in an effort to strengthen internet safety 

measures at schools. For example, parents in the Boulder Valley school district in Colorado 

requested that the district block social media sites at middle schools and provide parents with a log 

of their child’s internet activity.24

3. While some self-regulators provide easy-to-understand rating systems and effectively restrict content through retailer requirements, all of them should review and improve policies to ensure access 

to content is limited to age-appropriate consumers. 
66 Federal Commission on School Safety: Prevent

Chapter 7 Endnotes

1 Gildemeister, C. Protecting children or protecting Hollywood? A twenty-year examination of the effectiveness of the TV content ratings system. 

Retrieved from Parent Television Council. http://w2.parentstv.org/

MediaFiles/PDF/Studies/2016RRStudy.pdf. 

2 Brown, J.K. (February 17, 2018). To longtime friend, school shooter 

Nikolas Cruz was lonely, volatile, ostracized. Retrieved from Miami Herald. https://www.miamiherald.com/news/local/community/broward/

article200754714.html.

3 Obama Administration. (2013). Now is the time. Retrieved from https://

obamawhitehouse.archives.gov/issues/preventing-gun-violence.

4 Obama Administration. (2013). Presidential memorandum—Engaging 

in public health research on the causes and prevention of gun violence. 

Retrieved from https://obamawhitehouse.archives.gov/the-press-office/2013/01/16/presidential-memorandum-engaging-public-health-research-causes-and-preve.

5 Wilson, B.J. (2008). Media violence and aggression in youth. In Calvert, 

S., & Wilson, B. (Eds.). The handbook of children, media, and development. West Sussex, UK: Blackwell.

6 Anderson, C.A., Berkowitz, L., Donnerstein E., et al. (2003). The influence 

of media violence on youth. Psychol Sci Public Interest, 4 (3):81–110; and 

Bickham, D.S., & Rich, M. (2006). Is television viewing associated with 

social isolation? Roles of exposure time, viewing context, and violent 

content. Arch Pediatr Adolesc Med., 160(4):387–392. DOI:10.1001/archpedi.160.4.387.

7 Statement of Rowell Huesmann to the Federal Commission on School 

Safety (June 21, 2018). https://www.ed.gov/news/press-releases/

readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety.

8 Bickham, D.S., & Rich, M. (2006). Is television viewing associated with 

social isolation? Roles of exposure time, viewing context, and violent 

content. Arch Pediatr Adolesc Med., 160(4):387–392. DOI:10.1001/archpedi.160.4.387.

9 Markey, P.M., Markey, C.N., French, J.E., Kaufman, J.C., Broder Sumerson, J., & Ferguson, C. (2015). Violent video games and real-world 

violence: Rhetoric versus data. Psychology of Popular Media Culture, 

4(4), 277–295.

10 Statement of Christopher Ferguson to the Federal Commission on 

School Safety (June 21, 2018). https://www.ed.gov/news/press-releases/readout-commission-meeting-how-entertainment-media-cyberbullying-and-social-media-may-affect-violence-student-safety.

11 564 U.S.786 (2011).

12 https://www.mpaa.org/

13 The Classification & Rating Administration (CARA). Filmratings.com. 

Retrieved from https://filmratings.com/. 

14 Goldberg, M. (November 16, 2015). “Suicide squad’s” PG-13 shows why 

we need a new MPAA rating. Retrieved from Collider: http://collider.com/

suicide-squad-movie-rating-mpaa/.

15 TV Parental Guidelines. Retrieved from http://www.tvguidelines.org/.

16 https://www.riaa.com/resources-learning/parental-advisory-label/.

17 Federal Trade Commission. (March 25, 2013). FTC undercover shopper 

survey on entertainment ratings enforcement finds compliance highest 

among video game sellers and movie theaters. Retrieved from https://

www.ftc.gov/news-events/press-releases/2013/03/ftc-undercover-shopper-survey-entertainment-ratings-enforcement. 

18 Entertainment Software Rating Board. Frequently asked questions. 

Retrieved from http://www.esrb.org/ratings/faq.aspx#18. 

19 Entertainment Software Rating Board. Frequently asked questions. 

Retrieved from http://www.esrb.org/ratings/faq.aspx#18.

20 Common Sense Media. Retrieved from www.commonsensemedia.org.

21 Parents’ Choice: Children’s Media & Toy Reviews. Retrieved from www.

parentschoice.org.

22 Federal Trade Commission. Kids, parents, and video games. Retrieved 

from https://www.consumer.ftc.gov/articles/0270-kids-parents-and-video-games.

23 Jackson, N.M. (January 19, 2018). 5 key considerations for regulating 

web traffic to ensure safety and save bandwidth. Retrieved from District 

Administration. https://www.districtadministration.com/article/digital-gatekeepers-k12.

24 Bounds, A. (May 15, 2018). Boulder Valley school board talks technology, 

internet filtering at work session. Retrieved from Daily Camera: http://

www.dailycamera.com/boulder-county-schools/ci_31880207/boulder-valley-school-board-talks-technology-internet-filtering\
Federal Commission on School Safety: Prevent 67

CHAPTER 8

The Obama Administration’s 

“Rethink School Discipline” Guidance

Teachers are often best positioned to identify and 

address disorderly conduct at school. They have an 

understanding of the students entrusted to their care 

and can see behavioral patterns on an ongoing basis. 

In partnership with principals and other school leaders, teachers can help correct—and where necessary, 

discipline—those behaviors that are unwelcome or 

unsafe for the school community. Maintaining order 

in schools is a key to keeping schools safe. Federal 

policies that adversely impact maintaining order in 

schools should be corrected.

Policy guidance issued under the Obama Administration placed an emphasis on tracking school disciplinary actions by race. That guidance, set forth 

largely in a Dear Colleague Letter and other sub-regulatory documents (hereinafter collectively “Guidance”), suggests that even facially neutral school 

discipline policies may violate federal law if they have 

a “disparate impact” upon members of certain racial 

groups in rates of suspension, expulsion, or referral 

to law enforcement.1 The Guidance further communicates that such outcomes could give rise to an investigation by the U.S. Department of Education, putting a 

school at risk of losing federal funds. 

As written and implemented, the Guidance has been 

criticized on three primary grounds. First, it creates a 

chilling effect on classroom teachers’ and administrators’ use of discipline by improperly imposing, through 

the threat of investigation and potential loss of federal 

funding, a forceful federal role in what is inherently a 

local issue. Second, authorities, including the United 

States Supreme Court,2 have questioned the applicability of a disparate impact legal theory to Title VI 

of the Civil Rights Act of 1964, upon which the Guidance relies, thus calling into question its legal basis 

in the school discipline context.3 Third, the threat 

of investigations by the Office for Civil Rights (OCR) 

under sub-regulatory documents such as the “Rethink 

School Discipline” Guidance has likely had a strong, 

negative impact on school discipline and safety.4

This Administration is committed to ensuring that 

educational programs and policies are administered 

in a fair, equitable, and racially neutral manner that 

does not result in unlawful discrimination. When 

there is evidence beyond a mere statistical disparity 

that educational programs and policies may violate the federal prohibition on racial discrimination, 

this Administration will act swiftly and decisively to 

investigate and remedy any discrimination. At the 

same time, the federal government must also ensure 

that its policies and actions protect student safety, 

including when it is acting to ensure that educational 

programs and policies are administered in a racially 

neutral fashion. Where well-meaning but flawed policies endanger student safety, they must be changed. 

As President Trump noted when creating this Commission, “[e]very child deserves to grow up in a safe 

community surrounded by a loving family and to have 

a future filled with opportunity and with hope.”5

The Guidance sent the unfortunate message that the 

federal government, rather than teachers and local 

administrators, best handles school discipline. As a 

result, fearful of potential investigations, some school 
68 Federal Commission on School Safety: Prevent

districts may have driven their discipline policies and 

practices more by numbers than by teacher input. 

School discipline is a complex issue that is affected by 

local circumstances. For example, there may be other 

reasons for disparities in behavior if students come 

from distressed communities and face significant 

trauma. Local solutions are best suited for dealing 

with the unique needs of local communities. 

Commission Observations

The Departments of Justice and Education held a 

summit on school discipline in April 2018. Numerous 

educators, parents, and experts shared their experiences. Some favored preserving the Guidance to 

reinforce the message that discrimination based on 

race, nationality, or ethnicity is unacceptable. Others 

stressed the importance of preserving specific portions of the Guidance designed to reduce exclusionary discipline (i.e., discipline that results in students 

spending time away from the classroom), such as the 

Positive Behavioral Interventions and Supports (PBIS) 

program discussed in Chapter 1. These individuals 

argued that exclusionary discipline practices have 

negative outcomes that fall disproportionately on 

certain demographic groups. 

Others spoke against the Guidance, arguing that it is 

legally flawed and poses severe unintended consequences for school safety. These speakers described 

how their schools ignored or covered up—rather than 

disciplined—student misconduct in order to avoid any 

purported racial disparity in discipline numbers that 

might catch the eye of the federal government. They 

also argued that some alternative discipline policies 

encouraged by the Guidance contributed to incidents 

of school violence, including the rape of an elementary school student with a disability, the stabbing 

of one student by another student, and numerous 

assaults of teachers by students.

At the July 26 Commission meeting, school experts 

testified about the need for more local flexibility in 

handling student discipline and that the Guidance 

endangers school safety. These experts noted that disciplinary policy is most effectively addressed at a local 

level and that federal intervention in day-to-day disciplinary matters undermines local decision-making. 

Francisco Negron, General Counsel for the National 

School Boards Association, argued that discipline is a 

matter on which classroom teachers and local school 

leaders deserve both autonomy and deference.6

Judy Kidd, the President of the Classroom Teachers 

Association of North Carolina, stressed that the fear 

of an investigation by OCR has a negative effect on 

school climate and discipline. Specifically, she stated 

that the prospect of OCR intervention makes school 

staff less likely to refer matters to law enforcement. 

Instead of focusing on safety concerns and creating a 

climate conducive to learning in the classroom, Kidd 

noted that, in response to the Guidance, some school 

leaders have chosen to avoid potential OCR investigations by eliminating the use of out-of-school suspensions and expulsions, without considering the adverse 

impact that such practices have on school safety.7

When school leaders focus on aggregate school discipline numbers rather than the specific circumstances 

and conduct that underlie each matter, schools 

become less safe. A report of the AASA, The School 

Superintendents Association specifically discussed the 

safety issues that arise when schools are compelled to 

keep students in the classroom under circumstances 

where removal may be warranted. Salient comments 

from the survey underlying the report include:

Comments from 2018 AASA Discipline Survey

• “Students who are allowed to stay in school after 

gross offenses amp up their behavior in order to 

see how much they’ll get away with without 

consequence.”

• “There is a feeling that by keeping some students 

in school, we are risking the safety of students.”

• “Without proper additional staffing and facilities 

to keep these students in school, staff do experience a perceived (sometimes real) safety concern.”

• “Schools are not equipped to provide supports 

to mentally or emotionally unstable children. We 

need help.”

• “We have received numerous complaints from 

parents and staff about students who should not 

be in school based on their disciplinary records.”

• “We see victims of bullying and harassment tend 

to miss more days of school and are more likely 

to leave the district when the perpetrators are not 

removed from school.”8
Federal Commission on School Safety: Prevent 69

school when teachers turn a blind eye to misbehavior 

by disruptive or violent students in the interest of 

avoiding running afoul of federal investigators.12

Surveys of teachers confirm that the Guidance’s chilling effect on school discipline—and, in particular, on 

the use of exclusionary discipline—has forced teachers 

to reduce discipline to non-exclusionary methods, 

even where such methods are inadequate or inappropriate to the student misconduct, with significant 

consequences for student and teacher safety. Indeed, 

while research indicates that exclusionary discipline 

practices are associated with negative academic 

outcomes13 and increased behavioral problems,14

some teachers have reported challenges with relying 

on non-exclusionary discipline practices. In Santa Ana, 

CA, 65 percent of teachers stated that non-exclusionary practices were not effective. Similarly, in Hillsborough, FL, 65 percent of teachers reported that non-exclusionary practices failed to improve school climate. 

In Madison, WI, only 13 percent of teachers reported 

that non-exclusionary practices had a positive effect 

on student behavior.15 In Charleston, SC, only 13 

percent of teachers thought the school district’s 

“new discipline system works, that the consequences 

are appropriate, and that it represents an improved 

approach.”16 

As one teacher observed, 

[P]olicymakers have made it so we have no 

authority. Only perceived authority. Only as 

much power as you get your kids to believe. Once 

the kid finds out he can say ‘F*** you,’ flip over a 

table, and he won’t get suspended, that’s that.17

Accounts of similar teacher experiences have been 

reported across the country.18 And while alternatives 

to exclusionary discipline may be appropriate in many 

cases, it is important for teachers and schools to have 

the flexibility they need to impose appropriate discipline and maintain order in the classroom.

Separately, the Commission reviewed the Texas 

School and Firearm Safety Action Plan. That Plan 

notes that, when the individual disciplinary decisions 

of teachers are frequently questioned, teachers may 

pull back on removing potentially dangerous students 

from class. Not surprisingly, the Plan also showed that 

students in classes with disruptive students were less 

likely to learn.19

During an August 28, 2018, Commission listening 

session, Jonathan Butcher, the Senior Policy Analyst 

at the Heritage Foundation’s Center for Education Policy, shared similar sentiments, emphasizing that the 

Guidance extends beyond the appropriate role for the 

federal government on school safety.9 Instead, Butcher 

advocated “school-specific, targeted responses” 

created at the local level and cautioned that districts 

do not interpret the Guidance “simply as a suggestion.” Rather, he stated that districts respond to the 

Guidance in whatever manner is most likely to avoid a 

lawsuit or federal investigation. In other words, avoiding legal jeopardy rather than achieving school safety 

drives decision-making.

Those who spoke in support of the Guidance focused 

on reducing the racial disparities in the discipline 

numbers without addressing the adverse consequences of the Guidance on school safety and climate.10 No speaker took the position, for instance, 

that the Guidance protected schools and teachers 

from violent acts. Some speakers promoted PBIS 

and similar policies as innovative, evidence-based 

reforms that both reduce exclusionary practices and 

improve school safety. However, no speaker claimed 

that schools need a federal mandate to adopt those 

policies, nor did any identify how repeal of the Guidance would prevent states and local school districts 

from adopting such policies. The Commission encourages schools and localities to implement programs 

that work best for them as noted in Chapter 1 of this 

Report on Character Development and a Culture of 

Connectedness. 

In addition to the information provided by experts at 

Commission meetings, field visits, and listening sessions, materials considered by the Commission confirm the same troubling pattern noted by critics of the 

Guidance. For example, Gail Heriot, a University of San 

Diego law professor who also serves on the U.S. Commission on Civil Rights, captured how some teachers 

are caught in the unfortunate web of the Guidance.11

She noted that school administrators are naturally 

concerned about scrutiny that may occur if students 

are disciplined at racially disparate numbers. That 

concern, she notes, can lead to school administrators 

closely scrutinizing individual teachers’ disciplinary 

practices for real or imagined evidence of racial bias, 

while ignoring the underlying causes of student misbehavior. Heriot noted that students are less safe at 
70 Federal Commission on School Safety: Prevent

Research clearly indicates that the failure of 

schools to appropriately discipline disruptive 

students has consequences for overall student 

achievement.

Research also supports the Texas findings, clearly 

indicating that the failure of schools to appropriately 

discipline disruptive students has consequences for 

overall student achievement.20 For instance, research 

conducted by Scott Carrell of the University of California, Davis and Mark Hoekstra of Texas A&M University 

found as follows:

[D]isruptive students have statistically significant 

negative effects on the reading and math scores 

of students in their class. [Carrell and Hoekstra] 

also found that the presence of a disruptive 

student increases the probability that his classmates will commit a disciplinary infraction, 

with the largest behavioral effect observed in 

boys from low-income families. Thus, disruptive 

students can create a domino effect, increasing 

misbehavior and lowering academic achievement across the school.21

This domino effect can be seen, for example, in 

Wisconsin, where schools that adopted “non-punitive disciplinary measures” may have experienced 

lower reading and math scores than schools that 

maintained a traditional approach to discipline.22 In 

another study, University of Georgia professor Joshua 

Kinsler used data to simulate the interaction between 

school discipline policies and student achievement. 

His simulation found that a policy aimed at decreasing the racial discipline gap were associated with 

increases in the racial achievement gap, because the 

retention of disruptive students negatively impacted 

the achievement of African-American students as 

a whole.23

There are also concerns about the underlying premise 

that African-American students are overrepresented 

in disciplinary matters due to racial discrimination. 

Research indicates that disparities in discipline that 

fall along racial lines may be due to societal factors 

other than race. For example, using data from the 

Early Childhood Longitudinal Study, Kindergarten 

Class (ECLS-K), researchers replicated the racial gap 

in student suspensions, but then analyzed the specific circumstances underlying these suspensions and 

discovered that “the racial gap in suspensions was 

completely accounted for by a measure of the prior 

problem behavior24 of the student—a finding never 

before reported in the literature.”25 The report concluded that “[t]hese findings highlight the importance 

of early problem behaviors and suggest that the use 

of suspensions by teachers and administrators may 

not have been as racially biased as some scholars 

have argued.”26 This research undermines the core 

proposition in disparate impact theory that statistical 

disparities necessarily demonstrate that classroom 

teachers and administrators are motivated by race 

when disciplining students.27 

Legal concerns about the current Guidance

The Guidance relies on a disparate impact legal 

theory, but that theory lacks foundation in applicable 

law and may lead schools to adopt racial quotas or 

proportionality requirements. 

A school’s general duty to treat all students equally is 

enshrined into law by the Equal Protection Clause of 

the Fourteenth Amendment of the U.S. Constitution 

and Title VI of the Civil Rights Act of 1964.28 Title VI 

protects all students who attend institutions receiving 

federal funding from being treated differently based 

on their race, color, or national origin. That protection 

extends to the entire course of the school disciplinary 

process, from behavior management in the classroom, to referral to an authority outside the classroom 

because of misconduct, and to resolution of a discipline incident.

The Guidance relies, however, on principles that are 

not enshrined in Title VI. Instead, it relies upon an 

implementing regulation of questionable validity 

to argue that Title VI prohibits not only intentional 

discrimination, but also many evenhandedly implemented policies that may nevertheless have a racially 

disparate impact.29 That reading of Title VI is dubious, 

at best. 

In 1978, the Supreme Court determined that Congress 

intended Title VI to prohibit “only those racial classifications that would violate the Equal Protection 

Clause” if committed by a government actor.30 Just 

prior to this holding, the Supreme Court also held that 

the Equal Protection Clause requires proof of intentional discrimination and that disproportionate or disparate impact alone does not constitute a violation.31 
Federal Commission on School Safety: Prevent 71

In 2001, the Supreme Court went further, noting that 

interpreting Title VI’s implementing regulations to 

cover unintentional discrimination is in “considerable tension” with the fact that the Title VI statute 

itself “prohibits only intentional discrimination.”32

It also called “strange” the argument that executive agencies—like the Department of Justice or the 

Department of Education—would have the authority 

to adopt regulations that would prohibit a disparate 

impact on members of a specific racial group absent 

any evidence of intentional discrimination.

Despite the Supreme Court’s case law in this area, the 

Guidance opted to interpret Title VI’s implementing 

regulation as sufficient to establish a disparate impact 

theory for certain racial groups in the discipline area. 

Indeed, the Guidance told schools that even “neutral,” 

“evenhanded” application of school discipline policies—the administration of policies without racial animus or discriminatory intent—can potentially violate 

this regulation.33

By telling schools that they were subject to investigation, and threatening to cut federal funding because 

of different suspension rates for members of different 

racial groups, the Guidance gave schools a perverse 

incentive to make discipline rates proportional to 

enrollment figures, regardless of the appropriateness 

of discipline for any specific instance of misconduct. 

In response to OCR investigations involving school 

data, some school districts reportedly adopted racial 

quotas in school suspensions.34 Others entered into 

settlements with OCR that could be interpreted as 

imposing racial proportionality requirements in 

school discipline data.35

Although the Guidance did not expressly require any 

school to impose a strict racial quota in suspensions, 

it is inappropriate for the federal government to pressure schools to establish such quotas.36 The Guidance 

presented hypothetical examples of discipline policies 

that might lead to a federal investigation, thereby 

incentivizing schools to preemptively shield themselves from federal oversight by minimizing racial 

disparities in discipline rates. Such expansive application of disparate impact theory is in tension with the 

purpose of Title VI and leads to school environments 

where discipline decisions may be based on race 

rather than student safety. 

Courts are skeptical of schools attempting to achieve 

specific racial proportions in discipline through racial 

quotas or proportionality requirements, whether 

pursued unilaterally by a school or after an agreement 

with an executive agency. For example, the U.S. Court 

of Appeals for the Seventh Circuit struck down as 

unconstitutional a rule that it said would lead to racial 

quotas in discipline, stating: 

Racial disciplinary quotas violate equity in its 

root sense. They entail either systematically over 

punishing the innocent or systematically underpunishing the guilty. They place race at war with 

justice. They teach schoolchildren an unedifying 

lesson of racial entitlements.37

The Guidance also offends basic principles of federalism and the need to preserve state and local control over education. For example, the Department of 

Education Organization Act warns the Department not 

to “exercise any direction, supervision, or control over 

the...administration...of any educational institution, 

school, or school system.”38 As the Supreme Court has 

emphasized, “public education in our Nation is committed to the control of state and local authorities,” 

which should be respected even when student dismissals reflect “subjective” policy decisions.39 Schools 

should have the flexibility to enforce disciplinary rules 

in light of their “need to be able to impose disciplinary 

sanctions for a wide range of unanticipated conduct 

disruptive of the educational process.”40 Schools 

should also receive deference as to whether their policies promote a “valid educational purpose” due to the 

“special characteristics of the school environment,” 

and these policies should not be overturned merely 

because others disagree about their “wisdom.”41

A school’s decision to alter its discipline policies, even 

if prompted by a concern over racially disproportionate data, may end up resulting in another racial group 

displaying disproportionate discipline numbers. The 

disparate impact theory implicates an extraordinary 

range of decisions, as Civil Rights Commissioner Gail 

Heriot noted by illustration to contexts outside of 

discipline:

For example, in the education context, a university that considers the Math SAT score of an 

applicant for admission gives Korean Americans 

and Chinese Americans an advantage while 
72 Federal Commission on School Safety: Prevent

disadvantaging many other racial and national 

origin groups. A college that raises its tuition has 

a disparate impact on Cajun Americans, Haitian 

Americans and Burmese Americans, all groups 

that have below-average median household 

incomes. Similarly, a high school that decides to 

invest in a basketball team rather than a baseball 

team has a disparate impact on Latinos, who, 

on average, are shorter than African Americans 

and whites and hence less likely to qualify for 

the basketball team... A university that gives 

college credit to students who can pass a foreign 

language exam has a disparate impact on Irish 

Americans, Scottish Americans and Anglo Americans, since they are unlikely to have a language 

other than English spoken in the home.42

The flawed Guidance rests on a provision whose 

validity cannot be squared with the Supreme Court’s 

holdings. 

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

The Commission is deeply troubled that the Guidance, while well-intentioned, may have paradoxically contributed to making schools less safe. Significant concerns also remain regarding the legal 

framework upon which the Guidance is based. These concerns, together with the repeated concerns 

expressed by many that disciplinary decisions are best left in the hands of classroom teachers and 

administrators, warrant rescission of the Guidance. The Commission thus makes the following recommendations:

1. The U.S. Department of Justice (DOJ) and the U.S. Department of Education (ED), should rescind the 

Guidance and its associated sub-regulatory guidance documents. ED should develop information 

for schools and school districts that will identify resources and best practices to assist schools in 

improving school climate and learning outcomes as well as in protecting the rights of students with 

disabilities during the disciplinary process while maintaining overall student safety.

2. DOJ and ED should continue to vigorously enforce Title VI of the Civil Rights Act of 1964 and provide 

appropriate information to assist schools and the public in understanding how ED will investigate 

and resolve cases of intentional discrimination. 
Federal Commission on School Safety: Prevent 73

Chapter 8 Endnotes

1 On January 8, 2014, the U.S. Department of Justice and Department of 

Education jointly issued sub-regulatory guidance (collectively referred 

to as the “Guidance”). The Guidance includes the following documents:

• A Dear Colleague Letter jointly signed by the Department of Justice 

and the Department of Education (The Dear Colleague Letter also 

included an Appendix titled “Recommendations for School Districts, 

Administrators, Teachers, and Staff”).

• A Resource Guide titled “Guiding Principles: A Resource Guide for 

Improving School Climate and Discipline”;

• Appendix 1 titled “U.S. Department of Education Directory of Federal 

School Climate and Discipline Resources”;

• Appendix 2 titled “Sample Discipline Category Profile”;

• An FAQ document titled “School Discipline Guidance Package FAQs”; 

and

• A separate document titled “Supportive School Discipline Initiative.” 

2 See Alexander v. Sandoval, 532 U.S. 275, 280, 286 n.6 (2001).

3 Wright, J.P., et al. (2014). Prior problem behavior accounts for the racial 

gap in school suspensions. Journal of Criminal Justice. https://www.

sciencedirect.com/journal/journal-of-criminal-justice/vol/42/issue/3. 

(“Our results suggest, however, that the association between school 

suspensions and blacks and whites reflects long-standing behavioral 

differences between youth and that, at least in the aggregate, the use of 

suspensions may not be as racially biased as many have argued.”)

4 As noted by the AASA, The School Superintendents Association in its 

2018 Discipline Survey, “[t]he noticeable uptick in investigations and 

compliance reviews [by the Office for Civil Rights] over the last nine 

years seems to have acted as a more powerful lever in influencing 

districts to reduce out-of-school time for students, even if teachers, 

parents, or students preferred for that specific child to be removed 

from class.” 2018 AASA discipline survey: An analysis of how the 2014 

Dear Colleague Letter on nondiscriminatory administration of school 

discipline is impacting district policies and practices, at p. 6. Retrieved 

from http://aasa.org/uploadedFiles/AASA_Blog(1)/AASASurveyDisciplineGuidance2014.pdf. The survey was administered by the AASA, The 

School Superintendents Association; the Association of School Business 

Officials International (ASBO); and the Association of Educational Services Agencies (ASEA). For purposes of this Report, they are collectively 

referenced as “AASA.”

5 Briefing Statement from President Donald J. Trump, the White House 

(March 12, 2018), available at https://www.whitehouse.gov/briefings-statements/president-donald-j-trump-taking-immediate-actions-secure-schools.

6 See transcript, at p. 19: “But ultimately decisions about student 

discipline are pedagogical. They’re matters of school concern, entitling 

school leaders to the kind of deference for their educational judgment 

which the courts have repeatedly acknowledged. So in considering 

matters of student discipline, particularly as it relates to instances 

of individual behavior, unrelated to instances of mass violence, for 

instance, the federal government should follow suit and equally defer to 

local education experts.”

7 See transcript, at pp. 28–32.

8 2018 AASA discipline survey, at pp. 4–5. http://aasa.org/uploadedFiles/

AASA_Blog(1)/AASASurveyDisciplineGuidance2014.pdf.

9 Statement from Jonathan Butcher to the Federal Commission on 

School Safety (August 28, 2018). https://www2.ed.gov/documents/

school-safety/transcript-08-28-2018.pdf.

10 Various statements during Federal Commission on School Safety 

Public Listening Sessions (June 6, 2018; June 26, 2018; August 7, 2018; 

August 28, 2018) https://www2.ed.gov/documents/school-safety/transcript-06-06-2018.pdf; https://www2.ed.gov/documents/school-safety/

transcript-08-07-2018.pdf; https://www2.ed.gov/documents/schoolsafety/transcript-08-28-2018.pdf.

11 Gail L. Heriot & Alison Somin, The Department of Education’s initiative on 

racial disparities in school discipline: Wrong for students, wrong for teachers, wrong on the law. Tex. Rev. L. & Pol., 47–48, (forthcoming 2018); San 

Diego Legal Studies Paper No. 18–321, 3. https://papers.ssrn.com/sol3/

papers.cfm?abstract_id=3104221.

12 Ibid.

13 Arcia, Emily, (May 1, 2006). Achievement and Enrollment Status of 

Suspended Students: Outcomes in a Large Multicultural School District, 

Education and Urban Society.

14 Hemphill, SA et al., (November, 2006). The effect of school suspensions 

and arrests on subsequent adolescent antisocial behavior in Australia 

and the United States. Journal of Adolescent Health.

15 Madison Teachers, Inc., (May, 2015). Joint Committee on Safety and 

Discipline Report, at p. 5. http://www.madisonteachers.org/wp-content/uploads/2015/05/Joint-Committee-on-Safety-and-Discipline-Report-051315.pdf.

16 See Charleston Teacher Alliance, 2017 Teacher Survey (2017). http://

www.charlestonteacheralliance.com/surveys.html.

17 Eden, M. (June 11, 2018). In NYC school where a teenager was killed, students and educators say lax discipline led to bullying, chaos, and death. 

The 74 Million, Investigation. Retrieved from https://www.the74million.

org/article/investigation-in-new-york-city-school-where-a-teenagerwas-killed-students-educators-say-lax-discipline-led-to-bullying-chaosand-death/.

18 See Mac Donald, H. (April 6, 2018). Who misbehaves? Claims that 

school discipline is unfairly meted out ignores actual classroom 

misbehavior. City Journal. https://www.city-journal.org/html/

who-misbehaves-15811.html. See also https://www.mprnews.org/

story/2015/12/08/police-say-brothers-attacked-school-officials,and 

Lessons not learned. (Fall 2018). Thinking Minnesota. https://www.americanexperiment.org/magazine/thinking-minnesota-issue-13-fall-2018.

19 School and firearm safety action plan. (May 30, 2018). Governor Greg 

Abbott, pp. 29–30. https://gov.texas.gov/uploads/files/press/School_

Safety_Action_Plan_05302018.pdf.

20 Eden, M. (2009). School discipline reform and disorder: Evidence from 

New York City public schools, 2012–16, Education Next 9, No. 3. (supra at 

p. 9, citing Carrell, S.E., & Hoekstra, M.L. Domino effect.).

21 Ibid.

22 Mac Donald, H. (April 6, 2018). Who misbehaves? Claims that school discipline is unfairly meted out ignores actual classroom misbehavior. City 

Journal. https://www.city-journal.org/html/who-misbehaves-15811.

html. Heather Mac Donald, the Thomas W. Smith Fellow at the Manhattan Institute, recently reported on the impact that changes to disciplinary policies have had on teachers. For example, the district attorney 

in St. Paul, Minnesota called a spike in attacks on teachers following the 

implementation of non-exclusionary practices a “public health crisis.” 

Likewise, according to Ms. Mac Donald, Charlotte, North Carolina experienced “an increase in guns, drugs, and assaults on teachers; school 

assaults in Durham increased more than 50 percent last year.” She also 

noted that “the district attorney in Syracuse forced schools to return to 

traditional disciplinary policies after a teacher was stabbed.” 

23 Josh Kinsler. (2013). School discipline: A source or salve for the racial 

achievement gap. 54 International Economic Review, 355. (“[D]iscipline 

may affect achievement positively through its effect on student 

behavior.”); see also Eden, M. (July 28, 2017). NY educrats’ plan to make 

schools less safe. New York Post (citing Kinsler, and noting that “a study 

by a University of Georgia professor found that efforts to decrease the 

racial-suspension gap actually increase the racial achievement gap”); 

accord Andrew Coulson. (January, 23, 2014). Why team Obama’s new 

education guidelines may hurt, not help, black students. Cato Institute 

(Relaxing school discipline to shrink the “racial discipline gap” and 

“causes overall student achievement to fall” and thus “African-American 

children” suffer “disproportionately.”) www.cato.org/publications/commentary/why-team-obamas-new-education-guidelines-may-hurt-nothelp-black-students (citing Kinsler).

24 Some problem behaviors could potentially be due to adverse childhood 

experiences (ACEs). See generally https://www.cdc.gov/violenceprevention/acestudy/index.html. 

25 Prior problem behavior accounts for the racial gap in school suspensions. (2014). Journal of Criminal Justice, 42, 257–266.

26 Ibid.
74 Federal Commission on School Safety: Prevent

27 Ibid., p. 257. “A close read of the available empirical literature suggests, 

however, that racial bias may not be the only factor associated with 

racial differences in school disciplinary rates. For example, research 

studies reveal that black youth, in comparison with their white counterparts, are often less prepared for school entry (Magnuson & Waldfogel, 

2005; Murnane, et al., 2006; Sadowski, 2006), are disproportionately 

involved in delinquency and crime (Earls, 1994; Hawkins, Laub, & 

Lauritsen, 1998), and are more likely to behave in ways that interfere 

with classroom and school functioning (Beaver, Wright, & DeLisi, 2011). 

These studies, and others from various disciplines, suggest that the 

school disciplinary rates may also reflect the problematic behaviors of 

black youth—problem behaviors that are imported into schools and 

into classrooms.”

28 See 42 U.S.C. § 2000d.

29 See January 8, 2014, Dear Colleague Letter on the Nondiscriminatory 

Administration of School Discipline at 11, n.21 (“Schools also violate 

Federal law when they evenhandedly implement facially neutral 

policies and practices that, although not adopted with the intent to 

discriminate, nonetheless have an unjustified effect of discriminating 

against students on the basis of race. The resulting discriminatory 

effect is commonly referred to as ‘disparate impact.’” (citing 34 C.F.R. § 

100.3(b)(2))).

30 Regents of Univ. of Cal. v. Bakke, 438 U.S. 265, 287 (1978) (Powell, J., 

announcing judgment); ibid. at 325, 328, 352 (Brennan, J., joined by 

White, Marshall, and Blackmun, J.J., concurring in part). 

31 Washington v. Davis, 426 U.S. 229, 242 (1976) (finding a violation of the 

Equal Protection Clause requires discriminatory intent, compared to 

Title VII’s statutorily enacted disparate impact standard in employment); see also Village of Arlington Heights v. Metro. Hous. Dev. Corp. 429 

U.S. 252, 265 (1979) (“Proof of racially discriminatory intent or purpose 

is required to show a violation of the Equal Protection Clause.”); 

Personnel Admin. of Mass. v. Feeney, 442 U.S. 256, 272 (1979) (“[E]ven 

if a neutral law has a disproportionately adverse effect upon a racial 

minority, it is unconstitutional under the Equal Protection Clause only if 

that impact can be traced to a discriminatory purpose.”).

32 See Alexander v. Sandoval, 532 U.S. 275, 280, 286 n.6 (2001). 

33 See January 8, 2014, Dear Colleague Letter on the Nondiscriminatory 

Administration of School Discipline at 7; ibid. at 11 n.21 (citing 34 C.F.R. 

§ 100.3(b)(2)); see ibid. at p. 18, Example 6; see also Blad, E. (April 4, 

2018). DeVos meets with supporters, critics of discipline rules as GAO 

says racial disparities persist. Education Week. (Summarizing the guidance’s interpretation of disparate impact as mandating that “If a school 

finds black students...in violation of a rule at higher rates than their 

peers, that rule must be necessary to ‘meet an important educational 

goal’”). Even in the context of disparate impact case law, some argue 

that this was an overly expansive approach to disparate impact liability, 

in focusing on bottom line disparities in discipline rates rather than 

whether specific school practices caused those disparities. Regulatory 

Transparency Project. (September 12, 2017). A review of Department 

of Education programs: Transgender issues, racial quotas in school 

discipline, and campus sexual assault mandates, at 8–9; Clegg, R. (April 

11, 2018). How the “Dear Colleague” Letter missed the point. Washington Post (Describing the “hyperaggressive approach” taken by the Dear 

Colleague Letter).

34 See Robby Soave. (November 11, 2014). Schools implement explicit 

racial bias in suspensions. Reason (Describing a Minnesota school 

system’s mandate that suspensions meet a racial “quota” by 2018, and 

that “every suspension of a black or brown student” be subject to special review and describing it as a response to an investigation by “the 

Department of Education’s Office for Civil Rights.”). (http://reason.com/

blog/2014/11/11/schools-implement-explicit-racial-bias-i); Kirsanow, 

P. (April 10, 2017). Racial quotas in school discipline. National Review. 

(“[Al]though proponents of OCR’s Letter may claim it does not compel 

the use of racial quotas, that’s precisely the outcome produced”) (www.

nationalreview.com/corner/446590/racial-quotas-school-discipline); 

Williams, W. (April 15, 2014). Discipline and justice. Richmond Times-Dispatch (African-American columnist argues that the guidance incentivizes educators to adopt a “racial quota system for student discipline,” 

citing lawyers George Leef and Roger Clegg); letter from William Perry 

Pendley, Mountain States Legal Foundation, to the Attorney General and 

Education Secretary, dated April 3, 2017 (the Dear Colleague Letter led 

to “use of race-based discipline policies by local school districts”). www.

mountainstateslegal.org/docs/default-source/default-document-library/343921223-040317-doj-doe-racial-disparity-letter.pdf.

35 See, e.g., Resolution Agreement Oklahoma City Public Schools at 

18–19, OCR Docket No. 0714119. (April 4, 2016) (Any statistical disproportionality should be “eliminated to the maximum extent possible.”).

36 See, e.g., Lutheran Church—Missouri Synod v. FCC, 141 F.3d 344, 350-352 

(D.C. Cir. 1998).

37 See People Who Care v. Rockford Bd. of Educ., 111 F.3d 528, 535–538 (7th 

Cir. 1997) (striking down lower court decree that would have required 

school district to engage in racial proportionality requirements in discipline and reasoning that even though the district was under a racial 

desegregation consent decree, there was no evidence that the district’s 

current discipline practices intentionally discriminated against students 

based on race and thus no justification for a policy that amounted to a 

racial quota). 

38 20 U.S.C. § 3403(a).

39 Board of Curators, Univ. of Missouri v. Horowitz, 435 U.S. 78, 90–91 (1978).

40 Bethel Sch. Dist. v. Fraser, 478 U.S. 675, 686 (1986).

41 Hazelwood Sch. Dist. v. Kuhlmeier, 484 U.S. 260, 273–74 (1988) (rejecting 

First Amendment challenge to principal’s decision to restrict otherwise-protected news content of school publication because the decision was “not unreasonable” and thus related to a “valid educational 

purpose”); Morse v. Frederick, 551 U.S. 393, 397 (2007) (school given 

deference as to its decision to restrict speech around school that would 

concededly be protected by the First Amendment if it occurred away 

from school); see Bd of Educ. v. Earls, 536 U.S. 822, 838 (2002) (upholding school search policy that would be unconstitutional outside the 

schools, based on rational basis for it, while expressing “no opinion as 

to its wisdom”).

42 Gail L. Heriot & Alison Somin, The Department of Education’s initiative on 

racial disparities in school discipline: Wrong for students, wrong for teachers, wrong on the law. Tex. Rev. L. & Pol., 47–48, (forthcoming 2018); San 

Diego Legal Studies Paper No. 18–321, 3. https://papers.ssrn.com/sol3/

papers.cfm?abstract_id=3104221.
Federal Commission on School Safety: Prevent 75

Every youth who appears to be “troubled” or displays 

“troubled” behavior has a unique set of risk and 

protective factors contributing to his or her behaviors. 

Risk factors can include mental health symptoms 

such as mood problems, impulsivity, anxiety, hallucinations, or other psychotic symptoms. They can 

also include environmental factors such as history of 

trauma, adverse events, poor supervision, and inappropriate coping behaviors. 

Often, these risks can exacerbate and compound one 

another. Some examples include: speech or language 

delays combined with past traumas; developmental 

and intellectual disabilities combined with being bullied; and relationship challenges with caregivers combined with substance use disorders. Protective factors 

play an important role and can be further developed. 

Among these factors are a relationship with a trusted 

adult such as a teacher or coach, an undeveloped skill 

such as art or sports, or a desire to make friends. 

The term “youth with complex mental health needs” 

more accurately reflects the complex forces resulting 

in how a “troubled youth” may present and will be 

used henceforth. The term “youth” refers to children, 

adolescents, and transition-aged youth (ages 16–25). 

Given the multifactorial nature of causes of challenging behaviors, the role of medications will depend 

on such factors as the diagnosis, the presence of 

co-occurring mental or physical diagnoses, and 

provider, youth, and family preferences. In her July 11 

testimony to the Commission, Dr. Gabrielle Carlson 

highlighted the unique features of several youth with 

complex mental health needs, stating that “treatment 

requires an accurate diagnosis and attention to the 

individual circumstances and presentation of each 

child, his or her school, and family.” 

Despite the unique needs of every youth, there are 

several overarching principles that are important to 

consider with respect to the use of psychotropic medications.1

 While a full review of the principles to consider in prescribing is beyond the scope of this report, 

the most important points are listed in the sidebar.

The categories of medications most commonly used 

for youth with mental health conditions include 

selective serotonin reuptake inhibitors (SSRIs, such as 

fluoxetine, sertraline, citalopram), stimulant medications (e.g., methylphenidate medications, mixed 

amphetamine salts), antipsychotic medications (e.g., 

aripiprazole, risperidone), post synaptic alpha2-adCHAPTER 9

The Effectiveness and Appropriateness of 

Psychotropic Medication for Treatment of Troubled Youth

Overarching principles that are important to 

consider with respect to the use of psychotropic 

medications 

1. The goal of the use of psychotropic medications for youth 

with complex mental health needs should be to provide 

safe, effective, and evidence-based prescribing in the 

context of good quality mental healthcare. 

2. Particularly for youth with complex mental health needs, 

psychotropic medications should not be prescribed as the 

sole treatment modality. They should be part of a broader 

treatment plan to include psychosocial supports, therapies, coordination across service sectors, and educational 

supports. 

3. Collaboration among providers and service systems 

(e.g., school, medical, juvenile justice, child welfare) is 

important to reduce inappropriate prescribing. 

4. Prescribing of psychotropic medications should be 

conducted by professionals with adequate training and 

expertise or in consultation with professionals with such 

expertise.

5. The conditions that allow for safe and appropriate 

prescribing of psychotropic medications include 

ongoing clinical monitoring. 

6. Informed consent is an important part of prescribing. 

Further, the more engaged and informed youth and families are about medications, the greater the likelihood that 

medications are taken as prescribed and their adverse 

effects avoided (or addressed and monitored as they 

arise). Shared decision-making approaches—where 

the family and youth are fully involved in medication 

decisions—should be employed. 
76 Federal Commission on School Safety: Prevent

renergic agonists (e.g., guanfacine), and other antidepressants (e.g., bupropion). The Food and Drug 

Administration (FDA) has approved these medications 

for specific uses in youth (e.g., fluoxetine for youth 

with major depressive disorder, fluvoxamine or sertraline for youth with obsessive compulsive disorder, 

and methylphenidate for attention deficit hyperactivity disorder, or ADHD). 

Medications are often prescribed for youth even when 

the FDA has not approved them for that specific diagnosis or age group. This is referred to as prescribing for 

an “unapproved use.” In general, healthcare professionals may prescribe or use FDA-approved drugs for 

unapproved uses when they judge it medically appropriate for their individual patients. In some cases, 

depending on the medication and its use, prescribing 

an unapproved drug may be within the standard of 

care. A common example of prescribing an FDA-approved drug for an unapproved use is prescribing a 

medication for a child that has been FDA-approved for 

use in adults for a certain condition and not separately 

studied and approved for use in children. (See Table 

9.1 for medications approved by the FDA for children 

and adolescents and for what conditions.) 

Psychotropic medications are effective for many conditions in youth. They can facilitate better outcomes, 

such as improved academic functioning, reduced 

anxiety, decreased impulsivity, and decreased symptoms of major depressive disorder. Some examples 

of these medications and some of their uses include 

methylphenidate for ADHD, sertraline for generalized 

anxiety disorder, guanfacine for ADHD, and fluoxetine 

for depression.2,3,4

When prescribed appropriately, psychotropic medications can play a lifesaving role in the lives of youth 

with complex behavioral health needs. To give several 

examples, antipsychotics for youth with schizophrenia 

can not only reduce symptoms such as hallucinations, 

but may also reduce the severity of subsequent psychotic episodes.5

 For youth with severe major depression, antidepressants can improve mood and improve 

functioning.6 In situations of severe anxiety, an SSRI 

such as fluoxetine or sertraline can enable the youth 

to engage in therapy to develop new coping skills.7

Despite evidence supporting the use of psychotropic 

medications for specific conditions, more evidence is 

needed to better understand which medications are 

helpful for various conditions in youth. 

As Dr. Mark Olfson noted in his July 11 testimony to 

the Commission, “There is compelling evidence that 

U.S. children and adolescents are undertreated with 

psychotropic medications.” For example, although 

one in nine U.S. adolescents suffers from depression, 

only around 40 percent of them receive any treatment 

and only about half of those receive an antidepressant 

medication.8 Olfson noted that even larger gaps exist 

in the treatment of anxiety and substance use problems.9

Psychotropic medications also can be associated with 

adverse effects irrespective of whether the prescriber 

is adhering to best practice guidelines. Common 

examples of adverse effects include increased restlessness or agitation with SSRIs (particularly in younger 

age groups), weight gain, associated cardio-metabolic 

effects, sedation with antipsychotics, and decreased 

appetite with stimulants. 

Concerns have been raised regarding whether SSRIs 

cause increases in suicidality in youth. Some research 

has found an elevated risk of suicidality among 

youth who were prescribed SSRIs compared to those 

receiving placebo.10 It also described potential mechanisms for this phenomenon, including activation (i.e., 

increased energy for self-harm). Other researchers 

found that lower rates of SSRI use could be associated 

with higher rates of suicide among youth.11,12 Therefore, it is important to consider this potential risk 

when prescribing SSRIs. The current standard of care 

for youth on SSRIs includes close clinical monitoring. 

There is also significant uncertainty about the longterm impact of psychotropic medications on developing brains, and more research is needed in this area. 

There is variability across the United States in how 

closely prescribers adhere to best practice guidelines, 
Federal Commission on School Safety: Prevent 77

especially for vulnerable populations like youth and 

youth with complex behavioral health needs.13 Examples of inappropriate prescribing include: prescribing 

medications without a clear diagnosis; not monitoring 

at the recommended intervals (e.g., not checking a 

glucose level if prescribing second generation antipsychotics) and/or not monitoring the recommended 

clinical parameters (e.g., not checking blood pressure 

at regular intervals if the child is on a stimulant); and 

prescribing without appropriate consideration of 

proven non-pharmacological interventions, including 

various disorder-specific psychosocial interventions. 

Deviation from best practice prescribing impacts 

certain groups of youth disproportionately, such as 

those involved in the foster care system and minority 

youth.14 There is evidence that youth who have multiservice system involvement more frequently experience polypharmacy—the concurrent use of multiple 

medications by a patient—and long-term use, even 

in the absence of psychosocial treatments.15 While 

prescribing more than one medication may be clinically indicated, polypharmacy without a full psychiatric evaluation and without proper monitoring is not 

consistent with best practice treatment.

Youth with substance use disorders (SUDs) commonly 

have co-occurring psychiatric disorders16 and are 

represented in high numbers in the juvenile justice 

population.17 The standard of care is to evaluate 

and treat co-occurring psychiatric disorders while 

also addressing the SUDs.18 In conjunction with the 

full array of services for youth with SUDs, the use of 

buprenorphine in youth is promising.19

At this time, only buprenorphine/naloxone is 

approved for individuals aged 16 and older, although 

methadone pharmacotherapy for opioid use disorder 

can be provided at specially certified opioid treatment programs where specialized interventions for 

youth are offered for those aged 16–17. Methadone 

treatment for opioid use disorder can only be undertaken with informed consent from parents (unless 

the youth has been emancipated) and the adolescent 

patient. More research is needed to determine when 

Medication-Assisted Treatment (MAT) is clinically 

indicated in youth, as well as its adverse effects and 

efficacy. MAT is currently only available for opioid, 

alcohol, and nicotine use disorders. Workforce gaps 

also limit access to MAT. 

Workforce issues for clinicians who prescribe 

psychotropic medications to youth

Pediatricians and other primary care providers prescribe the majority of psychotropic medications in the 

United States,20 but their lack of training in behavioral 

health conditions is frequently cited as a major concern.21 Clinicians who prescribe psychotropic medications to youth and adolescents include child and adolescent psychiatrists, pediatricians, advance practice 

nurses, physician assistants, family medicine physicians, and psychiatrists trained in adult psychiatry. 

In some states and in the United States Military Health 

System, psychologists who have undergone specialized training can prescribe psychiatric medication. 

Although child and adolescent psychiatrists have the 

most extensive training in behavioral health conditions, physical health, and child development, families 

often receive psychotropic medications from providers with varying degrees of training and proficiency 

in prescribing for youth with complex behavioral 

health needs. While many pediatricians do an excellent job in addressing the behavioral health needs 

of their patients, there are ongoing concerns about 

inadequate training particularly regarding youth with 

complex behavioral health needs. The reasons for the 

high rates of prescribing by primary care providers is 

multifactorial. They include stigma associated with 

going to a psychiatrist, the convenience and trust in 

seeing the pediatrician, finding a psychiatrist who 

is affordable or in-network for insurance, and, most 

importantly, the critical workforce shortage of child 

and adolescent psychiatrists. 

Appropriate treatment, particularly for youth with 

complex behavioral health needs, begins with a 

thorough psychiatric evaluation that considers their 

developmental and behavioral health history, family history, environment, physical health, behaviors, 

mood, and other factors.22 Despite the importance of 

obtaining a comprehensive psychiatric evaluation, 

many youth with complex behavioral health needs 

experience barriers to these services. 

The standard of care is to evaluate and treat 

co-occurring psychiatric disorders while also 

addressing the substance use disorders.
78 Federal Commission on School Safety: Prevent

In the majority of states, there is a critical shortage of 

child and adolescent psychiatrists. For special populations, such as youth with intellectual and developmental disability disorders, shortages of child and 

adolescent psychiatrists are even more dire. Many 

counties throughout the country have no child and 

adolescent psychiatrists at all.23 Although the number 

of adolescents in the population is expected to grow 

to 45 million by 2050,24 the pool of child and adolescent psychiatrists is aging and not increasing at the 

same rate as the youth population. Even at the current 

time, there are approximately 8,300 practicing child 

and adolescent psychiatrists in the United States and 

more than 15 million youth in need of the special 

expertise of a child and adolescent psychiatrist.25

Because of the national shortage of child and adolescent psychiatrists, families with youth in need of a 

psychiatrist often have to wait for long periods before 

they are able to be evaluated, travel long distances, 

and go without specialized care.26 Pediatricians in 

rural and other critical shortage areas are sometimes 

left struggling to manage highly complex youth without adequate training in the management of mental 

disorders. They have limited access to providers with 

experience working with youth with mental and substance use disorders. 

Commission Observations

Best practice treatment varies according to the condition under consideration, the specific situation of 

the child and family, and other factors. Best practice 

guidelines are generally established through a process 

of expert consensus and research. As Dr. Mark Olfson 

testified to the Commission, treatment must be tailored to individual needs. 

Entities involved with developing best practice guidelines vary, but may include professional organizations, 

specialists contracted by states, or academic centers. 

In the area of psychotropic prescribing for youth with 

complex mental health needs, professional organizations such as the American Academy of Child and 

Adolescent Psychiatry and the American Academy of 

Pediatrics have developed a number of best practice 

guidelines. The guidelines cover the use of psychotropic medications in youth generally and for specific 

conditions.27 It is also notable that the Canadian Institute for Health Research has supported the development of guidelines for specific types of psychotropic 

medications for youth, such as antipsychotics.28 In 

addition, a number of states have developed psychotropic medication parameters specific to vulnerable 

populations, such as youth in foster care. Indiana is 

one such state.

29

A full description of the guidelines is beyond the scope 

of this report. However, recommended components 

of appropriate prescribing frequently include an 

evaluation of the youth’s behavioral health issues and 

history, appropriate clinical and laboratory monitoring, appropriate informed consent procedures, access 

to a broader treatment plan including psychosocial 

services, and coordination with other providers and 

service systems involved with the youth. 

A particular aspect of best practice prescribing incorporates an adequate informed consent process, which 

includes engagement of youth and their caregivers 

in the decision-making process as well as education 

about the risks and benefits of medications. Another 

aspect involves expanding shared decision-making approaches. When youth and families are educated about the risks, benefits, and alternatives to 

medications and are more involved in treatment 

decision-making, youth are more likely to take medications as prescribed, be engaged in treatment, and 

Nationally, there is only about one practicing child and 

adolescent psychiatrist for every 1,800 youth in need of 

their special expertise. This imbalance is expected to 

grow in coming decades.

Figure 9-1
Federal Commission on School Safety: Prevent 79

participate in other aspects of care. Family and youth 

peer advocates can also play an important role in this 

area.30

State-wide programs supporting best practice 

prescribing

Although guidelines exist for best practice prescribing 

of psychotropic medications, inappropriate prescribing is all too common. This is particularly so for vulnerable populations. A number of states have developed 

programs to address the problem of inappropriate 

prescribing of psychotropic medications for youth, 

especially where there are shortages of providers specializing in youth behavioral health disorders. 

Among the most successful programs are those that 

are financially supported (often at the state level) and 

that have multiple components. The latter include 

resources supporting the education of providers and 

families, resources such as case management to connect youth to other psychosocial services, a process 

for review of medication regimens, and the ability for 

providers to consult with a child psychiatrist specialist. Minnesota, Washington, Ohio, and New Jersey 

have developed such programs.

One example is Ohio Minds Matter. This quality 

improvement initiative was launched by the State of 

Ohio to evaluate and improve prescribing of psychotropic medications. The initiative is a public-private 

partnership with a $1 million investment from the 

Ohio Office of Health Transformation and Department 

of Medicaid. Initiative partners include various state 

departments, health systems, providers, community 

representatives, and child and family advocates. 

The goals for the project include increasing timely 

access to safe and effective psychotropic medications 

and other treatments, improving pediatric health 

outcomes, and reducing potential adverse effects. 

A key resource created by the initiative is the Minds 

Matter Toolkit. The toolkit includes design algorithms, 

evidence-based guidelines, fact sheets, and online, 

on-demand learning modules for prescribers, parents, 

consumers, schools, and agencies.31

Telephonic consultation programs with child and 

adolescent psychiatrists 

Consultation models with child and adolescent 

psychiatrists (which can be stand-alone or part of a 

broader system) have been successful in supporting 

pediatricians and other providers to prescribe medications and refer youth to appropriate psychosocial 

supports. When such telephonic consultations are 

provided, the primary care provider remains the prescriber of psychotropic medications, unless a decision 

is made for the youth to receive a face-to-face psychiatric evaluation. 

Despite the promising nature of such consultation programs, many providers and communities nationally 

do not have access to them. Even in the approximately 

30 states that have telephonic consultation lines in 

place, the service is not available to all pediatricians 

and providers statewide.32

Access to best practice psychosocial services for 

youth with complex behavioral health needs

To address complex behavioral health issues in youth, 

the Substance Abuse and Mental Health Services 

Administration (SAMHSA) has developed, funded, 

and implemented a treatment approach called the 

systems of care framework. The framework stipulates 

care coordination across multiple systems for youth. 

Systems such as schools, behavioral health, juvenile 

justice, and social services are commonly involved in 

care coordination. 

This approach has proven a best practice, as evidenced by annual reports to Congress that review 

and analyze data from the multisite national evaluation. Data from the 2016 report, “The Comprehensive 

Community Mental Health Services for Children with 

Serious Emotional Disturbances Program,” indicate 

that youth participating in systems of care demonstrate significant:

• improvements in behavioral and emotional 

functioning;

• reductions in suicide and suicide attempts;

• reductions in unlawful activities; and

• reductions in costs due to hospitalizations 

and arrests.33

New Jersey has invested significant efforts in developing coordination across multiple systems to enhance 

its system of care. The state has demonstrated some 

promising outcomes associated with these efforts.34

Several models of care have been effective for youth 

with complex behavioral health needs, such as 

wraparound systems of care.35 Multisystemic therapy is another evidence-based model for youth with 

severe behavioral health conditions who have been 
80 Federal Commission on School Safety: Prevent

or are involved in the justice system.36 For symptoms of trauma, which are common in youth with 

behavioral health disorders, there are a number of 

evidence-based psychotherapies.37 However, psychosocial treatments are only available to a small percentage of the youth who might benefit from them.38

Models beyond traditional outpatient behavioral 

health services are described elsewhere in this report. 

These models should also be acknowledged for 

facilitating youth access to appropriate psychotropic 

medication prescribing.39

Child and adolescent psychiatrists can play a variety 

of roles within school-based mental health programs, 

both in direct service provision as well as consultation.

40,41 One example of an innovative model of integrating psychiatry into schools is the University of New 

Mexico’s Center for Rural and Community Behavioral 

Health (CRCBH). It uses telehealth technology to 

connect child and adolescent psychiatry trainees and 

faculty with youth in rural and frontier schools. In 

addition to providing care, the CRCBH model provides 

continuing education to school-based providers.

SAMHSA has considerably enhanced its approach to 

the provision of technical and training assistance (TTA) 

on addressing mental disorders, including serious 

mental illness (SMI). In FY 2019, SAMHSA will fund a 

Network of Regional TTA Centers, the Mental Health 

Technology Transfer Centers, to provide training and 

education to professionals across the country working to address the needs of those affected by mental 

disorders. The network will include specialty areas 

of focus related to treating mental disorders. Two 

population-specific centers will address the needs 

of the American Indian/Alaska Natives and Hispanic 

populations. 

The network focus will be enhanced with the addition of a specialty emphasis on school-based mental 

health in each region. Complementing this regional 

approach, the Clinical Support Services for SMI is a 

new national TTA Center. It will serve as a national 

resource on best practices for the provision of evidence-based treatment for individuals living with SMI. 

In addition to the shortage of child and adolescent 

psychiatrists, there are multiple barriers to the availability of other evidence-based psychosocial services 

for youth with complex behavioral health needs. In 

fact, as described above, medications are a very small 

component of the broader treatment plan for many 

youth with complex behavioral health needs. 

“Medication is one aspect of treatment. 

We have considerable knowledge about 

how to use it. And often it works best 

in combination with psychosocial 

treatments including family and/or 

individual psychotherapy. It is a tragedy 

that misinformation, stigma and 

lack of access keep people from 

effective treatment.”

— Dr. Gabrielle Carlson, testimony to the Commissioners, 

July 11, 2018

Youth participating in systems of care 

demonstrate significant:

• improvements in behavioral and emotional functioning

• reductions in suicide and suicide attempts

• reductions in unlawful activities

• reductions in costs due to hospitalizations and arrests
Federal Commission on School Safety: Prevent 81

Table 9-1

Psychotropic medications approved by the FDA for behavioral health conditions in children and adolescents

Medication Brand names Indication Age group

Methylphenidate 

preparations

Methylin, Ritalin, Ritalin SR, Methylin ER, 

Quillivant XR, Concerta, Metadate CD, Ritalin 

LA, Daytrana, Focalin, Focalin XR, Aptensio XR, 

Cotempla-XR, Quillichew ER

Attention deficit 

hyperactivity disorder

(ADHD)

≥ 6 years

Amphetamine, 

dextroamphetamine and mixed 

amphetamine salts

Liquadd, Dexedrine, Dexadrine spansules, 

Vyvanse, Adderall, Adderall XR, Dexosyn, 

Adzenys, Evekeo, Mydayis

Attention deficit 

hyperactivity disorder

(ADHD)

≥ 6 years 

(Note several formulations 

specifically approved for 

children > 3 years)

Lisdexamfetamine Vyvanse

Attention deficit 

hyperactivity disorder

(ADHD)

≥ 6 years

Non-controlled 

ADHD 

medications 

Strattera (atomoxetine) Tenex, 

Intuniv (guanfecine and guanfacine ER)

Kapvay (clonidine)

Attention deficit 

hyperactivity disorder

(ADHD)

≥ 6 years

quetiapine Seroquel Bipolar disorder 

Schizophrenia

≥ 10 years 

≥ 13 years

palperidone Invega Schizophrenia 12–17 years

olanzapine Zyprexa Bipolar disorder 

Schizophrenia

≥ 13 years 

≥ 13 years

risperidone Risperdal 

Autism

Bipolar mania

Schizophrenia

≥ 5 years 

10–17 years

13–17 years

aripiprazole Abilify

Bipolar disorder

Irritability associated 

with autistic disorder

Schizophrenia

≥ 10 years 

≥ 5 years 

≥ 13 years

asenapine Saphris Bipolar mania 10–17 years 

lursidone Latuda Schizophrenia, Bipolar 

depression 

13–17 years

10–17 years 

chlorpromazine Thorazine Schizophrenia/psychosis ≥ 6 months

haloperidol Haldol

Sedation/psychotic 

disorders/Tourette’s 

disorder

3–12 years

pimozide Orap Tourette’s disorder ≥ 12 years

lithium Eskatlith, Lithobid Bipolar disorder ≥ 12 years

duloxetine Cymbalta Generalized anxiety 

disorder (GAD) ≥ 7 years

escitalopram Lexapro Major depressive 

disorder ≥ 12 years

fluoxetine Prozac

Depression

Obsessive compulsive 

disorder (OCD)

Ages 8–18

Ages 7–17

fluvoxamine Luvox OCD Ages 8–17

Sertraline Zoloft OCD Ages 6–17

amitriptyline Elavil Depressive disorders ≥ 12 years

clomipramine Anafranil OCD ≥ 10 years

imipramine Tofranil Depression

Enuresis

≥ 12 years 

≥ 6 years
82 Federal Commission on School Safety: Prevent

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.42

¢ FEDERAL GOVERNMENT 

1. U.S. Department of Health and Human Services (HHS) should seek to increase the number of specialty 

physicians by encouraging the Accreditation Council on General Medical Education (ACGME) and other key 

stakeholders to increase the number of residency slots for general psychiatry programs, as well as child 

and adolescent psychiatry, in order to increase the number of medical students entering psychiatry and 

increase the number of residents in child and adolescent psychiatry.

2. Appropriate federal agencies should work to support care coordination across multiple systems for complex youth by supporting mechanisms where feasible for collaboration between providers (e.g., billing 

codes to support communication of physicians with teachers, child welfare workers, probation officers, 

psychologists, social workers, and other providers as well as other team-based planning).

3. HHS operating divisions, such as the National Institutes of Health, should support research to answer 

questions regarding effectiveness, safety, and tolerability of psychotropic treatment in youth (including 

long-term effects) as well as research on safe, effective alternatives, such as psychosocial interventions. 

4. All appropriate federal agencies should support technical assistance (TA) for children’s mental health, 

school-based mental health services, and TA to support evidence-based treatments for serious emotional 

disturbances. 

5. Appropriate federal agencies should strengthen standards and quality metrics so that youth have access 

to high-quality treatment that matches their needs. Because of the uneven quality of psychotropic medication treatment, there is a need to coordinate federal, state, and local approaches to measuring the 

quality of mental healthcare for children and adolescents, including use of psychotropic medications. 

¤ STATES & LOCAL COMMUNITIES

1. State and local health and behavioral health departments, in collaboration with primary care facilities and 

practitioners and medical schools as appropriate, should expand and enhance the existing primary care 

workforce by making telephonic and telepsychiatry consultation models available, expanding and supporting provider education, and supporting provider learning collaboratives. Well-designed consultation models include real-time availability by phone of a child and adolescent psychiatrist to consult with a primary 

care provider to discuss treatment needs and consider the need for additional evaluations or resources.43 

Some of these programs include access to additional types of services, such as connecting youth to case 

management or therapy services. Examples include the Massachusetts Child Psychiatry Access Program 

(https://www.mcpap.com/), Maryland’s Behavioral Health Integration in Pediatric Primary Care (http://

www.mdbhipp.org/), and the University of Washington Partnership Access Line (http://www.seattlechildrens.org/healthcare-professionals/access-services/partnership-access-line/). 

2. State and local behavioral health departments should expand the integration of behavioral health providers appropriately trained to deliver psychosocial interventions. In addition, they should expand training 

and capacity in the delivery of non-pharmacological interventions as safe alternatives and/or augmentations to appropriate pharmacotherapy.

3. State and local behavioral health agencies, in collaboration with state and local school districts, should 

increase access to good treatment through increasing opportunities to access a full array of treatment 

services in schools. The provision of treatment delivery in schools is imperative to addressing the needs 

of youth with complex mental health needs. The direct availability of these services in the school setting 

reduces barriers to access and ensures easy access to mental health service provision. 
Federal Commission on School Safety: Prevent 83

Chapter 9 Endnotes

1 American Academy of Child and Adolescent Psychiatry. (2009). Practice 

parameter on psychotropic medications. https://www.jaacap.org/article/

S0890-8567(09)60156-8/pdf.

2 Agency for Healthcare Research and Quality (AHRQ). (2018). Attention 

deficit hyperactivity disorder: Diagnosis and treatment in children 

and adolescents. Comparative Effectiveness Reviews, 203. Retrieved 

from http://europepmc.org/books/NBK487761;jsessionid=B55F9AAA7B134FD236D551EC6C8441C1.

3 Wang, Z., Whiteside, S., Sim, L., Farah, W., Morrow, A.S., Alsawas, M., & 

Murad, M.H. (2017). Comparative effectiveness and safety of cognitive 

behavioral therapy and pharmacotherapy for childhood anxiety disorders: A systematic review and meta-analysis. JAMA Pediatrics, 171(11), 

1049–1056. DOI: 10.1001/jamapediatrics.2017.3036.

4 van Stralen, J.P.M. (2018). A controlled trial of extended-release guanfacine and psychostimulants on executive function and ADHD. Journal of 

Attention Disorders, 1087–0547. DOI: 10.1177/1087054717751197.

5 Kreyenbuhl, J., Medoff, D.R., McEvoy, J.P., Smith, T.E., Hackman, A., 

Nossel, I.R., Dixon, L.B., Essock, S.M., & Buchanan, R.W. (July 1, 2016). 

The RAISE Connection Program. Psychopharmacological treatment 

of people with a first episode of schizophrenia. Psychiatric Services, 

appips201500438. [Epub ahead of print] PubMed PMID: 27364816.

6 Ryan, N. (2005). The treatment of depression in children and adolescents. The Lancet, 366(9489): 933–940.

7 American Academy of Child and Adolescent Psychiatry. (2007). Practice 

parameters for the treatment of anxiety disorders in children and adolescents. https://www.jaacap.org/article/S0890-8567(09)65341-7/fulltext.

8 Hawton, K., & van Heeringen, K. (2009). Lancet. 373:1372–81.

9 Merikangas, K.R., He, J.P., Burstein M., et al. (2010). Journal of the American Academy of Child and Adolescent Psychiatry, 49(10):980–989.

10 Goodman, W., Murphy, T., & Storch, E. (2007). Risk of adverse behavioral 

effects with pediatric use of antidepressants. Psychopharmacology, 191: 

87–96. 

11 Umetsu, R., Abe, J., Ueda, N., Kato, Y., Matsui, T., & Nakayama, Y., & 

Nakamura, M. (2015). Association between selective serotonin reuptake 

inhibitor therapy and suicidality: Analysis of U.S. Food and Drug 

Administration adverse event reporting system data. Biological and 

Pharmaceutical Bulletin, 38(11), 1689–99. DOI: 10.1248/bpb.b15-00243.

12 Miller, M., Swanson, S.A., Azrael, D., Pate, V., & Sturmer, T. (June 

2014). Antidepressant dose, age, and the risk of deliberate self-harm. 

JAMA Internal Medicine, 174(6):899–909. DOI: 10.1001/jamainternmed.2014.1053. 

13 Olfson, M., King, M., & Schoenbaum, M. (2015). Treatment of young 

people with antipsychotic medications in the United States. JAMA 

Psychiatry, 72(9), 867–74. DOI: 10.1001/jamapsychiatry.2015.0500.

14 U.S. Gov. Accountability Office, GAO14-65IT, Foster children: HHS could

provide additional guidance to states regarding psychotropic medications. (2014). 

Retrieved from https://www.gao.gov/products/GAO-14-651T. 

15 McLaren, J.L., Barnett, E.R., Concepcion Zayas, M.T., Lichtenstein, J., 

Acquilano, S.C., Schwartz, L.M., & Drake, R.E. (2018). Psychotropic 

medication for highly vulnerable children. Expert Opinion on Pharmacotherapy, 19(6), 547–560. DOI: 10.1080/14656566.2018.1445720.

16 American Academy of Child and Adolescent Psychiatry. (2017). Frequently asked questions for child, adolescent and adult psychiatrists 

working with transitional age youth with substance use disorders. 

Retrieved from https://www.aacap.org/AACAP/Clinical_Practice_Center/

Systems_of_Care/FAQs_for_Child__Adolescent_and_Adult_Psychiatrists_Working_with_Transitional_Age_Youth.aspx.

17 Kilpatrick, D.G., Ruggiero, K.J., Acierno, R., Saunders, B.E., Resnick, H.S., 

& Best, C.L. (2003). Violence and risk of PTSD, major depression, substance abuse/dependence, and comorbidity: Results from the National 

Survey of Adolescents. Journal of Consulting and Clinical Psychology, 

71(4), 692–700. doi.org.proxygw.wrlc.org/10.1037/0022-006X.71.4.692.

18 American Academy of Child and Adolescent Psychiatry. (2017). Frequently asked questions for child, adolescent and adult psychiatrists 

working with transitional age youth with substance use disorders. 

Retrieved from https://www.aacap.org/AACAP/Clinical_Practice_Center/

Systems_of_Care/FAQs_for_Child__Adolescent_and_Adult_Psychiatrists_Working_with_Transitional_Age_Youth.aspx.

19 Marsch, L.A., Bickel, W.K., Badger, G.J., Stothart, M.E., Quesnel, K.J., 

Staner, C., & Brooklyn, J. (2005). Comparison of pharmacological treatments for opioid-dependent adolescents: a randomized controlled trial. 

Archives of General Psychiatry, 62(10). 1157–1164. Retrieved from www.

archgenpsychiatry.com. 

20 American Academy of Pediatrics. (2013). Primary care physicians prescribe psychotropic medications: Epros Study. AAP News, 34(6). Retrieved 

from http://www.aappublications.org/content/34/6/18.1.

21 McMillan, J., Land, M., & Leslie, L. (2018). Pediatric residency education 

and the behavioral and mental health crisis: A call to action. Pediatrics, 

139(1). Retrieved from http://pediatrics.aappublications.org/content/139/1/e20162141.

22 American Academy of Child and Adolescent Psychiatry. (2009). Practice 

parameter on psychotropic medications. https://www.jaacap.org/

article/S0890-8567(09)60156-8/pdf.

23 https://www.cdc.gov/childrensmentalhealth/stateprofiles-providers.

html.

24 Health and Human Services. https://www.hhs.gov/ash/oah/facts-andstats/changing-face-of-americas-adolescents/index.html.

25 Thomas, C.R., & Holzer, C.E. (2006). The continuing shortage of child 

and adolescent psychiatrists. Journal of the American Academy of 

Child and Adolescent Psychiatry, 45(9). 1023-31. DOI: 10.1097/01.

chi.0000225353.16831.5d. 

26 https://www.aacap.org/aacap/resources_for_primary_care/Workforce_

Issues.aspx. 

27 For a full list of AACAP practice parameters, see https://www.aacap.

org/AACAP/Resources_for_Primary_Care/Practice_Parameters_and_

Resource_Centers/Practice_Parameters.aspx. Also, Clinical guidelines 

developed by the American Academy of Pediatrics are published in 

the journal Pediatrics. e.g., American Academy of Pediatrics. (2011). 

ADHD: Clinical practice guideline for the diagnosis, evaluation, and 

treatment of attention-deficit/hyperactivity disorder in children and 

adolescents. Retrieved from http://pediatrics.aappublications.org/

content/128/5/1007.

28 Monitoring effectiveness and safety of antipsychotics in children

(CAMESA). http://camesaguideline.org/about-the-guidelines.

29 Indiana Psychotropic Medication Advisory Committee and Psychotropic 

Advisory Subcommittee. (January 21, 2016). Psychotropic medication 

guidelines for youth in care with the Indiana Department of Child Service. Indiana Department of Child Services. Retrieved from https://www.

in.gov/dcs/files/INPsychotropicMedicationGuide4YouthnCareDCSUpdate.pdf.

30 Rodriguez, J., Olin, S.S., Hoagwood, K.E., Shen, S., Burton, G., Radigan, 

M., & Jensen, P.S. (2011). The development and evaluation of a parent 

empowerment program for family peer advocates. Journal of Child and 

Family Studies, 20(4). 397–405. DOI: 10.1007/s10826-010-9405-4. 

31 Ohio Department of Job and Family Services, Office of Families and Children. (June 2016). Ohio’s updated health care, oversight and coordination 

plan for children in the child welfare system. Retrieved from http://jfs.

ohio.gov/PFOF/PDF/AppendixB-HealthCarePlanUpdate-2017.stm. Also, 

Ohio Minds Matters. (November 2015). Retrieved from http://www.ohiomindsmatter.org/documents/MM%20Final%20Project%20Evaluation.

pdf.

32 The National Network for Child and Adolescent Psychiatry Access 

Programs (NCPAP) is a repository of information regarding such access 

lines. http://web.jhu.edu/pedmentalhealth/nncpap_members.html. 
84 Federal Commission on School Safety: Prevent

33 U.S. Department of Health and Human Services, Substance Abuse and 

Mental Health Services Administration. (2016). The comprehensive 

community mental health services for children with serious emotional 

disturbances program: Report to Congress. Retrieved from https://store.

samhsa.gov/shin/content//PEP18-CMHI2016/PEP18-CMHI2016.pdf.

34 https://www.nj.gov/dcf/about/divisions/dcsc/.

35 Suter, J., & James, E. (2009). Effectiveness of the wraparound process 

for children with emotional and behavioral disorders: A meta-analysis. 

Clinical Child and Family Psychology Review, 12, 336–351. DOI: 10.1007/

s10567-009-0059-y.

36 Henggeler, S., Melton, G., Brondino, M., Scherer, D., & Hanley, J. (1997). 

Multisystemic therapy with violent and chronic juvenile offenders and 

their families: The role of treatment fidelity in successful dissemination. Journal of Consulting and Clinical Psychology, 65(5), 821–833. DOI: 

http://dx.doi.org/10.1037/0022-006X.65.5.821.

37 Weiner, D., Schneider, A., & Lyons, J. (2009). Evidence-based treatments 

for trauma among culturally diverse foster care youth: Treatment 

retention and outcomes. Children and Youth Services Review, 31(11), 

1199–1205. DOI: 10.1016/j.childyouth.2009.08.013.

38 Finnerty, M., Neese-Todd, S., Pritam, R., Leckman-Westin, E., Bilder, 

S., Byron, S., Olfson, M. (2016). Access to psychosocial services prior 

to starting antipsychotic treatment among Medicaid-insured youth. 

Journal of the American Academy of Child & Adolescent Psychiatry, 55(1), 

69–76. DOI: 10.1016/j.jaac.2015.09.020.

39 Adelsheim, S. (2014). From school health to integrated health: Expanding our children’s public health system. Academic Psychiatry, 38: 

405–408. 

40 American Academy of Child and Adolescent Psychiatry. (2005). Practice 

parameter on psychiatric consultation to schools. https://www.jaacap.

org/article/S0890-8567(09)61773-1/pdf.

41 Kriechman, A., Salvador, M., & Adelsheim, S. (2010). Expanding the 

vision: The strength-based, community-oriented child and adolescent 

psychiatrist working in schools. Child and Adolescent Clinics of North 

America, 19(1): 149–162. 

42 Recommendations were made with the underlying premise that promising and effective practices to support youth with complex behavioral 

health needs should be expanded and promoted. It is also important to 

note that the evidence for a causal link between the use of psychotropic 

medications and general school safety is weak; rather, the recommendations focus on promoting positive clinical and functional outcomes 

for youth with complex behavioral health needs.

43 Some examples include Massachusetts Child Psychiatry Access Program 

(https://www.mcpap.com/) and University of Washington Partnership 

Access Line (http://www.seattlechildrens.org/healthcare-professionals/

access-services/partnership-access-line/).
Federal Commission on School Safety: Prevent 85

The suspected shooter at Marjory Stoneman Douglas 

High School is a 19-year-old who purchased the long 

gun he allegedly used from a licensed dealer after 

passing a federal background check. His ability to do 

so sparked new debate about age restrictions on firearm sales. This section provides an overview of federal 

and state laws that place age-related restrictions on 

the possession and purchase of firearms. Existing 

research does not demonstrate that laws imposing 

a minimum age for firearms purchases have a measurable impact on reducing homicides, suicides, or 

unintentional deaths. 

Federal laws

Long Guns: Federal law provides no minimum age for 

the possession of long guns or long gun ammunition. 

However, the Gun Control Act of 1968 (GCA)1 does 

prohibit federally licensed importers, manufacturers, 

dealers, or collectors (collectively, Federal Firearms 

Licensees or “FFLs”) from selling or delivering any long 

gun or ammunition for a long gun to any individual 

less than 18 years old. Unlicensed persons may sell a 

long gun to a person of any age.

Handguns: Federal law establishes a minimum age for 

possession of handguns. The GCA2 prohibits persons 

under 18 years of age from possessing handguns 

or handgun ammunition, with certain exceptions 

for employment, ranching, farming, hunting, target 

practice, education, and a handgun possessed while 

defending the home of the juvenile or a home in which 

the juvenile is an invited guest. 

The GCA also prohibits FFLs from selling or delivering 

any handgun or handgun ammunition to any individual less than 21 years of age. This leaves a three-year 

“window” when an individual may legally possess 

handguns and handgun ammunition, but may not 

purchase them from an FFL. Unlicensed persons may 

sell a handgun to a resident of their own state so long 

as the buyer is 18 years old.

State laws

Similar to federal firearms laws, state laws pertaining 

to possession of firearms differ from those pertaining 

to their purchase. State laws may also distinguish 

between sales by FFLs and sales by unlicensed 

persons.

The laws in a number of states reach beyond federal 

law, placing further age restrictions on the purchase 

of handguns and long guns. Shortly after the Parkland 

shooting, the State of Florida passed a law that prohibits firearms (handguns and long guns) purchases by 

individuals under 21 years old regardless of whether 

the purchase is from a licensed firearms dealer or from 

CHAPTER 10

The Efficacy of Age Restrictions for Firearm Purchases

Table 10-1

Federal Laws

Long Guns Handguns

Minimum Age of 

Possession

None 18, with exceptions

Minimum Age of Purchase 

from Licensed Sellers 

(FFLs)

Prohibited from selling or delivering long 

guns/ammunition to individuals younger 

than 18

Prohibited from selling or delivering handguns/ammunition to individuals younger 

than 21

Minimum Age of Purchase 

from Unlicensed Seller

May sell a long gun to a person of any age May sell a handgun to a resident of their own 

state as long as the buyer is at least 18
86 Federal Commission on School Safety: Prevent

a non-licensee/private party.3 In taking this action, 

Florida joined two other states—Hawaii and Illinois—

that have similar laws setting the minimum age for 

all firearms purchases at 21. The 2018 change in the 

firearms law in Florida did not include modifications to 

age restrictions on firearms possession. 

Research on minimum age of purchase laws and 

firearms violence4

A 2017 study on the effects of firearms laws on firearms homicides in the United States was based on a 

systematic review of 34 empirical studies published 

between January 1970 and August 2016.5 Five of the 

34 studies examined juvenile age restrictions prohibiting the possession and/or purchase of handguns by 

persons younger than 18 or 21 years. 

This review found that the evidence does not indicate 

that additional state law age requirements would be 

effective.6 For example, one study included in the systematic review evaluated the effects of state firearms 

regulations on homicide and suicide death rates.7

The study examined laws in effect from 1979 to 1998, 

including laws pertaining to a minimum age of 21 

for handgun purchases and a minimum age of 21 for 

private handgun possession. None of these state laws 

was associated with a statistically significant decrease 

in the rates of firearms homicides or total homicides. 

Another study found these state age restrictions do 

not appear to be as effective in reducing homicide or 

suicide rates as other measures.8

One further study examined state-level minimum age 

laws in place between 1981 and 2010 for handgun 

possession and found no significant effects on youth 

suicides or youth unintentional deaths.9 However, 

it noted that the current federal minimum age of 

possession laws are effective in reducing suicide and 

unintentional deaths among youths.

Where do shooters obtain their firearms?

Laws that modify the age of purchase are likely to be 

effective if individuals obtain their firearms through 

legal purchase prior to using them in violent acts. 

As school shootings are of particular concern, it is 

important to ask: Where do school shooters get the 

firearms they use? 

The U.S. Department of Education and U.S. Secret 

Service reviewed 37 incidents of targeted school 

violence between 1974 and 2000 and found that most 

attackers had access to and had used weapons prior 

to the attack.10 More than two-thirds of the attackers acquired the gun (or guns) used in their attacks 

from their own home or that of a relative. The School 

Associated Death Study conducted by the Centers for 

Disease Control found similar results in a study of 323 

school-associated violent death events that occurred 

between 1992 and 1999. Of the firearms used to commit homicides, 23.4 percent were obtained from the 

home of the perpetrator and 27.6 percent came from 

a friend or a relative.11

The National Institute of Justice is funding researchers 

at City University of New York’s John Jay College to 

develop a database of all of the publicly known shootings that have resulted in at least one injury on K–12 

school grounds since 1990. This project will provide a 

detailed understanding of the perpetrators of school 

shootings as well as recommendations for intervention points that could prevent or reduce the harm 

caused by shootings. Although the project is ongoing, a preliminary analysis of 106 cases found that 

only 13 percent of shooters purchased the firearms 

legally. Higher percentages took the firearms from 

their parents (29 percent) or stole them from friends or 

family (25 percent) or strangers (2 percent). Another 5 

percent purchased the firearms illegally. 

A Wall Street Journal analysis of school shootings with 

at least three victims dead or injured since 1990 found 

32 incidents.12 Twenty-five of these cases involved 

shooters who were minors. In 20 cases, reporters were 

able to identify a source for the gun, and in 17 cases 

the gun came from the home. Given what we know 

about how underage shooters most often procure 

weapons (i.e., taking them from home or stealing 

them), laws aimed at a minimum purchase age would 

not have affected most school shooters.

Analyses of completed school shootings indicate 

that school shooters do not frequently use legal 

purchase as a method for obtaining firearms. More 

often, they obtain them from within the home or 

steal them.
Federal Commission on School Safety: Prevent 87

Commission Observations

The existing research findings on the efficacy of 

current minimum age of firearm purchase laws do 

not support the conclusion that those laws have a 

measurable impact on reducing homicides, suicides, 

or unintentional deaths. Analyses of completed school 

shootings indicate that school shooters do not frequently use legal purchase as a method for obtaining 

firearms. More often, they obtain them from within the 

home or steal them. These findings suggest that modifying the minimum age of firearm purchase is unlikely 

to be an effective method for preventing or reducing 

school shootings. 

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¤ STATES & LOCAL COMMUNITIES

1. Without more comprehensive research, and because most school shooters obtain their weapons 

from family members or friends rather than by purchasing them, states seeking to prevent unlawful 

adolescent access to firearms should consider offering training or other resources to promote safe 

storage of firearms.

2. States should consider sponsoring additional research to determine how best to prevent adolescents from unlawfully accessing firearms.

Chapter 10 Endnotes

1 18 U.S.C. § 922(b)(1).

2 18 U.S.C. § 922(x)(2).

3 The Florida statute only prohibits licensed dealers from engaging in 

sales (or facilitation of sales) to those under 21. For practical purposes, 

this means that no criminal penalty applies to a private seller who fails 

to ensure a purchaser is over 21 (i.e., a private seller has no affirmative 

legal obligation to verify the age of a purchaser).

4 The studies discussed in this section focus on the use of firearms by 

youth in homicides and suicides; they do not specifically address the 

use of firearms by youth in other crimes. 

5 Lee, L.K., Fleegler, E.W., Farrell, C., Avakame, E., Srinivasan, S., Hemenway, D., & Monuteaux, M.C. (2017). Firearm laws and firearm homicides: 

A systematic review. JAMA Internal Medicine, 177(1), 106–119. DOI: 

10.1001/jamainternmed.2016.7051. 

6 This discussion examines the results of a systematic review of multiple 

studies. We highlight several examples to elaborate on the overall 

finding of the review, but it is not our intention to summarize the 

characteristics of all studies included in the review. We note that one 

of the studies that was reviewed produced contradictory results, but 

that study was based on cross-sectional data, which cannot explain the 

impact of enacting a law.

7 Rosengart, M., Cummings, P., Nathens, A., Heagerty, P., Maier, R., & 

Rivara, F. (2005). An evaluation of state firearm regulations and homicide and suicide death rates. Injury Prevention, 11, 77–83. DOI: 10.1136/

ip.2004.007062. 

8 Kalesan, B., Mobily, M.E., Keiser, O., Fagan, J.A., & Galea, S. (2016). 

Firearm legislation and firearm mortality in the USA: A cross-sectional, 

state-level study. Lancet, 387(10030), 1847–1855. DOI: 10.1016/S0140-

6736(15)01026-0. Also, Kleck, G. (2011). The impact of the 1968 Gun 

Control Act’s restrictions on handgun purchases by persons age 18 to 

20. SSRN.

9 Gius, M. (2015). The impact of minimum age and child access prevention laws on firearm-related youth suicides and unintentional deaths. 

Social Science Journal, 52(2): 168–175. DOI: http://dx.doi.org/10.1016/j.

soscij.2015.01.003. This study included laws pertaining only to handguns and hand-gun possession. Restrictions on long gun possession 

and minimum age requirement for handgun purchases were not considered.

10 Vossekuil, B., Fein, R., Reddy, M., Borum, R., & Modzeleski, W. (2002). 

The final report and findings of the safe school initiative: Implications for 

the prevention of school attacks in the United States. U.S. Department 

of Education, Office of Elementary and Secondary Education, Safe and 

Drug-Free Schools Program, and U.S. Secret Service, National Threat 

Assessment Center, Washington, DC. https://www.secretservice.gov/

data/protection/ntac/ssi_final_report.pdf.

11 Reza, A., Modzeleski, W., Feucht, T., Anderson, M., Simon, T.R., & Barrios, 

L. (2003). Source of firearms used by students in school-associated 

violent deaths: United States, 1992–1999. Morbidity and Mortality 

Weekly Report, 52(09): 169–172. https://www.cdc.gov/mmwr/preview/

mmwrhtml/mm5209a1.htm.

12 Hobbs, T.D. (April 5, 2018). Most guns used in school shootings 

come from home. Retrieved from the Wall Street Journal. https://

www.wsj.com/articles/in-school-shootings-most-guns-come-fromhome-1522920600. Similarly, an August 1, 2018 Washington Post

report studied 145 acts of gun violence at primary and secondary 

schools that occurred between 1999 and 2018 and concluded that “[w]

hile investigators don’t always determine—or publicly reveal—the 

weapons’ origins, the Post found 105 cases in which the source was 

identified. Of those, the guns were taken from a child’s home or those 

of relatives or friends 84 times. https://www.washingtonpost.com/

news/local/wp/2018/08/01/feature/school-shootings-should-parentsbe-charged-for-failing-to-lock-up-guns-used-by-their-kids/?utm_term=.0369cf9a1045
88 Federal Commission on School Safety: Prevent

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Federal Commission on School Safety: Prevent 89

CHAPTER 11

Extreme Risk Protection Order Laws

Too often following a mass shooting we learn that 

people who knew the shooter saw warning signs of 

potential violence but felt powerless to do anything. 

If the person has not yet broken any law and may not 

meet the mental health standards for involuntary 

commitment, what can be done? 

A number of states have attempted to answer this 

question, at least in part, through “extreme risk 

protection order” (ERPO) laws. Also known as gun 

violence protection orders, risk warrants, or red flag 

laws, these state laws provide law enforcement (and 

in some instances, family members) with a legal, temporary way to prevent individuals who pose a threat to 

themselves or others from possessing or purchasing 

firearms. 

President Trump has called on states to adopt ERPO 

laws that protect the due process rights of law-abiding 

citizens.1 This section describes the state laws that 

have been enacted, reviews the limited research on 

their effectiveness, and offers several recommendations. 

ERPO laws: what they are and how they work

In every state, some form of protection or restraining 

order is already available in cases involving domestic 

violence, harassment, stalking, sexual assault, and, 

in some states, workplace issues. But outside of the 

context of domestic violence, most protection orders 

do not result in a temporary legal prohibition against 

possessing firearms.2 Additionally, most protection 

order laws focus on threats directed at the specific 

person requesting the order. Generalized threats (e.g., 

against a school) may not qualify under state laws.

ERPO laws seek to fill these gaps by providing a temporary mechanism for removing firearms from individuals found by a court to be a danger to themselves or 

others. Thirteen states currently have an ERPO law in 

effect, including eight states that have enacted laws 

since the Parkland shooting.3

The terms of each state statute are summarized in 

Table 11.1. While state laws differ, the basic process in 

each state is largely similar:

Initial Petition. A law enforcement officer, an attorney 

for the state, or, in some states, a family or household 

member offers a court evidence that an individual 

presents an imminent threat to himself or herself or to 

others and is in possession of a firearm. Depending on 

the jurisdiction, the evidence can include a history or 

pattern of recent threats or acts of violence, dangerous past behavior with firearms, substance abuse, and 

mental illness.

Temporary Order. If the petitioner offers sufficient 

evidence, the court issues either a search and seizure 

warrant or a temporary protective order. The initial 

evidentiary threshold varies by jurisdiction, including 

reasonable cause, substantial likelihood, clear and 

convincing evidence, and probable cause.

Seizure of Firearms. Once a warrant or protection 

order is issued, law enforcement seizes and temporarily holds for safekeeping the firearm(s) the at-risk 

individual owns or has access to.

Hearing. Typically, within 14 to 21 days of the issuance 

of the temporary order or warrant, the court holds a 

hearing at which the at-risk individual has the opportunity to present evidence that he or she is not an 

imminent threat to himself or herself or to others.4

Extension of Prohibition. If the court agrees with the 

finding that generated the initial warrant or temporary 

order (though the evidentiary standard may be higher 

at this point), it can extend the prohibition such that 

President Trump has called on states to adopt 

ERPO laws that protect the due process rights of 

law-abiding citizens.

Thirteen states currently have an ERPO law in 

effect, including eight states that have enacted 

laws since the Parkland shooting.
90 Federal Commission on School Safety: Prevent

the individual may not retain or purchase firearms for 

a period of, typically, one year. 

While the basic features of these state laws are largely 

similar, there are a number of notable differences. 

They include the following:

Scope. Both ERPOs and risk warrants provide for 

initial seizure of firearms already in the possession of 

the at-risk individual. However, ERPO statutes provide a clearer prohibition against future purchases 

or possession by the individual, while risk warrant 

statutes focus on seizure of firearms at the outset of 

the warrant’s issuance. 

Petitioners. In five states, only a law enforcement 

officer or other designated state official may file a 

petition. In eight states, a family or household member may file a petition with the court. One state also 

authorizes petitions by mental health professionals.

Standard of Proof. At the hearing that takes place 

after the issuance of the initial order, most states 

require the petitioner to prove that the individual continues to be a threat to himself or herself or to others 

by clear and convincing evidence. In three states, the 

standard of proof is a preponderance of the evidence. 

False Petitions. Filing a false petition or filing a petition with the intent to harass an individual is punishable in nine jurisdictions, either as a misdemeanor or 

a felony.

Additional Notice. In one state, if the court finds that 

the individual poses a risk of imminent personal injury 

to himself or herself or to others, it provides notice to 

that state’s Department of Mental Health and Addiction Services, as it deems appropriate. In five states, 

the order must be made available to the National 

Instant Criminal Background Check System (NICS).5

ERPO laws: do they work?

ERPO laws are of relatively recent vintage—the oldest 

is less than 20 years old, and more than half have been 

in effect for less than a year. So it is not surprising that 

there is little research on their effectiveness. Two studies (in the states where such laws have been around 

the longest) suggest a positive impact on suicide 

prevention. 

In the first study, researchers examining Connecticut’s 

risk warrant law concluded that the removal of firearms from high-risk individuals may have prevented 

up to 100 suicides.6  They estimated the law resulted 

in one averted suicide for every 10–11 cases. In 44 percent of cases, the risk warrant led to the respondents 

receiving psychiatric treatment they may not have 

received otherwise. Importantly, the study examined 

the impact of the law on suicides only, not violence 

against others.

A more recent study looked at both the Connecticut 

and Indiana risk warrant laws.7 It found that Indiana’s law was associated with a 7.5 percent decrease 

in firearm suicides during the 10 years following its 

enactment. Connecticut’s law was associated with a 

1.6 percent decrease in firearm suicides immediately 

after its passage, and a 13.7 percent decrease between 

2007 and 2015, following increased enforcement in 

the wake of the Virginia Tech shooting. Like the other 

study, it did not examine effects on gun violence more 

generally. 

Commission Observations

A growing number of states is adopting ERPO laws in 

an effort to prevent gun violence. The available evidence suggests that the older risk warrant laws may 

have a positive impact on suicide prevention. We do 

not know whether they impact gun violence more generally, and it appears no studies have yet evaluated 

the more recent ERPO laws in other states. 
Table 11-1

 Summary of State Extreme Risk Protection Order and Risk Warrant Laws*

Type

Who can 

petition?

Standard of proof for 

initial order or warrant Hearing held within

Standard of 

proof at hearing 

to continue 

prohibition

How long is 

firearm held 

initially?

O

m

California

Cal. Pen. Code § 18100

ERPO Law enforcement (LE) 

officer; immediate 

family member 

Ex parte order: Substantial likelihood that person poses a significant dangerTemporary emergency order (available to LE only): Reasonable cause that person poses immediate and present danger 

21 days Clear and 

convincing evidence

One year N

ConnecticutC.G.S.A. § 29-38c

Risk Warrant State’s Attorney; 

Assistant State’sAttorney; or 2 LE officers

Probable cause 14 days Clear and 

convincing 

evidence

Not more than one year

Nreof HASe

DelawareH.B. No. 222 

(effective Dec. 27, 2019)

ERPO LE officer, family 

member 

Nonemergency hearing: Petition may be filed, but no ex parte order availableEmergency hearing (available to LE only):Preponderance of the evidence that respondent poses an immediate and present danger

15 days Clear and 

convincing evidence

Not more than one year

N

FloridaFla. Stat. § 790.401

ERPO LE officer; LE agency Reasonable cause 14 days Clear and 

convincing evidence

Not more than one year

Ye

* This table is not intended to provide an exhaustive account of the differing provisions of these state laws. For more detailed information, please consult the various state s
Type

Who can 

petition?

Standard of proof for 

initial order or warrant Hearing held within

Standard of 

proof at hearing 

to continue 

prohibition

How long is 

firearm held 

initially?

O

m

IllinoisH.B. 2354 

(effective Jan. 1, 2019)

Firearms Restraining Order

LE officer; family member 

Probable cause 14 days 

(30 days if petitioner requests a six-month order and not an 

ex parte order)

Clear and convincing 

evidence

Six months N

Indiana IC 35-47-14

Risk Warrant LE officer Probable cause 14 days Clear and 

convincing evidence

At least 180 days, after which the individual may petition the court for return of firearm 

N

MarylandMd. Code Ann., Pub. Safety § 5-601

ERPO Physician; mental 

health provider; LE officer; spouse; cohabitant; relative; 

person with whom the individual has a child in common; current dating or intimate partner; current or former legal guardian

Reasonable grounds for initial interim ERPO (good for up to two days); probable cause for temporary ERPO (good for up to additional seven days)

A temporary ERPO hearing must be held within two business days of issuance of the interim ERPO A final ERPO hearing must be held within seven days after service of temporary ERPO(The parties may waive the temporary ERPO hearing and proceed directly to final hearing)

Clear and convincing evidence

Not more than one year

N

Massachusetts

H. 4670 (not yet codified)

ERPO Family or household 

member; licensing authority (local police department)

Reasonable cause 10 days Preponderance 

of the evidence 

One year Ye
Type

Who can 

petition?

Standard of proof for 

initial order or warrant Hearing held within

Standard of 

proof at hearing 

to continue 

prohibition

How long is 

firearm held 

initially?

O

m

New Jersey

A-1217; P.L. 2018,c. 35 (not yet codified)

ERPO LE officer; family or 

household member

Good cause 10 days Preponderance 

of the evidence

One year N

OregonORS 166.525

ERPO LE officer; family or 

household member 

Clear and convincing evidence

Respondent has 30 days to request hearing, which must take place within 21 days of request; if the respondent does not request a hearing, the protection order is effective for one year

Clear and convincing evidence 

One year Ye

Rhode IslandS. 2492 (not yet codified)

ERPO LE agency Probable cause 14 days Clear and 

convincing evidence

One year Ye

Vermont13 V.S.A. § 4051

ERPO State’s Attorney or 

Office of the Attorney General

Preponderance of the evidence

14 days Clear and 

convincing evidence

Up to six months

N

Washington

RCWA § 7.94.010 

ERPO Family or household 

member; LE officer or agency 

Reasonable cause 14 days Preponderance 

of the evidence

One year Ye
94 Federal Commission on School Safety: Prevent

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¤ STATES & LOCAL COMMUNITIES

1. States should adopt ERPO laws that incorporate an appropriate evidentiary standard to temporarily

restrict firearms access by individuals found to be a danger to themselves or others.

• States’ ERPO laws should ensure that the due process rights of the at-risk individual are

respected. Notice and an opportunity to be heard are foundational principles of American law,

guaranteed by the Fifth and Fourteenth Amendments, and gun ownership and possession are

protected by the Second and Fourteenth Amendments.

These rights must be upheld through appropriate processes, beginning with the initial consideration of a temporary order and continuing through all subsequent steps. For example, state laws

that do not require a full hearing promptly after a temporary order is issued, but that put the burden on the respondent to seek a hearing, do not afford as meaningful and robust of an opportunity to be heard as those state laws that do require full hearings. State laws should also provide

for prompt return of firearms at the conclusion of the order’s duration, assuming no other lawful

restrictions apply.

• States should likewise be thoughtful about who can file a petition for an ERPO so that the laws

effectively address safety concerns without inviting misuse by individuals who are less likely to

possess reliable information relevant to a person’s dangerousness.

Some existing state laws have prompted concerns that the scope of possible petitioners might

be too broad and poorly defined, potentially allowing the filing of petitions by people who are

unlikely to have relevant and reliable information. To mitigate such concerns, states should

adopt clear and narrow definitions identifying appropriate persons with standing to file a petition. States can deter misuse or abuse of the ERPO process through appropriate criminal penalties for false (bad faith) or harassing petitions.

• States with ERPO laws, and those considering them, should require and establish procedures for

sharing information regarding issued protection orders (including their expiration dates) with

the National Instant Criminal Background Check System (NICS), by submitting those orders to

the appropriate database (the National Crime Information Center or NICS Indices). Prohibitions

on the purchase of firearms can be enforced only if the information is made available to the

NICS in a timely and accurate manner. States wishing to explore how to accomplish this should

contact the Federal Bureau of Investigation’s NICS Section at CJIS-STATE@fbi.gov.
Federal Commission on School Safety: Prevent 95

Chapter 11 Endnotes

1 https://www.whitehouse.gov/briefings-statements/president-donald-j-trump-taking-immediate-actions-secure-schools/.

2 The federal Gun Control Act contains a provision that makes it unlawful 

for persons subject to certain qualifying domestic violence restraining 

orders to possess firearms during the pendency of the order. See 18 

U.S.C. § 922(g)(8). State laws may also impose such a restriction, or the 

restriction may be included as part of the underlying restraining order 

itself. 

3 Connecticut (1999); Indiana (2006); California (2014); Washington 

(2016); Oregon (2017); Delaware (2018); Florida (2018); Illinois (2018); 

Maryland (2018); Massachusetts (2018); New Jersey (2018); Rhode Island 

(2018); and Vermont (2018). The earliest laws (Connecticut and Indiana) 

are known as “risk warrant” laws and bear a closer resemblance to the 

process followed by law enforcement to obtain search warrants. Later 

ERPO statutes in other states bear a stronger resemblance to protection 

order processes. Similar bills have been introduced a number of other 

states. In addition, Texas provides a different mechanism for seizing 

firearms from certain mentally ill people who are taken into custody. 

Tex. Health & Safety Code § 573.001(h).

4 Oregon appears to be the only state in which a subsequent hearing is 

not required. Instead, a respondent has 30 days to request a hearing 

after he or she is served; if the respondent does not request a hearing, 

the ex parte order remains in effect for one year, unless terminated by a 

court. 

5 Some of these states direct entry of the order into the National Crime 

Information Center (NCIC), which is one of three databases accessed by 

the NICS. However, these orders may not meet the criteria for entry in 

the protective order file of NCIC. In these instances, the order may qualify for entry into a separate NCIC file. The orders may also be entered 

into the NICS Indices (one of the other databases accessed by the NICS). 

In addition, although some states do not require orders to be made 

available to the NICS by statute, they may submit the orders to state 

agencies that do so as a matter of policy.

6 Swanson, J.W., et al., (2017). Implementation and effectiveness of 

Connecticut’s risk-based gun removal law: Does it prevent suicides? Law 

and Contemporary Problems, 179. Available at https://scholarship.law.

duke.edu/cgi/viewcontent.cgi?article=4830&context=lcp.

7 Kivisto, A.J., et al. (2018). Effects of risk-based firearm seizure laws 

in Connecticut and Indiana on suicide rates, 1981–2015. Psychiatric Services. Abstract available at https://www.ncbi.nlm.nih.gov/

pubmed/29852823. 
96 Federal Commission on School Safety: Prevent

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Federal Commission on School Safety: Prevent 97

The Federal Bureau of Investigation receives thousands of calls a day from the public through its Public 

Access Line (PAL), a unit operating within its Criminal Justice Information Services (CJIS) Division. PAL 

serves as a central intake point for tip information 

from the public about potential or ongoing crimes. 

Following the February 14 shooting in Parkland, FL, 

the FBI conducted a special review of PAL to better 

understand the operational system and to recommend potential changes to PAL’s protocols and procedures. This section describes the changes made to PAL 

by the FBI as a result of this review.

PAL operates 24 hours a day, 365 days a year, providing an around-the-clock way for the FBI to receive 

and evaluate potentially critical information from the 

public and take appropriate action. Once PAL receives 

and processes information provided by the public for 

FBI investigative and intelligence purposes, it assesses 

the data and reports appropriate information to the 

local FBI field office. 

As of August 2017, PAL also assumed responsibility for 

telephone complaint calls from all 56 field offices (as 

well as most of the FBI’s smaller local offices, called 

resident agencies), the Major Case Contact Center, the 

Weapons of Mass Destruction tip line, and all other 

FBI electronic tips (E-Tips). Through these efforts, PAL 

centralizes the flow of tip information from the public 

to the FBI. Since its inception on September 24, 2012, 

it has received more than three million telephone calls 

and more than one million E-Tips.

Improvements to PAL

PAL is undergoing a transformation, from being the 

functional equivalent of a call intake center to being 

a full-fledged Operations Center. This change will 

provide PAL with greater resources and capabilities 

related to processing and taking action on information 

provided by the public. Although PAL will continue to 

perform the call-intake services associated with the 

FBI’s tip lines, as an Operations Center it will have the 

staff and functionality to analyze and disseminate 

information in a timely manner to the field. 

In developing the plans for this transition, FBI personnel visited operations centers of various law 

enforcement agencies to identify best practices and 

staffing models. The objective of this transition to an 

Operations Center is to improve the effectiveness and 

efficiency of tip handling by making changes to the 

process, personnel, and systems. The major features 

of the updated PAL are described below.

Process: PAL’s internal processes have been updated 

to ensure that decision-making is conducted at the 

most appropriate level. These processes include a 

new automated tiered triage structure for handling 

tips. Based on the selection made by the caller, each 

tip is automatically routed to the appropriate staff.

• Threats to Life. These calls are routed to designated Customer Service Representatives (CSRs) for 

expedited resolution. 

• Non-emergency Situations. All other appropriate 

calls offering tips or information are sent to CSRs 

via automated routing. CSRs then determine the 

lead value or lead potential of the call and disseminate the information to FBI offices and other law 

enforcement as appropriate. 

• Nuisance Callers. CSRs take appropriate action 

pursuant to PAL’s protocols. 

Supervisory Special Agents (SSA) serve as Watch Commanders to provide oversight of this process. For calls 

determined by a CSR not to have any value as a lead 

(“No Lead Value” or NLV) that also contain words from 

a Key Threat Word List, an SSA must review the call 

and the NLV decision prior to closing the tip. Between 

January 1, 2018, and June 30, 2018, approximately 40 

percent of calls were determined to be NLV. The process ensures that final designations for NLV calls are 

made based on the judgment of SSAs, who are subject 

to greater accountability and oversight.

CHAPTER 12

Improvements to the FBI’s Public Access Line

The objective of this transition to an Operations 

Center is to improve the effectiveness and 

efficiency of tip handling by making changes to 

the process, personnel, and systems.
98 Federal Commission on School Safety: Prevent

In addition, the FBI implemented a standalone Quality 

Management (QM) program to review PAL accuracy 

and quality in near real time. In this program, a QM 

team tracks performance by conducting reviews of 

calls to assess CSRs on phone skills, technical skills, 

and decision skills. The QM team proactively identifies 

and addresses gaps in PAL’s processes, procedures, 

and training.

The FBI also made improvements to the Standard 

Operating Procedure (SOP) that serves as a reference 

resource for CSRs. The improvements include the 

development of a single comprehensive and concise 

SOP that is searchable and available electronically. 

Personnel: The FBI implemented a new staffing model 

for PAL in July 2018 that includes a staffing increase of 

50 CSR and 12 SSA positions. The FBI has also provided a series of mandatory trainings that focus on 

threats, including a refresher training for CSRs on how 

to identify and respond to threat-to-life matters. 

The CJIS Training and Advisory Process Unit is working 

with the FBI Headquarters Training Division to develop 

specific training for the new two-tiered structure. The 

FBI Behavioral Analysis Unit (BAU) provided a number of training sessions to PAL personnel, including 

sessions relating to threat assessments of potential 

school shooters and identification of pre-attack mental health indicators. In August 2018, the United States 

Secret Service’s National Threat Assessment Center 

(NTAC) staff provided a daylong consultation for PAL 

personnel discussing threat assessment and the 

assessment and triage of concerning behavior. In addition, NTAC staff provided training at the PAL facility in 

West Virginia in November 2018.

Information Technology: The FBI updated PAL’s information technology system to better document the 

steps CSRs and SSAs take to process and review calls 

prior to final disposition. Additionally, a new product 

will be implemented by the end of the year that will 

use speech-to-text technology to identify key threat 

words in the digital transcript of a call as a means of 

elevating the call’s priority. The word cloud for E-Tips 

has already been improved to alert staff of trending 

and emerging threats. Finally, the FBI added a feature 

to SSAs’ desktop computer display to alert them when 

immediate assistance is needed to assess ongoing 

calls for potential lead value.

PAL is a critical component of the FBI’s efforts to keep 

the American people safe, and the FBI believes the 

improvements outlined above will result in a more 

effective and efficient tip-handling process. The FBI 

continues to review its pocesses and procedures for 

receiving and evaluating tip information reported to 

PAL to ensure that tip information is effectively and 

efficiently handled.

PAL is a critical component of the FBI’s efforts 

to keep the American people safe, and the FBI 

believes the improvements outlined here will 

result in a more effective and efficient tiphandling process.

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendation below.

¤ STATES & LOCAL COMMUNITIES

1. State and local leaders should encourage the public—including school staff and parents—to be 

vigilant about reporting information to the FBI that might help prevent violence in schools. This 

information can be reported by using the FBI’s Online Tips and Public Leads form (https://tips.fbi.

gov/) or by contacting a local FBI field office (https://www.fbi.gov/contact-us/field-offices).

2. State and local leaders should also continue to encourage the public to contact their local police 

department or call 911 to report information regarding immediate threats.
Federal Commission on School Safety: Prevent 99

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100 Federal Commission on School Safety: Prevent

SECTION 2

Protect 

& Mitigate
Federal Commission on School Safety: Protect and Mitigate 101

CHAPTER 13

Training School Personnel to Help Ensure Student Safety

All school personnel play an important role in school 

safety. Training on safety matters helps prepare 

them to respond to incidents of school violence. The 

school personnel best positioned to respond to acts 

of violence are those with specialized training such as 

school resource officers (SRO), who are typically sworn 

law enforcement officers, and school safety officers 

(SSO), who are typically unsworn school security staff. 

These officers have been specifically trained in school 

safety to act as a first-line of defense. Their presence 

at school facilities and on campus allows them to 

build the kinds of relationships with students that can 

prevent or mitigate incidents of school violence. 

The Columbine Review Commission made specific recommendations about the use of SROs in responding 

to potential acts of school violence. In the years since 

Columbine, school leaders have increased the number of specially trained school security staff as part of 

their strategies to combat school violence. Between 

2005 and 2016, the percentage of public schools that 

reported the presence of security staff at least once a 

week increased from 42 to 57 percent.1

However, these changes are not enough. At a meeting 

of the Marjory Stoneman Douglas High School Public 

Safety Commission held in the aftermath of the Parkland shooting, Commission members (including the 

parents of victims) raised specific concerns regarding 

the training and actions of school personnel during 

the tragedy.2 Effective training is critical, making it 

imperative that schools regularly review training 

protocols to ensure that every SRO, SSO, teacher, 

administrator, and student is as prepared as possible 

to respond to incidents of school violence within the 

framework of a comprehensive school safety plan.

Placement of specially trained personnel in schools is 

an effective tool in stopping acts of school violence. In 

Dixon, IL, SRO Mark Dallas stopped a gunman targeting a high school graduation rehearsal before anyone 

was harmed.3 In Leonardtown, MD, SRO Blaine Gaskill 

reacted quickly after a gunman fired one shot down 

the hallway by shooting the perpetrator in the hand 

before he could harm fellow students.4 In Ocala, FL, 

SRO Jimmy Long responded to a gunshot by rushing 

into a classroom and disarming the shooter before he 

could fire again.5

Commission Observations

Research and presentations to the Commission from 

subject matter experts like Officer Don Bridges from 

Baltimore, MD highlight the importance of defining the 

roles and responsibilities of all school staff, including 

SROs. One way to do so is through a Memorandum 

of Understanding (MOU) between schools and law 

enforcement agencies.6 These MOUs should include a 

discussion of key areas such as training expectations, 

duties and responsibilities, funding, information sharing, and student discipline. 
102 Federal Commission on School Safety: Protect and Mitigate

Sample Memorandum of Understanding 

Between the School District and Law Enforcement

The School Resource Officer (SRO) program in the Montgomery County Public Schools (MD) includes a 

Memorandum of Understanding (MOU) between four different police departments operating within the 

county, the Montgomery County State’s Attorney, and the Montgomery County Sheriff’s Office. The MOU is 

comprehensive and can serve as a model for other entities. Key provisions include:

1. Defined duties and responsibilities of the SROs (see Section B);

2. Training requirements, whereby twice annually the SROs, the school district administrators, and 

the security staff are required to participate in joint training opportunities (see Section D); 

3. Expectations about the chain of command and supervision of SROs between building level 

administrators and law enforcement (see Section H(1));

4. Expectations regarding information sharing between educators and SROs (see Section H(1)); and

5. Expectations regarding the handling of information received about a student who may pose a threat 

to himself or herself or to another (see Sections H(2), (4) & (5)).

For the full MOU, visit https://www.montgomeryschoolsmd.org/uploadedFiles/departments/security-new/

Executed%20SRO%20MOU.PDF. 

As subject matter experts such as Mo Canady, the 

Executive Director for the National Association of 

School Resources Officers (NASRO), told the Commission, it is imperative that school safety personnel 

receive extensive training and be screened for their 

effectiveness in working with students. NASRO’s 

Standards and Best Practices for School Resource 

Officers, first unveiled during the July 26 Commission 

meeting, emphasizes four main areas: administrative standards, careful selection of SROs, specialized 

SRO training, and interagency collaboration between 

schools and law enforcement.7

State education agencies (SEAs) play a key role in 

providing resources and training for all school personnel to help create and sustain a safe environment for 

students and educators. SEAs have found success in 

engaging school staff with law enforcement officers 

in unified safety training. For example, Sheriff D.J. 

Schoeff highlighted to the Commission the achievements of Indiana’s School Safety Specialist Academy. 

The Academy facilitates collaboration between educators and law enforcement officers through an annual 

two-day training in which educators from each district 

and SROs/SSOs train side by side.8

A review of state-mandated emergency drills and 

training related to school safety identified 43 states 

that required schools to conduct safety training for 

teachers or other school staff.9 Some 21 of the 43 

required training on emergency operations plans 

or emergency response procedures, and 14 of them 

required training related to mental health or violence 

prevention.10

In addition to training requirements, there are other 

considerations about personnel training such as the 

extent of collaboration between school leaders and 

law enforcement officers. Officer Rudy Perez of the Los 

Angeles Unified School District (LAUSD) explained to 

the Commission how states and school districts can 

collaboratively approach school personnel training.11

Virginia’s Center for School and Campus Safety provides in-person training on evidence-based bullying 

prevention tactics and the identification of students 

who may be at risk for violent behavior.12 The experience of the LAUSD and the Virginia Center may be of 

value to others. 
Federal Commission on School Safety: Protect and Mitigate 103

Examples of Training Requirements

The Los Angeles Unified School District (CA) offers a comprehensive emergency preparedness 

training program to build the capacity of all LAUSD employees (including educators and school police 

officers) in school safety, security, and emergency management. The Safety Training for Emergency 

Preparedness at Schools Program is a series of short, online courses that prepare employees for emergencies by detailing common procedures that employees can adopt. Participants receive certificates 

after completing each course and a Master Certificate of Emergency Preparedness for completing the 

entire series of courses. The U.S. Department of Education’s Readiness and Emergency Management 

for Schools grant funded this program. For more information, visit https://achieve.lausd.net/steps.

Virginia has created a rigorous training regimen for the certification of school security officers, 

including the following minimum requirements:

• Prospective school security officers must undergo a background investigation to include fingerprint-based criminal history record inquiry of both the Central Criminal Records Exchange and the 

Federal Bureau of Investigation;

• Have a high school diploma, have passed the General Educational Development exam, or have 

passed the National External Diploma Program;

• Be a minimum of 21 years of age;

• Possess a valid driver’s license if duties require operation of a motor vehicle;

• Successfully complete basic first aid training;

• Complete the minimum entry-level training requirements approved by the board and the 

Department of Criminal Justice Services and include, at a minimum:

• The role and responsibility of school security officers;

• Relevant state and federal laws;

• School and personal liability issues;

• Security awareness in the school environment;

• Mediation and conflict resolution;

• Disaster and emergency response; and

• Student behavioral dynamics.

6 Va. Admin. Code § 20-240-20. For more information, visit https://www.dcjs.virginia.gov/virginia-center-school-and-campus-safety/k-12/safety-security/school-security-officer-sso-certification-program. 

Indiana has statutory requirements for training SROs, including the minimum training requirements 

for law enforcement officers and at least 40 additional hours of training specific to SROs. This SRO 

training must be provided by the Indiana law enforcement training board, the NASRO, or another 

approved SRO training program. Training must include instruction on skills and strategies for school 

security. See Ind. Code § 20-26-18.2 - School Resource Officers.

Ohio has statutory requirements for training SROs, including a minimum of 40 hours of training from 

specific entities articulated in the statute including the NASRO, the Ohio school resource officer association, or a current SRO certified to conduct such training. Training requirement topics include how to 

be a positive role model for youth and strategies for classroom management. See Ohio Rev. Code Ann. 

§ 3313.951. Qualifications for school resource officers. 
104 Federal Commission on School Safety: Protect and Mitigate

As noted earlier, in 2016 some 57 percent of public 

schools reported the presence (at least once a week) 

of security staff. That number, while an increase over 

prior years, leaves almost half of America’s public 

schools without any regular school security staff 

presence. 

There are a wide variety of reasons for the decision 

not to have regular designated school security staff 

on site, ranging from funding to remoteness of locale. 

Ten states have sought to address this situation by 

allowing school staff to possess or have access to 

firearms at school. No state mandates arming school 

staff. Several hundred school districts provide school 

staff access to firearms, usually as part of a layered 

approach to school security (see Chapter 16 of the 

Report for more information about this strategy). All of 

these programs require a mandatory minimum level 

of training. Examples of effective training programs 

include the Texas School Marshal Program,13 the 

South Dakota School Sentinel Training Program,14 the 

Alabama Sentry Program,15 and the Arkansas Commissioned School Security Officer program.16

Examples of Additional State Statutes

Ga. Code Ann. § 16-11-127.1(a)(6). Weapons on school safety zones, school buildings or grounds, or 

at school functions

(6) A person who has been authorized in writing by a duly authorized official of a public or private elementary or secondary school or a public or private technical school, vocational school, college, university, or other institution of postsecondary education or a local board of education as provided in Code 

Section 16-11-130.1 to have in such person’s possession or use within a school safety zone, at a school 

function, or on a bus or other transportation furnished by a school a weapon which would otherwise 

be prohibited by this Code section. Such authorization shall specify the weapon or weapons that have 

been authorized and the time period during which the authorization is valid.

Kan. Stat. Ann. § 75-7c10(d). Same; restrictions on carrying concealed handgun; exceptions; liabilities; employees permitted to carry; penalties for violations; sign requirements.

(d) The governing body or the chief administrative officer, if no governing body exists, of any of the 

following institutions may permit any employee, who is legally qualified, to carry a concealed handgun 

in any building of such institution, if the employee meets such institution’s own policy requirements 

regardless of whether such building is conspicuously posted in accordance with the provisions of this 

section:

(1) A unified school district;

(2) A postsecondary educational institution, as defined in K.S.A. § 74-3201b, and amendments thereto.

Wyo. Stat. Ann. § 21-3-132. Possession of firearms on school property

(a) The board of trustees in each school district may adopt rules and regulations, in consultation with 

local law enforcement, to allow the possession of firearms by employees possessing a valid concealed 

carry permit under W.S. 6-8-104 on or in any property or facility owned or leased by the school district. 

Employees of a school district who hold a valid concealed carry permit issued under W.S. 6-8-104 may 

carry a concealed firearm on or into school facilities or other areas designated by the board of trustees, 

provided the employing school district has adopted rules and regulations that allow possession of firearms on school property and the employee has received approval by the board of trustees as required 

by this section.
Federal Commission on School Safety: Protect and Mitigate 105

During a field visit to the Lake Hamilton School District 

in Pearcy, AR, Commission members learned about 

the Arkansas Commissioned School Security Officer 

(CSSO) program. School leaders told them about the 

challenges small rural school districts face in terms 

of lengthy police response times. As Superintendent 

Steve Anderson said, “[w]hile we are blessed to have 

excellent law enforcement officers...because of where 

we’re located, the last two sheriffs here in Garland 

County told me we could expect 20 to 30 minutes’ wait 

time if an active shooter situation happened on campus before an officer could be here. We’re not willing 

to take that chance. We need someone to protect our 

kids.”17 As an example, the Parkland shooting took less 

than seven minutes.18

These concerns led the Arkansas legislature to amend 

Ark. Code Ann. §  17-40 et seq. to authorize the use 

of CSSOs by schools. CSSOs can be administrators, 

faculty, or staff, and they must pass a standard background check and undergo extensive training.19 In its 

preliminary report dated July 1, 2018, the Arkansas 

School Safety Commission reaffirmed the deterrent 

effect that such practices can have on school violence.20

There is no one-size-fits-all solution, and these programs vary according to the needs of each state. After 

the Parkland shooting, for example, Florida adopted 

the Marjory Stoneman Douglas High School Public 

Safety Act, which requires every school to have a “safe 

school officer.” Safe school officers can be deployed 

as an SRO, as an SSO, or through participation in the 

Coach Aaron Feis Guardian Program, which permits 

a school employee who does not work exclusively in 

the classroom to carry a weapon after completing 176 

hours of specialized training.21

Support for training

Numerous federal programs may, among other 

purposes, be used to support efforts to train school 

personnel in various school safety topics.22 Others 

specifically focus on criminal justice. For example, 

the Justice Assistance Grant (JAG) is a formula-based 

grant program that provides critical federal funding 

to states, tribes, and local governments to support 

a range of criminal justice program areas, including 

“prevention and education programs.”23 Typically, 56 

states and territories and more than 900 local and 

tribal jurisdictions receive grants each year.24

JAG funds may support firearms training for school 

personnel so long as the training is part of an allowable prevention and education program carried out 

by an authorized recipient jurisdiction. For example, 

a local law enforcement entity police department 

or sheriff’s office might choose to use part of its JAG 

funds to support a program specifically designed for 

crime prevention that incorporates such firearms 

training.25

✔ FAST FACTS

In 2016, some 57 percent of public schools reported 

the presence (at least once a week) of security staff.
106 Federal Commission on School Safety: Protect and Mitigate

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¤ STATES & LOCAL COMMUNITIES

1. States, districts, and local schools should develop a comprehensive school safety plan that includes 

a requirement for school safety training for all school personnel. When developing training for all 

school personnel, states and local communities should consider the following:

• Use specialized school personnel who are trained to prevent, recognize, and respond to threats of 

violence;

• Review the quality and quantity of training for all school staff, especially specialized school personnel and others who may carry weapons;

• Ensure that school administrators are trained on the proper role of SROs and SSOs, including how 

to work collaboratively with them;

• Clarify the roles and responsibilities of specialized school personnel such as SROs and SSOs 

through MOUs; 

• Clarify the parameters of information sharing between school staff, SROs, and SSOs, with special 

consideration and training regarding the privacy requirements of the Family Educational Rights 

and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act (HIPAA); and

• Determine, based on the unique circumstances of each school (such as anticipated law enforcement response times), whether or not it is appropriate for specialized staff and non-specialized 

staff to be armed for the sake of effectively and immediately responding to violence. This can 

be particularly helpful in districts where the distances involved can make police response times 

longer.

2. States and local communities, in concert with law enforcement, should consider various approaches 

to school safety based on their own unique needs. School districts may consider arming some 

specially selected and trained school personnel (including but not limited to SROs and SSOs) as a 

deterrent. Before deciding on the voluntary arming of school personnel, states, districts, and schools 

should carefully consider the following:

• Existing security measures

What types of security measures already exist to ensure student safety? 

Is there a full-time SRO already present in case of emergency? 

• Proximity of police

How quickly can local police arrive in the event of an active shooter? 

How well do local police know the school (e.g., layout of the school, area around the school) in 

order to coordinate an effective response?

• Acceptance of the school community

Are school community stakeholders comfortable with arming school personnel? 

Are there staff members willing to voluntarily participate in such a program, particularly those with 

prior law enforcement or military training? 
Federal Commission on School Safety: Protect and Mitigate 107

Chapter 13 Endnotes

1 Musu-Gillette, L., Zhang, A., Wang, K., Zhang, J., Kemp, J., Diliberti, M., 

& Oudekerk, B.A. (2018). Indicators of school crime and safety: 2017. 

(NCES 2018-036/NCJ 251413). National Center for Education Statistics, 

U.S. Department of Education and Bureau of Justice Statistics, Office of 

Justice Programs, U.S. Department of Justice. Washington, DC. https://

nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2018036

2 Marjory Stoneman Douglas High School Public Safety Commission. 

(June 6, 2018). Marjory Stoneman Douglas High School Public Safety 

Commission Part 1. Retrieved from https://thefloridachannel.org/

videos/6-7-18-marjory-stoneman-douglas-high-school-public-safetycommission-part-1.

3 Victor, D. (May 17, 2018). School resource officer stopped school 

shooting, authorities say. Retrieved from New York Times: https://

www.nytimes.com/2018/05/17/us/dixon-school-shooting.html; 

Grinberg, E., & Watts, A. (May 17, 2018). This officer stopped a school 

shooter before anyone got hurt. Retrieved from CNN: https://www.cnn.

com/2018/05/16/us/illinois-dixon-high-school-shooting/index.html. 

Following the incident, Secretary DeVos spoke with Officer Dallas about 

this experience. For additional examples of how SROs and other individuals avert instances of school violence, visit https://www.asvnearmiss.

org/publications/ (funded by the National Institute of Justice (NIJ) and 

the U.S. Department of Justice’s Office of Community Oriented Policing 

(COPs)).

4 National Association of School Resource Officers. (2018). Organization 

honors two other school resource officers for valor. Retrieved from 

https://nasro.org/news/press-releases/hawaii-police-officer-named-national-school-resource-officer-year/.

5 National Association of School Resource Officers. (2018). Organization 

honors two other school resource officers for valor. Retrieved from 

https://nasro.org/news/press-releases/hawaii-police-officer-named-national-school-resource-officer-year/.

6 Statement from Don Bridges to the Federal Commission on School 

Safety (July 26, 2018). https://www2.ed.gov/documents/school-safety/

transcript-07-26-2018.pdf.

7 National Association of School Resource Officers. (July 26, 2018). 

National school policing association announces recommended 

standards and best practices. Retrieved from https://nasro.org/news/

press-releases/national-school-policing-association-announces-recommended-standards-best-practices/.

8 Indiana Department of Education. (2018). School building physical security and safety. Retrieved from https://www.doe.in.gov/safety.

9 U.S. Department of Education, Office of Elementary and Secondary 

Education, Office of Safe and Healthy Schools. (2018). Internal review: 

Research on state-mandated emergency drills and exercises and staff 

training related to school safety. Washington, DC: Readiness and Emergency Management for Schools Technical Assistance Center.

10 During the 2015–2016 school year, 93 percent of public schools 

conducted training on safety procedures, and 82 percent of schools conducted training on positive behavioral interventions. Additionally, 71 

percent of schools conducted training on crisis prevention and intervention, and 53 percent of schools provided training on intervention and 

referral strategies for students with signs of mental health disorders. 

Also, Musu-Gillette, L., Zhang, A., Wang, K., Zhang, J., Kemp, J., Diliberti, 

M., & Oudekerk, B.A. (2018). Indicators of school crime and safety: 2017. 

(NCES 2018-036/NCJ 251413). National Center for Education Statistics, 

U.S. Department of Education and Bureau of Justice Statistics, Office of 

Justice Programs, U.S. Department of Justice. Washington, DC.

11 Statement from Rudy Perez to the Federal Commission on School 

Safety (July 26, 2018). https://www2.ed.gov/documents/school-safety/

transcript-07-26-2018.pdf.

12 Virginia law (Va. Code Ann. § 9.1-184) requires the Virginia Center for 

School and Campus Safety (Center) to provide training for public school 

personnel on evidence-based anti-bullying tactics, as well as how to 

identify students who may be at risk for violent behavior and in need 

of special services. The Center is also required to develop, along with 

other Virginia State agencies, a model “critical incident” (e.g., an active 

shooter) training program for public school personnel. Private schools 

may also participate in the training. The training programs are provided 

in-person to schools (including school security officers), either through 

Center staff or contractors. For additional information, see https://www.

dcjs.virginia.gov/virginia-center-school-and-campus-safety.

13 First enacted in 2013, the Texas School Marshal Program authorizes 

public school districts and open enrollment charter schools to appoint 

certain qualifying individuals to serve as school marshals to prevent 

or abate the commission of any offense that threatens serious bodily 

injury or death to students, faculty, or visitors on school premises. See 

Tex. Code Crim. Proc. Ann. Art. 2.127; Tex. Educ. Code Ann. § 37.0811; Tex. 

Gov’t. Code § 411.1871; Tex. Occ. Code § 1701.260, 1701.001; 1701.301. An 

employee of a school district or an open-enrollment charter school, 

school marshals are authorized to carry or possess a handgun on the 

physical premises of a school. Tex. Educ. Ann. § 37.0811. Marshals must 

attend an 80-hour training course conducted by a law enforcement 

academy specifically prepared to provide a school marshal curriculum, 

and must hold an appropriate gun license issued by the Texas Commission on Law Enforcement. Tex. Occ. Code §1701.260 & 1701.301. Course 

material includes topics such as physical security, use of force, active 

shooter response, and weapon proficiency. Tex. Occ. Code § 1701.260. 

See more at https://www.tcole.texas.gov/content/school-marshals.

14 Office of the Attorney General of South Dakota. (n.d.). School Sentinel 

Training Program. Retrieved from https://atg.sd.gov/LawEnforcement/

Training/schoolsentinel.aspx.

15 Office of the Governor of the State of Alabama. (May 30, 2018). Governor 

Ivey announces Alabama Sentry Program to train administrators in school 

security. Retrieved from https://governor.alabama.gov/press-releases/

governor-ivey-announces-alabama-sentry-program-to-train-administrators-in-school-security/.

• Preparedness

What would initial and ongoing background checks and screening requirements entail?

What initial and ongoing robust training requirements would be in place?

How would firearms be properly secured yet made easily accessible when necessary?

• Local policy and state law

Does local policy and state law allow for the arming of school personnel? 

What infrastructure and resources exist for the creation of such a program?

What potential liabilities exist for such a program (e.g., ability to maintain insurance coverage)?
108 Federal Commission on School Safety: Protect and Mitigate

16 Ark. Code Ann. § 17-40-330 et seq.

17 Statement from Superintendent Steve Anderson to the Federal Commission on School Safety (2018, August 1). https://www2.ed.gov/documents/school-safety/transcript-07-26-2018.pdf

18 https://www.nytimes.com/2018/02/16/us/stoneman-douglas-shooting.

html.

19 Ark. Code Ann. §17-40-102 provides: “(10) ‘Commissioned school security 

officer’ means a private security officer who: (A) Provides security for 

the school; and (B) Has received an authorization issued by the director 

to carry a firearm in the course of his or her employment.” A CSSO is a 

Private Security Officer who has completed additional training, and who 

has been granted the authorization by the Arkansas State Police to carry 

a firearm while on the property of a public-school (K–12). http://www.

arkansased.gov/divisions/communications/safety.

20 Arkansas Department of Education. (July 1, 2018). Arkansas School 

Safety Commission: Preliminary report. Retrieved from http://www.

arkansased.gov/public/userfiles/Communications/School_Safety/

Safe_School_Commission_Preliminary_Report_-_July_1_2018..pdf.

21 The Florida Senate. (2018). CS/SB 7026. Public safety. Retrieved from 

https://www.flsenate.gov/Session/Bill/2018/07026.

22 Supporting Effective Instruction Grants (https://www2.ed.gov/programs/teacherqual/index.html) may support programs for recruiting 

and training teachers, school leaders, and other staff from other fields, 

including military and law enforcement, to become teachers, principals, or other school leaders; providing professional development to 

educators to help engage parents, families, and community partners, 

and coordinate services between school and community; training to 

help educators understand when and how to refer students affected by 

trauma, and children with, or at risk of, mental illness; and addressing 

issues related to school conditions for student learning, such as safety, 

among other allowable uses of funds. Title I grants to local educational 

agencies (https://www2.ed.gov/programs/titleiparta/index.html) may 

support school districts in training teachers, school leaders, and other 

staff as part of schoolwide program plans that, in response to a needs 

assessment, address school climate and safety, including disciplinary 

interventions and violence prevention. Student Support and Academic 

Enrichment grants (https://www2.ed.gov/programs/ssae/index.html) 

and grants under both REAP programs (SRSA and RLIS) may be used 

for activities to support safe and healthy students, such as high-quality 

training for school personnel, including specialized instructional support personnel, related to suicide prevention, effective and trauma-informed practices in classroom management, crisis management and 

conflict resolution techniques, school-based violence prevention strategies, and bullying and harassment prevention, among other allowable 

uses of funds. 

23 34 U.S.C. § 10152(a)(1)(C). Also, U.S. Department of Justice, Bureau of 

Justice Assistance. (n.d.). Edward Byrne Memorial Justice Assistance 

Grant Program. Retrieved from https://www.bja.gov/jag/.

24 U.S. Department of Justice, Bureau of Justice Assistance. 

25 To seek JAG funds for such purposes, schools should reach out to their 

local recipient jurisdictions (local police departments, sheriff’s offices, 

or local or tribal government representatives) or to their State Administering Agency for JAG funds, which is the designated agency in each 

state that has a role in allocating JAG resources statewide.
Federal Commission on School Safety: Protect and Mitigate 109

CHAPTER 14

Emergency and Crisis Training for Law Enforcement

When school violence erupts, it is law enforcement 

officers who rush to the scene, neutralize the shooter, 

assist victims, and secure the site. The Parkland 

shooting was no different. Unfortunately, too many 

law enforcement officers around the country have 

been called upon to respond to such incidents. Those 

who have not are training and preparing for a day they 

hope will never come.

The U.S. Department of Justice provides a wide array 

of emergency and crisis training resources for state, 

local, and tribal law enforcement agencies across the 

country. Through the Bureau of Justice Assistance, the 

Office of Community Oriented Policing Services, and 

the Federal Bureau of Investigation (FBI), the Department offers grant funding, training and technical 

assistance, and other resources for those on the front 

lines working to keep students safe. These programs 

are outlined below.

Bureau of Justice Assistance 

Justice Assistance Grant: This is a formula-based 

grant program that provides states, tribes, and local 

governments with critical funding to support a range 

of program areas. The latter include law enforcement, 

prosecution and courts, crime prevention and education, corrections and community corrections, drug 

treatment and enforcement, planning, evaluation and 

technology improvement, crime victim and witness 

initiatives, mental health programs, and related law 

enforcement and corrections programs. Under this 

grant program, emergency and crisis training for local 

law enforcement can be an allowable cost. Typically, 

56 states and territories and more than 900 local and 

tribal jurisdictions receive grants each year.1

National Training and Technical Assistance Center: 

NTTAC offers online and no-cost training and technical 

assistance on a wide variety of criminal justice topics, 

including emergency and crisis training for local law 

enforcement.2

Identifying an Armed Person Training: This training, 

which is provided as part of the Project Safe Neighborhoods training and technical assistance support, 

covers guidance for handling felonious possession and 

use of firearm cases. It includes techniques for identifying/recognizing vehicles with hidden compartments 

and advanced techniques to identify/recognize armed 

suspects and their characteristics.3

VALOR Officer Safety and Wellness Training and 

Technical Assistance Program: The VALOR program 

delivers current, dynamic classroom and web-based 

trainings focused on recognizing indicators of dangerous situations. It involves applying a cognitive 

approach towards reinforcing effective techniques for 

managing difficult encounters, implementing casualty 

care and rescue tactics, and improving wellness and 

resilience. Since 2010, the VALOR Program has trained 

more than 41,400 law enforcement officers.4

Office of Community Oriented Policing Services

Preparing for Active Shooter Situations (PASS) 

Training Program: PASS supports active shooter training to improve the safety and resiliency of law enforcement officers, other first responders, and communities. It seeks to enhance the ability of law enforcement 

not only to secure the scene, but also to increase the 

survivability of the event and protect officers, critical 

assets, and first responders from the long-term effects 

of exposure to trauma. In addition to online training, more than 15,000 participants receive in-person 

training with existing funding, and FY2018 funding 

supports the delivery of 438 classes across the country 

that will train more than 16,000 first responders. PASS 

is also adding to its portfolio more classes in advanced 

medical skills, solo officer rapid deployment, civilian 

Through the Bureau of Justice Assistance, the 

Office of Community Oriented Policing Services, 

and the Federal Bureau of Investigation (FBI), the 

Department offers grant funding, training and 

technical assistance, and other resources for those 

on the front lines working to keep students safe.
110 Federal Commission on School Safety: Protect and Mitigate

casualty care, and exterior response to active shooter 

events.5

School Violence Prevention Program: SVPP makes 

competitive awards to states, counties, and local 

districts to support coordination with law enforcement on training to prevent student violence, to fund 

deterrent hardware, and to implement technology for 

expedited emergency notification.6

Federal Bureau of Investigation

Behavioral Analysis Unit (BAU) Active Shooter 

Reports: These BAU studies focus on the detection 

and disruption of targeted violence attacks in myriad 

settings, including K–12 schools. 

• The School Shooter: A Threat Assessment Perspective presents a systematic procedure for threat 

assessment and intervention for use by educators, 

mental health professionals, and law enforcement 

agencies.7

• Campus Attacks: Targeted Violence Affecting Institutions of Higher Education was prepared by the FBI, 

the U.S. Secret Service, and the U.S. Department of 

Education. It provides an overview of targeted violence at institutions of higher education, discusses 

initial observations regarding behaviors of the 

offenders, and offers preliminary considerations on 

the data that may have relevance to threat assessment.8

• Making Prevention a Reality: Identifying, Assessing, 

and Managing the Threat of Targeted Attacks is 

a collaboration between representatives of law 

enforcement, academia, law, and mental health, 

along with the FBI’s Behavioral Threat Assessment 

Center and the National Center for the Analysis of 

Violent Crime. It provides a useful and practical 

guide for understanding and implementing threat 

assessment and management at all levels.9

• A Study of the Pre-Attack Behaviors of Active Shooters in the U.S. Between 2000 and 2013 examines 

the pre-attack behavior of shooters in 160 active 

shooter incidents in an effort to pinpoint specific 

behaviors that might be useful in identifying, 

assessing, and managing those who might be on 

the pathway to such violence.10

Active Shooter Incidents Reports: The reports cited 

below focus on a specific type of shooting situation that law enforcement and the public may face. 

Though limited in scope, they provide clarity and 

valuable data to federal, state, tribal, and campus law 

enforcement as well as other first responders, corporations, educators, and the general public as they seek 

to neutralize threats posed by active shooters and 

save lives during such events. 

• A Study of Active Shooter Incidents in the United 

States Between 2000 and 201311

• Active Shooter Incidents in the United States in 

2014 and 201512

• Active Shooter Incidents in the United States in 

2016 and 201713

Crisis Communications Quick Reference Guide: This 

brochure is tailored to chiefs, sheriffs, command staff, 

and public information officers who handle crisis communications in response to an active shooter, mass 

casualty, or other law enforcement incidents. It provides checklists for the pre-event, the onset of the incident, and updating the media (pre-press conference 

and second and subsequent press conferences). Also 

included are 10 tips to improve communications.14

The following resources are available to law enforcement and emergency management professionals by 

contacting the nearest FBI Field Office or calling 202-

324-3000.

Behavioral Threat Assessment Center: The BTAC 

provides both operational support and training to 

K–12 schools, law enforcement, institutions of higher 

education, houses of worship, and private businesses. 

It remains the only multi-agency, behaviorally based 

threat assessment center operating within the federal 

government. The BTAC features representation from 

the FBI, the Bureau of Alcohol, Tobacco, Firearms and 

Explosives, the U.S. Capitol Police, and the Department of Defense’s Naval Criminal Investigative Services, and is staffed by experienced agents, analysts, 

certified threat managers, and a contract forensic psychiatrist. It provides a full suite of threat assessment 

and management services to assist K–12 schools and 

local law enforcement agencies in efforts to mitigate 

school shootings. 

On average, the BTAC annually receives more than 

150 requests for operational assistance in managing 

complex, urgent matters involving potentially violent individuals. This system focuses (a) on providing 

operational support related to K–12 school shootings 
Federal Commission on School Safety: Protect and Mitigate 111

and the prevention of acts of targeted violence against 

our children; and (b) on delivering the highest quality 

threat assessment training to law enforcement, mental health, and education professionals. 

The BTAC is supported by a robust field program 

involving more than 230 FBI Special Agents with 

advanced active shooter/school shooter and threat 

assessment training who serve as the liaison between 

schools and the BTAC. Since 2007, training on the 

pre-attack behaviors of school shooters has been 

delivered to more than 30,000 K–12 educators, law 

enforcement officers, and mental healthcare practitioners throughout the United States. 

Active Shooter: Managing the Mass Casualty Threat. 

This 35-minute DVD provides an in-depth look at three 

unique active shooter events: the Century Aurora 16 

Cinemark theatre shooting in Aurora, CO, the Washington Navy Yard shooting in Washington, D.C., and 

the Los Angeles International Airport shooting in 

Los Angeles, CA. Each story is told by the emergency 

professionals and private sector partners who were 

there. They offer a frank and introspective look at 

what worked and what could have been done better 

to manage these chaotic incidents. 

Initial On Scene Command Considerations. A two-inch 

by three-inch pocket guide, it delineates vital issues 

that need to be considered during the initial minutes 

and hours of an active shooter, mass casualty, or other 

law enforcement incident. Topics include priority 

staging areas, top-tier priority concerns, and secondary-tier priority concerns. 

Tactical Considerations for Law Enforcement: Quick 

Reference Guide. This two-inch by three-inch pocket 

guide covers pre-scene considerations, scene arrival, 

training, equipment, and active shooter lessons 

learned.

The Coming Storm. Through a fictional attack on a 

college campus, this DVD illustrates lessons learned 

and best practices drawn from real-life active shooter 

incidents. It offers practical and detailed first steps law 

enforcement should take when arriving at the scene 

of a critical incident. The film is designed to inspire 

discussion, preparation, and collaboration in managing these devastating and potentially overwhelming 

events. 

A Revolutionary Act. This documentary plus workshop 

seek to educate the law enforcement community on 

“the pathway to violence” and key warning behaviors. 

This can be useful to school resource personnel as the 

documentary traces the radicalization of shooters by 

their online media activity.
112 Federal Commission on School Safety: Protect and Mitigate

Chapter 14 Endnotes

1 https://www.bja.gov/jag/.

2 www.bjatraining.org.

3 http://www.theiacp.org/psnInitiative.

4 www.valorforblue.org.

5 https://cops.usdoj.gov/default.asp?Item=2936.

6 https://cops.usdoj.gov/default.asp?Item=2958.

7 https://www.fbi.gov/file-repository/stats-services-publications-schoolshooter-school-shooter/view.

8 https://www.fbi.gov/stats-services/publications/campus-attacks.

9 https://www.fbi.gov/file-repository/making-prevention-a-reality.pdf/

view.

10 https://www.fbi.gov/file-repository/pre-attack-behaviors-of-activeshooters-in-us-2000-2013.pdf/view.

11 https://www.fbi.gov/file-repository/active-shooter-study-2000-2013-1.

pdf/view.

12 https://www.fbi.gov/file-repository/activeshooterincidentsus_2014-2015.pdf/view.

13 https://www.fbi.gov/file-repository/active-shooter-incidents-us-2016-2017.pdf/view.

14 https://www.fbi.gov/file-repository/as-study-quick-reference-guide-updated1.pdf/view.

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendation below.

¤ STATES & LOCAL COMMUNITIES

1. State and local law enforcement should take advantage of these resources to assist them in preventing, planning for, and responding to school shooting incidents. They are also encouraged to 

suggest areas in which additional resources might be useful.
Federal Commission on School Safety: Protect and Mitigate 113

CHAPTER 15

The Transition of Military Veterans and Retired 

Law Enforcement Officers into New Careers in Education

Military veterans and retired law enforcement officers 

often have the leadership, experience in high-stress 

environments, and essential training to help ensure 

the safety and security of our nation’s schools. Many 

will also possess pedagogical skills—classroom 

management and real-world experience training 

others—that can make for highly effective educators. 

Former service members and police officers stepping 

into roles as principals, administrators, teachers, 

counselors, school resource officers (SROs), and other 

school-related positions could help foster safety in our 

schools. 

As some have noted, “administrators are increasingly 

finding that many service members make good teachers.”1

 The Troops to Teachers (TTT) program of the U.S. 

Department of Defense has placed more than 21,000 

veterans since 1993 into teaching positions across 

the country.2 TTT officials believe “veterans are an 

untapped resource to respond to a nationwide teacher 

shortage that has made it difficult to fill positions at 

high-needs schools and in math and special education.”3

Despite the success of efforts to place veterans into 

teaching positions, just 2.1 percent of U.S. teachers in 

2016 were veterans.4 School campuses would benefit 

from more veterans and retired law enforcement officers serving our nation’s students.

In recent years, several school shootings have been 

stopped due to the actions of police officers serving 

as SROs. For example, Officer Mark Dallas’s 24 years 

of law enforcement experience aided him in chasing 

down and neutralizing a shooter at a school in Dixon, 

IL.5 Similarly, Deputy Blaine Gaskill, a SWAT-trained 

officer who was working as an SRO at a school in Leonardtown, MD, responded rapidly to a school shooter 

and disabled him before he could fire another shot at 

one of his fellow students.6

Since the Columbine tragedy, several commissions 

at state and local levels have addressed the issue 

of school shootings. A task force report in response 

to the Parkland shooting was the first major school 

safety report that specifically addressed the topic 

of hiring retired law enforcement officers as SROs. It 

identified some of the financial and legal challenges in 

doing so: “pension plans prohibit re-hiring for a period 

of time post-separation and there are significant tax 

penalties for violating these prohibitions; there is still 

a need for background checks, screening and potentially training.”7

 The report proposed a legislative 

recommendation “to allow agencies to re-hire certified law enforcement officers, preempting the pension 

provisions which prohibit re-hiring during [a] separation period without penalty.”8

School safety would benefit from more veterans and 

retired law enforcement officers leveraging their 

knowledge and experience to serve our nation’s students in a variety of school roles. These individuals not 

only have the potential to be effective educators in the 

classroom but also are underutilized human assets for 

securing and protecting our schools. Because of their 

unique skillset with managing conflict and emergency 

preparedness, they can help foster safe school climates by serving on school safety committees, mentoring at-risk youth, or volunteering in other meaningful 

ways. 

Commission Observations

Commission research identified many programs and 

resources that can help veterans and retired law 

enforcement officers transition into new careers in 

“veterans are an untapped resource to 

respond to a nationwide teacher shortage 

that has made it difficult to fill positions 

at high-needs schools and in math and 

special education.”
114 Federal Commission on School Safety: Protect and Mitigate

education. The TTT program provides counseling and 

referral services for any interested active duty service 

member or honorably discharged veteran to help 

them meet the education and licensing requirements 

necessary to secure a teaching position.9

In addition, TTT grants to states support offices for 

recruitment and placement assistance for service 

members and veterans. For example, a TTT center 

in Virginia works with all colleges in the state to 

help veterans become licensed as teachers and find 

teaching positions in Virginia.10 One study found that 

TTT instructors are particularly effective in classroom 

management and maintaining student discipline.11

Principals say TTT participants provide a stable cadre 

of effective teachers who teach high-demand subjects 

in high-poverty schools.

Other local programs support TTT efforts. For example, the Los Angeles Unified School District military 

liaison and human resources office offers services to 

interested veterans. This includes fast-track application review, individualized guidance, and access to 

veteran support organizations that offer financial and 

career development.12

The U.S. Department of Veterans Affairs provides a 

variety of education benefits to help eligible veterans pay for tuition, training, and certification tests 

to support the transition into new careers in education.13 Veterans and law enforcement officers can take 

advantage of the Teacher Education Assistance for 

College and Higher Education (TEACH) grant program. 

This provides grants of up to $4,000 per year to college 

students who agree to teach for four years at schools 

serving students from low-income families.14

Law enforcement officers can also transition to a 

new career as a school resource officer through the 

Department of Justice’s Office of Community Oriented 

Policing Services (COPS) Hiring Program.15 Various 

other federal programs may, among other purposes, 

potentially support efforts to recruit and retain military and law enforcement officers as teachers, school 

leaders, and other staff.16

Additionally, a number of nonprofit organizations support veterans and law enforcement officers seeking 

to move into careers in education. Teach For America 

has placed more than 50,000 teachers in high-need 

classrooms, including 314 veterans. The organization 

maintains a recruiting initiative (“You Served For 

America, Now Teach For America”) and partnerships 

with TTT and other nonprofits to encourage veterans 

to consider the teaching profession.17

The Mission Continues is a nonprofit organization 

with more than 11,000 veterans engaged nationwide 

in various community projects, including mentoring 

at-risk youth in schools. In one of the organization’s 

projects, 72 veterans served alongside local volunteers 

to revitalize neighborhoods, parks, and schools in 

Detroit, MI.18

Veterans and law enforcement officers face various 

challenges when transitioning into new careers in 

education. 

• There is duplication and a general lack of coordination and control over the array of programs and 

resources to support the transition of veterans and 

retired law enforcement officers into careers in 

education. Many veterans and retired law enforcement officers are unaware of or may not fully 

understand the benefits of available programs. 

• Most programs are limited in scope, focusing on 

recruiting, preparing, and placing veterans and law 

enforcement officers as teachers in high-poverty 

public schools. Other education positions (such 

as SROs, security personnel, principals, administrators, deans, counselors, nurses, teacher aides, 

and other support personnel) are not eligible for 

the TTT program. While all schools could benefit 

from veterans and retired law enforcement officers 

helping to improve school safety, TTT is limited to 

high-poverty schools. The program should consider 

expanding the scope of eligible schools.

• State licensure and certification requirements 

can be excessive and unnecessarily burdensome 

for veterans and law enforcement officers seeking to transition into careers in education. A 2013 

Calvert Institute for Policy Research report found 

that becoming certified to teach in Maryland is so 

burdensome that it is causing teacher shortages 

in key subjects such as science, math, and special education. The report suggests that the state 

consider altering some of its teacher certification 

requirements to open the field to a larger number 

of candidates.19
Federal Commission on School Safety: Protect and Mitigate 115

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. Congress should pass legislation that establishes a public-private partnership led by a single federal 

agency to unify the funding and operational control of identifying and recruiting more veterans and 

retired law enforcement officers into new careers in education. A public-private partnership could 

help ensure the reach and sustainability of existing programs. 

2. Congress should change the intent and scope of the TTT program, broadening its reach to include 

a wide range of education professionals such as principals, administrators, nurses, counselors, and 

school resource officers, in addition to teachers. 

3. Congress should amend the TTT program to provide financial assistance to veterans and law 

enforcement officers when teaching at any U.S. school. Because of the importance of school safety 

issues to all schools, whether high-poverty or not, Troops to Teachers could expand the scope of 

eligible schools. 

4. The U.S. Department of Defense should consider promoting careers in education for future veterans 

throughout the military life cycle; creating a “future in education” curriculum within the Transition 

Assistance Program; and authorizing programs such as Skillbridge and the Army’s Career Skills 

Program to partner with state and local school districts. 

¤ STATES & LOCAL COMMUNITIES

1. States and districts should consider offering incentives and additional resources to recruit veterans 

and law enforcement officers into careers in education. Policies, programs, and incentives could 

include:

• Instituting fast-track application reviews for veteran and law enforcement applicants (e.g., as 

done by the Los Angeles Unified School District);

• Collecting and using data on veterans and law enforcement officers, including number of applications, hiring, and retention;

• Adding preference points to a job candidate’s score for relevant military and law enforcement 

experience;

• Employing a dedicated hiring officer to recruit and hire veterans and law enforcement officers; 

and

• Participating in the U.S. Department of Veteran Affairs GI Bill On-The-Job training and apprenticeship program as a way to attract veteran candidates to school employment positions.
116 Federal Commission on School Safety: Protect and Mitigate

2. States should reduce barriers to certification and incorporate appropriate incentives and programs 

that help veterans and law enforcement officers enter new careers in education. Policies, programs, 

and incentives could include: 

• Encouraging districts to provide compensation structures that include salary credit for prior 

military and law enforcement experience;

• Providing districts with financial incentives to hire significant numbers of veterans and law 

enforcement officers;

• Changing state legislation and policies that prevent local agencies from re-hiring certified law 

enforcement officers because of pension penalties;

• Establishing a dedicated military veteran and/or retired law enforcement liaison position;

• Applying for TTT grants and/or establishing a state center designed to conduct outreach and 

certification support to veterans and law enforcement officers; and

• Partnering with Department of Defense programs such as Skillbridge and the Army’s Career 

Skills Program.20
Federal Commission on School Safety: Protect and Mitigate 117

Chapter 15 Endnotes

1 Toppo, G. (January 2, 2013). Vets go from the front lines of the class. 

Retrieved from USA Today. https://www.usatoday.com/story/news/

nation/2013/01/02/soldier-teachers/1804537/.

2 Troops to Teachers (n.d.) About. Retrieved from: https://proudtoserveagain.com/About/Overview.

3 Balingit, M. (June 16, 2017). From the battlefield to the classroom: Are 

veterans a solution to teacher shortage? Retrieved from the Washington 

Post: https://www.washingtonpost.com/local/education/from-thebattlefield-to-the-classroom-are-veterans-a-solution-to-teachershortage/2017/06/16/346d51b2-4185-11e7-8c25-44d09ff5a4a8_story.

html?utm_term=.fcf87e857ea7. 

4 Hefling, K., & Doherty, T. (March 1, 2018). Trump sees veterans as the 

perfect armed teachers, but they’re divided. Retrieved from Politico. 

https://www.politico.com/story/2018/03/01/trump-armed-teachers-veterans-373732.

5 Victor, D. (May 17, 2018). School resource officer stopped school 

shooting, authorities say. Retrieved from New York Times. https://

www.nytimes.com/2018/05/17/us/dixon-school-shooting.html. Also, 

Grinberg, E. & Watts, A. (May 17, 2018). This officer stopped a school 

shooter before anyone got hurt. Retrieved from CNN. https://www.cnn.

com/2018/05/16/us/illinois-dixon-high-school-shooting/index.html.

6 Hendrix, S., & Vargas, T. (March 20, 2018). School resource officer Blaine 

Gaskill rushed to stop gunman at Maryland high school. Retrieved from 

Washington Post: https://www.washingtonpost.com/local/school-resource-officer-blaine-gaskill-helped-stop-gunman-at-a-maryland-highschool/2018/03/20/639a8e42-2c66-11e8-b0b0-f706877db618_story.

html.

7 The Broward County League of Cities’ School and Community Public 

Safety Task Force (June 4, 2018). Initial report and recommendations. 

Retrieved from http://browardleague.org/wp-cnt/uploads/2018/06/

BLOC_PUBLICSAFETY_TASKFORCE_FINAL_RR_6_2_18_PM1.pdf.

8 Ibid. at p. 85.

9 The program also offers a bonus of up to $10,000, which may be available for eligible participants teaching three years at a school that meets 

the “eligible” or “high-need” school criteria. For more information, visit 

the following website: https://proudtoserveagain.com/. Also, Troops 

to Teachers (n.d.). Overview Retrieved from https://proudtoserveagain.

com/About/Overview.

10 Satchell, E. (May 12, 2017). Grant will establish Troops to Teachers 

Center at William & Mary. Retrieved from http://www.wavy.com/

news/grant-will-establish-troops-to-teachers-pilot-program-at-william-mary/1060881880. For additional information, visit the following 

website: https://troopstoteachersvirginia.wm.edu/about/.

11 Owings, W.A., Kaplan, L.A., Khrabrova, I., & Chappell, S. (2015). Troops 

to Teachers update: Changing but still pleasing principals with high 

teaching quality. NASSP Bulletin, 99(1), at pp. 70–98.

12 Los Angeles Unified School District. (2018). Troops to education. 

Retrieved from https://achieve.lausd.net/Page/11121.

13 U.S. Department of Veteran Affairs (n.d.). Education and training. 

Retrieved from https://explore.va.gov/education-training. Additionally, the post-9/11 GI Bill provides eligible veterans up to 36 months of 

education benefits that covers in-state tuition. Eligible veterans may 

also be entitled to the following payments as well: monthly housing 

allowance, annual books and supplies stipend, and a one-time rural 

benefit. For more information, visit https://www.benefits.va.gov/gibill/

post911_gibill.asp.

14 Federal Student Aid: An Office of the U.S. Department of Education 

(n.d.). TEACH Grants. Retrieved from https://studentaid.ed.gov/sa/types/

grants-scholarships/teach.

15 Omnibus Crime Control and Safe Streets Act of 1968, 34 U.S.C. § 10381, 

as amended, and the Violent Crime Control and Law Enforcement Act of 

1994, Title I, Part Q, Pub. L. No. 103-322. Also, DOJ COPS Office Application Guide is available at https://cops.usdoj.gov/pdf/2017AwardDocs/

chp/app_guide.pdf.

16 For example, Supporting Effective Instruction State grants (https://

www2.ed.gov/programs/teacherqual/index.html) and grants under 

both REAP programs (SRSA and RLIS) (https://www2.ed.gov/nclb/freedom/local/reap.html) can support recruitment and retention efforts. 

Supporting Effective Educator Development grants (https://innovation.

ed.gov/what-we-do/teacher-quality/supporting-effective-educator-development-grant-program/) support alternative pathways to education 

careers that allow teachers and principals with nontraditional preparation and certification to obtain employment in underserved school 

districts.

17 Teach For America (2018). Our work. Retrieved from https://www.

teachforamerica.org/about-us/our-work. Also, Teach For America 

(2018). You served for America, now teach for America. Retrieved from 

https://www.teachforamerica.org/about-us/our-initiatives/military-veterans-initiative. Also, Gross, N. (April 26, 2016). Teach For America offers 

vets a second chance at public service. Retrieved from Military Times

Reboot Camp https://rebootcamp.militarytimes.com/education-transition/2017/04/26/teach-for-america-offers-vets-a-second-chance-atpublic-service/.

18 The Mission Continues (2018). The mission continues. Retrieved from 

https://missioncontinues.org/. Also, The Mission Continues (2018). Mass 

deployments. Retrieved from https://missioncontinues.org/deployments/.

19 Bowie, L. (September 6, 2013). Md.’s teacher certification law criticized 

as too tough. Retrieved from the Baltimore Sun. http://www.baltimoresun.com/news/maryland/education/bs-md-teacher-certification-20130829-story.html.

20 These programs are designed to prepare transitioning service members 

for civilian training through on-the-job training and internships, 

which could include school-based positions. For more information, visit https://dodskillbridge.com/ and https://www.army.mil/

standto/2017-07-13.
118 Federal Commission on School Safety: Protect and Mitigate

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Federal Commission on School Safety: Protect and Mitigate 119

In attempting to provide secure learning environments through school design and physical hardening, 

schools must balance many different objectives. These 

include reducing risks, maintaining open access for 

students and staff, facilitating a learning environment, 

and complying with required buildings codes and 

standards.1 However, most schools present a variety of 

avenues for “designing in” layers of security, starting 

with controlling access at the school’s perimeter and 

working inward to secure individual classrooms and 

other internal spaces. 

Previous Administrations have explored hardening 

schools. The Report to the President on the Issues 

Raised by the Virginia Tech Tragedy stressed the importance of emergency management planning, but did 

not directly address physical hardening of schools. 

However, it did recommend that schools use technology to improve security systems.2

 The Obama Administration’s plan to protect children assumed the need 

for physical security at schools and made it an explicit 

recommendation.3 It also proposed the creation of 

Comprehensive School Safety Grants for the purchase 

of, among other things, school safety equipment.4

State-level commissions also have a mixed record of 

studying school hardening. The Columbine Review 

Commission expressed concern over the cost of 

physically hardening schools and the lack of evidence 

demonstrating its impact in reducing school violence. 

Ultimately it recommended that security devices 

should be used as preventative measures for specific 

problems at individual schools but not as a broadbased antidote to school violence.5

 Conversely, the 

Sandy Hook Advisory Commission focused much of its 

report on “safe school design and operation,” largely 

endorsing the detailed school design standards developed by the Connecticut School Security Infrastructure Council.6

 While doing so, the Sandy Hook Advisory Commission articulated some key principles that 

are well-established today, such as ensuring school 

security design enhances, rather than diminishes, the 

school’s central educational mission.7

A full analysis of the school security measures in place 

at the time of the shooting at Parkland’s Marjory 

Stoneman Douglas (MSD) High School was still being 

developed at the time of the finalization of this Report 

by the MSD High School Public Safety Commission.8

However, public reporting on the incident provides a 

general outline of some of the vulnerabilities in the 

school’s overall physical security that the shooter 

exploited. For instance, MSD reportedly had classroom doors that could only be locked with a key from 

outside the classroom, requiring teachers to reach 

outside or fully exit the classroom to lock the door 

during the shooting.9 It also has been reported that 

classroom doors had translucent windows without 

deployable window blockers that would have allowed 

teachers to prevent the shooter from seeing through 

door windows and targeting victims inside the classroom.10 Moreover, doors and windows were made 

of standard, non-reinforced materials, allowing the 

shooter to kill many of his victims without having to 

breach a locked door or enter the classroom.11

Even with adequate funding for physical security, the 

decision on how best to provide security at a school 

to protect the students, visitors, and staff is complex 

and difficult. School officials should consider characteristics such as the age of the students, school 

campus layout, building design, and available financial resources to identify the policies, procedures, and 

equipment that can best assist efforts to secure their 

schools and mitigate overall risk. While it is generally 

agreed that it is not possible to stop every potential 

CHAPTER 16

Best Practices for School Building Security

... schools can reduce the likelihood of a violent 

incident with significant casualties from occurring 

on their campuses by establishing a strong security team, completing a security assessment, 

and developing and implementing appropriate 

plans for security and emergency operations.
120 Federal Commission on School Safety: Protect and Mitigate

act of violence in schools,12 schools can reduce the 

likelihood of a violent incident with significant casualties from occurring on their campuses by establishing 

a strong security team, completing a security assessment, and developing and implementing appropriate 

plans for security and emergency operations.

Commission Observations

The Commission identified various components of 

an effective approach to enhancing the security of 

schools. These include practices that have proven 

successful at either the school, school district, or 

state government level. Special emphasis was laid on 

proven plans to establish a sound security management program and enhance physical security at access 

points (including building façade) and in the context 

of the classroom. 

Security management

Schools and school districts employ people, develop 

plans, and implement procedures to manage school 

security and the safety of students on campus. Factors 

that contribute to the effectiveness of security and 

emergency management efforts at schools include the 

establishment of a security management team; the 

development of a school safety community of interest; the conduct of school risk assessments, with the 

inclusion of the full spectrum of activities that occur at 

a school during planning; and the existence of security 

and emergency operations plans. 

Establishing a Security Management Team and 

Cultivating a “Community of Interest” for School 

Safety and Security: To oversee proper development 

and implementation of a comprehensive school safety 

and security program, school districts and individual 

schools should consider first establishing a security 

management team and designating a team lead.13 The 

team should include individuals with a management, 

oversight, or other significant role in the security of 

the school, such as the principal or vice-principal, the 

designated emergency manager, and, if the school has 

one, the school resource officer.

In addition, every school district and individual school 

should try to develop a coalition from the community 

for the common purpose of enhancing the safety of 

students and the security of schools.14 As noted in the 

Final Report of the Sandy Hook Advisory Commission: 

“the successful implementation of Safe School Design 

and Operations (SSDO) strategies requires the support of ‘local champions.’ Each community or school 

district should have a small standing committee or 

commission, comprised of individuals representing 

the school community, law enforcement, fire, EMS and 

public health, whose responsibility is to ensure that 

the SSDO standards and strategies are actually implemented in their community.”15

A school’s security community of interest begins with 

its teachers, administrators, counselors, other staff, 

parents, and students, and also includes external 

partners like local first responders, social workers, 

and elected officials. These groups can collaborate to 

develop emergency operations plans that establish 

protocols for handling all types of potential hazardous incidents, including natural disasters, accidents, 

and deliberate attacks like an active shooter. A strong 

coalition can help carry the message to the rest of 

the community and minimize resistance to necessary 

security measures.16

Conducting Risk Assessments at Schools: A school’s 

security management team should first consider conducting a risk assessment to determine needs, identify vulnerabilities, and develop a security strategy. A 

facility risk assessment provides school administrators with an evaluation of current security practices 

and identifies options for preventing and protecting 

against violent incidents, including active shooters. In 

concert with school safety and security decision-makers, school administrators can use these assessments to prioritize security enhancements based on 

available resources. Recognizing the importance of 

risk assessments, in 2018 the Florida Department of 

Education is requiring all Florida school districts to 

complete an extensive facility risk assessment for each 

of their schools.17

✔ FAST FACTS

Factors that contribute to the effectiveness of security and emergency management efforts at schools 

include the establishment of a security management 

team; the development of a school safety community 

of interest; the conduct of school risk assessments, 

with the inclusion of the full spectrum of activities 

that occur at a school during planning; and the existence of security and emergency operations plans.
Federal Commission on School Safety: Protect and Mitigate 121

A risk assessment can be conducted internally, in 

conjunction with local law enforcement, or by a 

specialized third party security firm. To assist schools 

in conducting their own risk assessments, the U.S. 

Department of Homeland Security recently released 

K–12 School Security: A Guide for Preventing and Protecting against Gun Violence.

18 The Guide includes both 

a narrative overview of proven security practices, as 

well as considerations and instructions for completing 

a security self-assessment survey. Together, these documents outline action-oriented security practices and 

options for consideration based on the results of the 

individual school’s responses to the survey. 

The Phoenix Police Department’s Threat Mitigation 

Unit is a good example of how local law enforcement 

can be leveraged to conduct school risk assessments. 

The Threat Mitigation Unit uses its critical infrastructure vulnerability assessment capability to assess 

schools across Arizona. In the assessment process, 

detailed information is gathered about each school 

and provided to first responders electronically. In 

return, school districts receive options regarding ways 

to make their campuses more secure based on the 

training and experience of the assessment teams.

Developing Comprehensive Emergency Operations 

Plans: A school’s emergency operations plan should 

center on regular engagement between schools, 

school districts, and first responders. Collaboration 

increases the efficiency and effectiveness of response 

to school-based incidents by providing first responders 

with the information required to navigate and secure a 

campus during an incident. Any reduction in the time 

between the beginning and end of an incident can save 

lives. In 2013, a federal interagency team released the 

Guide for Developing High Quality School Emergency 

Operations Plans, which outlines the steps schools can 

take in collaboration with their local government and 

community partners to plan for potential emergencies 

through the creation of a school emergency operations 

plan.19 The Guide outlines the functions (e.g., communications, evacuation, shelter-in-place, lockdown) 

and threats or hazards (e.g., hurricanes, earthquakes, 

active shooters) for which every school should consider developing a plan.

Emergency operations plans must describe the actions 

that students, teachers, and school staff will take 

during an emergency. Actions may differ significantly 

depending upon the type of emergency. These differences should be outlined clearly according to the 

different threats and hazards. Everyone in the school 

should have a common understanding of what will 

be expected of them during an emergency—students, 

teachers, and school staff as well as parents, substitute 

teachers, coaches, and any contracted workers on 

the school campus. All areas of the school should be 

included in the planning, such as auxiliary locations for 

which the school is responsible and for any events that 

occur outside of regular school hours or school days. 

Informing students, teachers, and school administrators of the practices outlined in a security or emergency operations plan is just as important as developing the plan in the first place. Training provides the 

most effective way of educating everyone on their 

roles and responsibilities during an emergency. An 

effective plan requires meticulous practice and stakeholders trained in executing the plan.

Considering Before School, After School, and 

Extra-Curricular Activities in Planning: At many 

schools, large numbers of students or other members 

of the community will be present at the school before 

school, after school, during extra-curricular activities, 

and other times when classes are not in session.20

During these periods, schools often reduce security 

measures, such as by leaving entry doors unlocked 

or reducing security staff presence.21 When designing their security and emergency operations plans, 

schools need to consider security for these periods. 

A school’s security management team should first 

consider conducting a risk assessment to determine needs, identify vulnerabilities, and develop a 

security strategy.

Emergency operations plans must describe the 

actions that students, teachers, and school staff 

will take during an emergency.
122 Federal Commission on School Safety: Protect and Mitigate

School building hardening and other physical 

improvements

Three key areas comprise the physical aspects of 

schools: the campus, the buildings on the campus, 

and the classrooms in the buildings. When implemented as part of a security strategy, measures specific to each of these parts of schools can enhance the 

overall security posture of a school. When designing 

a physical security plan, schools should keep in mind 

certain principles, such as respecting the school’s 

primary mission and incorporating a layered approach 

to security.

Available funding and the age of existing infrastructure also play a role in determining the best strategy 

for hardening a school. Administrators must consider 

their budgetary constraints and identify the most 

appropriate investment for their schools. According to 

the National Center for Education Statistics, the average age of the main building of public schools in the 

United States is 44 years,22 and 53 percent of schools 

require funding for repairs, renovations, and modernization to ensure buildings are in overall good condition.23 Older schools are more challenging to retrofit 

for security. In addition, many schools do not have the 

funding to make basic infrastructure repairs, and this 

makes investing in security difficult.24

• Respecting the School Mission: Schools are first 

and foremost places for learning. When designing 

physical security measures, schools should ensure 

that the primary educational mission is not sacrificed for enhanced security.25 During his testimony 

at the August 16 Commission meeting, architect 

Jay Brotman provided numerous examples of how 

the new Sandy Hook Elementary School was able 

to further its primary institutional objective as a 

place of learning while ensuring improved security. 

For instance, architects designing schools often 

look for ways to incorporate security while still 

allowing natural light as “[d]aylight illuminates 

classrooms while using less energy and research 

shows positively influences a student’s ability to 

concentrate and learn.”26 To achieve this at Sandy 

Hook, the architects did not use high windows that 

might prove more difficult to breach but which 

would also be difficult for the elementary school 

children to see out of and would reduce natural 

light in the classroom. Instead, they sloped the 

ground away from the building, such that the 

windows are higher to a potential assailant but feel 

normal to the children inside.27

• Layers of Security: As multiple experts noted 

during Commission meetings, school security 

strategies should use a layered approach that 

incorporates multiple, reinforcing echelons of 

policy, programs, and protective measures.28 This 

can help prevent an attacker from exploiting a 

gap or single point of failure in a school’s security 

plan. Layering security can also prove valuable in 

delaying an attacker, thus providing more time for 

law enforcement to respond to an attack.29 This is 

especially valuable in more rural areas where law 

enforcement response time may be significantly 

longer due to the need to cover a significantly 

greater geographic area.30

• Access Controls—Limited Entry Points: As all of the 

experts testifying during the Commission’s August 

23 field visit to Miley Achievement Center in Las 

Vegas, NV, acknowledged, denying intruders and 

attackers access to school campuses and buildings 

is a key line of defense. It begins at the entrance 

to the school’s campus or building.31 Entry control 

measures limit the number of access points, allow 

access only to those who should be on the campus, 

and provide an opportunity to conduct searches of 

suspicious items or persons. Having entry controls 

in place can deter individuals from initiating violent 

attacks, detect attacks earlier from a safe distance, 

and delay attackers from reaching vulnerable locations or densely populated areas. 

By applying the principles of Crime Prevention 

Through Environmental Design, schools can implement security measures such as fencing, bollards, 

planters, curbs, or walls to create a single point of 

entry to the campus, for both vehicles and pedestrians. This allows school staff to more effectively monitor every individual who comes onto the campus.32

For example, the new Sandy Hook Elementary School 

is designed with a rain garden with three footbridges 

Schools are first and foremost places for learning. When designing physical security measures, 

schools should ensure that the primary educational mission is not sacrificed for enhanced 

security.
Federal Commission on School Safety: Protect and Mitigate 123

in front of its main entrance.33 Through this approach, 

the school was able to incorporate a natural barrier 

to vehicles that funnels pedestrian traffic to a single 

entryway in a visually pleasing design that can also 

help teach the children about the cycle of water and 

seasonal plants. 

Rerouting roads or eliminating access points might 

be necessary to assure minimal access points to the 

campus. Schools that consist of a single building 

should also work to have limited, monitored entry 

points by applying the appropriate security measures. All schools should consider equipping exterior 

doors with an electronic access system that allows for 

scheduled lock and unlock times. During lock times 

the use of access cards or video intercom door release 

systems may be used for student, teacher, or visitor 

movement. 

• Access Controls—Video Surveillance: Video surveillance is a valuable security measure for entry 

control. Surveillance cameras can also be used 

beyond entry points to monitor areas that are not 

within the normal view of teachers, administrators, or security personnel, such as hallways and 

enclosed stairwells. When feasible, school security 

personnel or other staff should actively monitor 

video feeds, and the local first responder community should have access to them.34 Schools sharing 

video feeds with local law enforcement or others 

should ensure they are complying with all appropriate privacy laws, such as the Family Educational 

Rights and Privacy Act (FERPA), when doing so. 

Additional information on how to properly share 

video surveillance while complying with FERPA can 

be found in Chapter 17 of this report.

• Access Controls—Screening Systems: Some 

schools may also wish to use screening systems 

to limit who and what can enter a building. These 

systems typically require one-at-a-time entry to 

check the person and belongings. Such systems 

can use metal detection, X-ray, explosives detection devices, or a physical search. The purpose 

of screening is to prevent illegal or prohibited 

items from entering any given facility, and there 

is evidence that supports the efficacy of screening as a method to detect, deter, or deny violent 

actors. However, these screening systems are 

labor-intensive, time consuming, and costly. The 

cost of a retrofit of a school or the time it takes to 

admit students into the building in accordance 

with screening procedures may be impediments 

to implementation. The impact of metal detectors, 

X-ray machines, and similar screening technologies 

on school violence is questionable, with at least 

one study concluding that metal detectors have 

no apparent effect on reducing violence on school 

grounds.35

• Building Envelope: The exterior face of school 

buildings, including the walls, roof, windows, and 

doors, comprise the building envelope. Much like 

in a classroom, these structural components can 

serve as a significant layer of defense from an 

incident or natural disaster. In particular, construction materials for doors and windows influence 

the effectiveness of these features in deterring, 

delaying, or denying active-shooter attacks. Doors 

constructed primarily with wood and non-reinforced glass windows offer a lower degree of 

protection than doors made from steel with blast 

or bullet-resistant glass windows. Replacing wood 

framed doors with fire-rated steel or aluminum can 

improve the level of protection offered. Replacing any non-reinforced glass windows with tempered, wire-reinforced, laminated, or bulletproof 

glass and applying blast-resistant safety films can 

strengthen windows to increase the protection 

they provide.36 Securing exterior windows so that 

individuals cannot use them to access a building can also improve the overall security of the 

building. In addition, clearing the exterior spaces 

surrounding school buildings of unnecessary 

foliage or structures may also eliminate spaces that 

School Security 

strategies should use 

a layered approach 

that incorporates 

multiple, reinforcing 

echelons of policy, 

programs, and 

protective measures.

Figure 16-1
124 Federal Commission on School Safety: Protect and Mitigate

could conceal illicit activity, provide access to the 

building above the first floor, or otherwise aid an 

intruder or attacker’s efforts.

• Classroom Doors, Locks, and Window Panels: 

Depending on their construction and configuration, classroom doors can significantly delay or 

prevent an attacker from reaching individuals 

within a classroom, thereby providing a safe area 

for students and staff during a lockdown. Much like 

the building envelope, the material from which 

doors are made will greatly affect their protective value. Reinforcing existing doors or replacing 

them with bulletproof doors can be very costly, 

but is an investment that some schools and school 

districts are making. For instance, in the wake of 

the Parkland shooting, the Charleston County 

(SC) School District announced that it will pilot 

bulletproof doors at three of its schools. The doors 

were designed to be strong enough to withstand 

high-powered ammunition, but lightweight enough 

for school-aged children to open.37

Regardless of the type of door used, all classrooms 

should have locks that allow the teacher to lock the 

classroom door from the inside. Locksets installed 

on classroom doors should have the ability to be 

opened from outside the classroom using a key, 

code, credential, or other method of deactivation. 

This enables teachers, administrators, and first 

responders to access the classroom, but not an 

attacker or intruder. When deciding on a locking 

device school officials must be aware of, and comply with, fire codes, life safety codes, and Americans with Disabilities Act (ADA) requirements.38 In 

addition to the physical locking hardware, training 

and continued reinforcement of their use is important to get the full benefits of locks. Entry control 

technologies such as locks can be (and have been) 

rendered useless by individuals not adhering to 

proper security processes, such as by propping 

open doors for convenience or other reasons.39

Many school doors have windows that allow someone outside the door to observe the inside of the 

classroom. These windows should be protected or 

reinforced and have a removable covering that can 

be quickly applied that obscures visual observation 

from both sides. Additionally, windows often are 

located on the door in a position where an attacker 

could smash the window to gain access to the 

door’s locking mechanism. Schools can address 

this by installing reinforcing film that strengthens 

the glass or using doors designed in a way that a 

breach of the window will not provide the attacker 

the ability to access the locking mechanism and 

unlock the door. 

Other measures can be taken to keep students and 

staff beyond the line of sight and line of fire of an 

attacker seeking to cause harm through the door 

window. One school district in southern Ohio has 

installed hurricane-type screening on door windows in its schools. These retractable screening 

devices prevent an outside observer from seeing 

into a room as they allow observation in a straight 

line only, thereby narrowing the field of view from 

outside of the classroom. Another approach some 

schools use is to place tape on the floor of the 

classroom designating areas of the classroom that 

cannot be seen through the door window. Students 

are trained to congregate in those designated areas 

during lockdowns.

• Door Numbering Systems: School buildings come 

in all shapes and sizes with many entrances and 

exits. To help first responders gain access to an incident scene in the most efficient manner, schools 

can collaborate with local first responders to apply 

a common numbering system to the walls, doors 

(interior, exterior, and non-access), roof hatches, 

and stairwells.40

The value of numbering systems was noted during 

the August 23 Commission field visit to the Miley 

Achievement Center by Clark County School District Police Chief James Ketsaa. He stated that the 

local fire marshal is exploring amending the fire 

code to require all schools to visibly number outside doors, provide directional (i.e., north, south, 

All classrooms should have locks that 

allow the teacher to lock the classroom door from the inside.

Figure 16-2
Federal Commission on School Safety: Protect and Mitigate 125

east, west) markings, and number school roofs to 

support identification from the air.41 At present, 20 

states provide recommendations and resources 

to schools about this practice via their Statewide 

School Safety Centers.42

• Hallways, Stairwells, Utility Rooms, and Other 

Areas: Each building will have certain areas that 

are more difficult than others to monitor, such as 

hallways, stairwells, and utility rooms. Although 

data about the location of school violence within 

a school is limited, there is some indication that 

students feel the least safe in areas with minimal 

adult oversight and that violence is most prevalent 

in areas like hallways and stairways that are least 

monitored.43 Similarly, spaces behind ceiling panels 

or walls can be easily accessed but prove difficult 

to monitor and can serve as staging areas for contraband or hiding places for intruders. Developing 

or installing systems to monitor these spaces by 

either physical inspection or surveillance cameras 

may be necessary to mitigate their use for nefarious purposes. Eliminating non-structural elements 

of ceilings and walls such as removable panels may 

help to serve the same purpose. 

• Portable Classrooms: Portable buildings that are 

used for classrooms can present unique challenges 

because they frequently do not have the same 

construction features as the primary buildings, 

resulting in windows and doors with lower levels of 

security. They might also be located in less secured 

areas that provide easier access to an attacker. 

If a school has portable buildings (and eliminating their use is not practical), additional security 

measures may be warranted, including increased 

monitoring, assigned security personnel, retrofitting doors and locks, or ballistic protection on the 

windows. 
126 Federal Commission on School Safety: Protect and Mitigate

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. One of the biggest concerns raised by schools and school districts since the Parkland shooting has 

been their inability to easily sift through the multitude of security options, equipment, technologies, 

etc., that are available to their schools. As a way to address this, many individuals in the school 

security community have suggested the establishment of a federal clearinghouse that could assess, 

identify, and share best practices on school security.44 The federal government should develop a 

clearinghouse to assess, identify, and share best practices related to school security measures, 

technologies, and innovations.

2. To assist schools and school districts in performing risk assessments and developing emergency 

operation plans, the U.S. Department of Homeland Security (DHS) should periodically update and 

provide training on its K–12 School Security: A Guide for Preventing and Protecting against Gun Violence (including the associated security self-assessment) and, along with its interagency partners, 

the Guide for Developing High Quality School Emergency Operations Plans. In addition, DHS should 

develop options for the creation of a train-the-trainer program to push expertise out into the states 

and localities to help school districts and individual schools complete these activities.

3. DHS, in partnership with the U.S. Departments of Education and Justice, should explore legislative, 

regulatory, or procedural modifications to existing grant programs to enable more grant funding 

or related resources to be available for enhancing school security operations and physical infrastructure. As part of this, DHS should explore designating a portion of Homeland Security Grants for 

school security activities, and premise the use of those funds on activities that accomplish enhancements recommended in DHS guidance or standards. 

¤ STATES & LOCAL COMMUNITIES

1. Schools or school districts should establish a security management team with a designated lead 

official to oversee security efforts. States and localities should consider supporting these efforts by 

providing dedicated funding for security management teams. States and localities should also consider requiring school districts or the individual schools within their jurisdiction to establish security 

management teams. Once established, these teams should work to develop a school security community of interest by engaging the school’s teachers, administrators, counselors, and other staff, 

parents and students, and external partners like local first responders, social workers, and elected 

officials. 

2. Schools should conduct a risk assessment or have a risk assessment performed in order to identify 

existing vulnerabilities and support the development of a strategy to address security gaps. To do 

this, schools could use the security self-assessment that DHS released along with its K–12 School 

Security: A Guide for Preventing and Protecting against Gun Violence or another assessment methodology (or they could work with a third party to conduct the assessment for them). States and localities should consider supporting these efforts by providing dedicated funding for the performing of 

school risk assessments. They can also consider requiring individual schools within their jurisdiction 

to complete risk assessments. 
Federal Commission on School Safety: Protect and Mitigate 127

Chapter 16 Endnotes

1 Federal Emergency Management Agency. (2012). Primer to design safe 

school projects in case of terrorist attacks and school shootings, at pp. 

1–2. https://www.dhs.gov/xlibrary/assets/st/bips07_428_schools.pdf.

2 Departments of Education, Justice, and Health and Human Services. 

(June 1, 2007). Report to the President on issues raised by the Virginia 

Tech tragedy, at p. 17.

3 Now is the time: The President’s plan to protect our children and our communities by reducing gun violence. (January 16, 2013) at p. 10 (“We need 

to make our schools safer, not only by enhancing their physical security 

and making sure they are prepared to respond to emergencies like a 

mass shooting, but also by creating safer and more nurturing school 

climates.”). 

4 Ibid., at p. 11.

5 The report of Governor Bill Owens’ Columbine Review Commission. (May 

2001) at pp. 120–121.

6 Final report of the Sandy Hook Advisory Commission. (March 6, 2015) 

at pp. 4–5.

7 Ibid.

8 Florida Statutes § 943.687(3) (2018); Broward County League of Cities’ 

School and Community Public Safety Task Force. (June 4, 2018). Initial 

Report and Recommendations, at p. 13. 

9 See, e.g., Spencer, T. (August 8, 2018). 18 safety staff, new door 

locks at Parkland students return. WITN.com: http://www.witn.

com/content/news/Sheriff-Massacre-suspects-behavior-was-a-roller-coaster-490352591.html.

10 Testimony of Max Schachter to the Federal Commission on School 

Safety Meeting (August 16, 2018), Creating a citadel of learning: New 

tools to secure our schools, inside and out.

11 Ibid.

12 Broward County League of Cities’ School and Community Public Safety 

Task Force. (June 4, 2018). Initial report and recommendations, at p. 

74. Also, Departments of Education, Justice, and Health and Human 

Services. (June 13, 2007). Report to the President on issues raised by 

the Virginia Tech tragedy, at p. 5. Also, Final report of the Sandy Hook 

Advisory Commission. (March 6, 2015). At p. 4. 

13 Department of Homeland Security. (2018). K–12 school security: A guide 

for preventing and protecting against gun violence, Second Edition, at p. 

6. https://www.dhs.gov/sites/default/files/publications/K12-School-Security-Guide-2nd-Edition-508.pdf.

14 Ibid.

15 Final report of the Sandy Hook Advisory Commission. (March 6, 2015) 

at p. 5.

16 Department of Homeland Security. (2018). K–12 school security: A guide 

for preventing and protecting against gun violence, Second Edition, at p. 

6. https://www.dhs.gov/sites/default/files/publications/K12-School-Security-Guide-2nd-Edition-508.pdf.

17 Broward County League of Cities’ School and Community Public Safety 

Task Force. (June 4, 2018). Initial report and recommendations, at p. 24.

3. All school districts and/or individual schools should develop and implement emergency operations 

plans in accordance with the Guide for Developing High Quality School Emergency Operations Plans, 

or other similar guidance. Indeed, according to a U.S. Government Accountability Office’s 2015 

survey of the 50 states and the District of Columbia, only 32 of the 51 state education departments 

surveyed indicated that their state required school districts to have emergency operations plans.45

When designing their security and emergency operations plans, schools should consider security 

for before school, after school, during extra-curricular activities, and other times when classes are 

not in session. States and localities should consider supporting these efforts by providing dedicated funding for the development and implementation of emergency operations plans. States and 

localities should also consider requiring individual schools within their jurisdiction to develop and 

implement emergency operations plans.

4. Following the completion of a risk or vulnerability assessment to determine what risks and security 

gaps exist in the school’s current building security program, schools should take steps to address 

those gaps. In doing so, they should design security measures in a way that achieves security goals 

without requiring sacrifices to the school’s primary educational and developmental missions. Every 

school is different, and, therefore, the protective measures in place will vary based on the characteristics of the site, location, resources, and personnel available. Schools should make sure to take into 

account their unique physical characteristics when designing a security plan. School security plans 

should use a layered approach across all three areas of a school (i.e., the entry points, the building 

envelope, and the classroom) with measures designed to complement and support each other. 

Schools also should consider the special needs of the student population and other individuals who 

access the school to ensure security measures, emergency notifications, and response plans are 

effective and account for all. 
128 Federal Commission on School Safety: Protect and Mitigate

18 See Department of Homeland Security. (2018). K–12 school security: A 

guide for preventing and protecting against gun violence, Second Edition, 

at p. 6. https://www.dhs.gov/sites/default/files/publications/K12-

School-Security-Guide-2nd-Edition-508.pdf. 

19 Department of Education, Department of Justice, Department of Health 

and Human Services, Department of Homeland Security, Federal 

Emergency Management Agency, and Federal Bureau of Investigation. 

(2013). Guide for developing high-quality school emergency operations 

plans. https://www.dhs.gov/sites/default/files/publications/REMS%20

K-12%20Guide%20508_0.pdf. 

20 Broward County League of Cities’ School and Community Public Safety 

Task Force. (June 4, 2018). Initial report and recommendations, at p. 8 

(“For some schools, the dismissal bell results in only a 30-40% reduction 

in the student population.”).

21 Ibid. (“There is no SRO coverage for pre-school, after-school, extra-curricular, camps over break, and summer camps.”).

22 National Center for Education Statistics. (2013). Digest of education statistics, Table 217.10. https://nces.ed.gov/programs/digest/d14/tables/

dt14_217.10.asp.

23 American Society of Civil Engineers. (2017). 2017 Infrastructure report 

card—Schools. https://www.infrastructurereportcard.org/wp-content/

uploads/2017/01/Schools-Final.pdf.

24 Ibid.

25 Final report of the Sandy Hook Advisory Committee. (March 6, 2015) at p. 

5.

26 Testimony of Jay Brotman to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out.

27 Ibid.

28 See, e.g., testimony of U.S. Representative John Rutherford to the 

Federal Commission on School Safety Public Listening Session (June 

6, 2018); testimony of Wyoming Director of Homeland Security Guy 

Cameron to the Federal Commission on School Safety Public Listening 

Session (August 7, 2018); testimony of Sheriff Tim Troyer to the Federal 

Commission on School Safety Field Visit (August 23, 2018), Best practices 

for school building safety; testimony of Russell Davidson to the Federal 

Commission on School Safety Field Visit (August 23, 2018), Best practices 

for school building safety. See also Broward County League of Cities’ 

School and Community Public Safety Task Force. (June 4, 2018). Initial 

report and recommendations, at p. 7; and The Partner Alliance for Safe 

Schools. (April 2017). K–12 security guidelines, Third Edition, at p. 15. 

29 Testimony of Jay Brotman to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out.

30 Ibid.

31 See, e.g., testimony of Chief James Ketsaa to the Federal Commission 

on School Safety Field Visit (August 23, 2018), Best practices for school 

building safety; testimony of Sheriff Tim Troyer to the Federal Commission on School Safety Field Visit (August 23, 2018), Best practices for 

school building safety; testimony of Paul Timm to the Federal Commission on School Safety Field Visit (August 23, 2018), Best practices for 

school building safety; testimony of Russell Davidson to the Federal 

Commission on School Safety Field Visit (August 23, 2018), Best practices 

for school building safety.

32 For more details about Crime prevention through environmental design, 

refer to www.cpted.net.

33 Testimony of Jay Brotman to the Federal Commission on School Safety 

Meeting (August 16, 2018), Creating a citadel of learning: New tools to 

secure our schools, inside and out.

34 See, e.g., testimony of Sheriff Tim Troyer to the Federal Commission 

on School Safety Field Visit (August 23, 2018), Best practices for school 

building safety.

35 Schwartz et al. (2016). The role of technology in improving K–12 school 

safety, at p. 15 (citing Hankin, Hertz, and Simon 2011 study).

36 Underwriters Laboratory (UL) 752 Standard for Bullet-Resisting 

Equipment offers a standard for use in determining the appropriate 

construction material for use in retrofitting or designing classroom components. School and school district administrators must determine the 

appropriate level of ballistic resistance that is necessary and apply the 

corresponding level from UL 752. UL 752 is a widely recognized standard 

in the security industry.

37 See, Bowers, P. (June 28, 2018). Bullet-resistant doors coming soon 

to three Charleston County schools. Post and Courier. https://www.

postandcourier.com/news/bullet-resistant-doors-coming-soon-tothree-charleston-county-schools/article_051ade5e-7a49-11e8-8579-

ff174799a51e.html.

38 The National Fire Protection Association (NFPA) 3000 guideline provides 

standard specifications that locksets must meet in order to comply 

with the ADA and widely accepted life safety best practices. NFPA 3000 

should be reviewed and its standards considered by everyone who is 

responsible for school security and student safety. For more information 

on different types of locks and considerations to take into account when 

selecting locks for a school, one valuable resource is the National Clearinghouse for Educational Facilities Guide to Door Locking Options in 

Schools, which can be found at http://www.ncef.org/pubs/door_locks.

pdf.

39 See e.g., Schwartz et al. (2016). The role of technology in improving K–12 

school safety, at p. 22.

40 In Kentucky, for instance, schools in Allen, Edmonton, Grayson, 

Mercer, Warren, and Scott Counties have worked with their local first 

responders to incorporate fast path door numbering, a logical system 

of marking doors, windows, hallways, and classrooms that assists first 

responders in navigating through school buildings quickly. Similarly, in 

New Jersey, schools are encouraged to use the Model Door Numbering 

System, which helps first responders more rapidly respond to incidents 

by numbering external doors. The New Jersey Center for Safe Schools 

has issued a guide to help New Jersey schools implement this system, 

which can be found at https://www.nj.gov/education/schools/security/

resources/DoorNumbering.pdf. Finally, a high school in Imperial County, 

CA, has also adopted the practice of labeling doors for first responders 

in a way that indicates which key to use, the direction in which the 

doors will open, and how many rooms are located behind the door.

41 Testimony of Chief James Ketsaa to the Federal Commission on School 

Safety Field Visit (August 23, 2018), Best practices for school building 

safety.

42 Information on Statewide Schools Safety Centers can be found at 

https://www.ncpc.org/programs/be-safe-and-sound-in-school/stateschool-safety-centers/. 

43 Schwartz et al. (2016). The role of technology in improving K–12 school 

safety, at p. 6.

44 See, e.g., testimony of Jay Brotman to the Federal Commission on 

School Safety Meeting (August 16, 2018), Creating a citadel of learning: New tools to secure our schools, inside and out; testimony of Max 

Schachter to the Federal Commission on School Safety Meeting (August 

16, 2018), Creating a citadel of learning: New tools to secure our schools, 

inside and out; testimony of Sheriff Tim Troyer to the Federal Commission on School Safety Field Visit (August 23, 2018), Best practices for 

school building safety; testimony of Russell Davidson to the Federal 

Commission on School Safety Field Visit (August 23, 2018), Best Practices 

for School Building Safety.

45 U.S. Gov’t Accountability Office, GAO-16-144, Improved federal coordination

could better assist K–12 schools prepare for emergencies, (2016).
Federal Commission on School Safety: Protect and Mitigate 129

CHAPTER 17

The Family Educational Rights and Privacy Act and Other 

Statutory and Regulatory Privacy Protections

A delicate balance exists between privacy and security 

in schools. On the one hand, there is the legal requirement to protect the privacy of student education 

records. On the other hand, it is critical to recognize 

that some education records may contain information 

that, if disclosed to appropriate officials, could help 

prevent students from harming themselves or others.

The primary federal law that governs the privacy of 

education records is commonly referred to as the 

Family Educational Rights and Privacy Act (FERPA).1

It grants parents certain rights with regard to their 

children’s education records. These include the right 

to inspect and review their education records, to seek 

to have their education records amended, and to file a 

written complaint with the U.S. Department of Education regarding an alleged violation of FERPA. The law 

also provides parents with certain consent rights over 

the disclosure of education records and personally 

identifiable information (PII) contained therein. 

While pursuing the laudable goal of protecting student 

privacy, FERPA was written in 1974, before the internet, and has repeatedly been criticized as archaic and 

in need of updating for the digital age. For example, a 

2014 White House report on “Big Data” recommended 

that the federal government “should explore how to 

modernize the privacy regulatory framework under 

the Family Educational Rights and Privacy Act.”2 Unfortunately, this modernization has not yet taken place, 

and FERPA retains a pre-Internet approach to data 

that is out of touch with today’s modern and digitally 

connected classroom. 

For students receiving special education and related 

services (or being evaluated for eligibility), the Individuals with Disabilities Education Act (IDEA)3

 and the 

associated federal regulations at 34 C.F.R. Part 300 

provide separate and additional confidentiality protections. Many of these confidentiality provisions are 

similar to FERPA in scope.4

Educators, parents, law enforcement officers, and others are often unclear about FERPA’s specific requirements and exceptions, and some take advantage 

of the confusion surrounding FERPA. Following the 

Parkland shooting, one article noted how schools use 

FERPA as a shield to hide incriminating or embarrassing information.5

Troy Eid, Chief Legal Counsel to Colorado Governor 

Bill Owens at the time of the Columbine shooting, said 

that a fear of liability and “overly restrictive interpretation” of FERPA has “sparked needless confusion among 

officials and their lawyers.”6 Teachers injured on the 

job by violent students similarly complained that their 

school administrators did not inform the teachers 

about any known violent behavior of students.7

Following the Virginia Tech shooting, the George 

W. Bush Administration recommended that school 

policies articulate what types of student information 

can be shared, with whom it can be shared, and under 

what conditions it can be shared.8 Based on those 

recommendations, the Department of Education 

amended FERPA regulations to clarify permissible disclosures of student records and PII contained therein 

in health or safety emergency situations.9

Prior to the amendments, schools and districts were 

more limited in what they could non-consensually disclose in the context of a health or safety emergency. 

In 2008, citing the need for “greater flexibility and 

deference” and “so they [schools administrators] can 

bring appropriate resources to bear on a circumstance 

that threatens the health or safety of individuals,” the 

Department removed the strict construction requirement.10 With the rule change, the Department affirmed 

that it would review determinations to disclose education records under FERPA’s health or safety exception 

by assessing whether: (1) there was an “articulable 

and significant threat to the health or safety of the 

student or other individuals;” (2) the disclosure was 

made to appropriate parties; and (3) there was a 

rational basis for the determination.11 The Department 

also stated that, assuming the foregoing was satisfied, 

it would “not substitute its judgment for that of the 
130 Federal Commission on School Safety: Protect and Mitigate

FERPA and School Safety

What is FERPA? 

Family Educational Rights and Privacy Act (FERPA) [20 U.S.C. § 1232g – 34 C.F.R. Part 99]

• Applies to all educational agencies (i.e., school districts) and institutions (i.e., schools) that receive funds 

under any program administered by the U.S. Secretary of Education. In K–12, FERPA applies to most public 

schools. In postsecondary, FERPA applies to nearly all postsecondary institutions.

• Gives parents the right to access the student’s education records (and to seek to amend any information 

in the student’s education record that is inaccurate, misleading, or in violation of the student’s right of 

privacy).

• Requires written parental consent before personally identifiable information (PII) from the student’s 

education record may be disclosed, subject to certain exceptions.

• When a student turns 18 years of age, or enrolls in a postsecondary institution (at any age), the student 

becomes an “eligible student” and all parental rights transfer to the student.

What education records does FERPA protect?

• Education records are generally defined as those records that are directly related to the student and maintained by (or on behalf of) an educational agency or institution.

• FERPA excludes certain types of records from this definition, including, but not limited to:

‒ Records created and maintained by the educational agency’s or institution’s law enforcement unit for 

law enforcement purposes;

‒ Records made or maintained by a professional or paraprofessional (e.g., physician, psychologist, etc.) 

that are made, maintained, or used only in connection with treatment of an eligible student, if certain 

conditions are met.

What are several key exceptions to FERPA’s written consent requirement?

• Health and Safety Emergencies. Educational agencies and institutions may disclose PII from education 

records without consent to appropriate parties (e.g., law enforcement, emergency responders) in connection with an articulable and significant health or safety emergency, if knowledge of the information is necessary to protect the health or safety of the student or other individuals. 34 C.F.R. §§ 99.31(a)(10) and 99.36;

• School Officials. Educational agencies and institutions may disclose PII from education records without 

consent to school officials (including School Resource Officers), provided they meet the school’s criteria for 

“school officials” with “legitimate educational interests.” 34 C.F.R. § 99.31(a)(1);

• Judicial Orders/Subpoenas. Educational agencies and institutions may disclose PII from education 

records without consent in order to comply with judicial orders and lawfully issued subpoenas if the 

conditions set forth at 34 C.F.R. § 99.31(a)(9) are met;

• Parents of Dependent Students. Educational agencies and institutions may disclose PII from the education records of an “eligible student” without consent to the parents of that student if the parents claim the 

student as a dependent for federal tax purposes. 34 C.F.R. § 99.31(a)(8).

• Juvenile Justice System. Educational agencies and institutions may disclose PII from education records to 

state and local officials or other authorities if the disclosure is allowed by a state law adopted after November 19, 1974, and if the disclosure concerns the juvenile justice system and its ability to serve, prior to adjudication, the student whose records are disclosed. The officials and authorities to whom such information 

is disclosed must certify in writing to the school that the information will not be provided to any other party 

without written consent, except as provided for under state law. 34 C.F.R. §§ 99.31(a)(5) and 99.38.
Federal Commission on School Safety: Protect and Mitigate 131

educational agency or institution in evaluating the 

circumstances and making its determination.”12

After these regulatory changes, the Departments of 

Education and Health and Human Services issued 

Joint Guidance on the Application of FERPA and the 

Health Insurance Portability and Accountability Act 

(HIPAA). This guidance sought to explain the relationship between the two laws and address apparent 

confusion on the part of school administrators, healthcare professionals, and others as to how they apply 

to student records and the ability to communicate 

information.13

Though these recommendations and actions sought 

to clarify FERPA, substantial misunderstanding 

remains at the local level among officials and educators concerning the privacy law, and in particular its 

application to school-based threats. 

Commission Observations

A misconception in both the education and law 

enforcement communities is that FERPA poses an 

impediment to the sharing of student information 

that could help prevent school violence and other 

emergencies.14 In her comments to the Commission, 

Sonja Trainor, Managing Director for Legal Advocacy 

at the National School Boards Association, highlighted 

this confusion which creates barriers to information 

sharing and collaboration, thus hampering the ability 

to prevent potential acts of violence.15

Privacy advocates have correctly noted that FERPA 

already permits schools to disclose the information 

necessary to protect students and other individuals 

before and during emergencies, but that continued 

confusion over the scope of FERPA remains. For example, John Verdi, Vice President of Policy at the Future 

of Privacy Forum, explained to the Commission how 

schools can educate school officials and other stakeholders about the existing legal authorities for sharing 

data to support school safety, rather than expand 

legal bases for disclosure of student data.16

Contrary to common misconceptions, schools have 

a great deal of flexibility under FERPA to disclose students’ education records, or the PII contained therein, 

in the context of school safety. These five exceptions 

to FERPA’s general requirement for written consent are 

especially relevant: 

• disclosures to other school officials;17

• disclosures pursuant to a court order or lawfully 

issued subpoena;18

• disclosures in connection with a health or safety 

emergency;

19

• disclosures (pursuant to state law) relating to 

juvenile justice;20 and 

• disclosures to the parents of an eligible student 

that is claimed by the parents as a dependent for 

federal tax purposes.21

Especially relevant to potential violence at school is 

FERPA’s health or safety emergency exception which 

permits the disclosure of students’ education records, 

or the PII contained therein, to appropriate parties if 

knowledge of such information is necessary to protect 

the health or safety of students or other persons in 

connection with an emergency.22

FERPA’s health or safety emergency exception specifically permits schools or districts themselves to 

disclose PII from students’ education records in the 

context of emergencies. However, there are certain 

circumstances when it may not be practical or expedient for schools or districts themselves to make the 

determinations and disclosures necessary to address 

the emergency. These situations might include natural 

disasters that impact multiple districts across the 

state, emergencies that disrupt a district’s data systems, or emergencies that occur when district personnel are not available. In these limited situations, it is 

often advantageous for the state education agency 

to make the disclosure directly, on the school’s or 

district’s behalf. In a 2005 letter to the Texas Education 

Agency relating to the disruption caused by Hurricane Katrina, the Department affirmed that in these 
132 Federal Commission on School Safety: Protect and Mitigate

types of situations FERPA authorizes state education 

agencies to re-disclose students’ education records to 

appropriate parties under the health or safety emergency exception.23

Police departments often seek access to school surveillance footage to help ensure school safety—only to 

have schools claim it is an education record protected 

by FERPA and therefore deny the request. However, 

FERPA’s definition of “education records” excludes 

those created and maintained by a school’s law 

enforcement unit for a law enforcement purpose.24 If a 

school’s security department or campus police maintains the school’s surveillance video system and, as a 

result, creates surveillance footage for a law enforcement purpose, FERPA would not prevent sharing the 

surveillance footage with local law enforcement.25

Smaller schools without an existing law enforcement unit or security department can still utilize this 

exclusion by designating a school official, such as the 

vice-principal, as the school’s law enforcement unit for 

this purpose.26

Another exception to FERPA’s written consent requirement allows disclosures to school officials who have 

been determined to have a legitimate educational 

interest in the education records, such as needing to 

review the education records in order to fulfill their 

professional responsibilities.27 Schools and districts 

specify the criteria for determining both who they consider school officials and what constitutes a legitimate 

educational interest.28 Under this exception, schools 

can disclose education records, or the PII contained 

therein, that are relevant to school safety to individuals designated as school officials and determined 

to have a legitimate educational interest, including 

teachers and school resource officers.29

Five exceptions to FERPA’s general requirement 

for written consent to disclose student education 

records are especially relevant:

• disclosures to other school officials;

• disclosures pursuant to a court order or lawfully 

issued subpoena; 

• disclosures in connection with a health or safety 

emergency;

• disclosures (pursuant to state law) relating to 

juvenile justice; and

• disclosures to the parents of an eligible student 

that is claimed by the parents as a dependent 

for federal tax purposes.
Federal Commission on School Safety: Protect and Mitigate 133

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. The U.S. Department of Education (ED), should provide technical assistance to clarify that FERPA’s 

“school official” exception may permit disclosures of disciplinary information about students to the 

appropriate teachers and staff within the school. 

2. ED should work with Congress to modernize FERPA to account for changes in technology since its 

enactment. 

3. ED should clarify that limited disclosures of PII from students’ education records by state education 

agencies (SEA) under the health or safety emergency exception are permitted, when done on behalf 

of the school(s) or district(s), and in compliance with other FERPA requirements when the SEA is best 

positioned to respond to the emergency.

¤ STATES & LOCAL COMMUNITIES

1. States should examine their state-level student privacy laws to identify protections that go beyond 

FERPA and may impede schools’ and districts’ efforts to promote school safety and student 

well-being. FERPA is not the only student privacy law that can hinder the appropriate sharing of 

student information in the context of emergency situations. Schools and districts may find that 

information that could be shared under FERPA may not be shareable under their state student 

privacy laws.

2. Districts and schools should raise awareness of existing FERPA flexibilities and utilize existing (and 

forthcoming) trainings through the U.S. Department of Education’s Privacy Technical Assistance 

Center (PTAC). District and school staff can also make recommendations on additional training 

needs that can support increased awareness and understanding of FERPA requirements by 

emailing privacyTA@ed.gov. 

The following are some of the existing PTAC resources: 

• In 2018, ED published a series of Frequently Asked Questions that clarified FERPA’s applicability 

to photos and video recordings of students, with specific applicability to surveillance videos.30

• ED has responded to requests from states, school districts, postsecondary institutions, law 

enforcement agencies, and others for technical assistance on FERPA’s requirements and general 

privacy best practices in the context of school safety.31

• ED’s June 2010 guidance “Family Educational Rights and Privacy Act (FERPA) and the Disclosure of 

Student Information Related to Emergencies and Disasters,” and June 2011 guidance “Addressing 

Emergencies on Campus,” provide detailed explanations of the various exceptions to consent 

under FERPA that may apply in different safety scenarios.32
134 Federal Commission on School Safety: Protect and Mitigate

Chapter 17 Endnotes

1 20 U.S.C. § 1232g.

2 https://obamawhitehouse.archives.gov/sites/default/files/docs/big_

data_privacy_report_may_1_2014.pdf, at p. 70.

3 20 U.S.C. § 1400 et. seq. 

4 For additional information on the interaction of FERPA and IDEA confidentiality provisions, see Department guidance IDEA and FERPA confidentiality provisions. (June 6, 2014). Available at: https://studentprivacy.

ed.gov/sites/default/files/resource_document/file/IDEA%20FERPA%20

Confidentiality%20Provisions%20Comparison%20Chart%2006.06.14.

pdf.

5 LoMonte, F. (March 16, 2018). Student privacy laws have been distorted 

(and that’s a problem). Education Week. Retrieved from https://www.

edweek.org/ew/articles/2018/03/21/student-privacy-laws-have-beendistorted-and.html.

6 Statement of Troy A. Eid Greenberg Traurig, LLP and former United 

States Attorney for the District of Colorado to the Federal Commission 

on School Safety (May 17, 2018). https://www2.ed.gov/documents/

press-releases/federal-commission-school-safety-troy-eid.pdf. See also 

Colorado School Safety Resource Center, Department of Public Safety. 

(September 2016). Review of the three Arapahoe High School shooting 

2013 reports facilitated by the Colorado School Safety Resource Center. 

Available at http://cdpsdocs.state.co.us/safeschools/CSSRC%20Documents/CSSRC-RWG-Report-FINAL.pdf (noting the need for school staff 

to be aware “that FERPA does not prevent reporting on students about 

whom staff have safety concerns.”).

7 Lonetree, A. (April 5, 2016). Minnesota bill would bolster teachers in 

discipline matters. Retrieved from Star Tribune: http://www.startribune.com/minnesota-bill-would-bolster-teachers-in-discipline-matters/374669351/. See also https://www.twincities.com/2017/06/23/

st-paul-central-safety-meetings-foreshadowed-violent-attack-on-teacher.

8 U.S. Secret Service and U.S. Department of Education. (May 2008). Prior 

knowledge of potential school-based violence: Information students learn 

may prevent a targeted attack, at p. 9. Washington, D.C. Retrieved from 

https://rems.ed.gov/docs/DOE_BystanderStudy.pdf.

9 73 Fed. Reg. 74806 (December 9, 2008).

10 Ibid. at 74837 (citing 73 Fed. Reg. 15574, 15589 (March 24, 2008)).

11 Ibid.; 34 C.F.R. § 99.36(c).

12 34 C.F.R. § 99.36(c). 

13 U.S. Department of Health and Human Services and U.S. Department 

of Education. (November 2008). Joint guidance on the application of the 

Family Educational Rights and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to student health 

records. Retrieved from https://www2.ed.gov/policy/gen/guid/fpco/doc/

ferpa-hipaa-guidance.pdf.

14 See, e.g., NBC10 Investigators. (June 7, 2018). Local police director wants 

laws protecting student records loosened in midst of school shootings. 

Retrieved from NBC 10: https://www.nbcphiladelphia.com/investigations/School-Shootings-FERPA-Student-Privacy-Bensalem-Pennsylvania-Fred-Harran-484749221.html.

15 Statement from Sonja Trainor to the Federal Commission on School 

Safety (July 11, 2018). https://www.youtube.com/watch?v=od-s0BrghKs. 

16 Statement from John Verdi to the Federal Commission on School Safety 

(July 11, 2018). https://www.youtube.com/watch?v=od-s0BrghKs. 

17 34 C.F.R. § 99.31(a)(1).

18 34 C.F.R. § 99.31(a)(9). 

19 34 C.F.R. § 99.31(a)(10) (emphasis added).

20 34 C.F.R. § 99.31(a)(5).

21 34 C.F.R. § 99.31(a)(8).

22 73 Fed. Reg. 74806 (Dec. 9, 2008).

23 Spellings, M. (September 21, 2005). Letter to Neeley. Retrieved from 

https://www2.ed.gov/katrina/letters/050921.html.

24 34 C.F.R. §§ 99.3 (definition of “[e]ducation records”) and 99.8(b).

25 See ibid.; see also U.S. Department of Education. (May 2018). FAQs on 

photos and videos under FERPA. Retrieved from https://studentprivacy.

ed.gov/faq/faqs-photos-and-videos-under-ferpa.

26 See 60 Fed. Reg. 3464, 3467 (January 17, 1995).

27 34 C.F.R. § 99.31(a)(1). https://studentprivacy.ed.gov/faq/

can-school%E2%80%99s-law-enforcement-unit-officials-be-considered-schools-officials-legitimate; 73 Fed. Reg. 74806; 74813-74815 

(Dec. 9, 2008) on “Outside Parties who Qualify as School Officials” 

(https://www2.ed.gov/legislation/FedRegister/finrule/2008-4/120908a.

html) 

28 Schools and districts must specify the criteria in their annual notice to 

parents and eligible students of their FERPA rights. 34 CFR § 99.7(a)(3)

(iii).

29 Disclosures to school officials must meet the requirements of 34 CFR 

§ 99.31(a)(1)(i) and 34 C.F.R. § 99.7(a)(3)(iii).

30 34 C.F.R. §§ 99.3 (definition of “[e]ducation records”) and 99.8(b). See 

also U.S. Department of Education. (May 2018). FAQs on photos and 

videos under FERPA. Retrieved from https://studentprivacy.ed.gov/faq/

faqs-photos-and-videos-under-ferpa.

31 The U.S. Department of Education’s Privacy Technical Assistance Center 

is a “one-stop” resource for education stakeholders to learn about data 

privacy, confidentiality, and security practices related to student-level 

data systems and other uses of student data. For more information visit 

https://studentprivacy.ed.gov.

32 U.S. Department of Education, Family Policy Compliance Office. 

(June 2010). Family Educational Rights and Privacy Act (FERPA) and 

the disclosure of student information related to emergencies and 

disasters. Retrieved from https://studentprivacy.ed.gov/sites/default/

files/resource_document/file/ferpa-disaster-guidance.pdf. Also, U.S. 

Department of Education, Family Policy Compliance Office. (June 2011). 

Addressing emergencies on campus. Retrieved from https://studentprivacy.ed.gov/sites/default/files/resource_document/file/emergency-guidance.pdf.
Federal Commission on School Safety: Protect and Mitigate 135

Protecting our students and preventing school 

violence require ensuring that the right people have 

access to the right information at the right time. There 

is a need to disclose information to enable safe medical treatment while maintaining a respect for privacy. 

This is particularly critical with the treatment of mental health conditions. The Health Insurance Portability 

and Accountability Act (HIPAA)1 is a privacy rule that 

establishes national standards to protect medical 

records and other personal health information. It 

applies to health plans, healthcare clearinghouses, 

and healthcare providers who conduct certain healthcare transactions electronically.2

The HIPAA Privacy Rule3 regulates the sharing of 

individually identifiable health information known 

as “protected health information” (PHI) and applies 

to covered entities (and their business associates).4

Covered entities are defined as health plans, healthcare clearinghouses, and healthcare providers who 

transmit health information in electronic form in 

connection with covered transactions, such as billing 

insurance electronically.5 Some healthcare providers, 

including cash-only practices that do not conduct covered transactions, are not subject to the HIPAA Privacy 

Rule. Even so, such providers may be subject to states’ 

health information privacy laws. 

Mental health and substance use information is highly 

relevant in the school safety context. The HIPAA 

Privacy Rule applies to PHI, including mental health 

information such as substance use disorder (SUD) 

diagnosis and treatment information. In addition to 

HIPAA, much substance use disorder diagnosis and 

treatment information is protected by 42 CFR (Code of 

Federal Regulations) Part 2, which is regulated by the 

U.S. Department of Health and Human Services (HHS) 

Substance Abuse and Mental Health Services Administration (SAMHSA). 42 CFR Part 2 is discussed later in 

this report. 

The HIPAA Privacy Rule establishes a floor of federal 

privacy protection for PHI held by covered entities and 

their business associates. However, it does not preempt or replace other federal or state laws that may 

offer greater privacy protection. Many states or other 

jurisdictions impose stricter privacy protections than 

HIPAA, particularly for information considered especially sensitive, such as information related to mental 

disorder and SUDs. Privacy protections for individuals’ health information are not uniform across the 

nation, and this is a source of confusion for healthcare 

entities. 

Congress recently considered whether HIPAA interferes with effective communication and treatment 

for people with serious mental illnesses. It concluded 

that there is confusion in the healthcare community 

regarding circumstances under which information can 

be released under HIPAA. This confusion often hinders communication of information with appropriate 

caregivers that would support safe and coordinated 

treatment. 

At the July 11 Commission meeting, Jennifer Mathis, 

Director of Policy and Legal Advocacy at the Bazelon 

Center for Mental Health Law, referenced the provision in the 21st Century Cures Act that directed HHS 

to issue guidance clarifying permissible disclosures of 

protected information under HIPAA (and as of December 2017 this guidance is available online). Mathis 

CHAPTER 18

The Health Insurance Portability and Accountability Act 

and Other Statutory and Regulatory Privacy Protections
136 Federal Commission on School Safety: Protect and Mitigate

stated that additional work needs to be done to promote this guidance to the public.6

 

The HIPAA Privacy Rule does not require a covered 

entity to disclose PHI in its possession.7 The Privacy 

Rule permits a covered entity to disclose an individual’s PHI pursuant to his or her authorization or under 

circumstances and for purposes expressly described in 

the Privacy Rule. 

Covered entities are permitted to share PHI in several 

circumstances that are relevant to the school safety 

context. This includes sharing information with law 

enforcement, public health authorities, parents and 

other caregivers, and persons in a position to help prevent a serious and imminent harm to health or safety. 

The February 14 Parkland shooting further highlighted 

many of the complexities surrounding HIPAA and 

other privacy rules—and the need for individuals, families, schools, and communities to better understand 

these regulations. The protection of the privacy of the 

alleged shooter, even after the shooting, has been a 

source of confusion and criticism. 

Commission Observations

It is important to note that disclosures are permissible and often necessary in certain circumstances. As 

one expert testified during the July 11 Commission 

meeting, often individuals find HIPAA complex and do 

not understand the scenarios under which disclosure 

is permitted.8 

Disclosing to law enforcement

The Privacy Rule allows covered entities to disclose 

PHI to law enforcement under certain circumstances.9

For example, providers are permitted to make such 

disclosures when required by state or federal law or 

in response to an administrative subpoena or other 

civil legal process. Providers may also disclose limited information to help identify or locate a suspect, 

witness, or missing person; and about individuals 

who are suspected to be or who are victims of crime. 

In general, school employees are not providers under 

HIPAA. However, there may be certain situations 

where a school employee (such as a nurse or counselor) is a health provider, and in that case HIPAA may 

apply. 

Disclosing to a public health authority

Covered entities may disclose PHI to public health 

authorities for public health activities (45 CFR 

164.512(b)), which could include violence prevention 

initiatives or state law requirements to report child 

abuse or neglect. 

Disclosing to parents and other caregivers

The Privacy Rule generally treats parents as “personal 

representatives” of their minor children. Personal 

representatives generally have the authority to act on 

behalf of the minor child when providing consent to 

share information under HIPAA. Providers can decide 

not to treat a parent as a personal representative if, for 

example, they have concerns that doing so might put 

the child’s safety at risk.10

The HIPAA Privacy Rule also permits healthcare providers and other covered entities to share PHI with 

persons involved in the care or payment for care of 

individuals who are not able to agree or object to the 

disclosure (e.g., due to a mental health crisis). This is 

based on the entity’s judgment that sharing PHI is in 

the best interests of the patient. Under these circumstances, the recipients of the information may include 

family members, such as parents of children who are 

no longer minors. 

Doris Fuller is a mental illness researcher, advocate, 

and family member and the former Chief of Research 

and Public Affairs (ret.) at the Treatment Advocacy 

Center. During the July 11 Commission meeting, she 

stated that providers have a history of “stonewalling” 

families when it comes to providing protected health 

information. Her experience is that medical providers 

and schools routinely withhold medical information 

from family members to avoid liability for violating 

HIPAA. 

Disclosing to anyone who can prevent serious and 

imminent harm

Providers and other covered entities may disclose 

patient PHI to avert a serious and imminent threat 

to the health or safety of the patient or others when 

they have a good faith belief that such a disclosure is 

necessary to prevent or lessen the threat. Under these 

circumstances, providers may alert those persons they 

believe are reasonably able to prevent or lessen the 

threat. This includes law enforcement, school offiDisclosures are permissible and often necessary 

in certain circumstances.
Federal Commission on School Safety: Protect and Mitigate 137

cials, teachers, parents, friends, school counselors, or 

anyone reasonably able to help avert the harm. The 

disclosure must be made in good faith and be consistent with applicable law and standards of ethical 

conduct.11 

Education records

With respect to records held by schools, HIPAA 

excludes individually identifiable information in “education records” covered by the Family Educational 

Rights and Privacy Act (FERPA) and certain “treatment 

records” of eligible students from the definition of 

PHI.12 In most cases, therefore, records created by 

a school nurse or other school health professional 

(including those that are HIPAA-covered entities) are 

not subject to the HIPAA Privacy Rule. 

When HIPAA does apply in school settings and for PHI 

related to minor children, HHS Office for Civil Rights 

(OCR) guidance and resource materials help clarify the 

circumstances when providers may disclose information to parents.13

At the July 11 Commission meeting, Jennifer Mathis 

also stated that the privacy protections of HIPAA are 

extraordinarily important for individuals with mental 

health disabilities. Without the assurance of privacy 

protections, students are less likely to seek help when 

needed and less likely to engage openly with mental 

health counselors or other service providers. Mathis 

stated HIPAA is not to blame for the lack of appropriate disclosures of mental health information.

Confidentiality of substance use disorder 

patient records 

Federal regulations governing the confidentiality of 

SUD patient records (42 CFR Part 2) include statutory 

provisions (42 U.S.C. 290dd-2) enacted nearly 50 years 

ago, at a time when individuals seeking treatment for 

SUDs faced significant discrimination and negative 

consequences because they sought treatment for 

addiction. Thus, Part 2 is “intended to ensure that 

a patient receiving treatment for a SUD in a Part 2 

program is not made more vulnerable by reason of the 

availability of their patient record than an individual 

with a SUD who does not seek treatment.”14

Persons who seek help for and who are in recovery 

from SUDs may face discrimination in education, 

healthcare, employment, housing, and family law 

(e.g., child custody disputes).15 This may deter patients 

from seeking treatment or make them reluctant to 

share information with their healthcare providers 

about their diagnosis and treatment for SUDs. For 

SUD patients who often have comorbid conditions, 

proactive, preventive, and chronic care is important 

to achieving desired outcomes. Such outcomes are 

facilitated by appropriate sharing of information 

by patients with their healthcare providers, among 

medical staff, and, occasionally, with non-medical 

providers (such as teachers and coaches) supporting 

their care. 

Information about a patient’s medical conditions, 

including SUDs, is critical to ensuring patients receive 

comprehensive care that facilitates and sustains their 

recovery and overall health. For instance, a healthcare 

provider treating a patient in recovery from a SUD may 

wish to avoid prescribing a highly addictive pain medication for the patient’s non-SUD condition because it 

could cause the patient in recovery to relapse. 

The Part 2 regulations apply to any federally assisted 

program that identifies itself as a SUD program providing treatment services. The regulations require that 

treatment records identifying a patient as having or 

having had a SUD be confidential and only disclosed 

under expressly authorized circumstances.16 In general, a SUD treatment program that is subject to Part 2 

must obtain written patient consent before disclosing 

patient-identifying information. Once this information 

is disclosed, re-disclosure is not permitted unless 

expressly permitted by the written consent of the 

patient or unless otherwise permitted under Part 2. 

Certain exceptions to the written consent requirement 

are permitted under Part 2, such as disclosures for 

research, medical emergency, and audit and evaluation purposes.17

Historically, Part 2 has included more stringent disclosure requirements for SUD records when compared to 

other health privacy laws such as HIPAA. However, in 

2017 and 2018 SAMHSA issued final Part 2 rules that 

aligned some aspects of Part 2 with HIPAA to facilitate 

greater information sharing and to ensure that care 

for SUD patients could be provided in a coordinated 

and integrated manner. In addition, in 2018 SAMHSA 

and the Office of the National Coordinator for Health 

Information Technology released fact sheets that 

provide examples of how Part 2 data can be shared 

through electronic health records and health information exchanges. 
138 Federal Commission on School Safety: Protect and Mitigate

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. OCR should analyze current HIPAA guidance to: 

a) Determine whether simpler, more user-friendly information is needed;

b) Identify additional scenarios based on current school settings to improve understanding of when 

HIPAA applies to such settings; and 

c) Determine how new or revised guidance may improve coordination between mental health providers, family members, other healthcare professionals, law enforcement, and school personnel.

2. The U.S. Department of Health and Human Services (HHS) should analyze the need for joint 

OCR-SAMHSA guidance to clarify and explain how HIPAA and 42 CFR Part 2 apply and intersect 

across different settings to help further address the potential for violence related to comorbidity of 

SUDs and Serious Mental Illness. 

3. HHS should analyze the HIPAA Privacy Rule and existing guidance to determine how current provisions related to disclosures (such as those relating to serious and imminent harm) impact the ability 

or willingness of covered healthcare providers to report when an individual poses a risk of violence 

to a school or in another setting. Determine if changes to the Privacy Rule are warranted.

4. HHS should amend the HIPAA Privacy Rule to create a stronger safe harbor for providers to disclose 

(to a state public health or law enforcement authority) information about patients who need to 

receive continuous, monitored care because they may be a threat to themselves or others.

5. All appropriate federal agencies should support the development of applications (including for 

mobile platforms) and electronic health record systems that facilitate patient consent to information sharing among providers. 

¤ STATES & LOCAL COMMUNITIES

1. State and local healthcare providers should ask patients to identify any family members or other 

helpers or caregivers involved in their care before an emergency occurs so the providers know not 

only who to notify in an emergency situation, but also who to call about their care. 

2. To prepare for potential emergency circumstances, schools, healthcare providers, and others 

affected by the HIPAA Privacy Rule should familiarize themselves with the OCR guidance described 

above (as well as other applicable law and professional ethical standards) before an emergency 

occurs.
Federal Commission on School Safety: Protect and Mitigate 139

Chapter 18 Endnotes

1 Health Insurance Portability and Accountability Act of 1996 (HIPAA) 

(Pub. L. No. 104–191).

2 HHS, Office of Civil Rights, accessed July 17, 2018. https://www.hhs.gov/

hipaa/for-professionals/privacy/index.html.

3 45 C.F.R. Parts 160 and 164, Subparts A and E.

4 See the definition of “business associate” at 45 C.F.R. § 160.103.

5 A transaction under the Privacy Rule is the transmission of information 

between two parties to carry out healthcare-related financial or administrative activities. 45 C.F.R. § 160.103.

6 Statement from Jennifer Mathis, Director of Policy and Legal Advocacy 

at the Bazelon Center for Mental Health Law, to the Federal Commission 

on School Safety. (July 11, 2018). https://www2.ed.gov/documents/

school-safety/transcript-07-11-2018.pdf.

7 A covered entity must disclose protected health information in only 

two situations: (a) to individuals (or their personal representatives or 

designated third party) when the individuals request access to, or an 

accounting of disclosures of, their protected health information; and (b) 

to HHS when it is undertaking a compliance investigation or review or 

enforcement action. See 45 CFR § 164.502(a)(2).

8 Statement to the Federal Commission on School Safety. (July 11, 2018). 

https://www2.ed.gov/documents/school-safety/transcript-07-11-2018.

pdf.

9 See 45 CFR § 164.512(f). Also see https://www.hhs.gov/hipaa/for-professionals/faq/505/what-does-the-privacy-rule-allow-covered-entities-todisclose-to-law-enforcement-officials/index.html.

10 Additional materials for consumers and families with minor children can 

be found at https://www.hhs.gov/hipaa/for-individuals/mental-health/

index.html. 

11 45 C.F.R. § 512(j).

12 45 C.F.R. § 160.103.

13 https://www.hhs.gov/sites/default/files/when-your-child.pdf. See also 

Joint guidance issued in November 2008 by OCR and the Department 

of Education, and which remains applicable, can be found at: https://

www2.ed.gov/policy/gen/guid/fpco/doc/ferpa-hipaa-guidance.pdf.

14 See Purpose and Effect, § 2.2 (b)(2).

15 See, e.g., Ending discrimination against people with mental and substance use disorders: The evidence for stigma change. (2016). https://

www.nap.edu/catalog/23442/ending-discrimination-against-people-with-mental-and-substance-use-disorders; van Boekel, L.C., et al. 

(July 1, 2013). Stigma among health professionals towards patients with 

substance use disorders and its consequences for healthcare delivery: 

Systematic review. Drug & Alcohol Dependence, Vol. 131, Issue 1, 23–35.

16 See Definitions, § 2.11 (https://www.law.cornell.edu/cfr/text/42/2.11); 

Applicability, § 2.12, Prohibition on Redisclosure (https://www.law.

cornell.edu/cfr/text/42/2.12); § 2.32 (https://www.law.cornell.edu/cfr/

text/42/2.32).

17 See Minor Patients, § 2.14 (https://www.law.cornell.edu/cfr/

text/42/2.14).
140 Federal Commission on School Safety: Prevent

SECTION 3

Respond & 

Recover
Federal Commission on School Safety: Respond and Recover 141

An active shooter is an individual actively engaged in 

killing or attempting to kill people in a confined and 

populated area.1 Active shooter situations are unpredictable and devolve quickly. In most cases, there 

is no pattern or method to the selection of victims. 

Because active shooter situations are often over 

before law enforcement arrives on the scene, individuals must be prepared both mentally and physically 

to deal with an active shooter attack—without the 

assistance of trained crisis response personnel. 

The shooting at Marjory Stoneman Douglas High 

School in Parkland, FL, bore all the standard characteristics of an active shooter situation. The shooter 

appeared to indiscriminately target people, firing into 

some classrooms while walking by others.2 In less 

than seven minutes, 17 individuals were killed, and 

the shooter exited the campus well before off-campus 

local law enforcement arrived on scene.3 According to 

some reports, total casualties may have been higher 

had the school not provided active shooter preparedness training to staff, the latest coming just six weeks 

before the shooter required teachers to put that training to use.4

Reports prepared in the aftermath of school shootings 

have universally recognized the value of preparing 

for a potential active shooter incident and other 

mass casualty events through training, planning, and 

related strategies. For example, the Columbine Commission recommended “a much-increased emphasis 

on training in preparation for large-scale emergencies.”5

 The Virginia Tech Commission recommended 

that states and locals “[i]ntegrate comprehensive 

all-hazards emergency management planning for 

schools into overall local and state emergency planning.”6

 The Sandy Hook Advisory Commission recommended that appropriate agencies “review all existing 

policies concerning planned responses to active 

shooters” and “develop and conduct joint regional 

exercises of planned responses to major events.”7

In its report on school safety, the Obama Administration stated “[o]ne of the best ways to minimize 

the loss of life in a mass shooting is to make sure law 

enforcement, first responders, school officials, and 

others are prepared to respond to an active shooter.”8

The report called for the immediate expansion of 

access to federal training and for Congress to provide 

an additional $14 million to help train police officers 

and others to respond to active shooter situations.9

The unique characteristics of K–12 school environments, including campus layout and building design, 

present complex challenges to active shooter planning. Therefore, approaches to address active shooter 

incidents at schools must be specific to each school’s 

unique environment. Numerous factors should inform 

the design of a school’s active shooter preparedness 

program. They include the following. 

• Age: Students in grades K–12 typically range in age 

from five to 19, presenting unique challenges for 

each age group. Elementary students, for example, are unable to understand and respond to 

an incident in the same manner as a high school 

student. Therefore, age is often an important consideration in how to discuss awareness campaigns 

and response methods with students. While the 

“Run, Hide, Fight”10 approach for reacting to active 

shooter incidents is widely taught nationwide, the 

“Fight” portion of the campaign may not be appropriate for all age groups and may require modification to ensure younger students better understand, 

respond, and react to an active shooter. Federal, 

state, and local governments as well as associations and nonprofits have developed approaches 

tailored for children to respond to active shooter 

incidents, including: “Lock Out, Get Out, Take Out” 

and “Observe, Navigate, Escape.”11

CHAPTER 19

Active Shooter Preparedness and Mitigation

Approaches to address active shooter incidents at 

schools must be specific to each school’s unique 

environment.
142 Federal Commission on School Safety: Respond and Recover

The Safe and Sound Schools organization created a 

guide to assist school communities in determining 

the appropriate approach for educating and training students and staff.12 Descriptions of the seven 

levels identified in that guide are below.

Table 19.1 

Safe and Sound Schools’ Summary of 

Developmental Levels of Safety Awareness13

Level Description

Early

(Pre-K and 

Kindergarten)

• General understanding of danger.

• Heavily reliant on adults for direction.

• Capable of practicing basic safety 

concepts like “get out” and “keep out.”

Developing

(Early 

Elementary)

• Demonstrates characteristics of early 

awareness.

• Capable of providing basic assistance in 

an emergency (e.g., turning out lights).

Practiced

(Upper 

Elementary)

• Demonstrates characteristics of 

developing awareness.

• Capable of assisting adults in an 

emergency (e.g., closing doors).

Proficient 

(Intermediate/

Middle School)

• Capable of performing practiced actions independently.

• May or may not demonstrate the ability 

to interrupt an attacker.

Independent

(High School 

and Adult)

• Demonstrates automatic response in 

a variety of safety situations.

• Demonstrates ability to independently

adapt and apply safety skills and 

knowledge in a variety of situations.

• May or may not demonstrate the ability 

to interrupt an attacker.

Advanced

(Professionally 

Trained Adults or 

Staff Members)

• Capable of leading others and making 

decisions in emergencies.

• May or may not demonstrate the ability 

to interrupt an attacker.

Professionals 

(Responders, 

Military, Security 

Professionals)

• Highly capable of decision-making in 

an emergency.

• Trained and equipped to provide 

tactical response in an emergency.

Individual levels may vary due to the unique 

developmental, cultural, educational, and personal 

profiles within a community or classroom. School 

communities and parents, in partnership, should 

consider the individual psychological backgrounds 

and educational needs of students when determining awareness levels as well as appropriate education and training.14

• School Design: A school’s design will have a great 

impact on how it prepares to prevent, protect, 

mitigate, respond to, and recover from active 

shooter incidents. Suburban schools often have 

campus-style environments with multiple buildings, while urban schools tend to consist of single 

multi-level buildings. Campus-style schools can be 

more difficult to secure, as the dispersed school 

buildings are exposed to attacks from multiple 

directions. A more compact organization of buildings or a single building provides for more streamlined surveillance and access control.15 The level of 

security in individual classrooms (e.g., strength of 

classroom doors and locks, presence or absence of 

windows with lines of sight) may influence decisions on active shooter preparedness, as can the 

existence or absence of layers of security to delay 

potential attackers. More information on school 

design and school hardening can be found in Chapter 16 of this Report. 

• Student Background and Special Needs: Students 

come from a variety of family, cultural, and medical disabilities and medical history backgrounds. 

This presents additional considerations for school 

safety and security. According to the most recent 

data provided by the National Center for Education 

Statistics, approximately 4.8 million public school 

students identify as English language learners,16

and 6.7 million students received special education 

services in 2015.17 Active shooter awareness and 

response communications, training, and planning 

should take language differences and disabilities 

into consideration to include the entire student 

population. For example, Washington, D.C.-based 

Gallaudet University serves deaf and hard-ofhearing students and employs several different 

methods to communicate with students during an 

emergency, such as emails, emergency blue lights, 

orange flags, and person-to-person messaging.18

• Laws and Policies: Schools may need to follow 

different rules than businesses when implementing 

security policies. Schools are not only responsible 

for training and keeping students safe, but also for 

leading students in an emergency.19 State and local 

laws as well as school policies concerning security 

and response vary nationwide, and schools should 

be aware of the regulatory responsibilities imposed 

upon them in their jurisdictions. 
Federal Commission on School Safety: Respond and Recover 143

Commission Observations

Through its various engagements with school safety 

and security stakeholders, the Commission identified 

a variety of elements and approaches that experts 

routinely recommend schools incorporate when 

developing their active shooter preparedness and mitigation program. These include physically hardening 

the school, engaging in community planning, encouraging and facilitating the reporting of suspicious 

behavior, conducting training and exercises, maintaining and testing effective communications systems, 

and establishing threat assessment teams. Each of 

these key elements are summarized below.

• School Hardening: As numerous witnesses testified 

during the August 16 Commission meeting and the 

August 23 Commission field visit, there are several 

core parts of a comprehensive active shooter preparedness strategy. They include security measures 

that help control access to the school and its campus, physically strengthen the building, and seek 

to create secure spaces within classrooms where 

students and teachers can shelter in the case of 

an active shooter.20These measures can deter an 

attacker from initiating an attack, protect individuals during an attack, and delay the attacker to 

allow additional time for local law enforcement to 

respond. Information on best practices for physically hardening school buildings can be found in 

Chapter 16 of this Report.

• Community Planning: As of the 2015–2016 school 

year, 92.4 percent of public schools reported having 

written plans to address a shooting on campus.21

As Paul Timm, Vice President of Facility Engineering Associates, testified to the Commission at the 

August 23 Commission field visit, it is beneficial 

for schools to establish safety planning teams that 

include school administrators, teachers, parents, 

students, and other community partners.22 This 

approach ensures a multi-disciplinary, multi-perspective methodology that reflects the community’s values, priorities, and unique needs, thereby 

increasing the chances of implementation success. 

Whole community planning should happen concurrently, and be coordinated, at the school district 

and individual school levels. Additional information on cultivating a “community of interest” can 

be found in Chapter 16 of this Report. 

• Identification and Reporting of Suspicious 

Behavior: Physical protection measures only go so 

far when it comes to preventing an active shooter 

incident. Potential warning signs are not always 

the result of a direct threat—more often, there is 

observable conduct that could signal a threat. As 

various witnesses during the August 16 Commission meeting attested, detecting and addressing 

concerning behavior, thoughts, or statements can 

prevent active shooter situations from occurring.23

Information related to identifying, reporting, 

assessing, and acting upon suspicious activity can 

be found in Chapter 5 of this Report. 

• Training and Exercises: It is widely agreed that a 

robust training and exercise program is essential to 

successfully addressing the complex active shooter 

threat. For example, during the August 28 Commission listening session, Alabama Governor Kay Ivey 

discussed how training is a major part of her Smart 

on Safety Initiative. Also during that session, Alabama State Representative Mac McCutcheon noted 

The Commission identified a variety of elements 

and approaches that experts routinely recommend schools incorporate when developing 

their active shooter preparedness and mitigation 

program. These include physically hardening the 

school, engaging in community planning, encouraging and facilitating the reporting of suspicious 

behavior, conducting training and exercises, maintaining and testing effective communications systems, and establishing threat assessment teams.

It is beneficial for schools to establish safety planning teams that include school 

administrators, teachers, parents, students, and other community partners. This 

approach ensures a multi-disciplinary, multi-perspective methodology that reflects 

the community’s values, priorities, and unique needs, thereby increasing the chances 

of implementation success.

Figure 19-1
144 Federal Commission on School Safety: Respond and Recover

the importance of having law enforcement and 

school officials train together to respond to emergency situations. Similarly, Kathy Martinez-Prather, 

Director of the Texas School Safety Center, noted 

how school districts in Texas are required to train 

school employees to respond to an emergency and 

conduct drills and exercises to prepare both school 

employees and students.24

Active shooter training for students should be 

age-appropriate and consist of prevention, situational awareness, and response training. School 

administrator and teacher training should include 

tabletop exercises (i.e., group exercises that do 

not involve hands-on practice or fieldwork, but 

rather are intended to generate discussion of issues 

surrounding a hypothetical, simulated emergency) 

with school safety and security teams. When 

possible and age-appropriate, response training 

for school administrators, teachers, and students 

should involve role-play, scenario-based training 

that simulates a real-life active shooter incident 

requiring quick decision-making. To the extent 

possible, all active shooter trainings, especially 

those related to responding to and recovering from 

an active shooter incident, should be trauma-informed.25 Additional details on active shooter training and exercises are found later in this section.

In addition to active shooter training, it is important for school staff and students to be trained on 

and follow appropriate security protocols. The 

best single entry access control system is of no 

use if a teacher or student leaves an alternative 

door propped open. The importance of people and 

training is well-stated in the Indiana School Safety 

Guidelines for Emergency Response Systems and 

echoed in the Broward County League of Cities’ 

School and Community Public Safety Task Force: 

“[n]o matter how much money or how many safety 

and security tools a facility can purchase, the most 

common failure to safety and security is human 

error. The term ‘People over Products’ stresses the 

important role of the individuals within a school 

in regard to safety. It is critical to ensure training 

opportunities are provided to employees and students, ensure awareness programs are taking place 

for the implemented safety and security measures, 

and employees and students are being empowered 

to be the most important line of defense.”26

• Communication Systems and Protocols: The 

ability to communicate quickly and effectively 

often is central to a successful response to an 

active shooter incident. This includes the ability 

of school staff or students to quickly inform law 

enforcement of an active shooter situation, thus 

initiating the law enforcement response; the ability 

to quickly alert staff, students, and other members 

of the community of an ongoing active shooter 

situation in order to initiate a lock down, evacuation, or other appropriate action; and the ability for 

law enforcement to communicate among themselves and with the school as necessary during a 

response. 

Unfortunately, as Max Schachter, CEO and Founder 

of Safe Schools for Alex, noted during his testimony 

to the Commission, there are “communication-related problems that impede law enforcement 

during all tragedies, including [the Parkland school 

shooting].”27These may include outdated or insufficient communications equipment (e.g., radios or 

phones that do not receive signals inside school 

buildings), lack of training on existing communications equipment or protocols, and a lack of interoperability between the communications equipment 

possessed by first responder organizations and the 

school. 

In regards to notifying law enforcement of an active 

shooter, Sheriff Tim Troyer told the Commission 

that calls to 911 typically occur two to three minutes after the start of an attack. As was the case 

in Parkland, 911 calls are often indirect calls (e.g., 

made by parents of students who had called their 

parents rather than law enforcement).28 In order 

to reduce this delay in notification, Troyer recommended that schools implement mechanically 

simple means of notification that contact the 911 

center directly.29 One school in Indiana accomA robust training and exercise program is essential to successfully addressing the complex active 

shooter threat.

The ability to communicate quickly and effectively 

often is central to a successful response to an 

active shooter incident.
Federal Commission on School Safety: Respond and Recover 145

plishes this by having teachers wear an emergency 

fob around their neck that they can press in the 

event of an active shooter incident, immediately 

triggering a school-wide alarm and notifying law 

enforcement.30

Schools should consider establishing, maintaining, 

testing, and training on communication technology 

and protocols (e.g., emergency alerts, mass notifications, intercom announcements) that can alert 

both staff and students, as well as parents and 

the broader local community, of an active shooter 

situation. Within schools, it is best if alerts are both 

audible and visual, and can be seen and heard 

throughout the entire school grounds. 

Finally, schools should consider working with local 

law enforcement to test, drill, and exercise the 

communications equipment first responders will 

be using during a response to ensure its adequacy. 

Often, the hardened physical construction of 

school buildings can make radio or phone communication within the school buildings difficult.31

Communications equipment that does not properly function within the school will be of extremely 

limited value during a response. Additionally, 

as Max Schachter pointed out in his testimony, 

interoperability of communications equipment, 

which was a problem during the 9/11 attacks, 

remains a problem today.32 For instance, during 

the response to the Parkland shooting, a lack of 

interoperable equipment forced law enforcement 

to resort to hand signals.33 States and localities 

can take action to help address these concerns. 

For example, during the August 28 Commission 

listening session, Georgia State Representative Rick 

Jasperse noted how the Georgia legislature provided funding for schools that many are using to 

acquire “better communication within the school 

building so when law enforcement rides up, the 

radios work in the building.”34

• Threat Assessments: Numerous witnesses stressed 

to the Commission the importance of schools 

establishing threat assessment teams. They 

included Dr. Jennifer Johnston, Assistant Professor 

of Psychology at Western New Mexico University; 

Donna Michaelis, Manager for the Virginia Center for School and Campus Safety; Kathy Martinez-Prather, Director of the Texas School Safety 

Center; and Dr. Kathy Murphy, Superintendent 

of Hoover (AL) City Schools.35 Threat assessment 

teams are most effective if they are multi-disciplinary and include a diverse group of stakeholders, such as school counselors, school resource 

officers, teachers, and school administrators. 

Parents and students are not typically part of the 

threat assessment team, as personal and confidential information about a student is often discussed. 

Threat assessment teams are addressed in greater 

detail in Chapter 5 of the Report.

Many state and local school districts, as well as their 

local communities, have implemented robust and 

innovative mitigation strategies, tactics, policies, and 

procedures to combat the active shooter threat. One 

example that demonstrates some of the key elements 

listed above through a layered approach to safety and 

security is the Spokane (WA) Public School District. 

Immediately following the December 2012 Sandy 

Hook tragedy, the Spokane Public School District commissioned a safety audit of every district school. Areas 

reviewed included access control, training, physical 

building security, security team staffing, and community suggestions.36 Spokane Public Schools have 

engineered a school safety program that combines 

important physical safeguards and crucial human elements to deter school violence. The district instituted 

a single-point-of-entry policy at each school—meaning the school locks every door once school begins 

and visitors must check in at a single entrance. Visitors 

enter only after having been cleared via video camera 

and intercom by office staff or a resource officer. They 

receive a badge, and the school scans their drivers’ 

licenses and checks them against a registered sex 

offender database and a database for anyone with 

trespass or domestic violence issues. 

Spokane Public Schools launched a “See Something, 

Say Something®” initiative that encourages students 

to report anything that may indicate a student is 

struggling and may need help or is posing a danger 

to himself or herself or to others. The initiative recommends students talk to an adult or report their 

concerns via text, email, or voicemail. The school 

district also has a threat assessment team that evaluates the reported information against possible threat 

indicators. It includes a school psychologist, special 

education personnel, teachers, principals, vice principals, and resource officers. Under state law, Spokane 

schools also are required to conduct multiple safety 

drills each year.
146 Federal Commission on School Safety: Respond and Recover

Numerous guides, trainings materials, and other 

resources have been developed by various federal 

entities, states, and nonprofit organizations to help 

schools develop comprehensive active shooter preparedness plans or aspects thereof. A number of these 

resources are listed in Appendix A.

Active shooter preparedness training, exercises, 

and workshops

As San Bernardino Chief of Police Jarrod Burguan 

told the Commission when discussing his experiences 

with two active shooter incidents in his community, 

“training works. And not just first responders, but it 

works for everybody involved.”37 Training for active 

school shooter scenarios should be designed with the 

audience receiving the training in mind, whether they 

are students, teachers and school administrators, or 

law enforcement officers.

Active Shooter Training for Students: While there is 

some disagreement over whether it is appropriate to 

subject students to active shooter training,38 as school 

shootings become more prevalent, more schools are 

opting to drill their students on how to respond to an 

active shooter situation. According to a 2016 U.S. Government Accountability Office report, an estimated 

67 percent of school districts conduct active shooter 

drills involving their students.39 Whether or not to 

conduct active shooter drills with the student population is something each community must determine for 

itself. For those that do elect to conduct active shooter 

drills with students, they should ensure that the training is age-appropriate and designed in a manner not 

to unduly traumatize any of the participants.

Active Shooter Training for School Staff: All schools 

should consider providing active shooter training to 

teachers and other on-site personnel. In his testimony 

to the Commission, Chief Burguan noted that during 

the April 2017 shooting at North Park Elementary 

School, previous training helped enable school staff 

to successfully evacuate and keep track of more than 

500 students.40 The most effective way to train staff 

to respond to an active shooter situation is to conduct mock active shooter training exercises. Local 

law enforcement is an excellent resource in designing 

training exercises. Training should include discussions 

on recognizing the sound of gunshots, the “Run, Hide, 

Fight” or similar approach used in the school, calling 911, reacting when law enforcement arrives, and 

adopting a survival mindset during times of crisis.41

Some school districts have developed videos to 

supplement training for school staff. For instance, 

the Santa Ana (CA) Unified School District created 

a video for teachers and administrators, “Active 

Shooter Response Protocols: Run, Hide Fight,” that 

demonstrates ways to fight back or distract a shooter. 

Videos such as this can also reinforce other school 

safety practices. One of the Santa Ana video’s many 

messages is for teachers and administrators to say 

something if they notice a student or colleague acting 

irregularly.

Both the U.S. Department of Homeland Security Federal Emergency Management Agency’s (FEMA) Emergency Management Institute and the U.S. Department 

of Education’s Readiness and Emergency Management for Schools (REMS) Technical Assistance Center 

provide a variety of training programs for school staff 

and other members of the school community on how 

to prepare for emergencies at schools. They include 

“Preparing for Emergencies—What School Staff Need 

to Know,” “Multi-Hazard Emergency Planning for 

Schools,” “Developing Emergency Operations Plans 

K–12 101,” and “Preparing for Mass Casualty Incidents: 

A Guide for Schools, Higher Education, and Houses of 

Worship.” Most of these courses provide instruction 

applicable to both natural and human-caused events, 

including active shooter situations.42

Active Shooter Training for Law Enforcement Officers: Both the U.S. Department of Homeland Security 

and the U.S. Department of Justice manage numerous 

programs to help train federal, state, local, and tribal 

law enforcement officers for active shooter situations. 

Examples include:

• Department of Homeland Security’s Federal Law 

Enforcement Training Centers (FLETC) Active Threat 

and Tactical Medical Training. More than 60 federal agencies send their new law enforcement 

recruits to one of FLETC’s basic training programs, 

each of which includes instruction in active threat 

response. FLETC also delivers five advanced 

“...training works. And not just first 

responders, but it works for everybody 

involved.”

— San Bernardino Chief of Police Jarrod Burguan
Federal Commission on School Safety: Respond and Recover 147

programs in active threat response and tactical 

medical training. A significant portion of program 

participants are state, local, and tribal law enforcement officers from across the United States, including sworn officers serving universities and local 

school districts. 

FLETC also offers versions of its active threat and 

tactical medical training programs that help officers return to their home districts with the knowledge, skills, and instructional materials to redeliver 

the training to others in their departments and geographic areas. Thus, when one officer completes 

this training, dozens of others can benefit, creating 

a force multiplying effect. Graduates of the Active 

Shooter Threat Instructor Training Program and 

Basic Tactical Medical Instructor Training Program 

gain access to FLETC’s instructional materials, 

which state accrediting agencies have often already 

evaluated and approved. This enables the officers 

to quickly redeliver the training without having 

to create their own materials. Moreover, because 

agencies across the nation end up using identical 

training materials, training is more consistent, 

which fosters a better coordinated and integrated 

response to active threat events among agencies 

that must work together in these instances.43

• FEMA Emergency Planning for Schools. Many of the 

school preparedness and emergency management 

training programs offered by FEMA are geared 

toward campus and local law enforcement officers. As noted above, most of these multi-hazard 

courses contain lessons relevant to preparing for 

and responding to both natural and human-caused 

events, including active shooter situations. Courses 

that are of particular use to law enforcement 

include “Multi-Hazard Emergency Planning for 

Schools,” “Crisis Management for School-Based 

Incidents—Partnering Rural Law Enforcement, 

First Responders, and Local School Systems,” and 

“Campus Emergencies Prevention, Response, and 

Recovery.”44

• The Department of Justice’s Office of Community 

Oriented Policing Services (COPS) Preparing for 

Active Shooter Situations (PASS) Training Program.

This program supports active shooter training to 

improve the safety and resiliency of law enforcement officers, other first responders, and communities. It seeks to enhance the ability of law 

enforcement not only to secure the scene, but 

also to increase the survivability of the event and 

protect officers, critical assets, and first responders 

from the long-term effects of exposure to trauma. 

In addition to online training, more than 15,000 

participants will be trained in-person with existing 

funding, and FY 2018 funding will support the delivery of 438 classes across the country that will train 

more than 16,000 first responders. PASS is adding 

to its portfolio more classes in advanced medical 

skills, solo officer rapid deployment, civilian casualty care, and exterior response to active shooter 

events.45 

• The Federal Bureau of Investigation’s Active Shooter: 

Managing the Mass Casualty Threat DVD. This 

35-minute documentary provides an in-depth look 

at three unique active shooter events: the Century 

Aurora 16 Cinemark theatre shooting in Aurora, CO; 

the Washington Navy Yard shooting in Washington, 

D.C.; and the Los Angeles International Airport 

shooting in Los Angeles, CA. Each story is told by 

the emergency professionals and private sector 

partners who were there. They offer a frank and 

introspective look at what worked and what could 

have been done better to manage these chaotic 

incidents.46 

• Federal Bureau of Investigation’s Crisis Communications Quick Reference Guide. This brochure is 

tailored to chiefs, sheriffs, command staff, and 

public information officers who handle crisis 

communications in response to an active shooter, 

mass casualty, or other law enforcement incidents. 

It provides checklists for the pre-event, the onset 

of the incident, and updating the media (pre-press 

conference and second and subsequent press 

conferences). Also included are 10 tips to improve 

communications.47 

• Federal Bureau of Investigation’s Initial On Scene 

Command Considerations. This two-inch by threeinch card delineates vital issues to be considered 

during the initial minutes and hours of an active 

shooter, mass casualty, or other law enforcement 

incident. Topics include priority staging areas, toptier priority concerns, and secondary-tier priority 

concerns.48 
148 Federal Commission on School Safety: Respond and Recover

Tactical Emergency Casualty Care/Mass Casualty 

Response Training: In active shooter situations, 

providing rapid medical care to the injured is critical. 

If students and personnel are seriously injured and 

do not receive aid in a timely manner, they may die 

before first responders are even able to enter the 

building. However, if the students and staff around 

them can provide appropriate first aid, they may buy 

the injured time. The Tactical Emergency Casualty 

Care (TECC) framework outlines how best to do this. 

TECC is evidence-based, best practice–driven medical guidance for providers at all levels, including lay 

persons. It seeks to improve survival from traumatic 

injuries sustained during intentional mass casualty 

events. Grounded in the military’s lessons learned in 

combat, TECC translates best practices in battlefield 

trauma care into appropriate practices for civilian 

emergency medicine. TECC includes guidance for First 

Care Providers (i.e., lay persons who are uninjured and 

able to help during and immediately after an act of 

intentional violence). First Care Providers can include 

students, staff, educators, coaches, volunteers, and 

administrators. Empowering these individuals to act 

as caregivers not only saves lives, it can also decrease 

their sense of helplessness and encourage resilience. 

Some of the actions taught through TECC include 

hemorrhage control with direct pressure, tourniquets, 

and pressure bandages; simple airway management 

(positioning someone to breathe best); simple management of torso injuries; hypothermia prevention; 

efficient movement of an injured person; and psychological support/comfort to the wounded and other 

survivors. 

There are three components to a successful First Care 

Provider program: policy, training, and equipment. 

• Policy: Any school policies on intentional violence 

should ensure that both students and staff are 

empowered to act rapidly during a hostile event, 

not only to protect themselves but also to provide 

care to the injured. For adults (educators, staff, 

administration, custodial staff, volunteers, coaching staff, etc.), policies must provide a clear outline 

of what is expected of them, what is encouraged of 

them, and what the scope of their duty to act is in 

these events, including any limitations.

• Training: Consistent, realistic training is necessary 

for anyone expected to be a First Care Provider. 

Training should occur frequently enough that all 

First Care Providers receive the training within 

a school year. Training should include drills that 

account for real incident issues like sensory overload, large volumes of blood, and decision-making 

under stress. A good training curriculum provides 

not only instruction on medical interventions but 

also reviews actual equipment available in the 

facility and discusses specific school system policies. For this to be successful, it is imperative that 

school systems partner with their local first-arriving law enforcement, fire, and emergency medical 

services agencies. 

• Equipment: While medical supplies and equipment 

(e.g., tourniquets, pressure dressings, hemostatic 

agents) may be cost prohibitive to some school 

systems, they are still strongly recommended. 

When purchasing supplies and equipment, schools 

should work with their jurisdiction’s public safety 

medical director(s) to ensure they purchase supplies that are appropriate for the student population. The physical size differences between pre-K 

and secondary students means that different supplies and equipment may be appropriate for different schools. Guidance from a public safety medical 

director will prevent the purchase of equipment 

appropriate for military or law enforcement use 

that does not work on children.

A number of resources are available to help school 

districts or individual schools design TECC training 

programs. They include Tactical Emergency Casualty 

Care Guidelines for First Care Providers49, You Are 

the Help Until Help Arrives50, Introduction to Tactical 

Emergency Casualty Care51, and Stop the Bleed52. In 

August 2018, the Department of Homeland Security 
Federal Commission on School Safety: Respond and Recover 149

(DHS) announced a grant opportunity to support the 

development of mass casualty event trauma training 

for high school students.53

Exercises and workshops

Exercises and workshops help evaluate the success 

of training, maintain optimal levels of performance, 

and test and evaluate plans. A well-designed exercise 

provides a low-risk environment to test capabilities, 

familiarize personnel with roles and responsibilities, 

and foster meaningful interaction and communication 

across organizations. Workshops are a type of discussion-based exercise focused on increased participant 

interaction and focusing on achieving or building 

a product, such as a report or best practices documentation. Both formats can enhance the security of 

schools and safety of students across the nation by 

empowering states and school districts to put their 

emergency plans in action and identifying areas for 

improvement. 

One of the most commonly used approaches to evaluate active shooter preparedness is through tabletop exercises (TTXs). TTXs are table-based activities 

typically held in an informal setting and presented by 

a facilitator. They do not involve hands-on practice or 

fieldwork, but rather are intended to generate discussion of various issues regarding a hypothetical, simulated emergency. TTXs can be used to enhance general 

awareness, validate plans and procedures, rehearse 

concepts, and/or assess the types of systems needed 

to guide the prevention of, protection from, mitigation 

of, response to, and recovery from a defined incident. 

Delivered in a low-stress environment, the TTX offers 

participants the opportunity to explore different ideas 

in the context of a real-world scenario.

When designing TTXs, other exercises, or workshops 

to evaluate active shooter preparedness, designers 

should consider following the Homeland Security 

Exercise and Evaluation Program (HSEEP) approach. 

HSEEP provides a set of guiding principles for exercise 

programs, as well as a common approach to exercise 

program management, design and development, 

conduct, evaluation, and improvement planning. 

Principles include using capability-based and objective-driven exercises informed by risk, engaging the 

whole community, and designing a progressive program with an increasing level of complexity over time. 

These can help a school or school district develop an 

effective exercise program. HSEEP also calls for the 

documentation of strengths, areas for improvement, 

core capability performance, and corrective actions in 

an After-Action Report or Improvement Plan. Through 

improvement planning, organizations take the corrective actions needed to improve plans, build and 

sustain capabilities, and maintain readiness.54

DHS offers a variety of exercises and workshops to 

assist schools, local law enforcement, and others 

prepare for active shooter situations. They include the 

following.

Active Shooter: What You Can Do: Developed by DHS, 

this independent study course seeks to guide the 

public on how to prepare for and respond to active 

shooter crisis situations. Upon completion of Active 

Shooter: What You Can Do, employees and managers 

will be able to: 

• Describe the actions to take when confronted with 

an active shooter and to assist responding law 

enforcement officers; 

• Recognize potential school or workplace violence 

indicators; 

• Describe actions to take to prevent and prepare for 

potential active shooter incidents; and 

• Describe how to manage the consequences of an 

active shooter incident.

The online training is available through the FEMA 

Emergency Management Institute.55 Additional training for law enforcement is available through the Louisiana State University’s National Center for Biomedical 

Research and Training’s website.56

Campus Resilience Program Tabletop Exercises: 

In support of state and local efforts to build greater 

resilience capacity through exercises, the DHS Office of 

Academic Engagement’s Campus Resilience Program, 

in partnership with the FEMA National Exercise Division, conducts a TTX series specifically for academia. 

The academia-focused TTX series is primarily focused 

on institutes of higher education. It consists of four 

offerings: 

Exercises and workshops help evaluate the 

success of training, maintain optimal levels of 

performance, and test and evaluate plans.
150 Federal Commission on School Safety: Respond and Recover

• the National Seminar and Tabletop Exercise—an 

annual two-day event that includes workshop sessions, resources, a full-scale TTX, and after-action 

review session; 

• Regional Tabletop Exercises—one-day events 

hosted multiple times a year designed to address a 

regionally specific threat; 

• the Leadership Tabletop Exercise—a half-day 

event hosted biannually for institution leadership 

designed to highlight its role in emergency management; and 

• the suite of Exercise Starter Kits—instructions and 

a set of scalable tools for institutions to develop 

and run their own tailored TTX to match their most 

pressing needs while validating specific emergency 

plans, protocols, and procedures.57

DHS Active Shooter Preparedness Workshop: These 

scenario-based workshops feature facilitated discussions to engage private sector professionals and 

law enforcement representatives from federal, state, 

and local agencies to learn how to prepare for, and 

respond to, an active shooter situation. Through the 

course of the exercises, participants evaluate current 

response concepts, plans, and capabilities for coordinated responses to active shooter incidents. The modules are structured following national preparedness 

guidance, using the national preparedness mission 

areas to organize the active shooter topics and the 

FEMA Comprehensive Preparedness guidance to cover 

the planning steps.58

Tabletop exercises (TTXs) can be used to enhance 

general awareness, validate plans and procedures, rehearse concepts, and/or assess the types 

of systems needed to guide the prevention of, 

protection from, mitigation of, response to, and 

recovery from a defined incident. 
Federal Commission on School Safety: Respond and Recover 151

Recommendations

Based on the information contained in this chapter, the Federal Commission on School Safety 

offers the recommendations below.

¢ FEDERAL GOVERNMENT 

1. The U.S. Department of Homeland Security (DHS), in coordination with other federal agencies, 

should develop active shooter preparedness training guidelines for educators and administrators, 

including 

recommended minimum standards for teacher certification requirements. 

2. In order to assist schools in deciding the optimal approach to preparing students for active shooter 

situations, federal agencies should work with school security stakeholders to identify and develop 

recommended, age-specific best practices or options for consideration for active shooter training 

and exercises for students spanning the K–12 spectrum.

3. DHS should develop options for expanding its offerings of TECC training, including train-the-trainer 

opportunities. Additionally, the federal government should review how grants are allocated to 

determine if there is a way to better support schools seeking to procure and preposition medical 

equipment needed to respond to a mass casualty event.

¤ STATES & LOCAL COMMUNITIES

1. States should consider requiring or providing funding for all school districts and individual schools 

to develop and (on no less than an annual basis) provide training and exercises on comprehensive 

active shooter preparedness programs. 

2. Teacher preparedness is critical to school security, especially in cases of an active shooter. As every 

state requires teachers to meet certain requirements for certification to teach in their state, it is 

recommended that states and school districts consider requiring basic school security and/or 

active shooter preparedness training as part of their state’s teacher certification requirements.

3. All schools should conduct active shooter training and exercises for staff on a recurring basis as 

well as age-appropriate active shooter training for students. Exercises might include evaluations 

that assess the participant’s ability to meet exercise objectives and capabilities, and document 

strengths, areas for improvement, core capability performance, and corrective actions in an 

After-Action Report or Improvement Plan. Following the exercise, organizations should develop a 

plan to implement the corrective actions identified during the exercise to improve plans, build 

and sustain capabilities, and maintain readiness.

4. Providing TECC training to school staff and maintaining appropriate, rapidly accessible medical 

equipment within schools is a proactive means of reducing loss of life in active shooter scenarios 

and other potential mass casualty incidents. School systems should provide TECC training to school 

staff or provide funding for school staff to complete TECC training. Schools should review existing 

medical equipment within the school and, to the extent possible under existing school budget 

conditions, maintain appropriate medical equipment consistent with the TECC training.

5. Effective communication systems and rapid dissemination of information can save lives during an 

incident or event. Schools should establish and maintain effective communications systems (e.g., 

one-way intercoms or two-way radios) to rapidly provide alerts, warnings, or other key information 

during an incident. Schools should test their communications equipment and methods during 

training and exercises. States and localities should also undertake efforts to ensure interoperability 

of local law enforcement and school communications equipment.
152 Federal Commission on School Safety: Respond and Recover

Chapter 19 Endnotes

1 Department of Homeland Security. (2017). Active shooter: How to 

respond, at p. 2. https://www.dhs.gov/sites/default/files/publications/

active-shooter-how-to-respond-2017-508.pdf. 

2 Price, W., & McCarthy, J. (February 17, 2018). Step by step: How the Parkland school shooting unfolded. Florida Today. https://www.floridatoday.

com/story/news/2018/02/17/minute-minute-how-parkland-schoolshooting-unfolded/345817002/.

3 Ibid.

4 See, e.g., Abt, C. (February 26, 2018). My teachers at Marjory 

Stoneman Douglas saved lives. New York Times. https://www.nytimes.

com/2018/02/26/opinion/florida-guns-training-trump.html.

5 The report of Governor Bill Owens’ Columbine Review Commission. (May 

2001) at p. x.

6 Departments of Education, Justice, and Health and Human Services. 

(June 13, 2007). Report to the President on issues raised by the Virginia 

Tech tragedy, at p. 17.

7 Final report of the Sandy Hook Advisory Commission. (March 6, 2015).

 At p. 76.

8 Now is the time: The President’s plan to protect our children and our 

communities by reducing gun violence. (January 16, 2013) at p. 8.

9 Ibid.

10 Department of Homeland Security. (2017). Active shooter: How to 

respond, at pp. 3–4. https://www.dhs.gov/sites/default/files/publications/active-shooter-how-to-respond-2017-508.pdf.

11 Destein, J. (2016). Introduction to active shooter programs. ASIS School 

Safety and Security Council—Active Shooter. https://www.asisonline.org/

globalassets/news/security-topics/soft-target--active-shooter/active_

shooter_wp_sssc.pdf.

12 Safe and Sound Schools. (2016). Toolkit one: Assess developmental levels 

of safety awareness. https://www.safeandsoundschools.org/wp-content/uploads/2018/01/Toolkit-1-Assess_Part10_Developmental-Levels-of-Safety-Awareness.pdf.

13 Ibid.

14 Ibid.

15 Federal Emergency Management Agency. (2012). Primer to design safe 

school projects in case of terrorist attacks and school shootings, at pp. 

2–13. https://www.dhs.gov/xlibrary/assets/st/bips07_428_schools.pdf.

16 National Center for Education Statistics. (April 2018). English language 

learners in public schools. https://nces.ed.gov/programs/coe/indicator_cgf.asp.

17 National Center for Education Statistics. (April 2018). Children and youth 

with disabilities. https://nces.ed.gov/programs/coe/indicator_cgg.asp.

18 Gallaudet University Department of Public Safety. (2018). Annual security and fire safety report, at p. 10. https://www.gallaudet.edu/Documents/Public-Safety/ANNUAL%20SECURITY%20REPORT2018.pdf.

19 Destein, J. (2016). Introduction to active shooter programs. ASIS School 

Safety and Security Council—Active Shooter, at p. 3. https://www.asisonline.org/globalassets/news/security-topics/soft-target--active-shooter/

active_shooter_wp_sssc.pdf.

20 See, e.g., testimony of Jay Brotman to the Federal Commission on 

School Safety Meeting (August 16, 2018), Creating a citadel of learning: 

New tools to secure our schools, inside and out; testimony of Max 

Schachter to the Federal Commission on School Safety Meeting (August 

16, 2018), Creating a citadel of learning: New tools to secure our schools, 

inside and out; testimony of Sheriff Tim Troyer to the Federal Commission on School Safety Field Visit (August 23, 2018), Best practices for 

school building safety; testimony of Paul Timm to the Federal Commission on School Safety Field Visit (August 23, 2018), Best practices for 

school building safety; testimony of Russell Davidson to the Federal 

Commission on School Safety Field Visit (August 23, 2018), Best practices 

for school building safety.

21 National Center for Education Statistics. (2017). Table 233.65. Percentage of public schools with a written plan for procedures to be 

performed in selected scenarios and percentage that have drilled 

students on the use of selected emergency procedures, by selected 

school characteristics: Selected years, 2003–04 through 2015–16. Digest 

of Education Statistics. https://nces.ed.gov/programs/digest/d17/tables/

dt17_233.65.asp.

22 Testimony of Paul Timm to the Federal Commission on School Safety 

Field Visit (August 23, 2018), Best practices for school building safety.

23 See, e.g., testimony of Officer Chris Fraley to the Federal Commission on 

School Safety Meeting (August 16, 2018), Creating a citadel of learning: 

New tools to secure our schools, inside and out; testimony of Donna 

Michaelis to the Federal Commission on School Safety Meeting (August 

16, 2018), Creating a citadel of learning: New tools to secure our schools, 

inside and out; testimony of Susan Payne to the Federal Commission on 

School Safety Meeting (August 16, 2018), Creating a citadel of learning: 

New tools to secure our schools, inside and out.

24 Testimonies of Governor Kay Ivey, Representative Mac McCutcheon, and 

Kathy Martinez-Prather to the Federal Commission on School Safety 

Roundtable, Montgomery, AL, (August 28, 2018).

25 For information on “trauma-informed” training, see https://www.samhsa.gov/nctic/trauma-interventions.

26 Indiana school safety guidelines for emergency response systems. (2017) 

at p. 9. https://www.in.gov/dhs/files/indiana%20school%20safety%20

guideline%20document.pdf; Broward County League of Cities’ School 

and Community Public Safety Task Force, Initial Report and Recommendations (June 4, 2018) at p. 5.

27 Testimony of Max Schachter to the Federal Commission on School 

Safety Meeting (August 16, 2018), Creating a citadel of learning: New 

tools to secure our schools, inside and out.

28 Testimony of Sheriff Tim Troyer to the Federal Commission on School 

Safety Field Visit (August 23, 2018), Best practices for school building 

safety.

29 Ibid.

30 Ibid.

31 Broward County League of Cities’ School and Community Public Safety 

Task Force. (June 4, 2018) Initial report and recommendations, at p. 73.

32 Testimony of Max Schachter to the Federal Commission on School 

Safety Meeting (August 16, 2018), Creating a citadel of learning: New 

tools to secure our schools, inside and out.

33 Ibid.

34 Testimony of Representative Rick Jasperse to the Federal Commission 

on School Safety Roundtable, Montgomery, AL (August 28, 2018).

35 Testimony of Dr. Jennifer Johnston to the Federal Commission on 

School Safety Meeting (June 21, 2018), The ecology of schools: Fostering 

a culture of human flourishing and developing character; testimony of 

Donna Michaelis to the Federal Commission on School Safety Meeting 

(August 16, 2018), Creating a citadel of learning: New tools to secure 

our schools, inside and out; testimony of Kathy Martinez-Prather to the 

Federal Commission on School Safety Listening Session (August 28, 

2018); and testimony of Dr. Kathy Murphy to the Federal Commission on 

School Safety Listening Session (August 28, 2018).

36 Spokane public schools safety audit. (2013). http://swcontent.spokaneschools.org/cms/lib/WA01000970/Centricity/domain/702/_files/Spokane%20Public%20Schools%20Safety%20Audit%203.6.13.pdf.

37 Testimony of Chief Jarrod Burguan to the Federal Commission on 

School Safety Meeting (August 16, 2018), Creating a citadel of learning: 

New tools to secure our schools, inside and out.

38 See, e.g., Magliozzi, D. (March 31, 2018). Are active shooter drills good 

for students? Newsweek. https://www.newsweek.com/school-shootershooter-training-school-safety-opinion-864708.

39 U.S. Gov’t Accountability Office, GAO-16-144. Emergency management: Improved

federal coordination could better assist K–12 schools prepare for emergencies,

37–38 (2016).
Federal Commission on School Safety: Respond and Recover 153

40 Testimony of Chief Jarrod Burguan to the Federal Commission on 

School Safety Meeting (August 16, 2018), Creating a citadel of learning: 

New tools to secure our schools, inside and out.

41 Department of Homeland Security. (2017). Active shooter: How to 

respond. https://www.dhs.gov/sites/default/files/publications/activeshooter-how-to-respond-2017-508.pdf.

42 Information on these and other FEMA and REMS courses can be found at 

https://training.fema.gov/emi.aspx and https://rems.ed.gov/trainings/

CoursesHome.aspx, respectively.

43 Information on these and other FLETC courses can be found at https://

www.fletc.gov/training-catalog.

44 Information on these and other FEMA courses can be found at https://

training.fema.gov/emi.aspx.

45 Additional information on PASS and other COPS training programs can 

be found at https://cops.usdoj.gov/training.

46 Copies of this DVD are available to law enforcement and emergency 

management professionals by contacting the nearest FBI Field Office or 

calling 202-324-3000.

47 The reference guide is available at https://www.fbi.gov/file-repository/

as-study-quick-reference-guide-updated1.pdf/view.

48 Copies of the card are available to law enforcement and emergency 

management professionals by contacting the nearest FBI Field Office or 

calling 202-324-3000.

49 http://www.c-tecc.org/guidelines/civilian-first-care-provider.

50 https://ready.gov/untilhelparrives.

51 http://tecc.inquisiqr4.com/.

52 https://www.dhs.gov/stopthebleed.

53 https://www.grants.gov/web/grants/view-opportunity.html?oppId=307563.

54 For more information on HSEEP, visit https://preptoolkit.fema.gov/web/

hseep-resources. 

55 https://training.fema.gov/is/courseoverview.aspx?code=IS-907.

56 http://www.ncbrt.lsu.edu/Course/PER-275.

57 Additional information on the DHS Campus Resilience Program TTXs is 

available at https://www.dhs.gov/academicresilience.

58 Additional information on the DHS Active Shooter Workshop Program is 

available at https://www.dhs.gov/active-shooter-workshop-participant. 
154 Federal Commission on School Safety

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Federal Commission on School Safety 155

Conclusion

President Donald J. Trump announced the establishment of the Federal Commission on School Safety 

on March 12, 2018 in the aftermath of the shooting 

in Parkland, FL. The shooting outraged the nation. It 

reignited discussions about ways to prevent such tragedies, what we can do to better protect our students, 

and how to respond to and recover from these acts of 

violence. 

This Commission has led and engaged in many of 

those discussions and has learned much from them. 

While Washington has an important role to play, it 

can play that role more successfully by acknowledging a truth understood by people across the country: 

What works in Wyoming may not work in New York, 

and what is effective in an urban setting may not be 

effective in rural communities. One size does not fit 

all. Real improvement requires:

a) the efforts and engagement of Americans and communities nationwide who have vitally important 

insights and experiences to share; 

b) recognition that best practices, lessons learned, 

and recommended approaches must be evaluated 

in light of, and adapted to, the particular needs and 

circumstances of each school and community; and

c) the coordination of multiple efforts by schools, 

school districts, and communities as well as by 

policymakers at the local, state, and federal levels.

A Multifaceted Longstanding Problem

Engaging a wide range of Americans is essential 

given the complex and multifaceted nature of school 

violence. The Commission heard from individuals with 

diverse perspectives and expertise at Commission 

meetings, field visits, and listening sessions. Participants included students and their families, state 

and local policymakers, principals and teachers, and 

law enforcement and healthcare professionals. Each 

provided a unique perspective that adds to our understanding of the multiple issues involved and the role 

each of us must play. 

The problem of school violence is complex and it has 

existed for decades. The Commission has drawn upon 

the work of previous commissions and reports on 

school violence at the federal, state, and local levels. 

Preventing School Violence

Many individuals have a role to play in prevention 

efforts—parents, teachers, the media, health care 

professionals, entertainment industry leaders, and 

law enforcement. Such efforts are wide ranging. They 

include creating a positive school climate, combatting 

cyberbullying, ensuring rating systems allow parents 

to fully assess the appropriateness of entertainment 

their children are consuming, and establishing “No 

Notoriety” practices in the wake of shootings. 

Local approaches and priorities are most important. 

Because teachers, in partnership with principals and 

other school leaders, know their schools, students, 

and classrooms best, they should be able to make 

decisions about school discipline without unnecessary 

worry about undue federal repercussions. 

Similarly, school-based counselors and other healthcare providers are best positioned to identify mental 

health needs and develop a course of action. 

A proper understanding of how school shooters get 

their hands on firearms (i.e., in most cases from family 

and friends) must inform state legislative efforts. 

Individuals deemed, through appropriate processes, 

to pose a threat to themselves or others can be denied 

the ability to possess or purchase firearms through 

“extreme risk protection orders.” They can also be 

reported through the Federal Bureau of Investigation’s 

tip line.

Protecting and Mitigating 

Training personnel, hardening schools, and engaging the community are all important tools to protect 

against school violence and to mitigate its effects. 

Training applies to teachers, school staff, school 

resource officers (SROs), and state, local, and tribal 

law enforcement. Increasing numbers of these person-
156 Federal Commission on School Safety

nel could come from the ranks of the country’s military 

veterans and retired law enforcement officers, both for 

security and teaching roles. 

All schools will benefit from higher levels of engagement with the communities in which they are located. 

Greater sharing of information and reporting of 

suspicious behavior is essential. However, it must be 

done in a manner that abides by statutory privacy 

protections. 

Responding and Recovering

The unique characteristics of each school (such as 

campus layout, building design, and age of students) 

present complex challenges to active shooter planning. Approaches to improve emergency response 

must be specific to each school. 

There is no doubt planning and training helps prepare 

police officers and first responders to deal with active 

shooters. However, because active shooter incidents 

are often over before law enforcement arrives on the 

scene, onsite personnel must be prepared to deal with 

an active shooter attack in the absence of trained 

crisis response officers. 

An Ongoing Challenge

The Parkland, FL, shooting was not the first such 

tragedy in this country and is not likely to be the last 

without changes at the federal, state, and local levels. 

The job of this Commission has been to identify best 

practices and lessons learned that will help schools 

better prepare for the future. 

Each section of the Report concludes with meaningful 

and actionable recommendations—for the federal 

government, states, tribes, and local authorities, and 

for school districts and schools. However, they are 

just that—recommendations to be considered and 

adopted as appropriate to each jurisdiction. School 

staff and local officials are best placed to determine 

which recommendations to implement in their communities. 

From start to finish, this Commission has recognized 

that the people who best understand the needs 

of their schools and communities are the families 

whose children attend those schools and live in those 

communities. Our job has been to listen to them—as 

well as to subject matter experts, practitioners, and 

professionals—and then to share their experiences 

and knowledge about what has succeeded and what 

has not. 

Going Forward 

The important job of finding ways to protect our students and our schools goes on. Americans will continue to seek answers and solutions to the problem of 

school violence, and those in the federal government 

will continue to work with state and local governments to protect our students. 

This Commission extends its deep gratitude to everyone who has contributed to this work and to those 

who will continue to engage in this area. The four 

departments will continue to disseminate federal 

resources on school safety and provide periodic 

updates. 

Only by working together at all levels and in communities nationwide, can we truly make a difference. For 

the sake of America’s schools and America’s students, 

may that work continue. 
Federal Commission on School Safety: Appendix 157

Appendix A: Federal Resources for School Safety 

The Commissioners identified select resources published by their agencies that highlight best practices that 

may be of immediate use to stakeholders at the state and local levels. Federal agencies may have additional 

resources that could be leveraged to support school safety efforts, and interested parties can contact relevant 

program offices to inquire further about such options. 

Prevent

Guide for Preventing and Responding to School Violence, 2nd Edition, Bureau of Justice Assistance, Office of Justice 

Programs, U.S. Department of Justice. 

• The guide addresses both prevention and intervention from a systemic view, clarifying the role of the school, the 

community, families, law enforcement, and the justice system and how these groups can work together effectively to prevent and respond to school violence. (http://www.theiacp.org/portals/0/pdfs/schoolviolence2.pdf) 

Police-Mental Health Collaboration Toolkit, Bureau of Justice Assistance, Office of Justice Programs, U.S. Department 

of Justice. 

• This toolkit provides resources for law enforcement agencies to partner with mental health providers to 

effectively respond to calls for service, improve outcomes for people with mental illness, and advance the 

safety of all. (https://pmhctoolkit.bja.gov) 

States’ Roles in Keeping Schools Safe: Opportunities and Challenges for State School Safety Centers and Other 

Actors, National Institute of Justice, Office of Justice Programs, U.S. Department of Justice. 

• This report documents the conclusions of a 2016 stakeholder meeting that assembled representatives from 20 

states to discuss state school safety issues. (https://www.ncjrs.gov/pdffiles1/nij/250608.pdf) 

Preventing School Shootings: A Summary of a U.S. Secret Service Safe School Initiative Report, National Institute of 

Justice, Office of Justice Programs, U.S. Department of Justice. 

• This report summarizes a U.S. Secret Service Report that examined the prevention of targeted violence in 

schools. (https://www.ncjrs.gov/pdffiles1/jr000248c.pdf) 

Preventing School Violence: Plenary Papers of the 1999 Conference on Criminal Justice Research and Evaluation, 

National Institute of Justice, Office of Justice Programs, U.S. Department of Justice. 

• This document puts forward the main points of a research forum on preventing school violence, co-sponsored 

by a variety of OJP offices. (https://www.ncjrs.gov/pdffiles1/nij/180972.pdf) 

School-Based Bullying Prevention, Model Programs Guide, Office for Juvenile Justice and Delinquency, Office of 

Justice Programs, U.S. Department of Justice. 

• This is a school-based bullying prevention research literature review (https://www.ojjdp.gov/mpg/litreviews/Bullying.pdf) and program implementation guide (https://www.ojjdp.gov/mpg-iguides/topics/bullying/index.html). 

School Violence Prevention Program (SVPP), Office of Community Oriented Policing Services, U.S. Department of 

Justice. 

• This program makes competitive awards to states, county and local districts to support coordination with law 

enforcement on training to prevent student violence; fund deterrent hardware; and implement technology for 

expedited emergency notification. (https://cops.usdoj.gov/svpp)

Addressing the Risk of Violent Behavior in Youth, Substance Abuse and Mental Health Services Administration, U.S. 

Department of Health and Human Services. 

• This PowerPoint presentation will help teachers and school personnel identify behaviors and other signs that 

could result in youth violence. The material is intended as a general guide regarding what is known about risk 

and protective factors and the warning signs that are associated with a risk of violent behavior. The purpose 

is to inform and help classroom teachers, counselors, and other staff understand the basic facts about youth 

violence. This useful tool also addresses the protective factors that reduce the risk of violent behavior. (https://

safesupportivelearning.ed.gov/addressing-risk-violent-behavior-youth-know-signs-youth-violence-and-howidentify-and-reduce-risk) 
158 Federal Commission on School Safety: Appendix

SAMHSA grants, Substance Abuse and Mental Health Services Administration, U.S. Department of Health and Human 

Services.

• Below are some examples of the school and/or child/adolescent/youth focused grants that were announced in 

fiscal year 2018.

• Project AWARE (Advancing Wellness and Resiliency in Education)

• Mental Health Awareness Training (MHAT) Grants

• Garrett Lee Smith Campus Suicide Prevention Grants

• Healthy Transitions: Improving Life Trajectories for Youth and Young Adults with Serious Mental Disorders 

Program

• Community Programs for Outreach and Intervention with Youth and Young Adults at Clinical High Risk 

for Psychosis

• Infant and Early Childhood Mental Health Grant Program

• Drug-Free Communities (DFC) Support Program

School Climate 

Student Support and Academic Enrichment, Office of Safe and Healthy Students, U.S. Department of Education.

• Title IV, Part A of the Elementary and Secondary Education Act is the Student Support and Academic Enrichment 

(SSAE) program. The SSAE program is intended to improve students’ academic achievement by increasing the 

capacity of states, school districts, and local communities to provide all students with access to a well-rounded 

education; improve school conditions for student learning; and improve the use of technology to enhance academic achievement and digital literacy of all students. (https://safesupportivelearning.ed.gov/ESSA-TitleIVPartA-SSAE)

• More information about how states subgrant these funds to districts is included in the “Non-Regulatory 

Guidance Student Support and Academic Enrichment Grants.” (https://www2.ed.gov/policy/elsec/leg/essa/

essassaegrantguid10212016.pdf) 

School Climate Improvement Resource Package, Office of Safe and Healthy Students, U.S. Department of Education 

and National Center on Safe Supportive Learning Environments (2016).

• This resource package contains a set of guides and reference manuals to improve school climate. Resources 

include information about planning for improvements, collecting and analyzing data, identifying and implementing interventions, and monitoring and evaluating such efforts. Guides contain action steps for district and 

school administrators, teachers and school staff, students, and community partners. (https://safesupportivelearning.ed.gov/scirp/about) 

School Climate Transformation Grants, U.S. Department of Education.

• The U.S. Department of Education provides funding to school districts and states to support schools implementing an evidence-based multi-tiered behavioral framework (such as positive behavior and intervention supports) 

for improving behavioral outcomes and learning conditions for all students. (https://www2.ed.gov/programs/

schoolclimatelea/index.html) 

School Climate Surveys, U.S. Department of Education.

• The U.S. Department of Education developed the high-quality, customizable ED School Climate Surveys 

(EDSCLS) and associated web-based platform. The EDSCLS allows states, local districts, and schools to collect and act on reliable, nationally-validated school climate data in real-time. (https://safesupportivelearning.

ed.gov/edscls) 

Positive Behavioral Interventions & Supports: Technical Assistance Center, U.S. Department of Education. 

• The Technical Assistance Center on PBIS helps schools, districts, and states build systems capacity for implementing a multi-tiered approach to social, emotional and behavioral support that can improve school climate, 

safety, and academic outcomes for all students, including students with disabilities and students from underrepresented groups. (https://www.pbis.org/) 
Federal Commission on School Safety: Appendix 159

Center to Improve Social and Emotional Learning and School Safety, U.S. Department of Education. 

• The Center to Improve Social and Emotional Learning and School Safety provides technical assistance to states 

and districts in the implementation of evidence-based programs and practices in social and emotional learning. 

(https://www.federalregister.gov/documents/2018/05/16/2018-10474/applications-for-new-award-center-to-improve-social-and-emotional-learning-and-school). 

National Center on Safe and Supportive Learning Environments, U.S. Department of Education. 

• The National Center on Safe Supportive Learning Environments offers information and technical assistance to 

states, districts, schools, institutions of higher learning, and communities focused on improving student supports and academic enrichment. The center also supports state and local efforts to implement the Title IV-A 

SSAE program previously described, which can help with the following: 1) provide all students with access to a 

well-rounded education, 2) improve school conditions for student learning, including school climate and safety, 

and 3) enhance the use of technology so all students have the opportunity to realize academic success and digital literacy in safe and supportive learning environments. (https://safesupportivelearning.ed.gov/) 

Project Prevent, U.S. Department of Education.

• This program provides funding to school districts to increase their capacity to identify, assess, and serve 

students exposed to pervasive violence, helping to ensure that affected students are offered mental health 

services for trauma or anxiety; support conflict resolution programs; and implement other school–based 

violence prevention strategies. (https://www2.ed.gov/programs/projectprevent/index.html) 

School Connectedness: Strategies for Increasing Protective Factors Among Youth, Centers for Disease Control and 

Prevention, U.S. Department of Health and Human Services. 

• School connectednes—the belief held by students that adults and peers in the school care about their learning 

as well as about them as individuals—is an important protective factor. This webpage contains fact sheets and 

training materials on strategies for increasing school connectedness for school administrators, teachers, and 

families. (https://www.cdc.gov/healthyyouth/protective/school_connectedness.htm) 

Parent Engagement in Schools, Centers for Disease Control and Prevention, U.S. Department of Health and 

Human Services. 

• Parent engagement in schools is defined as parents and school staff working together to support and improve 

the learning, development, and health of children and adolescents. Parent engagement in schools is a shared 

responsibility in which schools and other community agencies and organizations are committed to reaching out 

to engage parents in meaningful ways, and parents are committed to actively supporting their children’s and 

adolescents’ learning and development. Engaging parents in their children’s school life is a promising protective 

factor. This webpage includes strategies and fact sheets for increasing parent engagement in schools. (https://

www.cdc.gov/healthyyouth/protective/parent_engagement.htm) 

Creating and Sustaining a Positive and Communal School Climate: Contemporary Research, Present Obstacles, 

and Future Directions, National Institute of Justice, Office of Justice Programs, U.S. Department of Justice. 

• This report puts forward four recommendations for creating and sustaining a positive and communal school 

environment. (https://www.ncjrs.gov/pdffiles1/nij/250209.pdf) 

Development of a Standard Model for School Climate and Safety Assessment, Office for Juvenile Justice and 

Delinquency, Office of Justice Programs, U.S. Department of Justice. 

• The purpose of this project was to develop a standard model for the assessment of school climate and safety 

guided by authoritative school climate theory. (https://www.ncjrs.gov/pdffiles1/ojjdp/grants/251102.pdf) 

Bullying and Cyberbullying 

Readiness and Emergency Management for School (REMS) Technical Assistance Center Fact Sheets. Office of Safe 

and Healthy Students, U.S. Department of Education, and Readiness and Emergency Management for Schools 

Technical Assistance Center (2017).

• The Prevention for Schools and School Districts Fact Sheet describes “prevention” and the role it plays in school 

preparedness including examples of prevention activities, steps for integrating prevention into emergency 

planning, and key resources for schools and school districts. (https://rems.ed.gov/Docs/Prevention_Fact_

Sheet_508C.pdf)
160 Federal Commission on School Safety: Appendix

• The Cyber Safety Considerations for K–12 Schools and School Districts Fact Sheet includes information on the 

most common online threats facing students, including cyberbullying. The fact sheet describes how school and 

school district administrators can prepare and respond to online threats. (https://rems.ed.gov/docs/Cyber_Safety_K-12_Fact_Sheet_508C.PDF) 

Electronic Media and Youth Violence: A CDC Issue Brief for Educators and Caregivers, Centers for Disease Control 

and Prevention, U.S. Department of Health and Human Services. 

• This brief focuses on the phenomena of electronic aggression, which is any kind of aggression perpetrated 

through technology—any type of harassment or bullying (teasing, telling lies, making fun of someone, making 

rude or mean comments, spreading rumors, or making threatening or aggressive comments) that occurs through 

email, a chat room, instant messaging, a website (including blogs), or text messaging. (https://www.cdc.gov/violenceprevention/pdf/ea-brief-a.pdf) 

KnowBullying app, Substance Abuse and Mental Health Services Administration, U.S. Department of Health and 

Human Services. 

• This SAMHSA-developed app helps parents and educators start conversations with children; provides tips and 

strategies for children, youth, and teens; and teaches the warning signs of bullying or being bullied. (https://

store.samhsa.gov/apps/knowbullying/) 

Prevent Bullying, Centers for Disease Control and Prevention, U.S. Department of Health and Human Services. 

This website provides general information on bullying, such as definitions of bullying and tools to prevent bullying in 

schools. (http://www.cdc.gov/features/prevent-bullying/) 

Stopbullying.gov, U.S. Department of Health and Human Services. 

• This website contains resources for youth, parents, schools, and others to better understand bullying and 

cyberbullying, including the warning signs, those particularly at risk, and prevention tips. (https://www.stopbullying.gov/)

• Take Action Today: How Families and Students Can Take the Lead in Creating Safer School Environments 

(https://www.stopbullying.gov/blog/2014/09/16/take-action-today-how-families-and-students-can-take-leadcreating-safer-school.html) 

Bullying Prevention for Parents, Centers for Disease Control and Prevention, U.S. Department of Health and Human 

Services. 

• This podcast discusses the crucial role parents play in bullying prevention. (https://tools.cdc.gov/medialibrary/

index.aspx#/media/id/304116) 

MedlinePlus, U.S. Department of Health and Human Services.

• This website provides resources that inform users of the warning signs of bullying, prevention and risk factors, 

and how to help children deal with bullying. (https://medlineplus.gov/bullying.html)   

Impact of Cyberbullying: Addressing the Needs of Children and Youth, Substance Abuse and Mental Health Services 

Administration, U.S. Department of Health and Human Services. 

• This YouTube video reviews ways to help parents, caregivers, and educators better understand the issue of 

cyberbullying and the mental health needs of both the young person being bullied, and the young person 

initiating the bullying. (https://www.youtube.com/watch?v=IUjxqh0ZC0I&t=3s) 

Mental Health 

MentalHealth.gov resources for educators, U.S. Department of Health and Human Services. 

• This site provides general information for educators regarding warning signs for mental health issues, how to 

respond to mental health issues in schools, and how to access crisis support and other mental health services. 

(https://www.mentalhealth.gov/talk/educators) 

Addressing Emotional and Behavioral Issues in K–5 Classrooms, Substance Abuse and Mental Health Services 

Administration, U.S. Department of Health and Human Services. 

• This YouTube video addresses the topic of identifying and managing behavioral health concerns in elementary 

school classrooms. (https://www.youtube.com/watch?v=_uMHn_E5cR4) 
Federal Commission on School Safety: Appendix 161

Addressing Mental Health Concerns in College, Substance Abuse and Mental Health Services Administration, U.S. 

Department of Health and Human Services. 

• This YouTube video addresses the topic of mental and substance use disorders among college students. 

(https://www.youtube.com/watch?v=PfIFLG5yY38) 

Supporting Young Adults with Mental Health Difficulties in Post-Secondary Education, Substance Abuse and Mental 

Health Services Administration, U.S. Department of Health and Human Services. 

• This YouTube video focuses on supporting young people with mental health difficulties—including co-occurring 

substance abuse—who are engaged in post-secondary education. Presenters provide an overview of trends in 

college attendance of young adults with mental health difficulties and the challenges of living away from home 

while working toward recovery. (https://www.youtube.com/watch?time_continue=3&v=zMmS4PU1eNI) 

Finding Help, Finding Hope: What to Do If You Think Your Child May Have a Mental Health Problem, Substance Abuse 

and Mental Health Services Administration, U.S. Department of Health and Human Services. 

• This YouTube video focuses on how parents and caregivers can actively engage in their child’s behavioral health 

care, as well as identify available resources that can help the entire family thrive. (https://www.youtube.com/

watch?v=PRlxmmdsH8Y&feature=youtu.be) 

Mental Health Awareness Training Grants, Substance Abuse and Mental Health Services Administration, 

U.S. Department of Health and Human Services. 

• These grants train individuals to recognize the signs and symptoms of mental disorders, particularly serious 

mental illness; establish links with school-and/or community-based mental-health agencies for referrals; train 

emergency services personnel and others to identify people with a mental disorder; employ crisis de-escalation 

techniques; and educate individuals about resources available in the community for individuals with a mental 

disorder. (https://www.samhsa.gov/grants/grant-announcements/sm-18-009) 

School-based health centers, Health Resources and Services Administration, U.S. Department of Health and Human 

Services. 

• These centers are the center of health in the schools in which they are based. Services include primary medical care, mental/behavioral health care, dental/oral health care, health education, substance abuse counseling, case management, and nutrition information. Approximately 20 percent of these centers receive funding 

through the Health Resources and Services Administration’s Health Center Program. (https://www.hrsa.gov/

our-stories/school-health-centers/index.html) 

Project LAUNCH Grant Program (birth–eight years), Substance Abuse and Mental Health Services Administration, 

U.S. Department of Health and Human Services. 

• The purpose of Project LAUNCH (Linking Actions for Unmet Needs in Children’s Health) is to promote the wellness of young children by addressing the physical, social, emotional, cognitive, and behavioral aspects of their 

development (https://healthysafechildren.org/grantee/project-launch) 

Infant and Early Childhood Mental Health Grant Program (birth–12 years), Substance Abuse and Mental Health 

Services Administration, U.S. Department of Health and Human Services. 

• This program addresses children who are at risk for, show early signs of, or have been diagnosed with a mental 

illness including a serious emotional disturbance. The purpose of this program is to improve outcomes for these 

children by developing, maintaining, or enhancing infant and early childhood mental health promotion, intervention, and treatment services. (https://www.samhsa.gov/grants/grant-announcements/sm-18-018) 

The Center of Excellence for Infant and Early Childhood Mental Health Consultation (IECMHC), Substance Abuse and 

Mental Health Services Administration, U.S. Department of Health and Human Services. 

• The Center of Excellence for IECMHC helps communities support the success of the next generation by increasing 

access to evidence-based IECMHC—an approach that pairs mental health professionals with people who work 

with young children and their families. (https://www.samhsa.gov/iecmhc) 

System of Care (SOC) Expansion and Sustainability Cooperative Agreements (birth–21 years), Substance Abuse and 

Mental Health Services Administration, U.S. Department of Health and Human Services. 

• The SOC grants provide services to improve behavioral health outcomes for children and youth with serious 

emotional disturbances and their families. This program creates sustainable infrastructure and services that are 

required as part of the Children’s Mental Health Initiative. (https://www.samhsa.gov/grants/grant-announcements/sm-16-009)
162 Federal Commission on School Safety: Appendix

Project Advancing Wellness and Resilience Education (AWARE) Grant Program, Substance Abuse and Mental Health 

Services Administration, U.S. Department of Health and Human Services. 

• This program promotes youth mental health awareness among schools and communities and improves connections to services for school-aged youth. (https://www.samhsa.gov/nitt-ta/project-aware-grant-information) 

Safe Schools/Healthy Students (SS/HS) Grant Program, Substance Abuse and Mental Health Services Administration, 

U.S. Department of Health and Human Services. 

• This program is a collaborative effort and comprehensive model to promote mental health among students and 

create safe and secure schools. (https://www.samhsa.gov/safe-schools-healthy-students)

Healthy Transitions Grant Program, Substance Abuse and Mental Health Services Administration, U.S. Department of 

Health and Human Services. 

• The Now Is the Time Healthy Transitions grant program improves access to treatment and support services for 

16- to 25-year-olds who have, or are at risk of developing, a serious mental health condition. (https://www.samhsa.gov/nitt-ta/healthy-transitions-grant-information) 

Clinical High Risk for Psychosis Grant Program, Substance Abuse and Mental Health Services Administration, 

U.S. Department of Health and Human Services. 

• The purpose of this program is to identify youth and young adults, not more than 25 years old, at clinical highrisk for psychosis and provide evidence-based interventions to prevent the onset of psychosis or lessen the 

severity of psychotic disorder. (https://www.samhsa.gov/grants/grant-announcements/sm-18-012) 

The Role of Adverse Childhood Experiences in Substance Abuse and Related Behavioral Health Problems, Substance 

Abuse and Mental Health Services Administration, U.S. Department of Health and Human Services. 

• This overview of the Adverse Childhood Experiences (ACEs) Study includes findings on the role of ACEs in substance use and related behavioral health problems. (https://www.samhsa.gov/capt/tools-learning-resources/

aces-substance-abuse-behavioral-health) 

A Critical Look at Intergenerational Trauma and Substance Misuse: Implications for Prevention, Substance Abuse 

and Mental Health Services Administration, U.S. Department of Health and Human Services. 

• This webinar offers an introduction to intergenerational trauma and its link to substance misuse and explores 

ways for prevention practitioners to support and implement trauma-informed prevention approaches. (https://

www.samhsa.gov/capt/tools-learning-resources/critical-look-intergenerational-trauma-substance-misuse-implications) 

Trauma & Adverse Childhood Experiences: Implications for Preventing Substance Misuse, Substance Abuse and 

Mental Health Services Administration, U.S. Department of Health and Human Services. 

• This webinar outlines SAMHSA’s comprehensive approach to trauma-informed care, highlighting the mechanisms by which trauma and ACEs influence substance misuse and related behavioral health problems. (https://

www.samhsa.gov/capt/tools-learning-resources/trauma-adverse-childhood-experiences-implications-preventing-substance) 

Improving the Behavioral Health of Boys and Young Men of Color: Addressing Data Challenges, Substance Abuse and 

Mental Health Services Administration, U.S. Department of Health and Human Services. 

• This webinar discusses the prevalence of health disparities among boys and young men of color and how programs can strengthen their protective factors. (https://www.samhsa.gov/capt/tools-learning-resources/improving-behavioral-health-boys-color-data) 

Youth.gov, U.S. Department of Health and Human Services. 

• This program directory features evidence-based programs whose purpose is to prevent and/or reduce delinquency or other problem behaviors in young people. Youth.gov is composed of representatives from twenty 

federal agencies, including HHS. (https://youth.gov/) 

Increasing Effectiveness of Providers for Child Victims of Violence, Office for Victims of Crime, Office of Justice 

Programs, U.S. Department of Justice. 

• This training session was designed for mental health professionals. (https://www.ovcttac.gov/views/TrainingMaterials/dspIncEffectProv.cfm) 
Federal Commission on School Safety: Appendix 163

Violence Prevention 

School Violence: Prevention Tools and Resources, Centers for Disease Control and Prevention, U.S. Department of 

Health and Human Services. 

• This page provides various tools developed by CDC to help us understand and effectively prevent school violence, including the factors that increase or decrease the likelihood of school violence and what prevention 

strategies work. (https://www.cdc.gov/violenceprevention/youthviolence/schoolviolence/tools.html) 

Crime Prevention Through Environmental Design (CPTED) School Assessment (2017), Centers for Disease Control 

and Prevention, U.S. Department of Health and Human Services. 

• This school assessment can be used to rate the physical attributes of a school and provide specific indicators 

where protective measures are lacking. (https://stacks.cdc.gov/view/cdc/46282) 

A Comprehensive Technical Package for the Prevention of Youth Violence and Associated Risk Behaviors; 

Centers for Disease Control and Prevention, U.S. Department of Health and Human Services. 

• This technical package represents a select group of strategies based on the best available evidence to help 

communities and states sharpen their focus on prevention activities with the greatest potential to prevent youth 

violence and its consequences. These strategies include promoting family environments that support healthy 

development; providing quality education early in life; strengthening youth’s skills; connecting youth to caring 

adults and activities; creating protective community environments; and intervening to lessen harms and prevent 

future risk. The strategies represented in this package include those with a focus on preventing youth violence 

from happening in the first place as well as approaches to reduce the immediate and long-term harms of youth 

violence in order to prevent future violence. (https://www.cdc.gov/violenceprevention/pdf/yv-technicalpackage.

pdf )

Youth Violence: Using Environmental Design to Prevent School Violence (2016), Centers for Disease Control and 

Prevention, U.S. Department of Health and Human Services. 

• This website provides an overview of how CPTED can be incorporated at schools to help manage access to all 

school areas and minimize opportunities for out-of-sight activities. (https://www.cdc.gov/violenceprevention/

youthviolence/cpted.html) 

National Summits on Preventing Multiple Casualty Violence Reports, Federal Law Enforcement Training Centers 

(FLETC), U.S. Department of Homeland Security.

• These reports summarize the outcomes of summits hosted by FLETC that brought together experts from a 

variety of disciplines, including law enforcement, academic education, social sciences, private security, and 

emergency management to develop cross-cutting prevention strategies and a framework for a prevention toolkit 

adaptable to individual communities. (https://www.fletc.gov/summits-preventing-multiple-casualty-violence) 

Preventing Violent Extremism in Schools, Office of Partner Engagement, Federal Bureau of Investigation, 

U.S. Department of Justice. 

• This booklet was designed to educate school personnel about at-risk behaviors and activities that assist 

students with reducing social/psychological commitment to violence as a method of resolving a grievance. 

(https://info.publicintelligence.net/FBI-PreventingExtremismSchools.pdf) 

Violence Among Middle School and High School Students: Analysis and Implications for Prevention, National 

Institute of Justice, Office of Justice Programs, U.S. Department of Justice. 

• This “Research in Brief” summarizes conclusions drawn from in-depth interviews with students at risk of 

violence in schools. (https://www.ncjrs.gov/pdffiles/166363.pdf) 

Violence Prevention in Schools: Enhancement Through Law Enforcement Partnerships, Federal Bureau of 

Investigation, U.S. Department of Justice (March 2017).

• This report includes practical advice gathered from experienced school resource officers (SROs) on how law 

enforcement, schools, and school districts can work together to keep schools safe. The report includes best practices on choosing an SRO, necessary training and resources, improving school climate, and developing threat 

assessment teams. (https://www.fbi.gov/file-repository/violence-prevention-in-schools-march-2017.pdf/view) 
164 Federal Commission on School Safety: Appendix

Face Recognition Policy Development Template for Use in Criminal Intelligence and Investigative Activities, Bureau 

of Justice Assistance, Office of Justice Programs, U.S. Department of Justice. 

• The Facial Recognition Template was developed by state, local, and federal law enforcement, privacy, and criminal justice partners to provide law enforcement, fusion centers, and other public safety agencies with a framework for developing face recognition policies that comply with applicable laws, reduce privacy risks, implement 

minimum required training for authorized users and examiners, and establish entity accountability and oversight. (https://www.it.ojp.gov/GIST/1204/Face-Recognition-Policy-Development-Template-For-Use-In-Criminal-Intelligence-and-Investigative-Activities) 

Threat Assessments 

Enhancing School Safety Using a Threat Assessment Model: An Operational Guide for Preventing Targeted School 

Violence (2018), U.S. Secret Service, U.S. Department of Homeland Security. 

• This guide, produced by the U.S. Secret Service National Threat Assessment Center, provides actionable steps 

that schools can take to develop comprehensive targeted violence prevention plans. (https://www.secretservice.

gov/data/protection/ntac/USSS_NTAC_Enhancing_School_Safety_Guide_7.11.18.pdf) 

REMS Technical Assistance Center School Behavioral Threat Assessments: An Introduction, U.S. Department of 

Education. 

• The REMS Technical Assistance Center offers a one-day Train-the-Educator training designed to familiarize 

schools and school districts with school behavioral threat assessments in preventing and reducing targeted violence at K–12 schools. Topics covered include how a threat assessment team can be integrated into the broader 

framework of school safety, security, emergency management, and preparedness put forth in the Guide for 

Developing High-Quality School Emergency Operations Plans (School Guide) referenced above. (https://rems.

ed.gov/Docs/Threat_Assessment_Website_Marketing_Flyer_508C.pdf) 

The School Shooter: A Threat Assessment Perspective, Behavioral Analysis Unit, Federal Bureau of Investigation, 

U.S. Department of Justice. 

• In response to the 1999 attack at Columbine High School, the FBI’s Behavioral Analysis Unit (BAU) convened a 

symposium of educational, law enforcement, and mental health experts. This unprecedented effort resulted in 

the production of an operational manual to assist in the prevention of school shootings.  The manual identified 

best practices for K–12 schools to detect and mitigate targeted violence and remains a foundational guide for all 

community safety stakeholders. (https://www.fbi.gov/file-repository/stats-services-publications-school-shooterschool-shooter/view) 

Threat Assessment in Schools: A Guide to Managing Threatening Situations and to Creating Safe School Climates,

U.S. Secret Service and U.S. Department of Education. 

• This report sets forth a process for identifying, assessing, and managing students who may pose a threat of targeted violence in schools. (https://rems.ed.gov/docs/ThreatAssessmentinSchools.pdf) 

Campus Attacks: Targeted Violence Affecting Institutions of Higher Education, U.S. Secret Service, U. S. Department 

of Education, and Federal Bureau of Investigation (April 2010).

• This report includes findings from a review of 272 incidents of violence that affected institutions of higher education (IHEs) between 1900 and 2008. The report’s goal is to help threat assessment and campus safety professionals charged with identifying, assessing, and managing the risk of violence at IHEs. (https://rems.ed.gov/docs/

CampusAttacks_201004.pdf)

If You See Something, Say Something®, U.S. Department of Homeland Security. 

• “If You See Something, Say Something®” is a national campaign that raises public awareness of the indicators 

of terrorism and terrorism-related crime, as well as the importance of reporting suspicious activity to state and 

local law enforcement. This campaign has partnered with a number of schools to raise student and teacher 

awareness and encourage reporting of suspicious activity. (https://www.dhs.gov/see-something-say-something) 

Nationwide Suspicious Activity Reporting Initiative, Bureau of Justice Assistance, Office of Justice Programs, 

U.S. Department of Justice. 

• The Nationwide Suspicious Activity Reporting (SAR) Initiative (NSI) is a joint collaborative effort by the U.S. 

Department of Homeland Security, the Federal Bureau of Investigation, and state, local, tribal, and territorial 
Federal Commission on School Safety: Appendix 165

law enforcement partners. This initiative provides law enforcement with another tool to help prevent terrorism 

and other related criminal activity by establishing a national capacity for gathering, documenting, processing, 

analyzing, and sharing SAR information.  (https://nsi.ncirc.gov) 

Making Prevention a Reality: Identifying, Assessing, and Managing the Threat of Targeted Attacks, 

Behavioral Analysis Unit, Federal Bureau of Investigation, U.S. Department of Justice. 

• Recognizing the importance of threat assessment and threat management in the mitigation of school and active 

shooters, the BAU convened a panel in 2015 of domestic and international experts in targeted violence for the 

purpose of creating an operational guide.  In 2017, the BAU released this instructional handbook for schools, colleges, businesses, and houses of worship on initiating threat assessment teams, managing persons of concern, 

and implementing strategic threat management plans for potentially violent individuals.  (https://www.fbi.gov/

file-repository/making-prevention-a-reality.pdf/view) 

Early Warning, Timely Response: A Guide to Safe Schools, Office for Juvenile Justice and Delinquency, 

Office of Justice Programs, U.S. Department of Justice. 

• This guide presents a brief summary of the research on violence prevention and intervention and crisis response 

in schools. It tells school communities what to look for (the early warning signs that relate to violence and other 

troubling behaviors) and what to do (the action steps that school communities can take to prevent violence and 

other troubling behaviors, to intervene and get help for troubled children, and to respond to school violence 

when it occurs). (https://www.ncjrs.gov/pdffiles1/172854.pdf) 

Real-Time and Open Source Analysis (ROSA) Resource Guide, Bureau of Justice Assistance, Office of Justice Programs, 

U.S. Department of Justice. 

• The resource guide was developed to assist law enforcement agencies and fusion centers in understanding 

the lawful and appropriate use of open source information, focusing on social media. It is designed to help law 

enforcement agencies and analytic personnel understand the potential tools and resources available to support 

law enforcement operational and analytic activities. (https://www.it.ojp.gov/GIST/1200/Real-Time-and-OpenSource-Analysis--ROSA--Resource-Guide) 

STOP School Violence Threat Assessment and Technology Reporting Program, Bureau of Justice Assistance, 

Office of Justice Programs, U.S. Department of Justice.

• This program provides funding for the development and operation of school threat assessments and crisis intervention teams, and the development of technology for local or regional anonymous reporting systems. (https://

www.bja.gov/Programs/STOP-School-Violence-Act.html) 

Resource Libraries and Data Sources 

What Works Clearinghouse, Institute of Education Sciences, U.S. Department of Education.

• This clearinghouse reviews existing research on programs, products, practices, and policies in education. Administrators and teachers may find the clearinghouse especially helpful in choosing evidence-based programs, 

which may include programs such as character education. (https://ies.ed.gov/ncee/wwc/)

Averted School Violence Database, Office of Community Oriented Policing Services, U.S. Department of Justice.

• This Averted School Violence Near Miss reporting system, allows law enforcement officers, school personnel, and 

mental health professionals to share data and information on “close calls” in order to improve school safety and 

prevent tragedies. (www.asvnearmiss.org) 

School-Associated Violent Death Study, Centers for Disease Control and Prevention, U.S. Department of Health and 

Human Services.

• SAVD presents the most recent data available on school-associated violent deaths; common features of these 

events; and potential risk factors for perpetration and victimization. Data obtained from this study play an 

important role in monitoring and assessing national trends in school-associated violent deaths, and help to 

inform efforts to prevent fatal school violence. The system, which was developed in partnership with the Departments of Education and Justice, monitors school-associated violent deaths at the national level. Information is 

collected each year from media databases, police, and school officials. (https://www.cdc.gov/violenceprevention/youthviolence/schoolviolence/savd.html)
166 Federal Commission on School Safety: Appendix

CrimeSolutions.gov, National Institute of Justice, Office of Justice Programs, U.S. Department of Justice.

• CrimeSolutions.gov is a web-based clearinghouse of evaluated programs and practices, including programs 

related to school safety. In this video interview, Dr. Stephanie Gerstenblith discusses how to use CrimeSolutions.

gov to find evidence-based programs and practices to improve school safety. (www.crimesolutions.gov) 

National Registry of Evidence-based Programs and Practices (NREPP), Substance Abuse and Mental Health Services 

Administration, U.S. Department of Health and Human Services.

• This registry contains information about evidence-based mental health and substance use interventions, including school-based interventions. Administrators and teachers may find the registry especially helpful in choosing 

evidence-based prevention programs. (https://www.samhsa.gov/nrepp) 

Campus Resilience Program Resource Library, U.S. Department of Homeland Security.

• The Campus Resilience Program Resource Library is designed to provide members of the academic community 

with access to resources, strategies, guidelines, and templates to address a variety of different vulnerabilities 

and risks. This library organizes resources according to specific threats/hazards, and has a section dedicated to 

resources to support schools and other workplaces in preparing for and responding to violent incidents. (https://

www.dhs.gov/campus-resilience-program-resource-library) 

National Center for Campus Public Safety (NCCPS), Bureau of Justice Assistance, Office of Justice Programs, U.S. 

Department of Justice. 

• The NCCPS supports campus officials in creating safer and stronger campus communities by serving as a onestop clearinghouse for the many resources available from both the federal government and non-governmental 

sources.  The NCCPS has partnered with an array of public safety organizations, colleges and universities, and 

subject matter experts to address critical issues in campus safety. (https://www.nccpsafety.org/)

• The National Center Library of Resources (https://www.nccpsafety.org/resources/library)

• Active Threat Response Training Resources (http://nccpsafety.org/assets/files/library/Active_Threat_

Response_Trainings_Final.pdf)

• Emerging Issues Forums (https://www.nccpsafety.org/our-work/emerging-issues-forums/) 

K–12 School Shooting Database, Naval Postgraduate School’s Center for Homeland Defense and Security (CHDS). 

• The research project is a widely inclusive K–12 school shooting database that documents each and every 

instance a gun is brandished, is fired, or a bullet hits school property for any reason, regardless of the number of 

victims, time, day of the week, or reason (e.g., planned attack, accidental, domestic violence, gang-related). The 

database is available for download as a csv file from the CHDS website. (https://www.chds.us/ssdb/) 

Indicators of School Crime and Safety Annual Report, Bureau of Justice Statistics, Office of Justice Programs, U.S. 

Department of Justice and National Center for Education Statistics, U.S. Department of Education. 

• This report presents statistical data on crime and safety at school from the perspectives of students, teachers, 

and principals. The report contains 23 indicators of crime and safety at school on topics including victimization at school, teacher injury, bullying and cyber-bullying, school conditions, fights, weapons, availability and 

student use of drugs and alcohol, student perceptions of personal safety at school, and crime at postsecondary 

institutions. Data sources include the National Crime Victimization Survey (NCVS), the School Crime Supplement 

to the NCVS, the Youth Risk Behavior Survey, the School Survey on Crime and Safety, and the School and Staffing 

Survey. (https://www.bjs.gov/content/pub/pdf/iscs16.pdf) 

Summary of School Safety Statistics, National Institute of Justice, Office of Justice Programs, U.S. Department of 

Justice. 

• This document provides research and data to discuss common myths around school safety. (https://www.ncjrs.

gov/pdffiles1/nij/250610.pdf) 

School Safety: By the Numbers, National Institute of Justice, Office of Justice Programs, U.S. Department of Justice. 

• This document summarizes the findings of the NIJ report Summary of School Safety Statistics. (https://www.

ncjrs.gov/pdffiles1/nij/251173.pdf) 

High School Youths, Weapons, and Violence: A National Survey, National Institute of Justice, Office of Justice 

Programs, U.S. Department of Justice. 

• This “Research in Brief” discusses the findings of an NIJ-funded survey on the firearms experience of the average 

youth. (https://www.ncjrs.gov/pdffiles/172857.pdf) 
Federal Commission on School Safety: Appendix 167

A Study of the Pre-Attack Behaviors of Active Shooters in the U.S. Between 2000 and 2013, Federal Bureau of 

Investigation, U.S. Department of Justice.

• The report examines the pre-attack behavior of shooters in 160 active shooter incidents in an effort to pinpoint specific behaviors that might be useful in identifying, assessing, and managing those who might be on 

the pathway to such violence. (https://www.fbi.gov/file-repository/pre-attack-behaviors-of-active-shootersin-us-2000-2013.pdf/view) 

Protect and Mitigate

Personnel and Training 

Be Safe and Sound in School (B3S), Bureau of Justice Assistance, Office of Justice Programs, 

U.S. Department of Justice. 

• In collaboration with the National Crime Prevention Council, B3S is a program that seeks to raise awareness 

of school safety and security issues and provide the tools and resources needed to effectively address them. 

(https://www.ncpc.org/programs/be-safe-and-sound-in-school/) 

Serving Safely, Bureau of Justice Assistance, Office of Justice Programs, U.S. Department of Justice.

• This program, launched in May 2018, is a national initiative designed to improve interactions between police and 

persons affected by mental illnesses and developmental disabilities. The initiative includes leaders in policing, 

mental illness, intellectual/developmental disability, crisis intervention, peer advocacy, emergency medicine, 

technology development, and prosecution, who together serve as a network of training and technical assistance 

providers. (https://www.vera.org/projects/serving-safely) 

School Transportation Security Programs, Transportation Security Administration (TSA), U.S. Department of 

Homeland Security.

• TSA offers a number of services to school districts and transportation providers on school bus security including 

guidelines, assessments, and exercise support. (https://www.tsa.gov/for-industry/surface-transportation)

T3—Tact, Tactics, and TrustTM Training and Technical Assistance Program, Bureau of Justice Assistance, 

Office of Justice Programs, U.S. Department of Justice. 

• This program provides law enforcement officers with evidence-based knowledge, tools, and skills to better 

defuse and resolve tense situations. This program assists in protecting law enforcement officers, enhancing 

public safety, and improving outcomes within the communities they serve. Since July 2017, more than 1500 law 

enforcement officers have been trained. (www.polis-solutions.net) 

Law Enforcement and Community: Crisis Intervention Training Model Program, Bureau of Justice Assistance, 

Office of Justice Programs, U.S. Department of Justice. 

• The Crisis Intervention Training Model Program provides law enforcement and their communities with targeted 

training and technical assistance to implement BJA’s Crisis Intervention Team (CIT) model. (https://www.prainc.

com/lec-cit-2018/) 

Collaborative Reform Initiative for Technical Assistance (CRITA), Office of Community Oriented Policing Services, 

U.S. Department of Justice. 

• This initiative delivers targeted technical assistance directly to local law enforcement based on their identified 

needs and requests, including those around school safety and security issues. (https://cops.usdoj.gov/collaborativereform) 

COPS Hiring Program, Office of Community Oriented Policing Services, U.S. Department of Justice. 

• This program makes competitive awards open to all state, local, and tribal law enforcement agencies to hire/

rehire officers to address specific focus area using community policing approaches, including funding for school 

resource officers. (https://cops.usdoj.gov/chp) 

School Resource Officer Training, Office of Community Oriented Policing Services, U.S. Department of Justice. 

• This program provides funding for the Basic School Resource Officer Course, developed by the National Association of School Resource Officers. This is a 40-hour course designed for law enforcement officers and school safety 

professionals working in an educational environment. The course provides tools for officers on how to effectively 

carry out law enforcement and safety duties while building positive relationships with both students and staff in 

a school context. (https://cops.usdoj.gov/pdf/2017AwardDocs/chp/SRO_Mandatory_Training_Fact_Sheet.pdf) 
168 Federal Commission on School Safety: Appendix

DHS Campus Resilience Program Tabletop Exercise Series and K–12 Active Shooter Exercise Starter Kits, 

Office of Academic Engagement, U.S. Department of Homeland Security. (https://www.dhs.gov/academicresilience)

• TTX Series: Includes a collection of tailored events, each with unique objectives and outcomes, designed for the 

academic community. Each event in the series challenges participants with multifaceted threat based scenarios 

that test and strengthen their institution’s preparedness, response, and recovery capabilities.

• K–12 Active Shooter Exercise Starter Kits: A set of tools and resources for the academic community to self-conduct a tabletop exercise. The kits reinforce a school’s specific emergency plans, protocols, and procedures, while 

also testing and strengthening its preparedness, response, and recovery capabilities when responding to an 

active shooter incident. 

Enhanced Dynamic Geo-Social Environment (EDGE), Science & Technology Directorate, U.S. Department of Homeland 

Security.

• EDGE is a virtual training platform that allows teachers, school staff, law enforcement officers, and others tasked 

with school security to create and practice response plans for a wide range of critical incidents. EDGE allows first 

responders and educators to role-play complex scenarios in a virtual environment, improving and reinforcing 

coordination, communication, and critical decision-making skills. (https://www.cesiedgetraining.com/) 

Justice Assistance Grant, Bureau of Justice Assistance, Office of Justice Programs, U.S. Department of Justice. 

• This is a formula-based grant program that provides states, tribes, and local governments with critical funding to 

support a range of program areas. The latter include law enforcement, prosecution and courts, crime prevention 

and education, corrections and community corrections, drug treatment and enforcement, planning, evaluation 

and technology improvement, crime victim and witness initiatives, mental health programs, and related law 

enforcement and corrections programs. Under this grant program, emergency and crisis training for local law 

enforcement can be an allowable cost. Each year, 56 states and territories and more than 900 local and tribal 

jurisdictions receive grants. (https://www.bja.gov/jag/) 

National Training and Technical Assistance Center (NTTAC), Bureau of Justice Assistance, Office of Justice Programs, 

U.S. Department of Justice. 

• NTTAC offers online and no-cost training and technical assistance on a wide variety of criminal justice topics, 

including emergency and crisis training for local law enforcement. (www.bjatraining.org) 

Identifying an Armed Person Training, Bureau of Justice Assistance, Office of Justice Programs, U.S. Department 

of Justice. 

• This training, which is provided as part of the Project Safe Neighborhoods training and technical assistance 

support, covers guidance for handling felonious possession and use of firearm cases. It includes techniques for 

identifying/recognizing vehicles with hidden compartments and advanced techniques to identify/recognize 

armed suspects and their characteristics. (http://www.theiacp.org/psnInitiative) 

STOP School Violence Prevention and Mental Health Training Program, Bureau of Justice Assistance, 

Office of Justice Programs, U.S. Department of Justice. 

• This program provides funding directly to state, local, and tribal jurisdictions for training school personnel and 

educating students to prevent student violence as well as for training school officials in responding to related 

mental health crises. Such training, developed and delivered at the local level, seeks to meet the jurisdictions’ 

localized needs regarding the prevention of school violence and responses to related mental health crises. 

(https://www.bja.gov/Programs/STOP-School-Violence-Act.html) 

VALOR Officer Safety and Wellness Training and Technical Assistance Program, Bureau of Justice Assistance, 

Office of Justice Programs, U.S. Department of Justice. 

• The VALOR program delivers current, dynamic classroom and web-based trainings focused on recognizing 

indicators of dangerous situations. It involves applying a cognitive approach towards reinforcing effective 

techniques for managing difficult encounters, implementing casualty care and rescue tactics, and improving 

wellness and resilience. Since 2010, the VALOR Program has trained more than 41,400 law enforcement officers. 

(www.valorforblue.org) 
Federal Commission on School Safety: Appendix 169

Building Security and Emergency Planning 

K–12 School Security Guide (2nd Edition) and School Security Survey, U.S. Department of Homeland Security. 

• The documents provide preventive and protective measures to address the threat of gun violence in schools. 

The Guide is delivered in two parts: the first portion is a PDF with general security best practices and considerations in narrative format; while the second portion is a Microsoft Excel-based security survey. Together, these 

documents outline action-oriented security practices and options for consideration based on the results of the 

individual school’s responses to the survey. While the primary audience for the Guide is the K–12 community, 

institutions of higher education or pre-K schools may also benefit from the information presented. (https://www.

dhs.gov/publication/k-12-school-security-guide) 

DHS Protective Security Advisors, U.S. Department of Homeland Security. 

• Protective Security Advisors (PSAs) are security subject matter experts who engage with state, local, tribal, and 

territorial government mission partners and members of the private sector stakeholder community to protect 

regional, state, and local infrastructure. Since 2013, PSAs have engaged with more than 1,100 schools, providing 

best practices, conducting assessments, and facilitating exercises, among other things. (https://www.dhs.gov/

protective-security-advisors). 

REMS Fact Sheets, Office of Safe and Healthy Students, U.S. Department of Education (November 2017).

• The Mitigation for Schools and School Districts Fact Sheet describes “mitigation” and the role it plays in school 

preparedness. This fact sheet contains examples of mitigation activities, steps for integrating mitigation into 

emergency planning, and key resources for schools and school districts. (https://rems.ed.gov/Docs/Mitigation_

Fact_Sheet_508C.pdf)

• The Protection for Schools and School Districts Fact Sheet fact sheet describes “protection” and the role it plays 

in school preparedness. This fact sheet contains examples of protection activities, steps for integrating protection into emergency planning, and key resources for schools and school districts. (https://rems.ed.gov/Docs/

Protection_Fact_Sheet_508C.pdf) 

Grants to States for School Emergency Management, U.S. Department of Education. 

• These grants help schools address violence and foster safer school environments by providing grants to states to 

increase their capacity to assist school districts in the development, implementation, and review of high-quality 

and comprehensive school emergency operations plans (EOPs). (https://www2.ed.gov/programs/schlemergmgt-sea/index.html) 

Guide for Developing High-Quality Emergency Operations Plans for Institutions of Higher Education, 

U.S. Department of Education, U.S. Department of Health and Human Services, U.S. Department of Homeland Security, 

U.S. Department of Justice, Federal Bureau of Investigation, Federal Emergency Management Agency (June 2013).

• This guide includes information on the principles of emergency management planning for institutions of higher 

education (IHEs); a process for developing, implementing, and refining a higher education Emergency Operations Plan (EOP); and suggested content of higher education EOPs. Planning teams at IHEs responsible for 

developing and revising a higher education EOP may find this document particularly helpful. (https://www.dhs.

gov/sites/default/files/publications/REMS IHE Guide_508.pdf) 

Guide for Developing High-Quality School Emergency Operations Plans, U.S. Department of Education, 

U.S. Department of Homeland Security, U.S. Department of Health and Human Services, and U.S. Department 

of Justice, Federal Emergency Management Agency, and Federal Bureau of Investigation (2013).

• This guide includes information on the principles of school emergency management planning; a process for 

developing, implementing, and refining a school Emergency Operations Plan (EOP) with community partners; 

and suggested content of school EOPs. Planning teams responsible for developing and revising school EOPs may 

find this document particularly helpful. (https://rems.ed.gov/docs/REMS_K-12_Guide_508.pdf) 

National Strategy on Youth Preparedness and Ready.Gov/Youth Preparedness, U.S. Department of Homeland 

Security, Federal Emergency Management Agency, U.S. Department of Education, and the American Red Cross.

• The National Strategy for Youth Preparedness Education: Empowering, Educating, and Building Resilience presents 

nine steps partners can take to help build a nation of prepared youth. The steps focus on building partnerships 

to enhance youth preparedness learning programs; connecting young people with their families, communities, 

first responders, and other youth; and increasing preparedness at school. (ready.gov/youth-preparedness) 
170 Federal Commission on School Safety: Appendix

Primer to Design Safe School Projects in Case of Terrorist Attacks and School Shootings, Federal Emergency Management Agency, U.S. Department of Homeland Security (January 2012).

• This primer contains detailed information on assessing threats and vulnerabilities, and the design considerations needed to protect buildings and the people occupying them. The purpose of this primer is to provide the 

design community and school administrators with the basic principles and techniques to make a school safe 

from school shootings and ensure it meets the needs of students, teachers, and administrators. (https://www.

dhs.gov/xlibrary/assets/st/bips07_428_schools.pdf) 

Making Schools Safer Quick Reference Guide (2018), U.S. Secret Service, U.S. Department of Homeland Security. 

• This guide highlights the research the U.S. Secret Service National Threat Assessment Center conducted in partnership with the U.S. Department of Education Office of Safe and Drug-Free Schools on targeted school violence. 

(https://www.secretservice.gov/data/protection/ntac/Making_Schools_Safer_Quick_Reference_Guide_2018_

Update.pdf ) 

Comprehensive School Safety Initiative, National Institute of Justice, Office of Justice Programs, U.S. Department of 

Justice. 

• This is a list of awards made under the Comprehensive School Safety Initiative for various fiscal years.

• 2014: https://www.ncjrs.gov/pdffiles1/nij/248381.pdf

• 2015: https://www.ncjrs.gov/pdffiles1/nij/249228.pdf

• 2016: https://www.nij.gov/Documents/NIJ-CSSI-FY-2016-Awards.pdf 

• 2017: https://www.ncjrs.gov/pdffiles1/nij/251559.pdf

• The 2014 Comprehensive School Safety Initiative Report discusses the history, funding, and activities of the 

Comprehensive School Safety Initiative. (https://www.ncjrs.gov/pdffiles1/nij/247757.pdf) 

Preventing, Preparing for Critical Incidents in Schools, National Institute of Justice, Office of Justice Programs, U.S. 

Department of Justice. 

• This article discusses NIJ-funded research on school safety and how schools can better prepare for incidents of 

violence. (https://www.ncjrs.gov/pdffiles1/nij/225765.pdf) 

Keeping an Eye on School Security: The Iris Recognition Project in New Jersey Schools, National Institute of Justice, 

Office of Justice Programs, U.S. Department of Justice. 

• This NIJ Journal article discusses the Iris Recognition Project, a school safety initiative in New Jersey. (https://

www.nij.gov/journals/254/pages/iris_recognition.aspx) 

Appropriate and Effective Use of Security Technologies in U.S. Schools, National Institute of Justice, Office of Justice 

Programs, U.S. Department of Justice. 

• This document provides basic guidelines to law enforcement agencies and school administrators regarding 

security technology and school safety. (https://www.ncjrs.gov/school/178265.pdf) 

School Safety, Model Programs Guide, Office for Juvenile Justice and Delinquency, Office of Justice Programs, U.S. 

Department of Justice. 

• This is a topic page for school safety programs. (https://www.ojjdp.gov/mpg/Topic/Details/120) 

Safe and Secure, Guides to Creating Safer Schools, Office for Juvenile Justice and Delinquency, Office of Justice 

Programs, U.S. Department of Justice. 

• To assist schools in their safety efforts, the Northwest Regional Educational Laboratory (NWREL) developed 

a series of eight guidebooks intended to build a foundation of information that will assist schools and school 

districts in developing safe learning environments. 

• Guide 1: Creating Schoolwide Prevention and Intervention Strategies is intended to put the issue of 

schoolwide violence prevention in context for educators and outline an approach for choosing and creating 

effective prevention programs. (https://www.ncjrs.gov/pdffiles1/ojjdp/book1.pdf)

• Guide 2: School Policies and Legal Issues Supporting Safe Schools is a practical guide to the development 

and implementation of school policies that support safe schools. (https://www.ncjrs.gov/pdffiles1/ojjdp/

book2.pdf)
Federal Commission on School Safety: Appendix 171

• Guide 3: Implementing Ongoing Staff Development To Enhance Safe Schools discusses the role of staff 

development within the context of school safety. (https://www.ncjrs.gov/pdffiles1/ojjdp/book3.pdf)

• Guide 4: Ensuring Quality School Facilities and Security Technologies is intended to help educators and 

other members of the community understand the relationship between school safety and school facilities, 

including technology. (https://www.ncjrs.gov/pdffiles1/ojjdp/book4.pdf)

• Guide 5: Fostering School-Law Enforcement Partnerships is a practical guide to the development and 

implementation of partnerships between schools and law enforcement agencies. (https://www.ncjrs.gov/

pdffiles1/ojjdp/book5.pdf)

• Guide 6: Instituting School-Based Links With Mental Health and Social Service Agencies discusses how 

schools can improve their capacity to serve all students by linking with mental health and social service 

agencies. (https://www.ncjrs.gov/pdffiles1/ojjdp/book6.pdf)

• Guide 7: Fostering School, Family, and Community Involvement provides an overview of the nature and 

scope of collaboration, explores barriers to effectively working together, and discusses the processes of 

establishing and sustaining the work. (https://www.ncjrs.gov/pdffiles1/ojjdp/book7.pdf)

• Guide 8: Acquiring and Utilizing Resources To Enhance and Sustain a Safe Learning Environment provides 

practical information on a spectrum of resources that concerned individuals and organizations can use in the 

quest to create safe schools. (https://www.ncjrs.gov/pdffiles1/ojjdp/book8.pdf) 

Additional OJJDP Resources, Office for Juvenile Justice and Delinquency, Office of Justice Programs, U.S. Department 

of Justice.

• Police Foundation resources on school safety (https://www.policefoundation.org/school-safety-and-violence-prevention-resources/)

• International Association of Chiefs of Police Prevention and School Safety Resources (http://www.theiacp.org/

Prevention-And-Response-To-School-Violence)

• Combating Fear and Restoring Safety in Schools (https://www.ncjrs.gov/pdffiles/167888.pdf)

• Creating Safe and Drug-Free Schools: An Action Guide (https://www.ncjrs.gov/pdffiles/safescho.pdf)

• Creating Schoolwide Prevention and Intervention Strategies (Revised) (http://safeschools.info/docman/doc_

download/280-creating-schoolwide-prevention-and-intervention-strategies)

• Fostering School, Family, and Community Involvement (Revised) (http://smhp.psych.ucla.edu/publications/44%20guide%207%20fostering%20school%20family%20and%20community%20involvement.pdf)

• Promising Practices for Safe and Effective Schools Videoconference (http://www.juvenilenet.org/jjtap/

archives/safeneffctv/index.html)

• School Resource Officer Training Program (https://www.ncjrs.gov/pdffiles1/ojjdp/fs200105.pdf)

• School Safety & Youth Violence: A Legal Primer (https://www.ncjrs.gov/pdffiles1/ojjdp/grants/198396.pdf)

• School Safety by Management and Design Videoconference (https://www.juvenilenet.org/jjtap/schoolsafety/

index.html)

• School Safety: Annual Report, 2000 (https://www.ncjrs.gov/pdffiles1/ojjdp/193163.pdf)

• Stand Up and Start a School Crime Watch! (https://www.ncjrs.gov/pdffiles/94601.pdf)

• School Safety Special Feature (https://www.ncjrs.gov/schoolsafety/) 

Crisis Communications Quick Reference Guide, Federal Bureau of Investigation, U.S. Department of Justice.

• This brochure is tailored to chiefs, sheriffs, command staff, and public information officers who handle crisis 

communications in response to an active shooter, mass casualty, or other law enforcement incidents. It provides 

checklists for the pre-event, the onset of the incident, and updating the media (pre-press conference and second 

and subsequent press conferences). Also included are 10 tips to improve communications (https://www.fbi.gov/

file-repository/as-study-quick-reference-guide-updated1.pdf/view) 
172 Federal Commission on School Safety: Appendix

Privacy Considerations 

Privacy Technical Assistance Center (PTAC), U.S. Department of Education.

• PTAC is a “one-stop” resource for education stakeholders to learn about data privacy, confidentiality, and 

security practices related to student-level data systems and other uses of student data. (https://studentprivacy.

ed.gov) 

Family Educational Rights and Privacy Act: A Guide for First Responders and Law Enforcement, 

Office of Partner Engagement, Federal Bureau of Investigation, U.S. Department of Justice. 

• This guide defines the Family Educational Rights and Privacy Act (FERPA), delineates the rights afforded eligible 

parents and students, and discusses the types of information schools may provide to law enforcement agencies. 

It also discusses some relevant exceptions to FERPA’s general consent rule that permit the nonconsensual disclosure of personally identifiable information from education records to law enforcement agencies. (https://www.

fbi.gov/file-repository/ferpa-guide.pdf/vie) 

Information Sharing in Criminal Justice – Mental Health Collaborations: Working with HIPAA and Other Privacy 

Laws, Bureau of Justice Assistance, Office of Justice Programs, U.S. Department of Justice. 

• Understanding the legal framework of information sharing is the crucial first step for jurisdictions seeking to 

design and implement effective criminal justice-mental health collaborations. This guide introduces how federal 

and state laws are likely to influence criminal justice and mental health practitioners’ ability to share information. (https://www.bja.gov/Publications/CSG_CJMH_Info_Sharing.pdf) 

Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule: A Guide for Law Enforcement, 

Office of Partner Engagement, Federal Bureau of Investigation, U.S. Department of Justice. 

• This guide provides a summary of relevant HIPAA provisions. It defines the HIPAA privacy rule, identifies who is 

and it not required to comply with the rule, and describes the circumstances in which a HIPAA-covered entity 

may disclose protected health information to law enforcement agencies. (https://www.fbi.gov/file-repository/

hipaa-guide.pdf/view) 

HIPAA for Professionals, U.S. Department of Health and Human Services.

• The following is a series of questions with corresponding information on the HHS website. (https://www.hhs.

gov/hipaa/for-professionals/index.html)

• Does the HIPAA Privacy Rule apply to an elementary or secondary school?

• Does FERPA or HIPAA apply to elementary or secondary school student health records maintained by a health 

care provider that is not employed by a school?

• Are there circumstances in which the HIPAA Privacy Rule might apply to an elementary or secondary school?

• Where the HIPAA Privacy Rule applies, does it allow a health care provider to disclose protected health information (PHI) about a troubled teen to the parents of the teen?

• Does the HIPAA Privacy Rule allow a health care provider to disclose protected health information (PHI) 

about a student to a school nurse or physician?

• Does FERPA or HIPAA apply to records on students at health clinics run by postsecondary institutions?

• Does FERPA or HIPAA apply to records on students who are patients at a university hospital?

• Where the HIPAA Privacy Rule applies, does it permit a health care provider to disclose protected health 

information (PHI) about a patient to law enforcement, family members, or others if the provider believes the 

patient presents a serious danger to self or others?

• Are the health records of an individual who is both a student and an employee of a university at which the 

person receives health care subject to the privacy provisions of FERPA or those of HIPAA?
Federal Commission on School Safety: Appendix 173

Respond and Recover

Active Shooter Preparedness and Response 

Active Shooter Preparedness, U.S. Department of Homeland Security. 

• DHS provides a variety of active shooter preparedness resources for private citizens, human resources, security 

professionals, active shooter workshop participants, and first responders. (https://www.dhs.gov/active-shooter-preparedness) 

Active Shooter: How to Respond, U.S. Department of Homeland Security (October 2008).

• This guide informs employers how to respond to active shooter emergencies at their workplace, including how 

to respond when an active shooter is in the vicinity, how to respond when law enforcement arrives, how to train 

staff for an active shooter situation, and how to recognize potential workplace violence. (https://www.dhs.gov/

xlibrary/assets/active_shooter_booklet.pdf)

Planning and Response to an Active Shooter: An Interagency Security Committee Policy and Best Practices Guide,

Interagency Security Committee* (chaired by the U.S. Department of Homeland Security) (November 2015).

• This guide provides a consolidated overview of the federal government’s approach to active shooter preparedness for non-military federal facilities. Many of the policies and procedures discussed in this guide can be 

applied to schools. (https://www.dhs.gov/sites/default/files/publications/isc-planning-response-active-shooterguide-non-fouo-nov-2015-508.pdf) 

Preparing for Active Shooter Situations (PASS) Program, Office of Community Oriented Policing Services, 

U.S. Department of Justice. 

• This program provides funding for first responders to attend the Active Attack Integrated Response (AAIR) 

Course, a two-day in-person training designed to improve coordinated response during active attack incidents. 

(https://cops.usdoj.gov/training) 

Active Shooter Event Quick Reference Guide, Office of Partner Engagement, Federal Bureau of Investigation, U.S. 

Department of Justice.

• This pocket guide discusses the three options—Run, Hide, Fight—that can make a difference during an active 

shooter incident. (https://www.fbi.gov/file-repository/active-shooter-event-quick-reference-guide_2015.pdf/

view) 

A Study of the Pre-Attack Behaviors of Active Shooters in the U.S., Behavioral Analysis Unit, Federal Bureau of 

Investigation, U.S. Department of Justice. 

• Understanding the prevention of active shootings often relies upon the recognition of worrisome pre-attack 

behaviors, the BAU released this study in 2018.  Using law enforcement records (vs. open source) as the primary 

source of information, this study thoroughly examined 63 active shooters, including nine who attacked K–12 

schools.  Key findings included insights into the active shooters’ mental health, concerning behaviors displayed 

before their attacks, and specific stressors they experienced.  This study provides the most current and detailed 

exploration of observable pre-attack behaviors to date. (https://www.fbi.gov/file-repository/pre-attack-behaviors-of-active-shooters-in-us-2000-2013.pdf/view) 

Preparing for Mass Casualty Incidents: A Guide for Schools, Higher Education, and Houses of Worship, 

U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA).

• Provided by FEMA’s Emergency Management Institute, this online course provides leading practices and 

resources to assist elementary and secondary schools, institutions of higher education, and houses of worship 

in developing emergency plans for preparing for, responding to, and recovering from mass casualty incidents. 

(https://training.fema.gov/is/courseoverview.aspx?code=IS-360) 

* The Interagency Security Committee’s primary members include: Assistant to the President for National Security Affairs, U.S. Central Intelligence Agency, 

Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Education, U.S. Department of Energy, U.S. 

Department of Health and Human Services, U.S. Department of Homeland Security, U.S. Department of Housing and Urban Development, U.S. Department of the Interior, U.S. Department of Justice, U.S. Department of Labor, U.S. Department of State, U.S. Department of Transportation, U.S. Department 

of the Treasury, U.S. Department of Veterans Affairs, U.S. Environmental Protection Agency, U.S. General Services Administration, U.S. Office of Management and Budget, and the U.S. Marshals Service.
174 Federal Commission on School Safety: Appendix

Disaster Technical Assistance Center Supplemental Research Bulletin Mass Violence and Behavioral Health, 

Substance Abuse and Mental Health Services Administration, U.S. Department of Health and Human Services 

(September 2017).

• This bulletin focuses on how mass violence affects the behavioral health of adult and young survivors or 

witnesses of a mass violence incident. Public health, behavioral health, and emergency management professionals can use this bulletin to improve their disaster behavioral health preparedness plans. (https://www.

samhsa.gov/sites/default/files/dtac/srb-mass-violence-behavioral-health.pdf\) 

Active Shooter Resources, Federal Bureau of Investigation, U.S. Department of Justice. 

• The Investigative Assistance Act for Violent Crimes Act of 2012 delegated responsibility to the FBI to provide 

federal assistance during active shooter incidents and mass killings in public places. The FBI has teamed with 

the Texas State University Advanced Law Enforcement Rapid Response Training program, which trains law 

enforcement and first responders on national standards for response protocol. The FBI’s Office for Victim Assistance also provides a variety of support services for victims, family members, first responders, and investigative 

teams. (https://www.fbi.gov/about/partnerships/office-of-partner-engagement/active-shooter-resources) 

Recovery 

REMS fact sheets, Office of Safe and Healthy Students, U.S. Department of Education and Emergency Management for 

Schools Technical Assistance Center (2017). 

• The Recovery for Schools and School Districts Fact Sheet describes “recovery” and the role it plays in school 

preparedness. This fact sheet contains examples of recovery activities, steps for integrating recovery into emergency planning, and key resources for schools and school districts. (https://rems.ed.gov/Docs/Recovery_Fact_

Sheet_508C.pdf)

• The Response for Schools and School Districts Fact Sheet describes “response” and the role it plays in school 

preparedness. This fact sheet contains examples of response activities, steps for integrating response into emergency planning, and key resources for schools and school districts. (https://rems.ed.gov/Docs/Response_Fact_

Sheet_508C.pdf) 

Project School Emergency Response to Violence (SERV), U.S. Department of Education.

• This program funds short-term and long-term education-related services for school districts and institutions of 

higher education (IHEs) to help them recover from a violent or traumatic event in which the learning environment has been disrupted. (https://www2.ed.gov/programs/dvppserv/index.html) 

Mass Violence Toolkit, Office for Victims of Crime, Office of Justice Programs, U.S. Department of Justice. 

• The Helping Victims of Mass Violence and Terrorism Toolkit leverages expertise from partner agencies, subject 

matter experts, and lessons learned from past incidents to provide communities with a holistic approach to 

victim assistance in cases of criminal mass violence and domestic terrorism from planning through long-term 

recovery. The Toolkit includes checklists, templates and other resources to help communities through these 

processes. (https://ovc.gov/pubs/mvt-toolkit/index.html) 

Vicarious Trauma Toolkit, Office for Victims of Crime, Office of Justice Programs, U.S. Department of Justice. 

• The Vicarious Trauma Toolkit is an online collection of resources and tools to support  victim-serving organizations—victim services, law enforcement, first responders—to mitigate the impact and consequences of vicarious 

trauma. The Toolkit provides an Organizational Assessment that enables organizations to assess their current 

response and then set a path forward using nearly 500 items—policies, practices and program descriptions, 

research literature, links to websites and podcasts, and videos and testimonials from each discipline. (https://

vtt.ovc.ojp.gov/) 

Schools/Education Community, Office for Victims of Crime, Office of Justice Programs, U.S. Department of Justice 

• This page contains DOJ and DOJ-sponsored publications relevant to students and others who are victims of 

crime.  (https://ovc.ncjrs.gov/Publications.aspx?TopicID=91) 

Through Our Eyes: Children, Violence, and Trauma, Office for Victims of Crime, Office of Justice Programs, 

U.S. Department of Justice. 

• The sixth video in this series focuses on Interventions in Schools. (https://ovc.gov/pubs/ThroughOurEyes/) 
Federal Commission on School Safety: Appendix 175

Supporting Children Living with Grief and Trauma: A Multidisciplinary Approach, Office for Victims of Crime, 

Office of Justice Programs, U.S. Department of Justice. 

• This training session was designed with victim service providers, mental health professionals, and law enforcement in mind. (https://www.ovcttac.gov/views/TrainingMaterials/dspSupportingChildren.cfm) 

Expert Q&A: Addressing the Impact of Trauma When a Mass Violence Incident Occurs, Office for Victims of Crime, 

Office of Justice Programs, U.S. Department of Justice. 

• Incidents of mass violence and terrorism present unique challenges to the communities in which they occur, 

requiring a coordinated, cross-sector approach among federal, state, local, and tribal governments; private entities; and nonprofit organizations to drive an effective response. This training session addresses how to create 

and maintain partnerships, address resource gaps, develop victim assistance protocols, and use the protocols 

after an incident of mass violence or terrorism. (https://www.ovcttac.gov/expert-qa/?tab=2) 

VAT Online: Terrorism and Mass Violence, Office for Victims of Crime, Office of Justice Programs, 

U.S. Department of Justice. 

• Terrorism and mass violence are of concern to the public at large because events seem to be random, and perpetrators generally have a definitive plan and their own logic behind their attacks. This training module defines 

terrorism and mass violence, describes the effects on victims and survivors, identifies potential issues arising 

from these types of events, identifies responders to mass violence incidents and where you should develop a 

partnership prior to an event, identifies potential needs of victims and communities after a terrorism and mass 

violence event, and identifies resources for victims and communities. (https://www.ovcttac.gov/views/TrainingMaterials/dspOnline_VATOnline.cfm?tab=1#crimes) 

Mass Violence and Terrorism Web Training Series, Office for Victims of Crime, Office of Justice Programs, 

U.S. Department of Justice. 

• This web training series highlights the importance of communities, states, and regions planning a response to 

incidents of mass violence and terrorism using the OVC resource, Helping Victims of Mass Violence & Terrorism: 

Planning, Response, Recovery, and Resources Toolkit. The first webinar in this series provides a detailed overview of how to use the Toolkit. Subsequent web trainings delve deeper into sections of the Toolkit. (https://www.

ovcttac.gov/views/TrainingMaterials/dspWebinars.cfm#massviolence) 

American Academy of Pediatrics (AAP): Medical Home for Children and Adolescents Exposed to Violence,

Office for Victims of Crime, Office of Justice Programs, U.S. Department of Justice. 

• Developed through a grant from OVC, this section of the AAP web site provides pediatricians and all medical 

home teams with the resources they need to modify practice operations to more effectively identify, treat, and 

refer children and youth who have been exposed to or victimized by violence. (https://www.aap.org/en-us/advocacy-and-policy/aap-health-initiatives/resilience/Pages/Resilience-Project.aspx) 

ChildVictimWeb, Office for Victims of Crime, Office of Justice Programs, U.S. Department of Justice. 

• Funded by OVC, ChildVictimWeb is a free online training resource designed for professionals from all disciplines 

who work with children who have experienced or witnessed serious violence. This course describes the prevalence and characteristics of different forms of victimization often experienced in childhood, their psychological, 

behavioral, social, and health consequences, and implications for practice. Assessment strategies, an evidence-based approach to treatment planning, trauma-informed case management skills, and information about 

evidence-supported treatments are presented. (http://cv.musc.edu/) 

Enhancing Police Responses to Children Exposed to Violence: A Toolkit for Law Enforcement, Office for Juvenile 

Justice and Delinquency, Office of Justice Programs, U.S. Department of Justice. 

• This toolkit may be helpful to law enforcement officers addressing school shootings. (http://www.theiacp.org/

children-exposed-to-violence) 

Gun Violence and Youth, Model Programs Guide, Office for Juvenile Justice and Delinquency, Office of Justice 

Programs, U.S. Department of Justice. 

• This research literature review on gun violence and youth focuses on intentional gun violence involving youths 

ages 10 to 24, including school violence/school shootings. (https://www.ojjdp.gov/mpg/litreviews/gun-violenceand-youth.pdf) 
176 Federal Commission on School Safety: Appendix

Child and Youth Victimization Known to Police, School, and Medical Authorities, Office for Juvenile Justice and 

Delinquency, Office of Justice Programs, U.S. Department of Justice. 

• This paper presents the survey results from the National Survey of Children’s Exposure to Violence (NatSCEV) 

regarding authorities’ knowledge of victimization incidents involving children and youth, particularly police, 

school, and medical authorities. (https://www.ojjdp.gov/pubs/235394.pdf) 

Supporting Young People in the Wake of Violence and Trauma, Office for Juvenile Justice and Delinquency, 

Office of Justice Programs, U.S. Department of Justice. 

• This guide provides mentors with recommendations and resources to help them support youth who have faced 

experiences with violence or trauma. (http://www.nationalmentoringresourcecenter.org/index.php/component/

k2/item/418-supporting-young-people-in-the-wake-of-violence-and-trauma.html) 

Trauma Resilience Resources, Substance Abuse and Mental Health Services Administration, U.S. Department of Health 

and Human Services. 

• This page provides information on agencies, foundations, and other resources that collect data on trauma and 

resilience. (https://www.samhsa.gov/capt/tools-learning-resources/trauma-resilience-resources) 

Coping with Traumatic Events: Resources for Children, Parents, Educators, and Other Professionals, Substance 

Abuse and Mental Health Services Administration, U.S. Department of Health and Human Services. 

• This page offers online resources designed to assist parents, educators, and other professionals in helping children cope with traumatic events. (Includes a number of resources from the National Child Traumatic Stress Network and a resource related to traumatic stress after mass violence, terror, or disaster.) (https://www.samhsa.

gov/capt/tools-learning-resources/coping-traumatic-events-resources) 

The National Child Traumatic Stress Network (NCTSN), Substance Abuse and Mental Health Services Administration, 

U.S. Department of Health and Human Services. 

• The NCTSN and its various centers have developed and implemented a range of clinical treatments, mental 

health interventions, and other trauma-informed service approaches as a means of promoting the Network’s 

mission of raising the standard of care for traumatized youth and families. (https://www.nctsn.org/treatments-and-practices/treatments-that-work/interventions)

U.S. Department of the Interior, Bureau of Indian Affairs, Office of Justice Services. 

• This office supports tribal justice systems and provides victim assistance on Indian reservations. (https://www.

bia.gov/bia/ojs)
Federal Commission on School Safety: Appendix 177

Appendix B: Compilation of Past Findings and 

Recommendations from Key School Safety Reports

To better understand past federal and state after-action and related school safety and school violence reports, the 

Commission identified 10 key reports from the period 2001 to 2018. The Commission reviewed the reports and 

identified actions taken in response. The information has been compiled into a document titled: Compilation of Past 

Findings and Recommendations from Key School Safety Reports and may be found at https://www2.ed.gov/documents/

school-safety/key-school-safety-reports.pdf.
4 Federal Commission on School Safety: Prevent