School Bullying: Extent of Legal Protections for Vulnerable Groups Needs to Be More Fully Assessed
Published: 2012-05-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Millions of youths are estimated to be subject to bullying in U.S. schools. GAO was asked to address (1) what is known about the prevalence of school bullying and its effects on victims, (2) approaches selected states and local school districts are taking to combat school bullying, (3) legal options federal and selected state governments have in place when bullying leads to allegations of discrimination, and (4) key federal agencies coordination efforts to combat school bullying. GAO reviewed research on the prevalence and effects on victims; analyzed state bullying laws, and school district bullying policies; and interviewed officials in 8 states and 6 school districts. States were selected based on various characteristics, including student enrollment, and their definitions of bullying. Also, GAO reviewed selected relevant federal and state civil rights laws, and interviewed officials from Education, HHS, and Justice.
section_title: What GAO Found
paragraphs: School bullying is a serious problem, and research shows that it can have detrimental outcomes for victims, including adverse psychological and behavioral outcomes. According to four nationally representative surveys conducted from 2005 to 2009, an estimated 20 to 28 percent of youth, primarily middle and high school-aged youths, reported they had been bullied during the survey periods. However, differences in definitions and questions posed to youth respondents make it difficult to discern trends and affected groups. For example, the surveys did not collect demographic information by sexual orientation or gender identity. The Departments of Education (Education) and Health and Human Services (HHS) are partially addressing the issue of inconsistent definitions by collaborating with other federal departments and subject matter experts to develop a uniform definition of bullying that can be used for research purposes. However, gaps in knowledge about the extent of bullying of youths in key demographic groups remain.
According to Education, as of April 2012, 49 states have adopted school bullying laws. The laws in the 8 states that GAO reviewed vary in who is covered and the requirements placed on state agencies and school districts. For example, 6 of the states cover a mix of different demographic groups, referred to as protected classes, such as race and sex or gender, in their bullying laws, while 2 states do not include any protected classes. With respect to school districts, each of the 6 districts GAO studied adopted policies that, among other things, prohibit bullying and describe the potential consequences for engaging in the behavior. Also, school district officials told GAO that they developed approaches to prevent and respond to bullying. For example, several school officials said they implemented a prevention-oriented framework to promote positive school cultures. Both state and local officials expressed concerns about various issues, including how best to address incidents that occur outside of school.
Federal civil rights laws can be used to provide protections against bullying in certain circumstances, but certain vulnerable groups are not covered and therefore have no recourse at the federal level. For example, federal agencies lack jurisdiction under civil rights statutes to pursue discrimination cases based solely on socioeconomic status or sexual orientation. While some state civil rights laws provide protections to victims of bullying that go beyond federal law, federal complainants whose cases are dismissed for lack of jurisdiction are not always informed about the possibility of pursuing claims at the state level.
Three federal departmentsEducation, HHS, and the Department of Justice (Justice)have established coordinated efforts to carry out research and broadly disseminate information on bullying to the public, including establishment of a central website and an informational campaign to raise awareness about bullying. In addition to these efforts, Education has issued information about how federal civil rights laws can be used to address bullying of protected classes of youths and is conducting a comprehensive study of state bullying laws and how selected school districts are implementing them. However, no similar information is being gathered on state civil rights laws and procedures that could be helpful in assessing the adequacy of legal protections against school bullying.
section_title: What GAO Recommends
paragraphs: GAO recommends that Education compile information about state civil rights laws and procedures that relate to bullying, and inform complainants about state legal options; Education, HHS, and Justice develop information about bullied demographic groups in their surveys; and assess whether legal protections are adequate for these groups. Education disagreed with our first recommendation and we clarified it to address some of their concerns. Education is considering our second recommendation, agreed with our third, and provided information on efforts related to the last. HHS agreed with our recommendations. Justice did not provide a written response.

section_title: Letter
paragraphs: It is estimated that millions of American youths have been bullied by their  peers, including physical, verbal, and electronic attacks. Some of these  incidents, including some where bullying has been linked by the media to  teen suicide, have received widespread attention, resulting in heightened  awareness of bullying, as well as a wide range of actions at the federal,  state, and local levels to address the behavior. Some of these incidents  involved bullying based on personal characteristics, including race,  religion, or sexual orientation, and have also raised questions about the  role and availability of federal and state civil rights protections. Given the  dynamic and rapidly changing nature of these efforts, governments at all  levels, as well as the public, face a growing need for information about  possible legal and practical approaches to combating bullying. In this  context, you asked us to address the following questions:  1.  What is known about the prevalence of school bullying and its effects  on victims? 2.  What approaches are selected states and local school districts taking  to combat school bullying? 3.  When bullying leads to allegations of discrimination, what legal  options do federal and selected state governments have in place? 4.  How are key federal agencies coordinating their efforts to combat  school bullying?
To identify what is known about the prevalence of school bullying and its  effects on victims, we interviewed knowledgeable federal officials,  compared estimates and methodologies of four nationally representative  surveys that captured information on bullying, and conducted a literature  review of meta-analyses on the subject of the effects of bullying on  victims.aged youths and were conducted by federal statistical agencies from  2005 to 2009. The results of the meta-analyses are not generalizable, but  represent a systematic approach to summarizing or analyzing findings  across studies included in the meta-analyses. To describe approaches  that selected states and local school districts are taking, we reviewed  relevant state bullying laws, regulations, guidance, and documents from  eight selected states and conducted interviews with state education  officials. We selected eight states—Arkansas, California, Illinois, Iowa,  Massachusetts, New Mexico, Vermont, and Virginia—based on the  following criteria: Each has bullying laws or regulations, and they vary  with respect to bullying definitions and enumeration of protected classes,  geographic variation, and student enrollment. Further, we selected three  states—New Mexico, Vermont, and Virginia, which vary on the  characteristics listed above—to review policies and guidance of six local  school districts, two in each state. School districts and schools were  selected to reflect a range of size and urbanicity (urban, suburban, and  rural), as well as racial and socioeconomic diversity. Participation in the  National School Lunch Program is used as a proxy for socioeconomic  status. In these school districts, we conducted interviews with central  administrators, principals, school staff, and parents. To identify legal   The four surveys focused primarily on middle and high school- options that federal and selected state governments have in place when  bullying leads to allegations of discrimination, we reviewed relevant  federal anti-discrimination laws, as well as state anti-discrimination laws  for the eight states included for review. We also conducted interviews with  officials in the Departments of Education (Education) and Justice  (Justice), as well as with state education and civil rights officials, on anti- discrimination laws and complaint processes. Last, to identify  coordination of efforts of key federal agencies to combat school bullying,  we conducted interviews and reviewed documents from three federal  departments: Education, Justice, and the Department of Health and  Human Services (HHS). We analyzed coordination of efforts based on  our professional judgment and relevance of selected key practices that  we have previously identified as effective coordination practices.
We conducted this performance audit from April 2011 through May 2012  in accordance with generally accepted government auditing standards.  These standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives. For more information on our  scope and methodology, see appendix I.
subsections: section_title: Background
paragraphs: Although definitions vary, including definitions used by federal agencies,  many experts generally agree that bullying involves intent to cause harm,  repetition, and an imbalance of power. The pioneering research of Dr.  Dan Olweus in Norway has defined being bullied or victimized as when a  student “is exposed, repeatedly and over time, to negative actions on the  part of one or more other youths” with an intent to harm.bullying is distinct from general conflict or aggression, which can occur  absent an imbalance of power or repetition. For example, a single fight  between two youths of roughly equal power is a form of aggression, but  may not be bullying. When bullying occurs it may take many forms that  can also be associated with conflict or aggression, including physical   Notably,  harm, such as hitting, shoving, or locking inside a school locker; verbal  name calling, taunts, or threats; relational attacks, such as spreading  rumors or isolating victims from their peers; and the use of computers or  cell phones to convey harmful words or images, also referred to as  cyberbullying. Often bullying occurs without apparent provocation and  may be based on the victim’s personal characteristics. For example,  youth may be bullied based on the way they look, dress, speak, or act.
There are several federal efforts under way to bring together federal  resources that can be used to identify and address bullying. In particular,  given their focus on education, health, and safety issues, Education,  HHS, and Justice, along with other federal agencies, have been involved  in efforts to help coordinate federal resources to identify and address  bullying. Additionally, several bills have been introduced in the 112th  Congress that relate to bullying. Among the various issues addressed in  these bills are bullying policies, the collection and reporting of bullying  data, and the prohibition of discrimination on the basis of sexual  orientation or gender identity. Some of the bills would authorize federal  grants to states and school districts for antibullying-related purposes.  Although there is not presently a federal law directly targeted to address  school bullying, several federal civil rights laws that prohibit discrimination  based on protected characteristics of individuals may, under certain  circumstances, be used to address particular incidents of bullying.
With respect to states’ efforts to address bullying, Education  commissioned a two-part study that examines the elements of state  bullying laws and the manner in which school districts are implementing  the laws. The first part of Education’s study, issued in December 2011,  included a review of all state bullying laws and model policies in effect as  of April 2011, including those of the eight states we reviewed, as well as  policies from 20 large school districts. The second part of Education’s  study is scheduled for completion during fall 2012. It will include case  studies of how 24 schools, selected from four states, implement their  states’ bullying laws.
section_title: Reported Levels of Bullying and Related Effects Are Significant
subsections: section_title: Federal Survey Data
paragraphs: Being bullied is a serious problem, as evidenced by four federally  sponsored nationally representative surveys conducted from 2005 to  2009. Estimates of the national prevalence of bullying ranged from  approximately 20 to 28 percent of youth reporting they had been bullied  during the survey periods, which ranged from a couple of months to a  year. However, differences in definitions and survey methods make it  difficult to draw definitive conclusions regarding trends and affected  demographic groups. Our analysis and similar work from HHS’s Centers  for Disease Control and Prevention (CDC), one of the sponsors of two of  the surveys, showed that the surveys vary in the way they pose questions  about being bullied and how bullying is defined, if at all.Education, the sponsor of one of the surveys, and HHS also told us that  different survey questions and definitions of bullying lead to different  results in estimates of prevalence.
While it is clear that bullying is a serious problem, it is unclear from the  surveys the extent to which bullying affects certain groups of youths  relative to other groups. Specifically, the surveys collected information on  the percentage of youths bullied based on gender and race. However, the  information showed varying results. For example, there was no significant  difference in the percentage of boys and girls that reported being bullied,  according to two surveys, while one noted that girls were bullied at a  higher percentage. In two of the three surveys, white youths reported  being bullied at a higher percentage than African-American youths, while  one other survey found no significant difference.
In addition, the four national surveys we identified did not consistently  collect information about other demographic characteristics, making it  impossible to determine percentages of bullying for these groups. For  example, none of the surveys collected demographic information for  youths by sexual orientation or gender identity. Researchers noted  various challenges to obtaining such information, such as some schools  may not permit questions on sexual orientation or gender identity status,  potentially resulting in a sample that would not be nationally  representative. Also, questions about sexual orientation or gender identity  may be sensitive for youth respondents to complete, and researchers  noted that such questions may not yield accurate information.  Additionally, the surveys varied in whether or not they collected  demographic information to allow for analysis based on religion, disability,  or socioeconomic status, and two of the surveys did not include any  questions asking specifically if youths had been bullied based on specific  demographic characteristics. (See table 1.)
While federal agencies have not collected information on some  demographic groups, other researchers have attempted to fill the void.  For example, the Gay, Lesbian and Straight Education Network (GLSEN)  conducted a survey in the 2008-2009 school year and received  responses from more than 7,000 students between the ages of 13 and 21  who self-reported as not heterosexual. Although not nationally  representative, the results found, among other things, that 85 percent of  students who responded to the survey said they were called names or  threatened at some point in the past school year based on their sexual  orientation, and 64 percent based on their gender expression; for  example, for not acting “masculine enough” or “feminine enough”. Forty  percent of students who responded said they were pushed or shoved  based on their sexual orientation, and 27 percent based on their gender  expression.
In addition to the fact that there are voids in information about  demographic groups, Education and HHS officials said that researchers  need a uniform definition to measure bullying. To better understand the  prevalence of bullying, and given the different definitions used by bullying  research instruments, CDC is leading an interdepartmental project to  develop a uniform definition of bullying for research purposes. According  to CDC officials, a report is expected to be issued in 2012 that contains a  uniform definition along with information on other data elements to  measure bullying, such as the frequency or types of bullying behavior.  According to CDC, the project on the uniform definition is still under  review, but may contain data elements for a number of demographic  characteristics, including sex, race, ethnicity, disability status, religion,  and sexual orientation.
section_title: Negative Outcomes from Bullying
paragraphs: Research, spanning more than a decade, has demonstrated that bullying  is associated with a variety of negative outcomes for victims, including  psychological, physical, academic, and behavioral issues. For example,  a 2000 analysis of 23 bullying research studies found that youth who  were bullied experienced higher levels of depression, loneliness, low self- esteem, and anxiety than their peers who had not been bullied.  Similarly, a 2010 analysis of 18 research studies found that being bullied  was linked to increased psychological issues later in life. A third  analysis, of 20 studies, published in 2011, found that being bullied was  associated with greater likelihood of being depressed later in life.
A 2009 analysis of 11 research studies found that bullying victims had a  higher risk for such physical health outcomes as headaches, backaches,  sleeping problems, and bad appetite, as compared with their peers who  had not been bullied. Additionally, a 2010 analysis of 33 research  studies on bullying and academic achievement found that bullying is  related to concurrent academic difficulties for victims. Academic  achievement was assessed based on such measures as grade point  averages, standardized test scores, or teacher ratings of academic  achievement. Researchers have also linked bullying to increases in  behavioral problems for victims over time, such as aggression,  delinquency, and truancy.
While researchers point out that the causes of suicide and violence are  varied and complex, bullying has been identified as one risk factor  associated with violent actions against oneself and others. For example,  one 2011 analysis of 18 studies found that gay, lesbian, and bisexual  youth were more likely to be verbally harassed and teased or physically  and sexually victimized than heterosexual youth, and more likely to  experience detrimental outcomes, such as suicidal thoughts and  attempts. According to a federally sponsored website on bullying,  specific groups have an increased risk of suicide, including American  Indian and Alaskan Native, Asian-American, lesbian, gay, bisexual, and  transgender youths. Their risk of suicide can be increased further by  bullying. Bullying has also been linked to acts of violence against others.  For example, a 2002 study by Education and the Secret Service reviewed  37 incidents of school attacks and shootings occurring between 1974 and  the end of the 2000 school year, and reported out 10 key findings that  could be used to develop strategies to address targeted school violence.  One of those 10 findings was that nearly three-quarters of attackers were  bullied, persecuted, or injured by others prior to the attack, and that in  several cases the bullying was severe and long-standing.
section_title: Selected State Legislatures and Educational Agencies Are Taking Various Approaches to Reduce Bullying
subsections: section_title: State Laws Vary in How They Address Bullying
paragraphs: According to Education, 49 states had school bullying laws as of April  2012, including the 8 states that we reviewed. These 8 states’ laws vary  in several ways, including who is covered and the requirements placed on  state agencies and school districts. For example, the 8 states’ laws that  we reviewed vary in whether and the extent to which they cover specific  demographic groups, referred to as protected classes. Five states— Arkansas, Illinois, Iowa, New Mexico, and Vermont—identify race, color,  sex or gender, national origin or nationality, disability, sexual orientation,  gender identity, and religion as protected classes. California includes all  of these groups, except for color. Some states also prohibit bullying of  other protected classes. For example, Illinois also includes as protected  classes ancestry, age, and marital status. Virginia and Massachusetts do  not include protected classes in their state bullying laws. According to  Massachusetts officials, protected classes were intentionally omitted from  the state’s law to ensure that all youths were equally protected. Within  Massachusetts’ state educational agency (SEA), a specific office is  designated to receive complaints, including from youths who have been  bullied for any reason, such as obesity or socioeconomic status.  Additionally, four of the states that identify protected classes—Arkansas,  Illinois, Iowa, and New Mexico—provide that the list of classes is not  exhaustive, so protection can be afforded to youths with characteristics  not explicitly listed. For example, Iowa prohibits bullying “based on any   In contrast,  actual or perceived trait or characteristic of the student.”California’s bullying law is more exclusive and limits protection to only  those groups that are listed in the law.
We also found that state laws impose various requirements on SEAs. For  example, laws in California, Massachusetts, Vermont, and Virginia require  that SEAs develop model bullying policies as a resource for school  districts. Also, we found that while SEAs in Arkansas, California, and  Illinois are required by law to review or monitor school district’s bullying  policies, the approach taken to do so is different from state to state. For  example, officials in Arkansas reported that as part of a broader effort to  ensure that school districts’ policies align with federal and state laws, they  conduct on-site reviews every 4 years, and require school districts to  forward information to the Department of Education for review every year,  including information about discipline and bullying policies. Conversely,  an Illinois official reported that little meaningful oversight is occurring, in  part because of resource constraints.
In each of the states we reviewed, the laws require school districts to  adopt bullying policies or plans, but the states differed in the specific  requirements of what must be included in these policies or plans. For example, of the 8 states’ laws we reviewed, 6 states require school  districts to set forth a process for receiving and investigating complaints,  and 2 do not. Similarly, we found that 6 states’ laws require district  policies to identify the consequences for bullies, while 2 do not. Table 2  provides information about commonly required school district provisions  in state bullying laws.
States are also making changes to their bullying laws, as evidenced by 4  of our 8 selected states amending or enacting bullying laws since we  began our study in the spring of 2011.other things, amended its law to include protected classes based on  actual or perceived characteristics. Vermont amended its law to include  protections against cyberbullying and incidents that do not occur during  the school day on school property, or at school-sponsored events.
section_title: Selected School Districts’ Antibullying Policies and Programs
paragraphs: The six school districts we reviewed in New Mexico, Virginia, and  Vermont have all adopted policies, plans, or rules, and implemented a  range of approaches, to combat bullying. Among other components of the  bullying policies and rules, each prohibits bullying and describes potential  consequences for the behavior. Also, the school districts in New Mexico  and Vermont developed policies and procedures covering the reporting  and investigation of bullying behavior.
School district officials explained that they have developed several  approaches to prevent and respond to bullying. For example, in five of the  six school districts we visited, central administrators or principals said  they conduct student surveys that include questions about bullying to  determine the prevalence of the behavior, and two administrators said the  surveys are used to develop strategies to address the behavior. Also,  officials from four of the six school districts said that several or all of their  schools utilize the prevention-oriented framework Positive Behavioral  Interventions and Supports (PBIS) to improve overall behavior in schools  (see text box). Additionally, several school districts and schools use  curricula that help youths develop interpersonal skills and manage their  emotions, such as Second Step, a classroom-based social skills program  for youths 4 to 14 years of age, and Steps to Respect, a bullying  prevention program developed for grades three through six. Several  central administrators and principals mentioned that antibullying-focused  events have been held at their schools, such as Rachel’s Challenge and  Ryan’s Story. Rachel’s Challenge is a program that seeks to create a  positive culture change in schools and communities and begins with  video/audio footage of Rachel Scott, the first person killed during the  1999 Columbine High School incident. Ryan’s Story is a presentation that  recounts the factors that led to the 2003 suicide of Ryan Halligan, a victim  of both bullying and cyberbullying.
The Positive Behavioral Interventions and Supports framework utilizes evidence-based,  prevention-oriented practices and systems to promote positive and effective classroom  and school social cultures. According to Education’s Office of Special Education  Programs, PBIS steps to addressing bullying behavior at school include the following:  examining discipline data to determine, for example, the frequency, location, and  timing of specific bullying behaviors;  examining the extent to which staff members have, for example, actively and  positively supervised all students across all school settings, had high rates of  positive interactions and contact with all students, and arranged their instruction so  all students are actively engaged, successful, and challenged ; and  teaching students and staff common strategies for preventing and responding to  bullying behavior, such as intervening and responding early and quickly to interrupt  bullying behavior, removing what triggers and maintains bullying behavior, and  reporting and recording when a bullying behavior incident occurs.
Students whose bullying behavior does not improve are considered for additional  supports. For example, on the basis of the function of a student’s behavior, students  would (1) begin the day with a check-in or reminder about the daily expectations; (2) be  more overtly and actively supervised; (3) receive more frequent, regular, and positive  performance feedback each day; and (4) conclude each day with a checkout or  debriefing with an adult.
In addition to mentioning efforts focused on youths, several central  administrators and principals said that teachers receive some bullying  prevention guidance or training. Information about bullying prevention is  also shared with parents during workshops and forums. For example, one  official mentioned that Rachel’s Challenge includes a session with  parents and community leaders. A parent said that his school district  hosted a national speaker to share information with parents about  bullying.
section_title: State and Local Officials Cited Concerns That Hinder Antibullying Efforts
paragraphs: Both state and local officials expressed concerns about various issues  associated with implementing state bullying laws, regulations, and local  policies and codes of conduct. For example, administrators and principals  reported that determining how to respond to out-of-school incidents, such  as cyberbullying, is challenging. Administrators and principals said that  sometimes they are not informed of incidents in a timely manner, resulting  in a delayed response. Additionally, some parents discourage school  officials’ involvement in out-of-school incidents. However, administrators  and principals agreed that when out-of-school incidents affect school  climate, the behavior has to be addressed.
Another issue of concern for both state and local officials is that parents  and youths can confuse conflict with bullying. According to the state and  local officials that we spoke with, they spend a lot of time on nonbullying  behavior and more could be done to educate parents and youths on the  distinction between bullying behavior and other forms of conflict. On a  related matter, state and local officials said that it is important to train  teachers and staff to prevent, identify, and respond to bullying behavior.  However, according to these officials, because of state budget cuts and  the elimination of some federal funding that could be used for bullying  prevention activities, there is little funding available for training. State  officials specifically cited the loss of funding from Title IV, Part A of the  Elementary and Secondary Education Act of 1965, as amended, which  among other things could be used to prevent violence in and around  schools. According to federal officials, funding for this program was  eliminated in 2009.
section_title: Federal and State Civil Rights Laws Offer Some Protections against Bullying, but Vulnerable Groups May Not Always Be Covered
paragraphs: When bullying rises to the level of discrimination, federal civil rights laws  may be used to provide redress to individuals in legally protected groups.  Federal civil rights laws protect against discrimination based on sex, race,  color, national origin, religion, or disability. However, federal agencies  generally lack jurisdiction to address discrimination based on  classifications not protected under federal civil rights statutes. For  example, federal agencies lack authority to pursue discrimination cases  based solely on sexual orientation.
Additionally, federal civil rights laws do not cover all youths in all  educational settings, and as a result, where a student goes to school  could affect the student’s ability to file a claim of discrimination with the  federal government. For example, Title IV of the Civil Rights Act of 1964  (Title IV) prohibits discrimination in public schools and institutions of  higher learning. Since Title IV is the only federal civil rights law  addressing religious discrimination in educational settings, only youths at  public schools and public institutions of higher learning, where Title IV  applies, could file such a claim. Youths who attend public schools or other  schools receiving federal education funding and who belong to other  federally protected classes may have the option to file a complaint with  Education, Justice, or both departments, depending on which agency has  enforcement authority.laws, protected classes, and agency enforcement authority.
According to OCR’s case processing manual, a complaint must be filed within 180  calendar days of the date of the alleged discrimination, unless the time for filing is  extended by Education’s Office for Civil Rights for good cause shown under certain  circumstances. complaints is partly due to Education’s greater staff resources.  Education’s Office for Civil Rights has roughly 400 staff, and Justice’s  Civil Rights Division, Educational Opportunities Section, has about 20  attorneys. According to departmental officials, Education investigates all  complaints it receives for which it has jurisdiction. Conversely, Justice  selects a limited number of complaints to review based on such factors as  the severity of the complaint and whether the federal government has a  special interest in the case. Additionally, officials from Education and  Justice told us that they collaborate closely. Generally, Justice and  Education share information about complaints because they may have  overlapping jurisdiction, and try to coordinate efforts where feasible.
Education and Justice do not currently have a systematic approach for  tracking information about the number of cases related to various  demographic groups that they do not have jurisdiction to address. The  U.S. Commission on Civil Rights, in a 2011 report on the protections of  federal anti-discrimination laws relating to school bullying, recommended  that Justice and Education, among other things, track dismissed civil  rights claims by various demographic characteristics. However, Education  and Justice officials told us that as part of their complaint review  processes, they focus on collecting information to establish federal  jurisdiction, and as a result neither department collects information in a  way that would allow them to routinely assess the demographic  characteristics of cases where they lack jurisdiction. Thus, they do not  plan to address the commission’s recommendation. Additionally,  according to officials from both departments, attempting to track such  information would be problematic because of difficulties in ascertaining  demographic information. They also believe the information could be  misleading. According to Justice officials, they dedicate significant  resources to outreach designed to educate communities on their  jurisdiction, and this may impact the number of complaints they receive  from demographic groups that fall outside of their jurisdiction.
subsections: section_title: State Civil Rights Protections
paragraphs: We found that some states’ civil rights laws extend beyond the  protections afforded at the federal level, but information about the  possibility of pursuing claims at the state level was not always provided to  federal complainants. For all eight states we reviewed, state anti- discrimination laws, like federal civil rights laws, provide protections for  individuals who are discriminated against on the basis of sex, race,  national origin, religion, and disability, and in all but Arkansas, color.Thus, in these eight states, for these protected classes, legal action can  generally be taken at the federal, state, or both levels.
The majority of the eight states that we reviewed include in their anti- discrimination laws protections for various groups of people who are not  explicitly covered at the federal level. For example, six of the eight states  we reviewed prohibit discrimination on the basis of sexual orientation, and five of the eight states prohibit discrimination on the basis of gender  identity. Beyond these protected classes, most states we reviewed also  prohibit discrimination on the basis of other personal characteristics, such  as marital status. California is unique among the states in our review in  that its anti-discrimination laws explicitly protect individuals on the basis of  citizenship, gender-related appearance and behavior, and individuals who  are associated with a person with (or perceived to have) a protected  characteristic. However, because some characteristics are not explicitly  protected under anti-discrimination laws at either the federal level or in  the states we reviewed, youths in these states who are bullied on the  basis of one of these characteristics would have no recourse under civil  rights law at either level. For example, state education and civil rights  officials mentioned that anti-discrimination laws generally do not apply to  youths who were bullied based on their socioeconomic status or obesity.
The six states are California, Illinois, Iowa, Massachusetts, New Mexico, and Vermont. who withdraws his or her complaint may be informed in a phone  discussion about legal options at the state level. Also, officials said that if  a complaint reaches the stage of a dismissal, Education’s letter to the  complainant sometimes suggests that the claimant might have a claim  under state civil rights law, along with the name and address of the  relevant state agency. However, according to Education officials, when  the agency lacks jurisdiction, it does not presently notify complainants  about the availability of possible recourse under state law on a routine  basis. As a result, individuals who file complaints with Education may not  be fully aware of their legal options. On the other hand, according to  Justice officials, department officials routinely share with complainants  that they may have legal options available to them through their state’s  civil rights laws. While not specific to particular states and their laws,  Justice provides a general notification in letters to complainants for  complaints they do not pursue.
section_title: Coordinated Federal Antibullying Efforts Are Under Way, but Assessment of Legal Remedies Is Incomplete
subsections: section_title: Federal Coordination Efforts
paragraphs: Education, HHS, and Justice have established coordinated efforts to carry  out research and broadly disseminate information on bullying. Education  has also provided key information about how federal civil rights laws can  be used to address bullying and is conducting a study of state bullying  laws and how selected school districts are addressing bullying. Three  federal efforts, in particular—formation of a coordinating committee,  establishment of a central website, and an informational campaign—have  provided the public with a range of information about bullying, through a  variety of media.
The Federal Partners in Bullying Prevention Steering Committee serves  as a forum for federal agencies to develop and share information with  each other and the public. The committee was created in 2009 and is  composed of the Departments of Education, HHS, Justice, Agriculture,  Defense, and Interior, along with the Federal Trade Commission, the  National Council on Disability, and the White House Initiative on Asian  Americans and Pacific Islanders. Among other activities, the coordinating  committee helped to plan a conference on bullying in March 2011 hosted  by the White House, as well as annual conferences of the coordinating  committee in August 2010 and September 2011. Following each annual  conference, the committee has developed priorities and formed  subcommittees to address those priorities. For example, after identifying  a need for better coordination of bullying research, a research  subcommittee was created after the August 2010 conference. Following  the September 2011 conference, this subcommittee’s activities in the  upcoming year will also include identifying best practices for training  teachers as well as drawing attention to programs that could help youths  develop interpersonal skills and manage their emotions.
The three federal departments, along with the White House, established a  central federal website (www.stopbullying.gov, last accessed May 22,  2012), launched in March 2011 at the White House conference on  bullying. The central website sought to consolidate the content of different  federal sites into one location to provide free materials for the public.  Hosted by HHS, with content and technical support from the Health  Resources and Services Administration (HRSA), the website aims to  present a consistent federal message and features content arranged by  target audience, such as teens, along with sections on special topics such  as cyberbullying.
HHS through HRSA launched the informational campaign called Stop  Bullying Now! in 2004. Federal departments outside HHS that assist with  the campaign include the Departments of Education, Justice, Agriculture,  Defense, and Interior. The campaign is designed for youth and adults to  raise awareness, foster partnerships, and disseminate evidence-based  findings to help prevent and intervene in instances of bullying. The  informational campaign offers a variety of free materials, including a DVD  with 14 cartoon episodes, 30 tip sheets based on research and evidence- based practices, public service announcements, posters, brochures,  comic books, and kits for youth leaders and adults. According to data  from HRSA as of August 2011, recipients of materials in mass mailings  included, among others, all 66,000 public elementary and middle schools  in the country, 17,000 libraries, relevant state health and education  agencies, offices serving Indian and military youth, 4,000 Boys and Girls  Clubs, relevant state health and education agencies, schools on military  bases worldwide, and offices serving American Indian youth. (See app. V  for more information on the campaign.) However, according to HHS  officials, the campaign and its online content are currently in a period of  transition, as they adapt to the new interdepartmental website and its  governance.
While these efforts are still evolving, we found that they are consistent  with key practices that we determined can help or sustain coordination  efforts across federal agencies. Specifically, we found that in each of  these three efforts that key agencies reached agreement on roles and  responsibilities. For example, the roles and responsibilities of the federal  agencies responsible for stopbullying.gov are spelled out in a governance  document, and the lead agency, HHS, for this website has executed  agreements to provide funding for the maintenance and operation of the  website. Similarly, we found that these agencies worked to establish  compatible policies and procedures, and to develop mechanisms to  monitor progress for these coordinated efforts. Appendix V provides more  information on federal coordination efforts on bullying.
In addition to these collaborative agency efforts to share information  about bullying, Education has disseminated information about federal civil  rights laws that can be used to address bullying, and key components of  state bullying laws. In October 2010, Education sent a letter to state and  local education officials outlining how federal civil rights laws can be  applied to bullying. The letter stated that student misconduct may trigger  school responsibilities under federal civil rights laws and provided  examples of behavior that may meet the threshold for violating the laws.  In December 2010, the department issued another letter that summarized  several key components of state bullying laws, such as specifying  prohibited behavior, development and implementation of school district  policies, and training and preventive education. As previously discussed,  following up on this letter, the department commissioned a study of state  bullying laws to determine the extent to which states and school districts  incorporate the key components into their laws and policies. In December  2011, Education issued the first part of this two-part study on state  bullying laws.
section_title: No Assessment of State Civil Rights Laws and Procedures Has Been Performed
paragraphs: While Education, HHS, and Justice have initiated several efforts to better  inform the public about how to utilize federal, state, and other resources  to better address bullying, none of these efforts include an assessment of  state civil rights laws and procedures for filing complaints. Since some  states’ civil rights laws provide protection for groups not named in  applicable federal civil rights laws, collection and dissemination of such  information could assist in better understanding how these laws vary in  coverage and in the procedures states have in place for filing complaints.  For example, five states in our review—California, Illinois, Iowa,  Massachusetts, and Vermont—have established processes and  procedures for resolving civil rights complaints, and have empowered a  statewide organization with the authority to hold schools and school  districts accountable when discrimination is found, according to state  officials. Specifically, according to a state official, California’s Uniform  Complaint Process empowers its Department of Education’s Office of  Equal Opportunity to ensure compliance with state and federal civil rights  laws. California’s state code also requires uniform complaint procedures  that each school district within the state must follow when addressing  complaints of discrimination against protected groups, according to a  state official. The complaint process allows up to 60 days for an  investigation and decision to be rendered at the district level, unless a  child is directly in harm’s way and the school district is unresponsive, in  which case a complaint can be filed directly with the state. In Vermont,  the state’s Human Rights Commission acts as an independent agency  focused solely on the protection of civil rights, and if its investigation  determines unlawful discrimination occurred, the agency assists the  parties in negotiating a settlement. Human Rights Commission officials  told us if a settlement cannot be reached, the agency may choose to take  the case to court. However, they said that this usually does not happen  because cases are generally settled. The Massachusetts Department of  Elementary and Secondary Education has a formal process called the  Problem Resolution System that handles complaints that allege a school  or a district is not meeting legal requirements for education, including  complaints of discrimination. In each of the five states with established  processes and procedures for resolving civil rights complaints, the SEAs  include information on their websites about the civil rights complaint  process, including where to file, required information, and time frames.
According to their respective state officials, Arkansas and New Mexico  offer only limited legal options for protected classes with complaints of  discrimination based on school bullying because they lack a state entity  with the authority to investigate and hold school districts accountable for  such complaints. Although Arkansas has an Equity Assistance Center  within its Department of Education that can serve as an intermediary  between the complainant and the school district, its decisions lack the  authority to discipline a school district, according to state officials. New  Mexico has a human rights commission that receives and investigates  complaints of discrimination based on protected classes, but the  commission is focused on employment issues and does not address  discrimination complaints related to education. As a result, the state lacks  formal processes and procedures to address complaints of discrimination  stemming from instances of bullying, according to state officials.  Therefore, according to state officials from these two states, if an  individual cannot afford an attorney to file a private right of action related  to complaints of discrimination because of school bullying, the individual’s  only legal option is to file a federal complaint.
By not incorporating an assessment of state civil rights laws and  procedures into their various bullying prevention efforts, federal agencies  are overlooking a potentially important source of information. Building on  information from Education’s study of state bullying laws and the letters  they issued on federal civil rights laws, information on state civil rights  laws and procedures would provide a broader and more complete  perspective of the overall coverage of federal and state efforts to prevent  and address bullying.
section_title: Conclusions
paragraphs: Students who are bullied may seek recourse through a number of  avenues—local and state educational policies, state bullying laws, state  civil rights laws, or federal civil rights laws. However, the nature and  extent of protections available to them depend on the laws and policies of  where they live or go to school. Education and Justice have taken  important steps in assessing how federal civil rights laws can be used to  help combat certain instances of bullying of protected classes of youth for  which they have jurisdiction. And Education has completed a study of  state bullying laws and is conducting another study looking at how school  districts are implementing these laws. However, neither Education nor  Justice has assessed state civil rights laws and procedures as they may  relate to bullying. Many of the states’ civil rights laws we reviewed extend  protections to classes of individuals beyond the groups protected at the  federal level, but states vary in the groups that are explicitly protected;  therefore, whether bullying victims have any recourse through civil rights  laws can depend on the state in which they live or go to school. Also,  states vary in their procedures for pursuing civil rights claims, which could  also affect the ability to pursue a bullying-related discrimination claim.  State civil rights laws, just like federal civil rights laws and state bullying  laws, can play an important role in addressing this important issue. More  information about state civil rights laws and procedures is a key missing  link and is needed by administration officials and decision makers alike, to  understand the potential overall legal protections available to students  who have been bullied.
Federal claimants would also benefit from knowing that options may be  available to them at the state level. This is particularly key when cases  are dismissed at the federal level because of a lack of jurisdiction. While  Justice routinely informs individuals when their complaints are dismissed  because of a lack of jurisdiction of possible recourse under their state civil  rights laws, Education does not. Routinely making this basic information  available would be another key step in helping ensure that bullying  victims are aware of some of the legal options available to them.
Multiple efforts to collect information about bullying have been under way  for several years; however, the prevalence of bullying of youths in certain  vulnerable demographic groups is not known. A greater effort by key  federal agencies to develop more information about the extent to which a  broader range of demographic groups are subject to bullying and bullying- related discrimination would better inform federal efforts to prevent and  remedy bullying. Understanding the prevalence of bullying by  demographic groups would help administration officials develop additional  actions targeted at the greatest areas of need. This information, together  with an assessment of federal and state legal protections, could also aid  policymakers in determining whether additional actions are needed to  protect vulnerable groups of youths who are subjected to bullying.
section_title: Recommendations for Executive Action
paragraphs: To allow for a more comprehensive assessment of federal and state  efforts to prevent and address bullying, we recommend the Secretary of  Education, in consultation with the Attorney General, as appropriate,  compile information in a one-time study—similar to its study of state  bullying laws—about state civil rights laws and procedures, as they may  pertain to bullying.
In order to better ensure that individuals are aware of their options to seek  legal redress, especially in cases where their complaints to Education are  not pursued because of a lack of jurisdiction, we recommend that the  Secretary of Education develop procedures to routinely inform individuals  who file complaints of discrimination stemming from bullying about the  potential availability of legal options under their state’s anti-discrimination  laws.
To address gaps in knowledge about targets of bullying and  discrimination, we recommend that the Secretaries of Education and HHS  and the Attorney General work together to develop information in their  future surveys of youths’ health and safety issues on the extent to which  youths in various vulnerable demographic groups are bullied.
To aid policymakers and program administrators at the federal and state  levels in understanding more comprehensively what is being done to  address bullying and discrimination, we recommend that the Secretaries  of Education and HHS and the Attorney General, in conjunction with the  Federal Partners in Bullying Prevention Steering Committee, assess the  extent to which legal protections against bullying exist for vulnerable  demographic groups. Such an assessment, to be comprehensive, should  make use of information federal agencies have already compiled on state  bullying laws and federal civil rights laws together with information from  our recommendations above to compile information on state civil rights  laws and collect more information on demographic groups in federal  surveys of youth health and safety issues.
section_title: Agency Comments
paragraphs: We provided Education, HHS, and Justice an opportunity to comment on  a draft of this report. Education and HHS provided written responses,  which appear in appendixes VII and VIII, respectively. Each of the  agencies provided technical comments, which we incorporated as  appropriate. Justice chose not to provide a written response.
Education disagreed with our recommendation that it compile information  about state civil rights laws and procedures as they pertain to bullying.  Specifically, Education noted that it does not have jurisdiction over state  civil rights laws, nor the appropriate expertise, to interpret and advise on  these laws. The department stressed that its previous analysis of state  bullying laws was limited to compiling a list of statutes or regulations and  identifying key components of statutes and regulations. Further,  Education suggested that compiling information about state civil rights  laws and procedures would only be useful if kept current, and that  undergoing such a time-intensive and costly survey and review of state’s  civil rights laws would not be an appropriate use of the department’s  limited resources.
We continue to believe that a one-time compilation of state civil rights  laws and procedures would be beneficial, and provide a basis, along with  other information, for analyzing the overall legal protections that are  available for vulnerable demographic groups. Such an assessment would  help determine the extent to which states are positioned to respond to  these types of civil rights complaints and to identify those instances where  certain students are left with little recourse to pursue discrimination claims  simply because of the state in which they reside or go to school. While we  appreciate the work involved in any analysis of state laws, we believe that  Education can develop a methodological approach that would limit the  scope of their work and hone in on those aspects of civil rights laws that  come into play when bullying leads to allegations of discrimination. For  example, this review could be limited to compiling basic information about  state civil rights laws, such as which protected classes are included and  whether they apply in educational settings, and may not require an  extensive analysis of state case law. In implementing a study of this type,  Education may consider approaches similar to those they used in their  previous work on state bullying laws. Alternatively, Education officials  could choose to rely on the knowledge and expertise of cognizant state  officials by conducting a survey or otherwise soliciting pertinent  information, rather than undertaking the bulk of this work themselves. We  acknowledge Education’s concerns regarding keeping the information on  state civil rights laws updated and have modified language in the report  and our recommendation to clarify that this is meant to be a onetime  effort.
Regarding our second recommendation, Education indicated that they are  considering whether to develop procedures that would inform  complainants whose complaints are dismissed for lack of jurisdiction that  they may have possible recourse under state or local laws. We  encourage Education to review the language that Justice currently  includes in similar notification letters. As Education suggested, more  detailed guidance regarding rights and procedures for seeking redress  may then be provided by state and local agencies.
Both HHS and Education agreed with our recommendation that they  develop additional information in their surveys about youths in various  vulnerable groups who are bullied.
In response to our recommendation that Education, HHS, and the  Attorney General assess the extent to which protections exist for various  demographic groups likely to be the target of bullies, HHS agreed with the  recommendation and Education cited many of its ongoing efforts to this  end. We commend Education on its current efforts as well as other efforts  we have discussed in our report. However, as we point out in our  previous recommendations, more information is needed on state civil  rights laws as well as about how various demographic groups are  affected by bullying. Utilizing all of the information at their disposal,  including information we recommend be collected, Education, HHS, and  Justice could work together to assess how well the available laws and  resources address areas of need and identify measures that could be  taken to help prevent bullying. We believe that it is an important step to  assimilate information on resources and laws with research about areas  of need in order to assist federal policy makers and agency officials in  their efforts to address this important issue. Based on questions we  received during discussions with Justice on our report, we modified this  recommendation to clarify that such an assessment should make use of  information from our previous recommendations in this report, as well as  information that federal agencies have already gathered, and that the  three agencies in our review could work through the Federal Partners in  Bullying Prevention Steering Committee to conduct such an assessment.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretaries of  Education, and Health and Human Services, and the Attorney General;  relevant congressional committees; and other interested parties. In  addition, the report will be available on GAO’s website at  http://www.gao.gov.
If you or your staff have any questions about the report, please contact  me at (206) 287-4809 or calboml@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff that made major contributions to this report  are listed in appendix IX.
section_title: Appendix I: Objectives, Scope, and Methodology
subsections: section_title: Analysis of Surveys and Literature Review
paragraphs: To obtain information on the prevalence of school bullying of victims in  the United States, we primarily compared estimates and methodologies of  available data on being bullied in four nationally representative surveys by  federal statistical agencies conducted from 2005 to 2009. Specifically, we  compared data on being victims of bullying from the Youth Risk Behavior  Survey, the School Crime Supplement to the National Crime Victimization  Survey, the Health Behavior in School-aged Children Survey, and the  National Survey of Children’s Exposure to Violence (see table 4). We  selected these surveys based on interviews with officials at the  Departments of Education (Education), Health and Human Services  (HHS), and Justice (Justice), as well as the similar work of the Centers for  Disease Control and Prevention (CDC) on this topic that compared the  four surveys. We evaluated these federal surveys for methodological  rigor, as well as to determine the extent to which the data could be used  to offer a national perspective on bullying in schools. This included  interviews with researchers, as appropriate. We determined that the data  were sufficiently reliable for our purposes. Because the survey data were  collected using generalizable probability samples, this sample is only one  of a large number of samples that might have been selected. Since each  sample could provide different estimates, we have used 95 percent  confidence intervals to show the precision of our results. All percentage  estimates used in this report have 95 percent confidence intervals of  within plus or minus 2.1 percentage points, unless otherwise noted. In  addition to sampling error, surveys are subject to nonsampling error, such  as how respondents interpret questions, including any biases or  tendencies to provide desirable answers or false answers. Although  respondents self-reported being bullied in the surveys, this approach to  measure the prevalence of bullying is viewed as valid and robust,  according to some previous research on bullying. We also reviewed  certain other relevant research as appropriate. Finally, we conducted  interviews with officials at Education and HHS to obtain information about  how different surveys and research define bullying and their efforts to  develop a uniform definition of bullying for research purposes.
To describe the effects of school bullying on victims, we conducted a  literature review. To identify studies on the effects of bullying on victims,  we searched numerous databases—including MEDLINE, Embase,  Education Resources Information Center (ERIC), ProQuest, PsycINFO,  Sociological Abstracts, Social Services Abstracts, and WorldCat. We also  consulted with officials at Education, HHS, and Justice to identify relevant  studies. Because of the extensive available literature, we limited our  review to meta-analyses, which analyze other studies and synthesize  their findings. Additionally, we limited our review to articles published in  peer-reviewed journals. Our literature search covered studies published  from 2001 through July 2011. Subsequently, new meta-analyses were  brought to our attention by agency officials, and we reviewed them to the  extent they were consistent with our search criteria. We identified seven  relevant studies. We reviewed the methodologies of these studies to  ensure that they were sound and determined that they were sufficiently  reliable. The meta-analyses synthesized the findings of studies of school- aged children in a variety of countries, including the United States. They  were not designed to establish causal relationships, nor are the results of  the meta-analyses generalizable.
subsections: section_title: States and Local School District Interviews and Document Review
paragraphs: To describe approaches that selected states and local school districts are  taking, we reviewed relevant state bullying laws and regulations, as well  as guidance and other documents from eight selected states and  conducted interviews with state education officials. We selected eight  states—Arkansas, California, Illinois, Iowa, Massachusetts, New Mexico,  Vermont, and Virginia—based on the following criteria: Each has bullying  laws or regulations, and they vary with respect to bullying definitions and  enumeration of protected classes, geographic variation, and student  enrollment. Further, we selected three of these states (New Mexico,  Vermont, and Virginia), which vary on the characteristics listed above, to  review policies and guidance of local school districts and conduct  interviews with school officials. We selected a total of six school districts,  two in each state—Albuquerque Public Schools, Rio Rancho Public  Schools, Fairfax County Public Schools, Warren County Public Schools,  Windham Southeast Supervisory Union, and Windham Southwest  Supervisory Union. The six school districts were selected from the  National Center for Education Statistics (NCES) Common Core of Data  Public Elementary/Secondary School Universe Survey: School Year  2008–09. The Common Core of Data (CCD) nonfiscal surveys consist of  data submitted annually to NCES by state educational agencies (SEA).  School districts and schools were selected to reflect a range of size, and  urbanicity (urban, suburban, or rural), as well as racial and socioeconomic  diversity. Participation in the National School Lunch Program was used as  a proxy for socioeconomic status. We held interviews with central  administrators, principals, school staff, and parents. In several instances,  multiple individuals attended an interview; for example six parents  attended one parent interview. During the interviews, we asked about  measures taken to prevent bullying, school officials’ response to bullying  behavior, and lessons learned. We analyzed narrative responses  thematically.
section_title: Review of Laws and Discrimination Complaint Processes
paragraphs: To identify legal options that federal and selected state governments have  in place when bullying leads to allegations of discrimination, we reviewed  relevant federal and state anti-discrimination laws and regulations,  selected federal court decisions, as well as guidance and other  documents of the federal government and the eight states selected for  review. We also conducted interviews with federal officials in the  Department of Education’s Office for Civil Rights (OCR) and the  Department of Justice’s Civil Rights Division (CRT), Educational  Opportunities Section, as well as with state officials. State officials were  from various departments, including state educational agencies and  human rights or civil rights commissions or departments. During the  interviews with federal and state officials, we asked about provisions,  discrimination complaint processes, complaint resolutions, and legal  mechanisms available to individuals who are not members of a protected  class.
section_title: Interviews with Federal Officials and Document Review
paragraphs: To address how key federal agencies are coordinating their efforts to  combat school bullying, we interviewed officials from Education, HHS,  and Justice and reviewed relevant documents. These departments were  represented with officials from many component agencies. For Education,  we spoke to officials from the Office of Safe and Healthy Students  (formerly the Office of Safe and Drug-Free Schools), OCR, and Office of  Special Education Programs. For HHS, we spoke to officials from the  Office of the Assistant Secretary for Public Affairs, Office of the Assistant  Secretary for Planning and Evaluation, CDC, Health Resources and  Services Administration (HRSA), National Institutes of Health, and  Substance Abuse and Mental Health Services Administration (SAMHSA).  For Justice, we spoke to officials from the Office of Community Oriented  Policing Services, CRT, and Office of Justice Programs. We focused on  these three departments, given their leadership roles on an  interdepartmental coordinating committee and website  (www.stopbullying.gov, last accessed May 22, 2012) on bullying. We  analyzed coordination of efforts based on key practices that GAO has  previously identified as effective coordination practices.our interviews and analysis, we asked questions about such effective  coordination practices as agreeing on roles and responsibilities or  establishing compatible policies, procedures, or other means to operate  across agency boundaries. We focused on these practices, among those  GAO has identified, based on our professional judgment and relevance   For example, in  for the coordinated federal efforts regarding bullying. Related documents  that we reviewed included plans, meeting agendas, conference materials,  interagency agreements, and educational materials provided to the  public. We also attended the second annual bullying prevention  conference of the interdepartmental coordinating committee. In addition,  we conducted interviews with Education, HHS, and Justice officials about  efforts within their departments to combat bullying. We also reviewed  relevant documents and agency websites.
We conducted this performance audit from April 2011 through May 2012  in accordance with generally accepted government auditing standards.  These standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comparison of the Definition and Measurement of Bullying in Four Nationally Representative Surveys
paragraphs: Table 5 compares how four nationally representative surveys define and  measure bullying.
section_title: Appendix III: Selected Data on National Prevalence of Youth Who Report Being Bullied in School
paragraphs: This appendix provides estimates of the overall prevalence of youth who  reported being bullied by sex and by race/ethnicity. Three of the four  federal surveys that we reviewed present an estimate of overall  prevalence of being bullied, and for these three surveys, the results of  each are shown separately by sex and by race/ethnicity. Unless  otherwise noted, all estimates in these tables have 95 percent confidence  intervals of within plus or minus 2.1 percentage points.
The difference between boys and girls reporting that they were bullied  was statistically significant in one survey (YRBS), with girls reporting a  higher percentage of bullying, but was not statistically significant in the  other two surveys (SCS and HBSC). See table 6.
White youth reported being bullied at higher percentages than African- American youth in two of the three surveys (YRBS and HBSC), while the  other survey found no difference. In two of the three surveys (YRBS and  HBSC), differences between the overall prevalence for white compared  with Hispanic youth and for African-American youth compared with  Hispanic youth were not statistically significant.Hispanics reported a lower percentage of bullying than whites or African- Americans. Asian-American youths reported a lower percentage of  bullying in the one survey (NCVS) that captured information for that  demographic group. See table 7.
section_title: Appendix IV: Selected Data on National Prevalence of Certain Types of Bullying Behaviors
paragraphs: This appendix provides estimates of the prevalence of being bullied for  certain types of bullying behaviors. Three of the four federal surveys that  we reviewed provide estimates of the prevalence of being bullied for  certain types of behaviors, and the results of each are shown separately.  Unless otherwise noted, all estimates in these tables have 95 percent  confidence intervals of within plus or minus 2.1 percentage points.
These surveys also found that boys may be subject to somewhat different  types of bullying than girls. For example, estimates from SCS and HBSC  showed that a higher percentage of boys were bullied physically than  girls, while girls were more commonly bullied than boys with rumors or  social exclusion, which are examples of relational bullying, or bullying  using interpersonal relationships.
section_title: Appendix V: Coordination Practices of Key Interdepartmental Federal Efforts on Bullying
paragraphs: In table 11 are selected coordination practices that we have previously  found help to enhance and sustain coordination across federal agencies,  as well as the ways that key interdepartmental activities against bullying  reflect those coordination practices.
section_title: Appendix VI: Additional Federal Programs and Services Are Available to Combat Bullying
paragraphs: In addition to supporting antibullying activities, the Departments of  Education, HHS, and Justice support more broadly focused services and  programs that may be used for bullying prevention. Generally, bullying  prevention represents one of many allowable activities within these  services and programs. Within each agency, officials identified a range of  services and programs, including technical assistance, funding  opportunities, information sharing, and research, that may include bullying  prevention. For example, HHS provides funding for the Children’s Safety  Network (CSN), a national resource center for the prevention of childhood  injuries and violence. See table 12.
While these programs and services generally support a broader range of  activities than just bullying, several of them have been used to directly  address bullying. For example, several grantees have used Safe  Schools/Healthy Students funding to implement bullying prevention  programs. Also, in fiscal year 2010, 2 of the 11 SEAs awarded Safe and  Supportive Schools grants devoted resources to bullying prevention.  While these services and programs do not always exclusively focus on  bullying prevention, officials across the three federal agencies— Education, HHS, and Justice—agreed that their emphasis on violence  reduction and healthy behaviors can help prevent and reduce bullying  behavior, even if the funds are not used specifically to address bullying.
section_title: Appendix VII: Comments from the Department of Education
section_title: Appendix VIII: Comments from the Department of Health and Human Services
section_title: Appendix IX: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: Bryon Gordon (Assistant Director), Ramona L. Burton (Analyst-in- Charge), Susannah Compton, Alex Galuten, Avani Locke, Ashley McCall,  Sheila McCoy, Jean McSween, Mimi Nguyen, Karen O’Conor, Kate  O’Dea, Michael Pahr, Rebecca Rose, Regina Santucci, Matthew  Saradjian, Ronni Schwartz, and John Townes made significant  contributions to all aspects of this report.