Bullying and Disability Harassment: Understanding the Overlap

1. Bullying and Disability HarassmentArlington Special Education Advisory Committee Meeting February 25, 2014 - Content Draft - Presented by Jack Toner

2. Learning Objective U.S. DOE OCR definitions of “Bullying” and “Disability Harassment” overlap: OVERLAP Many incidents falling within the Bullying definition will not meet the Disability Harassment definition. Some incidents meeting the Disability Harassment definition will not fall within the Bullying definition.

3. Learning Objective Stated Another Way: Disability Harassment is not a subset of Bullying

4. Acronyms Arlington Public Schools - APS FAPE - Free Appropriate Public Education IDEA - Individuals with Disabilities Education Act IEP - Individualized Education Program OCR - Office for Civil Rights OSERS – Office of Special Education and Rehabilitative Services PIP – Policy Implementation Procedures SBP – School Board Policy U.S. DOE – United States Department of Education VA DOE – Virginia Department of Education

5. U.S. DOE Definitions OVERLAP “Bullying is characterized by aggression used within a relationship where the aggressor(s) has more real or perceived power than the target, and the aggression is repeated, or has the potential to be repeated, over time.” “Disability harassment under Section 504 and Title II is intimidation or abusive behavior toward a student based on disability that creates a hostile environment by interfering with or denying a student's participation in or receipt of benefits, services, or opportunities in the institution's program.” Disability Harassment does not have to include intent to harm,  be directed at a specific target, or involve repeated incidents. 

6. VA DOE Definitions Bullying is defined in Code of Virginia § 22.1-276.01.  "Bullying" means any aggressive and unwanted behavior that is intended to harm, intimidate, or humiliate the victim; involves a real or perceived power imbalance between the aggressor or aggressors and victim; and is repeated over time or causes severe emotional trauma. "Bullying" includes cyber bullying. "Bullying" does not include ordinary teasing, horseplay, argument, or peer conflict. Virginia statutes do not define “Disability Harassment,” or other forms of discriminatory harassment. Neither the State of Virginia, not its public schools, are legally authorized to define “Disability Harassment” more narrowly than the U.S. DOE OCR guidiance.

7. VA DOE Model Policy “Model Policy to Address Bullying in Virginia Public Schools” Adopts definition of “Bullying” in Code of Virginia § 22.1-276.01. Reinforces that bullying is characterized by the following: • Intentionally aggressive behavior designed to inflict harm; • Repetitive behavior planned into the future; • Interpersonal relationship marked by an imbalance of power  Defines “Harassment” to mean “a course of conduct which annoys, threatens, intimidates, alarms, or puts a person in fear of his/her safety. Harassment is unwanted, unwelcomed and uninvited behavior that demeans, threatens or offends the victim and results in a hostile environment for the victim and bystanders.” Remember: U.S. DOE specifically states that Disability Harassment does not have to include intent to harm, be directed at a specific target, or involve repeated incidents.

8. APS Policy SBP 25-1.17 Student Safety - Bullying/Harassment Prevention Definition of Bullying/Harassment “Student bullying or harassment is the repeated infliction or attempted infliction of injury, discomfort, or humiliation on a student by one or more students. It is a pattern of aggressive, intentional or hostile behavior that occurs repeatedly and over time. Bullying/harassment typically involves an imbalance of power or strength.” Compare with U.S. DOE guidance: “Disability harassment under Section 504 and Title II is intimidation or abusive behavior toward a student based on disability that creates a hostile environment by interfering with or denying a student's participation in or receipt of benefits, services, or opportunities in the institution's program.” Jack’s Opinion: APS’ joint definition of Bullying/Harassment is inconsistent with U.S. DOE guidance and U.S. Civil Rights court decisions. It reinforces a false concept that Disability Harassment does not occur unless there is an intent to harm, be directed at a specific target, and repeated incidents.

9. The Facts • Bullying Statistics • In the United States, nearly 1 in 3 students (27.8%) report being bullied during the school year. Source: U.S. Department of Education, National Center for Educational Statistics (2013). Student reports of bullying and cyber-bullying: Results from the 2011 school crime supplement to the national crime victimization survey. • In the 2010 Youth Risk Behavior Survey, 20% of all Arlington students who participated reported being bullied at school during the previous year. 26% of 6th Grade students, 25% of 8th Grade students, 18% of 10th Grade students, and 12% of 12th grade students. • 81.9% of students who identify as LGBTQ were bullied in the last year based on their sexual orientation. Source: Kosciw, J. G., Greytak, E. A., Bartkiewicz, M. J., Boesen, M. J., & Palmer, N. A. GLSEN, (2011). The 2011 national school climate survey. Retrieved from website: http://glsen.org/sites/default/files/2011 National School Climate Survey Full Report.pdf.

10. The Facts • Effects of Bullying • Students who experience bullying are at increased risk for depression, anxiety, sleep difficulties, and poor school adjustment. Source: Center for Disease Control, National Center for Injury Prevention and Control (2012). Understanding bullying. • Students who experience bullying are twice as likely as non-bullied peers to experience negative health effects such as headaches and stomachaches. Source: Gini, G., & Pozzoli, T. (2013). Bullied children and psychosomatic problems: A meta-analysis. Pediatrics; 132:4 720-729. • Research links bullying at any age with worse mental and physical health, more depressive symptoms and a lower sense of self-worth. • Source: Bogart, L. M., Elliott, M.N., Klein, D. J., Tortolero, S.R., Mrug, S., Peskin, M.F., Davies, S.L., & Schink, E.T. (2014). Peer Victimization in Fifth Grade and Health in Tenth Grade. Pediatrics, published online. Retrieved from http://pediatrics.aappublications.org/content/early/2014/02/11/peds.2013-3510.full.pdf+html.

11. The Facts • Effects of Bullying (cont.) • Research suggests that long-term bullying has a severe impact on a child's overall health, and that its negative effects can accumulate and get worse with time. Source: Bogart, L. M., Elliott, M.N., Klein, D. J., Tortolero, S.R., Mrug, S., Peskin, M.F., Davies, S.L., & Schink, E.T. (2014). Peer Victimization in Fifth Grade and Health in Tenth Grade. Pediatrics, published online. Retrieved from http://pediatrics.aappublications.org/content/early/2014/02/11/peds.2013-3510.full.pdf+html. • Youth victimized by their peers were 2.4 times more likely to report suicidal ideation and 3.3 times more likely to report a suicide attempt than youth who reported not being bullied. Source: Espelage, D. L., & Holt, M. K. (2013). Suicidal ideation and school bullying experiences after controlling for depression and delinquency. Journal of Adolescent Health, 53. • In 2001, a U.S. Secret Service and U.S. Department of Education study of 37 school shooting incidents from 1974-2000 found that 71% (29/41) of the shooters felt bullied, threatened, attacked or persecuted.

12. The Facts • Statistics about Bullying of Students with Disabilities • Only 10 studies have been conducted in the United States on the connection between bullying and developmental disabilities, but all of these studies found that children with disabilities were two to three times more likely to be bullied than their nondisabled peers. Source: C. Marshall, E. Kendall, M. Banks & R. Gover (Eds.)(2009), Disabilities: Insights from across fields and around the world (Vol. 1-3). Westport, CT: Praeger Perspectives. • In a study of 8-17-year-olds, researchers found that children with Autism Spectrum Disorder were more than three times as likely to be bullied as their peers.Source: Twyman, K. A., Saylor, C. F., Saia, D., Macias, M. M., Taylor, L. A., & Spratt, E. (2010). Bullying and ostracism experiences in children with special health care needs. Journal of Developmental Behavioral Pediatrics, 31, 1-8.

13. The Facts • Statistics about Bullying of Students with Disabilities (cont) • When reporting bullying youth in special education were told not to tattle almost twice as often as youth not in special education. Source: Davis, S., & Nixon, C. (2010). The youth voice research project: Victimization and strategies. • Students have reported that the most harmful things teachers can do are in response to bullying incidents are: tell the student to solve the problem themselves, tell the targets of bullying that the bullying wouldn’t happen if they acted differently, ignored what was going on, or tell the bullying target to stop tattling. Davis, S., & Nixon, C. (2010). • As reported by students who have been bullied, the self-actions that had some of the most negative impacts (telling the person to stop/how I feel, walking away, pretending it doesn’t bother me) are often used by youth and often recommended to youth. Davis, S., & Nixon, C. (2010).

14. U.S. DOE OCR Guidance Dear Colleague Letter: Prohibited Disability Harassment (July 25, 2000): “Schools, colleges, universities, and other educational institutions have a responsibility to ensure equal educational opportunities for all students, including students with disabilities.” “This responsibility is based on Section 504 of the Rehabilitation Act of 1973 (Section 504) and Title II of the Americans with Disabilities Act of 1990 (Title II), which are enforced by OCR.” “Section 504 covers all schools, school districts, and colleges and universities receiving federal funds. Title II covers all state and local entities, including school districts and public institutions of higher education, whether or not they receive federal funds.”

15. U.S. DOE OCR Guidance Dear Colleague Letter: Prohibited Disability Harassment (July 25, 2000): “Disability harassment under Section 504 and Title II is intimidation or abusive behavior toward a student based on disability that creates a hostile environment by interfering with or denying a student's participation in or receipt of benefits, services, or opportunities in the institution's program.” “Harassing conduct may take many forms, including verbal acts and name-calling, as well as nonverbal behavior, such as graphic and written statements, or conduct that is physically threatening, harmful, or humiliating.” “When harassing conduct is sufficiently severe, persistent, or pervasive that it creates a hostile environment, it can violate a student's rights under the Section 504 and Title II regulations.”

16. U.S. DOE OCR Guidance Dear Colleague Letter: Prohibited Disability Harassment (July 25, 2000): Examples of harassment that could create a hostile environment: “Several students continually remark out loud to other students during class that a student with dyslexia is ‘retarded’ or ‘deaf and dumb’ and does not belong in the class; as a result, the harassed student has difficulty doing work in class and her grades decline. “Students continually taunt or belittle a student with mental retardation by mocking and intimidating him so he does not participate in class.” “When disability harassment limits or denies a student's ability to participate in or benefit from an educational institution's programs or activities, the institution must respond effectively.” “Where the institution learns that disability harassment may have occurred, the institution must investigate the incident(s) promptly and respond appropriately.”

17. U.S. DOE OCR Guidance Dear Colleague Letter: Prohibited Disability Harassment (July 25, 2000): “Schools, school districts, colleges, and universities have a legal responsibility to prevent and respond to disability harassment.” “As a fundamental step, educational institutions must develop and disseminate an official policy statement prohibiting discrimination based on disability and must establish grievance procedures that can be used to address disability harassment.” “A clear policy serves a preventive purpose by notifying students and staff that disability harassment is unacceptable, violates federal law, and will result in disciplinary action.” “The responsibility to respond to disability harassment, when it does occur, includes taking prompt and effective action to end the harassment and prevent it from recurring and, where appropriate, remedying the effects on the student who was harassed.”

18. U.S. DOE OCR Guidance Dear Colleague Letter: Prohibited Disability Harassment (July 25, 2000): “Disability harassment is a form of discrimination prohibited by Section 504 and Title II.” “States and school districts also have a responsibility under Section 504, Title II, and the Individuals with Disabilities Education Act (IDEA), which is enforced by OSERS, to ensure that a free appropriate public education (FAPE) is made available to eligible students with disabilities.” “Disability harassment may result in a denial of FAPE under these statutes.”

19. U.S. DOE OCR Guidance Dear Colleague Letter: Harassment and Bullying (October 26, 2010): “[S]ome student misconduct that falls under a school’s anti‐bullying policy also may trigger responsibilities under one or more of the federal antidiscrimination laws enforced by the Department’s Office for Civil Rights (OCR).” “[B]y limiting its response to a specific application of its anti‐bullying disciplinary policy, a school may fail to properly consider whether the student misconduct also results in discriminatory harassment.” “Harassing conduct may take many forms, including verbal acts and name‐calling; graphic and written statements, which may include use of cell phones or the Internet; or other conduct that may be physically threatening, harmful, or humiliating.” “A school is responsible for addressing harassment incidents about which it knows or reasonably should have known.”

20. U.S. DOE OCR Guidance Dear Colleague Letter: Harassment and Bullying (October 26, 2010): “[S]chools should have well‐publicized policies prohibiting harassment and procedures for reporting and resolving complaints that will alert the school to incidents of harassment.” “When responding to harassment, a school must take immediate and appropriate action to investigate or otherwise determine what occurred.” “If an investigation reveals that discriminatory harassment has occurred, a school must take prompt and effective steps reasonably calculated to end the harassment, eliminate any hostile environment and its effects, and prevent the harassment from recurring.” “These duties are a school’s responsibility even if the misconduct also is covered by an anti‐bullying policy, and regardless of whether a student has complained, asked the school to take action, or identified the harassment as a form of discrimination.”

21. U.S. DOE OCR Guidance Dear Colleague Letter: Harassment and Bullying (October 26, 2010): Example of disability harassment under Section 504 and Title II: Several classmates repeatedly called a student with a learning disability “stupid,” “idiot,” and “retard” while in school and on the school bus. On one occasion, these students tackled him, hit him with a school binder, and threw his personal items into the garbage. The student complained to his teachers and guidance counselor that he was continually being taunted and teased. School officials offered him counseling services and a psychiatric evaluation, but did not discipline the offending students. As a result, the harassment continued. The student, who had been performing well academically, became angry, frustrated, and depressed, and often refused to go to school to avoid the harassment.

22. U.S. DOE OCR Guidance Dear Colleague Letter: Harassment and Bullying (October 26, 2010): In this example, the school failed to recognize the misconduct as disability harassment under Section 504 and Title II. The harassing conduct included behavior based on the student’s disability, and limited the student’s ability to benefit fully from the school’s education program (e.g., absenteeism). In failing to investigate and remedy the misconduct, the school did not comply with its obligations under Section 504 and Title II. Counseling may be a helpful component of a remedy for harassment. In this example, however, since the school failed to recognize the behavior as disability harassment, the school did not adopt a comprehensive approach to eliminating the hostile environment. Such steps should have at least included disciplinary action against the harassers, consultation with the district’s Section 504/Title II coordinator to ensure a comprehensive and effective response, special training for staff on recognizing and effectively responding to harassment of students with disabilities, and monitoring to ensure that the harassment did not resume.

23. U.S. DOE OSERS Guidance Dear Colleague Letter: Bullying of Students with Disabilities (August 20, 2013): “Bullying is characterized by aggression used within a relationship where the aggressor(s) has more real or perceived power than the target, and the aggression is repeated, or has the potential to be repeated, over time.” “Bullying can involve overt physical behavior or verbal, emotional, or social behaviors (e.g., excluding someone from social activities, making threats, withdrawing attention, destroying someone’s reputation) and can range from blatant aggression to far more subtle and covert behaviors.” “Cyberbullying, or bullying through electronic technology (e.g., cell phones, computers, online/social media), can include offensive text messages or e-mails, rumors or embarrassing photos posted on social networking sites, or fake online profiles.”

24. U.S. DOE OSERS Guidance Dear Colleague Letter: Bullying of Students with Disabilities (August 20, 2013): “Whether or not the bullying is related to the student’s disability, any bullying of a student with a disability that results in the student not receiving meaningful educational benefit constitutes a denial of FAPE under the IDEA that must be remedied.” “[P]arents have the right to request an IEP Team meeting at any time, and public agencies generally must grant a parental request for an IEP Team meeting where a student’s needs may have changed as a result of bullying.”

25. APS Policy SBP 25-1.17 Student Safety - Bullying/Harassment Prevention “Complaint procedure. All students will be informed of their right to protection against bullying behaviors and the right to file a complaint if they believe they have been the victim of bullying behavior. School administrators are responsible for investigating each complaint, determining if the complaint is legitimate, and taking appropriate corrective action. Any student may initiate a complaint by talking to school staff. All staff will be informed of a student’s right to initiate a complaint. Administrators will maintain a written record of reported incidents of bullying, including dates, times, places, witness names, and other information about the incident.” “Assistance for alleged bullies and victims. Victims of bullying/harassment will be offered counseling services, as appropriate.” Compare with U.S. DOE guidance: Schools must have a clear policy against Disability Harassment, establish grievance procedures, and offering counseling services to a student targeted by disability harassment may not be a sufficient remedy.

26. APS Policy Excerpts from APS Handbook 2013-2014 BULLYING “Bullying or harassment of students, including bullying based on an actual or perceived characteristic, such as race; color; religion; ancestry; national origin; gender; sexual orientation; gender identity and expression; or mental, physical or sensory disability is strictly prohibited and will not be tolerated.” “Bullying is defined as ‘any aggressive and unwanted behavior that is intended to harm, intimidate, or humiliate the victim; involves a real or perceived power imbalance between the aggressor or aggressors and victim; and is repeated over time or causes severe emotional trauma.’” “Students who believe that they have been the victim of bullying have the right to file a complaint by talking to school staff.” “Students who are victims of bullying/harassment will be offered counseling services, as appropriate.” - Compare with U.S. DOE guidance.

27. APS Policy Bully Incident Form Does not require the person who is investigating the incident to conduct any inquiry into whether Disability Harassment, or another form of discriminatory harassment, might have occurred. - Compare with U.S. DOE guidance. • APS reported to the VA DOE that there were only 37 Bullying and 20 Harassment incidents that resulted in student disciplinary action throughout all of its schools during the 2010-2011 school year. • APS reported to the VA DOE that there were only 42 Bullying and 18 Harassment incidents that resulted in student disciplinary action throughout all of its schools during the 2009-2010 school year. • Source: VA DOE Discipline, Crime, and Violence Annual Reports

28. Bullying is a Public Health Challenge and School Safe Concern, • Disability Harassment is a Civil Rights Issue • Students who experience bullying are at increased risk for depression, anxiety, sleep difficulties, and poor school adjustment. • Long-term bullying has a severe impact on a child's overall health, and its negative effects can accumulate and get worse with time. • Students children with disabilities are 2x to 3x more likely to be bullied than their nondisabled peers. • Disability harassment under Section 504 and Title II is intimidation or abusive behavior toward a student based on disability that creates a hostile environment.

29. APS Response is “In Need of Improvement” • APS reported to VA DOE that the prevalence of Bullying and Harassment (Non-Sexual) in all of APS schools was an annual average of less than 2 incidents per school per year between 2006-2011. • In the 2007 APS Community Satisfaction Survey, 18% • of students admitted to being bullied. • In the 2009 APS Community Satisfaction Survey, 14% • of students admitted to being bullied. • In the 2012 APS Community Satisfaction Survey, 16% • of students admitted to being bullied. • In the 2010 Youth Risk Behavior Survey, 20% of Arlington students reported being bullied at school during the previous year. • 26% of 6th Grade students 25% of 8th Grade students • 18% of 10th Grade students 12% of 12th Grade students

30. Students who have been bullied report that two of the most psychologically harmful things teachers can do are in response • to bullying incidents are: • Ignoring what was going on • telling the bullying target to stop tattling • APS teachers frequently do not intervene and when they observe peer conflict and tell children who ask for help stop tattling. • Students who have been bullied report that the self-actions that had some of the most negative impacts: • - asking the bully to stop • - telling the bully how you • - pretending the bullying doesn’t bother you • APS teachers frequently criticize children who ask for help without first trying to use strategies (e.g., de-bug system) the conflicts themselves.

31. Peer Mediation is a “Bully Get Out of Jail Free Card” • Too often the APS approach is to give the two children involved in a conflict the option of choosing to go to a School Counselor for “Peer Mediation” or an Assistant Principal for possible “Disciplinary Action.” • Children are taught at the beginning of the school year that the “Disciplinary Action” route is punitive in nature: • - Their parent will be called • - They could be suspended

32. The APS approach of giving children involved in a conflict an option of either • Peer Mediation or Disciplinary Action makes children causes with disabilities, • especially those with self-advocacy deficits, to feel unfairly pressured into • agreeing to Peer Mediation: • - If the target of bullying, who is often socially isolated, • doesn’t agree to Peer Mediation, the friends of the • bully become upset because the target intentionally • chose to get their friend into trouble. • - Children with anxiety issues are fearful that if they • choose the Disciplinary Action route they might end • up being punished, too. • - Children who are repeatedly targeted by bullies often • feel humiliated and ashamed, and they don’t want • their parent’s to know they were victimized again, so • they choose Peer Mediation to keep their parents • from knowing about the incident.

33. In Peer Mediation, the target sits across from the bully and the school counselor encourages the target to: • Recount what happened from your perspective • Explain how the experience made you feel • Listen to the bully’s version of events • Say whether or not you accept the • bully’s version of events • Agree to a resolution • Shake hands with the bully • Many times the target feels more victimized by the Peer Mediation than by the bullying incident and will agree to any proposed “resolution” just to get it over with. • Worse of all, if the target agreed to Peer Mediation, APS treats the incident as peer conflict, so parents might never know about it • and it is never reported as Bullying or Disability Harassment.

34. When I said my child with disabilities was bullied and harassed due to his disability, APS administers have told me (paraphrased): No Bullying or Harassment occurred, because there was no intent to harm, your child accepted the other student’s version of events that it was an accident. No Bullying or Harassment occurred, because there was no real or perceived imbalance of power, the two boys are the same age and your child is taller and weighs a lot more. No Bullying or Harassment occurred, because there was no real or perceived imbalance of power, your child is socio-economically advantaged and the other child is socio-economically disadvantaged. No Bullying or Harassment occurred, because there been no repeated behavior by the same child (though the same cliche is responsible for all the incidents and may be targeting your child).

35. APS staff should be trained to implement the US DOE guidance: • Disability harassment under Section 504 and Title II is intimidation or abusive behavior toward a student based on disability that creates a hostile environment by limiting or denying a student's participation in benefits, services, or opportunities of the school program. • Harassing conduct may take many forms, including verbal acts and name-calling, as well as nonverbal behavior, such as graphic and written statements, or conduct that is physically threatening, harmful, or humiliating. • Disability Harassment does not have to include intent to harm,  • be directed at a specific target, or involve repeated incidents. 

36. Jack’s Opinion: • Examples: A hostile environment exist if your child was harassed due to a disability and as a result of that harassment: • - Experiences lower self-esteem and earns lower grades • - Experiences frequent headaches or stomach aches • - Experiences depression or suicidal ideation • - Refuses to eat lunch in the school cafeteria • - Is afraid of enrolling a High School P.E. course during the school year

37. Recommendationsfor Parents Understand that Bullying and Disability Harassment are complex issues. - The bullies often struggle with social, emotional, or mental health issues - About 15% of bullies are bully-victims - Zero tolerance policies are not effective - Expressing anger or aggression about your child being bullied is likely to make school administrators defensive and your message will not be heard If you believe your child was bullied, promptly report it in writing to the school principal, request an investigation, and request a copy of the investigation’s findings. If you believe your child was harassed due to a disability, promptly report it in writing to the school principal, cc’d the Superintendent, request an investigation, and request a copy of the investigation’s findings. .

38. Recommendationsfor Parents • If you believe your child cannot effectively self-advocate, or will not benefit from Peer Mediation, advise the school principal that you do not want your child to participate in any peer mediation without your consent on a case-by-case basis. • Request notification via telephone anytime your child misses instructional time as a result of spending time with a school administrator, counselor, or nurse. • If you believe your child was a target of Bullying or Disability Harassment, request that the IEP process be used as a means to remediate past occurrences and prevent future. • Examples: IEP Annual Goals for developing self-advocacy skills in • response to bullying, increased adult supervision in P.E. classes, • counseling services, and Positive Behavior Intervention Supports. .

39. Recommendationsfor Parents • If you know who is bullying your child, consider asking that child’s parents to help resolve the situation in a non-confrontational manner. Often APS parents are not aware of incidents that occurred at school and are mortified when they learn of their children’s misbehavior. • If you believe your child is being bullied, or there is a bullying problem at your child’s school, go to one of the school PTA’s monthly meetings and public ask for help with the situation. APS school principals are usually prioritize PTA requests. • Ask the school PTA to request that the school’s in-session training • prioritize bullying prevention. • Ask the school PTA to request that the school’s Improvement Plan • address Bullying and Disability Harassment in the school climate metrics. • Ask the school PTA to have the school adopt a Code of Student Conduct • that is based on Principles of Human Dignity, and emphasizes respect, • tolerance, and diversity. .

40. Recommendationsfor School Administrators Review APS policies, procedures, publications, and staff training on Bullying and Discriminatory Harassment for compliance with VA DOE and U.S. DOE guidance. Target completion date May 30, 2014. Issue APS written procedures for how schools should respond to incidents that could involve Bullying or Discriminatory Harassment. These procedures should implement VA DOE and U.S. DOE guidance, and include standard forms for reporting and investigating complaints of Bullying or Discriminatory Harassment. Target completion date July 30, 2014. Ensure APS staff training for the 2014-15 school year covers U.S. DOE guidance on Discriminatory Harassment, especially the different definitions of Bullying and Discriminatory Harassment. Target completion date August 15, 2014. Issue APS policy requiring school principals to forward to the Office of Pupil Services a copy of the “Investigation Form” from each complaint of Bullying or Discriminatory Harassment. Target completion date August 29, 2014. .

41. Recommendationsfor School Administrators • Draft revisions APS SBPs and SBP PIPs, as appropriate, to clarify the different definitions of Bullying and Discriminatory Harassment and fully implement VA DOE and U.S. DOE guidance. Forward those draft documents to the School Board with the recommendation to approve them. Target completion date October 31, 2014. • Issue APS technical assistance guidance on the IEP process can be used to support children with disabilities who are experiencing bullying or discriminatory harassment at school. This guidance should include: • - Templates of Positive Behavior Intervention Supports to teach children • what to do in response to bullying or harassment behaviors. • - Examples of specially designed instruction, based on peer-reviewed • research, for improve self-advocacy skills. • Target completion date January 23, 2015. .

42. Recommendationsfor School Administrators • Ensure APS Student Handbook for the 2015-16 school year contains language to: • Define Bullying and Discriminatory Harassment, • Inform students of their right to report incidents • of Bullying or Discriminatory Harassment, and • Clearly explains the procedures which will be • followed to investigate and resolve reported incidents. • Target completion date March 20, 2015. • Modify APS Internet site to add a Bullying Prevention webpage that will summarize and link to APS’ new policies and procedures on Bullying and Discriminatory Harassment, and permit complaints to be electronically submitted. Target completion date August 28, 2015. .

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