OCR What Superintendents Need to Know - AASA · U.S. Dep’t of Educ., Office for Civil Rights, Helping to Ensure Equal Access to Education: Report to the President and Secretary

February 26, 2015

OCR—What Superintendents Need to Know

John W. Borkowski, Partner Joel D. Buckman, Associate

Source: National Archives

www.hoganlovells.com

Introduction

True or False:

• According to the U.S. Department of Education’s

Civil Rights Data Collection released in 2014 (for

2011–12), although African American students

represent 15% of students, they comprise 35% of

students suspended once, 44% of those suspended

more than once, and 36% of those expelled.

2


Introduction

True or False:

• If the U.S. Department of Education Office for Civil

Rights (“OCR”) initiates an investigation against

your district, it is limited to the allegations of the

complaint.

3


Introduction

True or False:

• From 2009 to 2012, OCR received more disability

discrimination complaints than any other category.

4


Introduction

Choose the best answer:

• From 2009–12, OCR launched __________

compliance reviews (proactive, broad-scale,

system-wide investigations of strategic

significance).

A. 50 C. 150

B. 100 D. 200

5


Introduction

True or False:

• OCR’s regulations prohibit only intentional

discrimination.

6


Overview

I. What is OCR?

II. Recent OCR Guidance

III. OCR Enforcement Priorities

IV. Examples of Recent Enforcement Actions

V. Strategies You Can Take Home

7

8

I. What is OCR?


I. What is OCR?

• U.S. Department of Education Office for Civil Rights

– 558 full-time equivalents in D.C. headquarters and 12

enforcement offices scattered throughout the country.

• Created in 1966, two years after this watershed

moment.

9

http://www.youtube.com/watch?list=UUwRQxHVCyShQyky_HzHdZEQ&v=YXIaFLPjYgU&feature=player_detailpage


I. What is OCR?

• OCR’s jurisdiction has expanded over time.

10

Source: 2009-12 Report U.S. Dep’t of Educ., Office for Civil Rights, Helping to Ensure Equal Access to Education: Report to the President and Secretary of Education,

Under Section 203(b)(1) of the Department of Education Organization Act, FY 2009 –12, Washington, D.C., 2012 (2009 – “2012 Report”)


I. What is OCR?

• OCR enforces federal discrimination prohibitions on

the basis of:

– Race, color, national origin or English language

proficiency;

– sex;

– disability; and

– age.

11


I. What is OCR?

• How does OCR enforce its mandate?

12

Source: 401(K)2013, Flickr under creative commons license.

https://www.flickr.com/photos/68751915@N05/6355318323/sizes/m/in/photostream/

https://creativecommons.org/licenses/by-sa/2.0/legalcode


I. What is OCR?

• More complete answer:

– Technical assistance (e.g., Dear Colleague Letters);

– Civil Rights Data Collection (“CRDC”);

– Complaint process; and

– Compliance reviews.

13


I. What is OCR?

• The CRDC

– The CRDC is a mandatory, biennial survey through which

OCR collects civil rights data directly from school districts.

– Historically, not all districts were required to participate;

that changed in 2014 when OCR obtained approval to

require every public school district in the country to

respond to the 2013 –2014 CRDC.

• The 2013-14 CRDC will contain many of the same data elements

as the 2011-12 CRDC, previewed by the next slides.

14


I. What is OCR?

• The CRDC—presents detailed civil rights data to

the public for research and enforcement purposes.

• Latest data (2011–12) released March 2014.

• OCR analyzes the data to identify concerns at the

nationwide and local level.

15


I. What is OCR?

• For example, nationwide:

– According to the latest data, African American students

comprise 15% of students, but 35% of students

suspended once, 44% of those suspended more than

once, and 36% of those expelled.

16


I. What is OCR?

• Complaints

– Anyone may file a complaint, and generally complaints must be

filed within 180 days after the alleged discrimination.

– OCR considers every complaint it receives and opens an investigation when necessary.

– Complaints tend to be focused on specific groups of students rather than discrimination that is acute, regional, or national in scope.

– OCR acts as “neutral fact-finder.”

17


I. What is OCR?

• 2009–12 OCR Complaint data:

18

Source: 2009-12 Report


I. What is OCR?

• 2009–12 OCR Complaint data:

19



I. What is OCR?

• In 2013, OCR received 9,950 complaints (a 27%

increase from FY 2012).

20


I. What is OCR?

• Compliance Reviews

– Proactive, broad-scale, system-wide investigations of strategic

significance.

– School districts selected based on CRDC, media, tips from parents, and other sources of information.

– From 2009–12, OCR conducted 100 compliance reviews nationwide.

– Designed to “affect significant change at the target institution” and to “provide widely applicable solutions.”

21


I. What is OCR?

22



I. What is OCR?

• What to expect when OCR initiates an investigation

or compliance review:

– Extensive information requests;

– An expanding set of issues (OCR investigates “holistically,

attempting to root out multiple manifestations of

discrimination”); and

– Negotiated settlement with required corrective actions.

23

24




Title VI

25



• Title VI prohibits discrimination on the basis of race,

color or national origin in programs and activities

operated by recipients of federal financial assistance.

– If any part of a district receives federal financial assistance,

Title VI applies to all activities and programs of the district.

– Title VI also protects English-language learners.

– Title VI itself prohibits only intentional discrimination (private

right of action); OCR’s regulations also prohibit discriminatory

impact.

26


II. Recent OCR Guidance: Title VI

Since 2010, OCR has issued nine Title VI Dear Colleague Letters applicable in the K-12 context addressing:

1. Consideration of race to avoid racial isolation in schools (three times, 2011, 2013 in response to Fisher, 2014, in response to Schuette);

2. Enrollment regardless of immigration/citizenship status (twice, 2011, updated 2014);

3. Discriminatory discipline;

4. Access to educational resources;

5. Race-based bullying and harassment; and

6. Retaliation.

27



• January 8, 2014 – discriminatory discipline

– Illegal to discriminate on basis of race in discipline in

classroom behavior management, referrals to office, and

imposition of sanctions.

– “Discrimination” means both intentional discrimination and

disparate impact.

28




– The following may raise an inference of discrimination:

• Disciplining similarly situated students of different races differently

for the same offense;

• Selective enforcement of facially neutral prohibitions; and

• School official uttering a racial slur when disciplining a student.

29




– When presented with a discipline policy that results in a

disparate impact, OCR will ask:

• Is the discipline policy “necessary” to meet an important

educational goal?

• If so, are there comparably effective alternative practices that

would meet the important educational goal with less of an adverse

impact or is the school’s justification pretext for discrimination?

30




– “[I]t is incumbent upon a school to take effective steps to eliminate all racial discrimination in initial discipline referrals.”

• Referrals involve “subjective exercise of unguided discretion.”

• Race-based referrals result in violations regardless of the underlying behavior and ultimate sanction.

• OCR expects schools to have a system in place to monitor referrals and to train referring authorities on nondiscrimination.

31




– In an investigation, OCR reviews policies and practices.

• If a school does not collect accurate and complete data necessary

to evaluate compliance, OCR may require a district to collect data

(including, for example, data on referrals).

– Impossible to contract away liability—OCR can and will

hold districts accountable for SROs, security guards, or

other contractors.

32




– Remedies for violations can include:

• Correcting student records;

• Providing compensatory, comparable academic services;

• Revising discipline policies;

• Requiring Positive Behavior Support with exclusion as a last

resort;

• Designating a school official as a discipline supervisor;

• Collecting data and community engagement.

33



• October 1, 2014 – Access to educational resources (37 pages)

– DCL a response to “[c]hronic and widespread racial

disparities in access to rigorous courses, academic programs, and extracurricular activities; stable workforces of effective teachers, leaders, and support staff; safe and appropriate school buildings and facilities; and modern technology and high-quality instructional materials . . . .”

– The “allocation of school resources . . . Too often exacerbates rather than remedies achievement and opportunity gaps.”

34



• October 1, 2014 – Access to educational resources

– “[D]isparities in the opportunity for students to benefit from

strong teachers, leaders, and support staff — ones who,

generally speaking, are qualified, experienced and

accomplished — exist among and within districts, as well

as among classes in the same school.”

– “[O]lder buildings with inadequate or poorly maintained

heating, ventilation, and air conditioning (HVAC) systems

still are more likely to house schools attended mostly by

students of color . . . .”

35




– OCR will examine many factors including:

• Evidence of quality, quantity and availability of critical educational

resources to identify and disparities among schools serving similarly situated students.

– Similarity judged by size, grade, and level.

– OCR typically does not consider Title I funds in a resource equity analysis.

• Justification for any disparities (e.g., thematic magnet; school, based budgeting).

• Available alternatives capable of serving equally well any legitimate justification with less of a disparity.

36




– OCR will examine many factors, including (cont.):

• Scope and severity of resource disparities;

• District’s process for allocating resources;

• Whether schools take proactive, concrete, and effective steps to address the root causes of such disparities;

• Funding levels, relevant but not conclusive (question is equal educational opportunities).

37




– In the school leadership context, for example, OCR will

examine:

• Stability of principals and other school leaders (absenteeism,

substitutes, turnover);

• Level of experience;

• Credentials;

• Certification; and

• Appropriate training and professional development and other relevant characteristics.

38




– “Sound educational judgments made by State and local

education officials, as well as budgetary constraints, may lead school districts to prioritize certain resources or the needs of certain schools, but such decisions cannot reflect unlawful race discrimination, in purpose or effect.”

– “OCR’s legal determinations will necessarily be context-specific and will require a holistic analysis of both quantitative and qualitative factual findings, including an evaluation of evidence presented that the quality of education students receive in a particular school or district is equitable despite apparent resource inequities in some areas.”

39




– OCR encourages self-assessment and has provided a link

to materials that may help:

www.ed.gov/ocr/resourcecomparability.html.

40

http://www.ed.gov/ocr/resourcecomparability.html




– OCR has articulated the following principles for remedies:

• Remedies must effectively end the discrimination and eliminate its

effects;

• Remedies must be implemented in a timeframe that is prompt and

appropriate given the nature and difficulty of the corrective action

at issue;

• OCR encourages schools to work cooperatively with stakeholders.

41




– Selected potential remedies:

• Developing additional programs for schools where those programs

were previously lacking.

• Simplifying process for school personnel to raise outside funds;

• Encouraging enrollment in advanced courses;

• Reassigning effective principals to schools with fewer effective teachers;

• “OCR will work with school districts to identify remedies that do not conflict with staffing policies or vested teacher rights.”

42



Title IX

43


II. Recent OCR Guidance: Title IX

• Title IX prohibits discrimination on the basis of sex in all education programs and activities operated by recipients of federal financial assistance.

– If any part of a school district receives federal financial

assistance, Title IX applies to all activities and programs of the district.

– Title IX itself prohibits only intentional discrimination, including sexual harassment, and provides a private right of action; OCR’s regulations also prohibit discriminatory impact.

– From 2009–12, OCR received 4,138 Title IX complaints and launched 37 large-scale compliance reviews and directed inquiries.

44



45

Since 2010, OCR has issued four Title IX Dear Colleague Letters in the K-12 context addressing:

1. Sexual violence;

2. Pregnant and parenting students;

3. Sex-based bullying and harassment; and

4. Retaliation.



46

Since 2010, OCR has also issued other guidance,

including:

– Title IX and Single-Sex Elementary and Secondary

Classes and Extracurricular Activities;

– Questions and Answers on Sexual Violence.



• April 4, 2011 – sexual violence

– Sexual harassment and sexual violence are a form of sex

discrimination prohibited by Title IX.

– Peer-to-peer sexual harassment/violence creates a hostile environment if it interferes with or limits a student’s ability to participate in or benefit from the school’s program.

– If school officials know or reasonably should know about harassment that creates a hostile environment (including peer-to-peer), Title IX requires the school to take immediate action to eliminate the harassment, prevent its recurrence, and address its effects.

47



• April 4, 2011 – sexual violence (cont.)

– Districts must appoint a Title IX coordinator, publish notice of nondiscrimination, and train employees.

– Schools must adopt/update polices and procedures to conform to detailed provisions in DCL, including:

• Prohibiting mediation in cases of sexual assault;

• Requiring a preponderance of the evidence standard; and

• Requiring prompt investigation and remedies.

48



• April 4, 2011 – sexual violence (cont.)

– Districts must investigate all instances of sexual violence,

including off-campus complaints and should inform and

obtain consent from parents when complainant <18.

– If consent is withheld, schools must take reasonable steps

to investigate consistent with request.

49



• June 25, 2013 – DCL pregnant and parenting students

– Illegal to exclude pregnant students from participating in any educational program, including extracurricular activities.

– Permissible to implement special instructional programs or classes, provided they are comparable and voluntary.

– Pregnant students must be treated the same as similarly situated students (e.g., special services and medical certifications).

– “A school must excuse a student’s absences because of pregnancy or childbirth for as long as the student’s doctor deems the absences medically necessary.”

50



Section 504 and

Title II

51


II. Recent OCR Guidance: Section 504

and Title II

• Section 504 of the Rehabilitation Act of 1973

prohibits discrimination based on disability in

programs and activities operated by recipients of

federal funds (same framework as Titles VI and IX).

• Title II of the Americans with Disabilities Act of 1990

(ADA) prohibits discrimination based on disability by

public entities

52



and Title II

• A school district must provide a qualified student

with a disability an opportunity to benefit from the

school district’s program equal to that of students

without disabilities.

53



and Title II

54

Since 2010, OCR has issued five Title IX Dear Colleague Letters in the K-12 context addressing:

1. Accessibility to educational technology;

2. Definition of “disability” after 2008 amendments to ADA;

3. Access to extracurricular activities and sports;

4. FAQs on effective communication for students with hearing, vision or speech disabilities;

5. Disability-based bullying and harassment; and

6. Retaliation.



and Title II

55

October 21, 2014 – bullying of students with disabilities

– In response to “ever-increasing number of complaints

concerning the bullying of students with disabilities.”

• Bullying of a student with a disability on any basis can similarly result

in a denial of FAPE under Section 504 that must be remedied;

• School’s investigation of alleged disability-based harassment should

include determination whether student’s receipt of services affected; if

so, school must remedy those effects.

• Even absent a hostile environment, school must address FAPE-

related concerns.



and Title II

56

October 21, 2014 – bullying of students with disabilities

– School must evaluate FAPE when student bullied on any

basis, especially when there are “changes in academic performance or behavior” such as decline in grades, emotional outbursts.

– “When a student who receives IDEA FAPE services or Section 504 FAPE services has experienced bullying resulting in a disability-based harassment violation, however, there is a strong likelihood that the student was denied FAPE.”



and Title II

57

Jan. 25, 2013 – extracurricular activities

– Must make reasonable modifications and provide aids and

services necessary to ensure equal opportunity, unless doing

so would be a fundamental alteration.

• For example, bona fide safety standards are permissible, but districts

must consider whether modifications/aids/services for individuals.

– Permissible to require a level of skill or ability in order for a

student to participate in a selective or competitive program or

activity, so long as the selection or competition criteria are not

discriminatory.



and Title II

58

Jan. 25, 2013 – extracurricular activities

– When the interests and abilities of some students with

disabilities cannot be as fully and effectively met by the

school district’s existing extracurricular athletic program,

the school district should create additional opportunities

for those students with disabilities.

– Alternative athletic opportunities “should be supported

equally” with a school district’s other athletic activities.



Guidance with Application

Across Numerous Areas

59


II. Recent OCR Guidance: Cross-Cutting

Guidance

• Since 2010, OCR has issued four cross-cutting

Dear Colleague Letters in the K-12 context

addressing:

– Race-, sex-, and disability-based bullying that rises to the

level of harassment;

– Retaliation;

60



Guidance

• October 26, 2010 – bullying / harassment

61



Guidance

• October 26, 2010 – bullying / harassment (cont.)

– Harassing conduct can take many forms and does not have to involve intent to harm.

• Is it so severe, pervasive, or persistent so as to interfere with or

limit a student’s ability to benefit from a school program?

– A district must investigate all complaints of harassment and incidents about which it knew or reasonably should have known.

• Including peer-to-peer and off-campus.

62



Guidance

• October 26, 2010 – bullying / harassment (cont.)

– Requires “prompt and effective steps” reasonably

calculated to:

• end the harassment;

• eliminate any hostile environment and its effects; and

• prevent the harassment from recurring.

63



Guidance

• April 24, 2013 – retaliation

– Unlawful to retaliate against any individual for the purpose of interfering with any right or privilege secured by any law OCR enforces.

– Protection includes any complainant or participant and prohibits any threats, intimidation, demoting, disciplining, excluding or any other adverse action.

– OCR will seek appropriate remedies, which may include training, better communications strategies, and monetary relief.

64


II. Recent OCR Guidance: Miscellaneous

• OCR has issued a few miscellaneous guidance

documents:

– “Fact Sheet: Implementing CDC’s Ebola Guidance for

Schools while Protecting the Civil Rights of Students and

Others”

– Dear Colleague Letter re. Juvenile Justice System (Dec.

8, 2014)

– Dear Colleague Letter re. Charter Schools (May 14, 2014)

65

66

III. OCR Enforcement

Priorities



• OCR’s Fiscal Year 2015 Budget Request stated

“sufficient funding is needed to support the following

initiatives and activities:”

– Promote Teacher and Resource Equity;

– Reduce Discriminatory Discipline;

– Reduce Racial Isolation and Increase Diversity;

– Increase Knowledge of Title IX and Disability

Coordinators; and

– Other Select Areas of Civil Rights Enforcement

• Access to college- and career-preparatory courses; protection of

ELL and students with disabilities; reducing discriminatory bullying.

67



Title VI

68

www.hoganlovells.com 69



III. OCR Enforcement Priorities: Title VI

Title VI Enforcement Priorities

– College/career readiness: assuring equal access to resources,

curricula and opportunities (2009–12, 15 investigations)*

– Eliminating more frequent and more severe discipline for racial minorities (2009–12, 20 investigations)*

– Ensuring equal opportunity for English Language Learners (2009–12, 21 investigations)

– Nondiscrimination in enrollment (immigrant status) (2009–12, “OCR has addressed allegations”)

*Indicates called out by OCR in most recent Budget Request to Congress

70



Title IX

71




III. OCR Enforcement Priorities: Title IX

Title IX Enforcement Priorities

– Sexual violence (2009–12, 11 investigations, including

some at K-12 level)

– Athletics (2009–12, 20 investigations)

– College/career readiness: assuring equal access to

resources, curricula and opportunities (2009–12, at least 3

investigations)

73



Section 504 and

Title II

74




III. OCR Enforcement Priorities: Section 504 &

Title II

Section 504 and Title II Enforcement Priorities

– Free Appropriate Public Education (“FAPE”) (2009–12, 15

investigations)

– Discipline

– Accessibility of Technology

– Physical accessibility of programs, services and facilities

76



Title VI, Title IX,

Section 504 and

Title II

77


III. OCR Enforcement Priorities: Cross-Cutting

• Harassment

– OCR received over 1,600 complaints involving racial or

national origin harassment, more than 1,100 complaints

involving sexual or gender-based harassment, and near

1,500 complaints of disability harassment.

– During the same period, OCR launched 12 proactive

investigations to address harassment.

78

79

IV. Examples of Recent

Enforcement Actions


IV. Examples of Recent Enforcement Actions:

Christina School District (DE)

• On March 19, 2010, OCR initiated a compliance

review to investigate whether the school district

subjected African American students to harsher and

more frequent discipline than white students.

• OCR examined the district’s written policies and

procedures, reviewed data from 27 schools and

interviewed stakeholders.

80




• OCR found the district violated Title VI due to:

– Examples of harsher punishments for African American

students when they engaged in the same misconduct as white students (with the same or worse disciplinary history).

– Analysis of first-time referrals found that African American students were 2X as likely as white students to receive in-school-suspension and 3X as likely to receive out-of-school suspensions for violations of similar severity.

– District policy allowed decision-makers to use their discretion to exceed specified penalties for certain violations, which disproportionately penalized African American students.

81




• District and OCR entered into resolution agreement,

which required the district to, among other things:

– Hire a consultant to review district policies and conduct a

longitudinal study of discipline data;

– Implement Positive Behavior Support;

– Revise disciplinary policies and submit them to OCR for review

and comment;

– Require administrators to consider non-exclusionary discipline;

82




• District and OCR entered into resolution agreement, which required the district to, among other things:

– Hire/designate a discipline supervisor;

– Record 13 data items for every disciplinary action taken (including on students considered for but who do not receive discipline); and

– Use the above data to “implement an educational dashboard portal that provides . . . discipline data disaggregated by race, ethnicity, sex, disability, ELL status to building administrators and parents.”

83



Anoka-Hennepin School District (MN)

• November 2, 2010, DOJ received complaint of peer-

to-peer harassment because student did not act and

dress in ways conforming to traditional gender

stereotypes.

• DOJ and OCR together opened an investigation,

interviewing 60 individuals and reviewing over 7,000

pages of documents.

84




• Investigation found:

– “[M]ultiple students were harassed on the basis of sex in

District middle and high schools and that harassment included both verbal and physical harassment.”

• While investigation was pending, a private law suit was filed.

• After “extensive negotiation” the parties entered into a consent decree (settlement).

85




• Under the settlement, District agreed to, among other things: – Pay the students $270,000;

– Review and improve applicable policies;

– Hire a Title IX and Equity Coordinator;

– Train faculty, staff, and students;

– Hire a mental health consultant;

– Survey students once per year;

– Provide compliance reports to DOJ and OCR each trimester; and

– Hire a consultant to determine additional steps needed to comply with consent decree.

86



Manchester Public School District (NH)

• OCR initiated compliance review: Did the District discriminate against black and Hispanic students by establishing policies and procedures that excluded them from college and career ready programs and courses, including the District’s Advanced Placement (AP) courses, honors, and other higher level learning opportunities?

• OCR interviewed stakeholders and reviewed data from two school years together with policies and procedures relating to enrollment in courses and programs.

– Found, e.g., Hispanic students 11% of district but 0% of AP

course enrollment.

87



Manchester Public School District (NH)

• On April 2, 2014, District agreed to, among other things:

– Conduct analysis to identify cause of disparities;

– Act to eliminate root cause, including possibly increasing

number of opportunities, eliminating GPA and class rank

penalties for attempting and withdrawing;

– Increase support for enrolled students; and

– Staff training targeted at identification and selection of students

for participation in higher learning opportunities.

88



Memphis City School District (TN)

• OCR investigation included a meeting with

administrators, a week-long site visit, and data

analysis (from each school in the District).

• Before OCR completed its investigation, the District

offered to settle and OCR agreed.

89



Memphis City School District (TN)

• The resolution agreement required the district to, among other things:

– Provide written notice to parents at the time of registration

of the district’s obligation to evaluate students to determine eligibility under Section 504 and Title II;

– Revise/update policies with respect to proper identification, evaluation, and placement of students with disabilities for OCR approval; and

– Implement a procedure to monitor implementation of new/revised policy.

90

91

V. Strategies to Take

Home


Strategies to Take Home: Proactive

• As an administrator member, you can protect your district by informing yourself, asking questions, and setting policy:

– Review your district’s CRDC information every two years

and understand any disparities.

– Audit policies, practices, and procedures. Items might include: • Inventory of district’s policies, including when last updated;

• CRDC data, including as to any disparities;

• Civil rights complaints and compliance; and

• Other (see handout).

92


Strategies to Take Home: Proactive

• Proactive strategies (cont.)

– Create an anonymous tip-line for complaints and

concerns.

– Require training, data collection, and strategies to address

areas of concern.

– Do well by doing good: OCR respects districts that try to

address inequities proactively.

93


Strategies to Take Home: If Faced with an

Investigation

• Preserve documents and be prepared for large information requests.

• Conduct an internal investigation to identify the root problem and the district’s best position (it often becomes a negotiation).

• Take proactive, good faith steps while the investigation is pending.

• Consider offering a resolution agreement to cut short an investigation.

94

95

Conclusion


Finishing Where We Started

True or False:



2011-12), although African American students




96



True or False:



2011-12), although African American students




TRUE

97



True or False:

• If OCR initiates an investigation against your district,

its is limited to the allegations of the complaint.

98



True or False:

• If OCR initiates an investigation against your district,

they are limited to the allegations of the complaint.

FALSE

99



True or False:



100



True or False:



TRUE

101






system-wide investigations of issues of strategic

significance).

A. 50 C. 150

B. 100 D. 200

102






system-wide investigations of issues of strategic

significance).

B. 100

103



True or False:


discrimination.

104



True or False:


discrimination.

FALSE

105


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Documents

OCR What Superintendents Need to Know - AASA · U.S. Dep’t of Educ., Office for Civil Rights, Helping to Ensure Equal Access to Education: Report to the President and Secretary