Michigan Special Education Advisory Committee

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Requested Feedback on Draft State Board of Education Integrating Mental Health in Schools Policy

November 9, 2009

In October 2009, the Michigan Special Education Advisory Committee received a specific request from Mrs. Elizabeth Bauer to provide feedback on the Draft State Board of Education Integrating Mental Health in Schools Policy. Copies of the proposed mental health in schools policy were provided electronically for review in preparation for the November 4 meeting of the committee. On November 4, Lauren Kazee, LMSW, Mental Health Consultant from the Office of School Improvement Coordinated School Health and Safety Programs presented an overview of the proposed policy and answered questions with regard to its meaning and intent.

The Special Education Advisory Committee (SEAC) is Michigan’s Individuals with Disabilities Education Improvement Act (IDEA) mandated State Advisory Panel to the State Board of Education and the Michigan Department of Education (MDE). The members of the SEAC represent a broad diversity of stakeholders – administrators, providers, advocates and consumers -- concerned with the education of all children, including students with disabilities. The SEAC has as two of its mandated duties to comment publicly on any rules or regulations proposed by the State regarding the education of children with disabilities and to advise the State of unmet needs within the state in the education of children with disabilities.

The SEAC is in a unique position in its advisory role to the State Board of Education and the Michigan Department of Education. The SEAC has engaged in extensive learning, dialogue and discussion with regard to matters that impact the education of all children, including those with disabilities. The SEAC welcomes this invitation to publicly comment on the Draft State Board of Education Integrating Mental Health in Schools Policy and wishes to thank the State Board of Education for this generous opportunity to give feedback. The SEAC recognizes the extensive work that the development of this document represents and appreciates both the willingness and openness of the Office of School Improvement Coordinated School Health and Safety Programs to engage us in this conversation.

The SEAC firmly believes that concern for the mental health of all students is of the utmost importance and for students with disabilities in

Draft Draft Draft Draft Draft Draft Draft - 1 - Draft Draft Draft Draft Draft Draft Draft particular. Attention to their social-emotional needs often sets the opportunity for school success. Further, the SEAC sees that the development of proactive policies to support the mental health of all students will help all students to succeed. However, in considering on this draft, we do not believe as presented, this document will support that effort.

The draft policy as presented to the SEAC does not appear to be a policy. The document appears to be more a conversation about the critical topic of mental health and its impact on students. It appears to present groundwork for the potential need for a policy, however, no specific policy statement is presented. To understand the State Board of Education’s policy, it needs to be clearly stated as such at the beginning of the document. As presented, the information reads more like guidelines for schools to follow in establishing policy on mental health in schools.

Our understanding is one of the major outcomes from this federal Office of Safe and Drug Free Schools grant is to enhance and develop collaborative efforts between schools and community health services. We believe that collaboration between the schools and community health services is essential and applaud the desire to establish joint letters of understanding. In reviewing the document as presented, we were struck by the responsibility assigned to schools for addressing mental health concerns in school. We believe that the roles and commitments of the Michigan Department of Education and Michigan Department of Community Health must be clear prior to the State Board of Education adopting policy that obligates the schools to provide mental health services.

We wonder about the allocation of district resources as articulated in the document. For instance, the document suggests that district school social workers and school psychologists would be used to provide mental health in school services to all children. Under our current system, the school social workers and school psychologists who most often provide this type of services are special education staff. The students who receive these services are students with IEPs. Expanding their availability may tax these very limited services. We wonder if the intent is to allocate special education services – and funds – towards general education. Additionally, we wonder about the absence of the school counselor in this document. They, too, can provide essential front line services to students with mental health needs. More clarity with regard to the role of school counselors is necessary.

We urge the State Board of Education to consider revisiting this Draft State Board of Education Integrating Mental Health in Schools Policy and refocusing the effort. Specifically, what is the desired outcome from such a

Draft Draft Draft Draft Draft Draft Draft - 2 - Draft Draft Draft Draft Draft Draft Draft policy? For whom is this policy intended? Is it to address the mental health needs of all students or is the intent to alert all to the needs of those students who are most at risk?

Further, we urge the State Board of Education to assure in any future work that all key stakeholders be involved in the development of such documents. We wonder what this document – and a more clearly articulated policy statement – might be if a broader array of voices had been involved, including key school voices such as general and special educators, school counselors, principals, curriculum directors, parents and students. Given that the Special Education Advisory Committee is a diverse group of stakeholders representing a wide variety of perspectives and positions, we clearly understand the resulting clarity that emerges when diverse voices come together to clarify issues and develop solutions. We urge the State Board of Education to assure diversity of perspectives are represented in the documents they consider.

With regard to the Draft State Board of Education Integrating Mental Health in Schools Policy, we offer the following feedback on specific aspects of the document:

 With regard to the document being a policy, what is the specific policy? This appears to be a document with information, resources and links, but lacking in specific policy.  The document presents extensive rationale why concern about the mental health of students is important, but we wonder what the outcome expectation is from the adoption of this ‘policy’  If the intent of this document is to alert people of the problem or need, then is a policy the best means?  If this is a policy, who will be held accountable for the policy and what is the nature of that accountability?  As written, the document is highly prescriptive as to what districts must do.  Policies are often perceived as mandates. If this is a guidance document, that lessens the concern about mandates.  In some places it appears that the document and by inference this policy, allocates special education services to general education. Our understanding was the intent was not to suggest that those services be redirected to general education, but rather, to suggest that more general education services need to be added. We do not believe that as written, that intent is clear nor can special education services to students with IEPS be reallocated to serve students in general education.  In reading the document, we wondered what the critical need is for mental health in schools. The ideas presented sound like a smorgasbord

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of strategies that could be used to address issues. What is the specific focus or intent of this policy statement? If the intent is to coordinate mental health services in school to prevent issues, how might we focus the resources of education, mental health and human services (juvenile justice) to prevent the dire outcomes that come from failing to address mental health issues?  In many ways, the document seems to be a recipe for districts to follow in developing mental health in school procedures either within a school or school district. Is this a guidance document or guidelines as opposed to policy?  Might this document be enhanced if the specific policy was clearly articulated followed with a directive from the SBE for a group to set up procedures to support districts in the implementation of such a policy  Integrating the indicators for mentally healthy schools into the school improvement checklist is a great idea to infuse this thinking into the work of schools. We wonder if that is sufficient to reach all schools as many use the NCA accreditation process with a different set of indicators. If this approach is used, aligning the indicators for mental health with both school improvement and NCA seems appropriate.  The importance of the coordination of services is stated throughout the document. Within the school community, school psychologists and school social workers are identified as key mental health providers in the schools. We wonder if this approach to looking at available school personnel is comprehensive and recognizes the array of professionals available in many schools. For instance, where were school counselors in the development and review of this document?  With regard to the coordination of services, we wonder what the expectation is with regard to this. Specifically, who is responsible for the coordination of services? How are districts to operationalize this –or – is this a policy recommendation that districts determine this locally?  Assuming the intent of this document was to establish a policy, we wonder about the joint nature of this policy, given that it impacts not only the Michigan Department of Education, but also the Michigan Department of Community Health and Michigan Department of Human Services. It seems like establishing a policy as a function of signed letters of agreement/memos of understanding or better yet, establishing a joint policy might be a stronger approach.  Further, we wonder if memos of understandings between these agencies might be an essential first step prior to the establishment of policy.  In looking at the districts in which the policies were developed, we understand that all had existing school based health centers. There are 70 such centers in the State of Michigan representing (percent of total districts or buildings possible) of all schools. We wonder if this unique experience might have tipped the results that emerged.

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 In looking at the list of those invited to review the document, we wonder why some essential players are missing?  The issue of mental health in our schools and the impact on student learning is one of which all need to be more aware. The information in this ‘policy’ could be used as a means to alert the broader community of the problem, to generate community support and create a context to take action. We wonder if reworking this information to articulate the need or problem and from there, to develop white papers that help generate community support might be a preferred strategy.

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