441 G St. N.W. Washington, DC 20548 June 18, 2019 The Honorable Roy Blunt Chairman The Honorable Patty Murray Ranking Member Subcommittee on Labor, Health and Human Services, Education, and Related Agencies Committee on Appropriations United States Senate The Honorable Rosa DeLauro Chairwoman The Honorable Tom Cole Ranking Member Subcommittee on Labor, Health and Human Services, Education, and Related Agencies Committee on Appropriations House of Representatives K-12 Education: Education Should Take Immediate Action to Address Inaccuracies in Federal Restraint and Seclusion Data As we reported in February 2019, the Department of Education’s (Education) data suggest that the restraint and seclusion of K-12 public school students is rare nationwide, though it disproportionately affects students with disabilities and boys in general. 1 In broad terms, Education defines restraint as restricting a student’s ability to freely move his or her torso, arms, legs, or head, and defines seclusion as involuntarily confining a student alone in a room or area from which the student is physically prevented from leaving. Education’s 2012 resource document on the use of restraint and seclusion states that restraint or seclusion should never be used except when a child’s behavior poses imminent danger of serious physical harm to self or others. 2 Every 2 years, Education collects and publicly reports data from nearly all public school districts and schools as part of its Civil Rights Data Collection (CRDC). 3 Districts self-report and certify 1 GAO, K-12 Education: Federal Data and Resources on Restraint and Seclusion, GAO-19-418T (Washington, D.C.: Feb. 27, 2019). 2 U.S. Department of Education, Restraint and Seclusion: Resource Document (Washington, D.C.: May 15, 2012). According to Education, this resource document is intended to serve as a resource for states, localities, and districts to consider when developing policies and procedures on restraint and seclusion. 3 Except for Puerto Rico, districts in US territories are not required to participate in the CRDC. Similarly, districts are not required to provide information for tribal schools operated by the Department of the Interior’s Bureau of Indian Education. Schools operated by the Department of Defense Education Activity are also not required to participate, according to Education. Page 1 GAO-19-551R Accuracy of Restraint and Seclusion Data the data. Education’s Office for Civil Rights (OCR) uses CRDC data in its enforcement of various federal civil rights laws prohibiting discrimination on the basis of race, color, national origin, sex, and disability. We have work under way on districts’ reporting practices for restraint and seclusion data in response to a provision in the explanatory statement from the House Committee on Appropriations accompanying the Consolidated Appropriations Act of 2018. As part of our data reliability testing for that work, we analyzed the number of districts that left fields pertaining to restraint and seclusion blank, or that reported all zeros for those fields, to determine the prevalence of blanks or zeros in the CRDC at the national, state, and district levels. Our data reliability testing raised questions about the completeness and accuracy of the CRDC restraint and seclusion data. We are therefore issuing this separate report on the issues we have identified to date regarding potentially incomplete data. Because Education is currently collecting and validating restraint and seclusion data for the 2017-18 school year, it is important it take immediate steps to address underreporting before it publishes these data. 4 As part of this work, we reviewed the explanations that Education requires the largest districts to provide if they report zero incidents of restraint and seclusion. We also reviewed documentation on Education’s investigations into underreporting of restraint and seclusion. Additionally, we interviewed federal Education officials and the contractor responsible for maintaining the CRDC and providing routine CRDC technical assistance, as directed by OCR. We conducted this performance audit from March 2019 to June 2019 in accordance with generally accepted government auditing standards. Those 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. Background Education requires nearly every school district in the country to submit data on their schools to Education’s CRDC through an online submission tool. 5 This tool automatically performs edit checks, which flag data errors or potential errors. These edit checks are called “business rules” and occur in real time as districts enter data or after they upload files. The CRDC online tool uses three business rules specifically related to restraint and seclusion data. If the data entered by a district triggers any of these rules, an error message appears with instructions on how to clear the errors. One rule triggers an error message if a district with more than 100,000 students enrolled reports zero incidents of restraint or zero incidents of seclusion. 6 In part, the error message states that, “based on trends in past data, at least one instance of restraint or seclusion occurs within a population greater than 100,000 students.” The online tool then prompts the district to correct the error. If the district finds no error, it is instructed to explain 4 According to the Department of Education, as of May 22, 2019, 94 percent of districts had submitted their 2017-18 school year data. 5 There are two options for data submission. Districts may enter data through data entry screens or through a data file upload. 6 For 2017-18, the threshold was lowered so that the rule applied to districts with more than 50,000 students enrolled. The other two rules are logic tests that compare the number of incidents to the number of students subjected to restraint and seclusion. Page 2 GAO-19-551R Accuracy of Restraint and Seclusion Data why the data it submitted were valid. For districts of any size, if data are missing, districts are required to provide an explanation and submit an action plan for reporting the required data in the next CRDC. 7 Districts must certify that the data they submit are “true and correct,” which is a step completed by the district superintendent or an authorized designee. The CRDC submission tool should not allow a district to certify its submission unless all required data pass the system validation checks or all errors are explained. If districts have not collected the data required for the CRDC—or if the data are unavailable for some other reason—districts are to leave relevant data cells blank. A zero in a data cell should represent an actual count—that is, zero students were restrained or secluded. Education’s contractor, working in conjunction with OCR, conducted the 2015-16 CRDC and is currently coordinating the 2017-18 CRDC. At OCR’s direction, the contractor manages all aspects of the CRDC, including the online submission tool, data quality, and data analysis. The contractor also provides routine technical assistance by responding to requests from districts that need help. In January 2019, Education officials announced an initiative to address inappropriate use of restraint and seclusion. According to Education officials, OCR will conduct data quality reviews of the CRDC in four to five school districts in each of OCR’s 12 regions, and provide technical assistance to schools to ensure districts are collecting and reporting accurate restraint and seclusion data. CRDC Data Do Not Reflect All Incidents of Restraint and Seclusion For the most recent CRDC—school year 2015-16—70 percent of the more than 17,000 school districts in the U.S. reported zero incidents of restraint and zero incidents of seclusion. In 39 states and the District of Columbia, more than half of the school districts reported zero incidents; and in 12 states, 80 percent or more of the districts reported zero incidents. (See fig. 1.) However, our analyses of 2015-16 CRDC data and review of Education documents indicate that CRDC data do not accurately capture all incidents of restraint and seclusion in schools. 7 According to the manual for the public use file for the 2015-16 CRDC, to indicate the reason why a district was able to certify its submission with a blank, Education’s contractor later adds a “reserve code” to the blank field. For example, one code indicates that although the data are missing, the district was able to certify its submission because it submitted an action plan. Other codes indicate that the field is blank because of a system error or because the district was able to skip questions that did not apply to that district. Page 3 GAO-19-551R Accuracy of Restraint and Seclusion Data Figure 1: Percentage of K-12 Public School Districts Reporting Zero Incidents of Restraint and Zero Incidents of Seclusion, by State, School Year 2015-16 Note: At the time of our review, the latest data available were from the 2015-16 school year. Restraint includes both physical restraint and mechanical restraint. Hawaii has only one school district. While according to Education’s business rule districts with more than 100,000 enrolled students are likely to have at least one incident of restraint or seclusion, one-third (10 of 30) of such districts in the country reported zero incidents of restraint and zero incidents of seclusion in the 2015-16 school year. (See table 1.) Page 4 GAO-19-551R Accuracy of Restraint and Seclusion Data Table 1: Incidents of Reported Restraint and Seclusion for K-12 Public School Districts with More than 100,000 Students, School Year 2015-16 Size Number of Number of Incidents of Incidents of District State Rank Schools Students Restraint Seclusion NEW YORK CITY PUBLIC SCHOOLS NY 1 1,637 984,500 0a 0 LOS ANGELES UNIFIED CA 2 785 539,634 184 0 CITY OF CHICAGO SCHOOL DISTRICT IL 3 579 392,303 41 8 DADE FL 4 485 358,179 0 0 CLARK COUNTY SCHOOL DISTRICT NV 5 361 326,238 1,107 0 BROWARD FL 6 348 269,502 0 0 HOUSTON INDEPENDENT SCHOOL DISTRICT TX 7 282 215,989 66 0 HILLSBOROUGH FL 8 289 211,731 24 32 ORANGE FL 9 243 196,987 18 81 PALM BEACH FL 10 234 188,590 94 0 FAIRFAX COUNTY PUBLIC SCHOOLS VA 11 206 185,630 0 0 HAWAII DEPARTMENT OF EDUCATION HI 12 290 182,913 0 0 GWINNETT COUNTY GA 13 135 175,958 427 0 WAKE COUNTY SCHOOLS NC 14 171 159,149 0 0 DALLAS INDEPENDENT SCHOOL DISTRICT TX 15 239 158,941 182 0 MONTGOMERY COUNTY PUBLIC SCHOOLS MD 16 203 156,819 332 120 CHARLOTTE- MECKLENBURG SCHOOLS NC 17 168 149,270 18 0 PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS MD 18 208 142,536 0 0 PHILADELPHIA CITY SCHOOL DISTRICT PA 19 218 133,814 0 0 SAN DIEGO UNIFIED CA 20 226 130,964 203 46 DUVAL FL 21 206 129,003 23 26 CYPRESS-FAIRBANKS ISD TX 22 83 113,912 98 0 SHELBY COUNTY SCHOOLS TN 23 207 113,208 279 107 Page 5 GAO-19-551R Accuracy of Restraint and Seclusion Data Size Number of Number of Incidents of Incidents of District State Rank Schools Students Restraint Seclusion COBB COUNTY GA 24 114 112,708 178 10 BALTIMORE COUNTY PUBLIC SCHOOLS MD 25 169 110,786 388 157 NORTHSIDE INDEPENDENT SCHOOL DISTRICT TX 26 116 104,847 0 0 PINELLAS FL 27 155 102,893 42 33 POLK FL 28 152 101,468 0 0 DEKALB COUNTY GA 29 133 101,355 2 0 JEFFERSON COUNTY KY 30 172 101,018 1,239 118 Source: GAO analysis of 2015-2016 CRDC data. | GAO-19-551R Note: At the time of our review, the latest data available were from the 2015-16 school year. Restraint totals include both physical restraints and mechanical restraints. Districts that reported zero incidents of restraint and zero incidents of seclusion are shaded gray. a New York City’s data on mechanical restraint were missing. The district reported zero incidents of physical restraint. When school districts with more than 100,000 enrolled students reported zero incidents to CRDC, they were to correct the apparent error by modifying the data or confirming that the data were valid. If data were unavailable, they were to leave the fields blank and submit an action plan to explain how they would collect the data in the future. Districts were to report zeros only to indicate that there were no incidents of restraint or seclusion. However, only one of the 10 districts with more than 100,000 enrolled students that reported zero incidents, Hawaii Department of Education, reported to Education that the zeros actually represented zero incidents. The other nine districts reported zero incidents but, according to explanations provided to Education or information districts provided publicly, had incidents they did not report, had incidents they were unable to report, or were not collecting the data. Specifically: • Northside Independent School District in Texas stated that it did not have a way to export its data to the CRDC but could provide the data upon request. Wake County Public School System in North Carolina indicated that it was unable to disaggregate its restraint and seclusion data by school, race, and gender, as required by the CRDC. Further, neither Northside nor Wake submitted an action plan, as required by Education, to indicate how they would collect and report these data in the future. These districts were able to bypass the CRDC system requirement to provide an action plan because they reported zero incidents instead of leaving the fields blank to indicate the data were missing. • New York City, NY; Philadelphia, PA; and Prince George’s County, MD were not collecting data on restraint and seclusion and should have left the fields blank in the CRDC submission tool. These districts did submit action plans for reporting the data in the future, as required for missing data. However, New York City’s action plan only discussed the reasons why it was unable to collect and report data on mechanical restraint. It did not mention collecting the remaining data on physical restraint or seclusion, nor affirm that the zeros were correct. According to Education officials, they did not request that New York City provide a plan for collecting the remaining data. In Page 6 GAO-19-551R Accuracy of Restraint and Seclusion Data commenting on a draft of this report, Education stated prior to the 2017-18 submission that it emailed districts with action plans and requested that the districts review their own action plans. • Fairfax County, VA reported zero incidents of both restraint and seclusion but, according to Education officials, due to a system error, the CRDC business rule was not triggered. Fairfax did not provide an action plan explaining how it would meet reporting requirements in the next collection, according to Education officials. Fairfax County Public Schools have since publicly stated that they did, in fact, have incidents, and in school year 2017-18, had more than 1,600 incidents. • Restraint and seclusion data for the remaining three districts, all in Florida, were submitted by the state, according to Education officials. 8 The state reported zero incidents for all three districts. While Florida submitted an action plan for some CRDC data elements, the plan did not address the reports of zero incidents of restraint and seclusion. According to Education officials, a submission system error occurred allowing Florida to certify without including the restraint and seclusion data elements in their action plan. Education did not ask Florida to submit a revised plan. For these nine districts, the CRDC’s 2015-16 publicly available data file remains uncorrected. Specifically, the CRDC still indicates that the districts had zero restraints and zero seclusions, rather than indicating that the districts did not report data. While it is difficult to know the full extent of underreporting of restraint and seclusion in the CRDC, the fact that only one of the 10 largest districts that reported zeros actually affirmed that it had no incidents calls into question the data showing zero incidents for 70 percent of the nation’s public school districts. For the current collection, Education is applying the business rule for reporting zero incidents of restraint and seclusion to more districts, but it is unclear if this change will significantly improve reporting. Education officials said that they were concerned that the 2015-16 collection rule for districts with more than 100,000 enrolled students, which included 30 districts or 13 percent of total public school enrollment, did not adequately help them detect reporting problems. Therefore, in the 2017-18 data collection, they are applying the rule to districts with more than 50,000 enrolled students. Education officials were unable to provide us with any analysis used to establish either the 100,000 or 50,000-student threshold for the CRDC business rule. We determined that, had this change been in effect for the 2015-16 CRDC, Education’s business rule would have applied to just 65 more districts, or to 21 percent of total public school enrollment. However, the rule still does not apply to the overwhelming majority of school districts that report zero incidents of restraint or seclusion, leaving the meaning of zeros unclear for smaller districts attended by about 80 percent of public schoolchildren. Documents from Education that we reviewed indicated that the misreporting of zeros occurred in smaller districts as well. These erroneous reports were detected either by the media or in the course of larger investigations by Education into restraint and seclusion, rather than by any systemic review of the CRDC data. Specifically: 8 Florida submits and certifies data on behalf of all school districts. Page 7 GAO-19-551R Accuracy of Restraint and Seclusion Data • After Education’s Office of Inspector General received a congressional inquiry in 2018, Education followed up with three smaller districts in Iowa that reported zero incidents of restraint and seclusion, according to documents provided by Education. • Documentation on Education’s website showed that Education found underreporting in previous CRDC collections. Specifically, from 2014 to 2017, Education completed investigations on the inappropriate and disproportionate use of restraint and seclusion and found underreporting in four districts in Texas, Utah, Virginia, and California. Two of these districts reported zero incidents of restraint and zero incidents of seclusion to the CRDC, while Education’s investigations revealed that incidents had occurred. A third district reported zero incidents for students without disabilities, stating that no data were maintained for those students, although the district had reported incidents in earlier collection periods. • CRDC technical data notes accompanying the results of all four CRDC surveys since 2009 (when Education began collecting data on restraint and seclusion) cautioned that districts might have reported zero incidents, instead of indicating that the information was not available. Further, the 2015-16 notes said that districts with incomplete data may have reported zero incidents, and that it is not possible to determine where this may have occurred. Collecting accurate civil rights data is key to OCR’s mission to ensure equal access to education and to promote educational excellence throughout the nation through vigorous enforcement of civil rights laws that protect students from discrimination on the basis of race, color, national origin, sex, or disability. Federal Standards for Internal Control state that agency management should use quality information to achieve the entity’s objectives. These standards also note that such data should be reasonably free from error and bias and faithfully represent what they purport to represent, and that agency management should evaluate sources of data for reliability. 9 Absent reliable and accurate data, neither Education nor the public can know the prevalence of restraint and seclusion in public schools. Instructions for Reporting Zero Incidents versus Reporting Unavailable Data Are Difficult to Find Education created a CRDC data tip sheet clarifying when school districts should report zero incidents of restraint and seclusion and how to indicate that data are not available. However, the tip sheet may be difficult for districts to find because it is not on the data entry screen itself, nor in the instructions for submitting data files. Instead, the tip sheet is located on a CRDC technical assistance website. 10 Further, we were only able to find the tip sheet after searching page by 9 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G (Washington, D.C.: September 2014). 10 The technical assistance website can be found at https://crdc.grads360.org/#program. There is a link to a resources page with the data tip sheet on it within the submission system, but the link does not appear on the data entry screen. In commenting on this report, Education stated that the instructions are available in a new user starter kit. We found that the data tip sheet is referenced but the instructions on the sheet are not included in the kit. Page 8 GAO-19-551R Accuracy of Restraint and Seclusion Data page on the website because the search function was difficult for us to find. 11 According to Education officials, within the CRDC data tool, there is a link to a list of resources. The tip sheet is on that list of resources, but its instructions are not visible to the person entering the data. So that external parties can help an agency achieve its objectives and address related risks, Federal Standards for Internal Control state that agencies should communicate information relating to activities that impact the internal control system. Agency management should periodically evaluate its methods of communication and consider a variety of factors in selecting an appropriate method of communication. One such factor to consider is availability. These standards state that information should be readily available to the audience when needed. 12 Absent easily accessible information about how to report accurate data, school districts may continue to erroneously report zero incidents when data are in fact not available, misleading the public and policymakers about the prevalence of restraint and seclusion in public schools. Conclusions Our analyses raise questions about whether the confirmed instances of misreported zeros to the CRDC are indicative of a more pervasive pattern of underreporting of restraint and seclusion in U.S. public schools. Although districts, not Education officials, are required to certify their data as “true and correct,” Education has repeatedly published restraint and seclusion data in its CRDC without always correcting known reporting errors. Data left uncorrected could further undermine the public’s confidence in these data and limit the utility of a dataset intended to assist with federal civil rights monitoring, enforcement, and oversight. We believe the 2017-18 data collection is at risk for similar reporting issues. A fundamental first step toward improving the quality of the restraint and seclusion data is to assure that when school districts report zero incidents it truly means there were no incidents, and to accurately distinguish districts with no incidents from districts that do not track or collect the data. Given that Education is currently collecting restraint and seclusion data for the 2017- 18 school year, it is important that Education immediately take steps to address underreporting. Failure to do so will result in data that continues to provide an incomplete picture of the prevalence of restraint and seclusion, leaving OCR unable to reliably use a key tool in carrying out its enforcement of civil rights laws. Recommendations GAO is making four recommendations to the Department of Education’s Office for Civil Rights: The Assistant Secretary for the Office for Civil Rights should immediately remind and clarify for all school districts that they are to only report zero incidents of restraint and seclusion when there are none and that they are to leave cells blank to indicate when data are not collected or incomplete. The Assistant Secretary should also ensure that instructions for when to record zeros and when to leave cells blank are prominently displayed and readily available to districts as they complete the CRDC. (Recommendation 1) 11 On the website homepage, we found links to five main resource pages with information on preparing and submitting CRDC data. In a separate text box near the bottom of the homepage, we found links to six additional webpages. One of those webpages on “Data Tips” contained the clarification. The clarification did not appear on the data entry screen itself or in the instructions for submitting files. 12 GAO-14-704G. Page 9 GAO-19-551R Accuracy of Restraint and Seclusion Data The Assistant Secretary for the Office for Civil Rights should, as part of the 2017-18 CRDC quality assurance process, follow up with school districts that have already submitted reports of zero incidents of restraint or seclusion to obtain assurances that zero incidents means no incidents or ask the districts to submit corrected data. (Recommendation 2) The Assistant Secretary for the Office for Civil Rights should monitor compliance with its action plan requirement, and ensure plans are submitted and address all missing data. (Recommendation 3) The Assistant Secretary for the Office for Civil Rights should prominently disclose for past collections the potential problems with using restraint and seclusion data given the known misreporting issues, such as those detailed in this report involving 9 of the nation’s large public school districts. (Recommendation 4) Agency Comments and Our Evaluation We provided a draft of this report to the Department of Education for review and comment. Their comments are reproduced in enclosure I. Education agreed with 3 of our 4 recommendations, but provided the caveats that implementation of the recommendations was contingent on the availability of resources, and that the 2017-18 collection was too far along to clarify instructions. However these data have not been published and Education allows districts a significant period of time in which to correct errors. Education disagreed with our fourth recommendation that they correct known errors in previous reporting. Education also provided technical comments, which we incorporated as appropriate. With respect to our first recommendation, Education agreed to remind districts going forward that they are only to report zero incidents of restraint and seclusion when there are none and to ensure that instructions for when to record zeros and when to leave cells blank are prominently displayed, but said that this reminder is too late for the 2017-18 data collection because 94 percent of districts had already submitted their data. Dependent on available funds and staff resources, Education agreed to feature the instructions more prominently on the website and consider other changes, such as targeted communications and changes in the placement of the instructions for the 2019-20 collection. We are encouraged that Education recognizes the seriousness of this issue and the data quality issues it has allowed to persist when districts inappropriately and inaccurately report zero incidents of restraint and seclusion. While we appreciate that most districts have already submitted data for 2017-18, Education allows districts a significant period of time in which to correct errors. We believe that reminding districts about when to record zeros, even retroactively, could prompt districts to address any errors before Education publishes these data sometime in 2020, thereby improving the integrity of its CRDC data. We urge Education to remind districts for the current 2017-18 collection about its requirements to only report zero incidents of restraint and seclusion when there are none and when to leave cells blank for the current collection and subsequent collections. With respect to our second recommendation, Education said it agreed with the overall intent of following up with districts that have already submitted reports of zero incidents to obtain assurances that zero incidents means no incidents. Education stated that once the 2017-18 collection ends, it will review data quality findings, including the reporting of zero incidents, to determine appropriate outreach to states and districts. Education stated depending on available resources, it would also continue to explore opportunities to follow up on submissions of reports of zero incidents. We continue to urge Education to make follow-up a priority before Education Page 10 GAO-19-551R Accuracy of Restraint and Seclusion Data makes these data publicly available so that the public, researchers, and federal policymakers that use these data know if it can be relied upon. With respect to the third recommendation, Education agreed to monitor compliance with its action plan requirement. Education stated that it had recently taken steps to more closely scrutinize action plans for the 2017-18 data collection, including directly communicating with districts about their action plans and scheduling calls with any district that requests similar or repetitious action plans over the course of two or more collections. Regarding the fourth recommendation that Education correct known errors in previous CRDC data collections, Education disagreed, saying it did not believe it feasible to continually update the published data files for closed collections due to the need to finalize consistent data for the federal agencies, policymakers, researchers, educators, school officials, and others who use the CRDC data. Instead, Education stated that for the 2015-16 data collection, it would amend the data notes to ensure the public is aware of potential changes. We appreciate Education’s concern for its resources. However, as Education pointed out, these data are widely used by policymakers, researchers, educators, school officials, and others. Because there is a compelling reason to believe that there is some misreporting of restraint and seclusion data, and because Federal Standards for Internal Control provide for agencies to use quality information to achieve the entity’s objectives, it is important that, at a minimum, Education be clear and transparent about the limitations of the restraint and seclusion data it makes publicly available. We have therefore revised our recommendation to state that for past collections Education should prominently disclose the potential problems with using restraint and seclusion data given the known misreporting issues, such as those detailed in this report involving 9 of the nation’s largest public school districts. ____________ We are sending copies of this report to the Secretary of Education, appropriate congressional committees, and other interested parties. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov. If you and your staff have any questions, please contact Jacqueline M. Nowicki at (617) 788- 0580 or firstname.lastname@example.org. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report were Sherri Doughty (Assistant Director), Lara Laufer (Analyst-in-Charge), James Bennett, Holly Dye, Maria Gadel, Morgan Jones, Christy Ley, Jean McSween, John Mingus, Kristin Petroff, and James Rebbe. Also contributing were Deborah Bland and Sheila McCoy. Jacqueline M. Nowicki Director, Education, Workforce, and Income Security Page 11 GAO-19-551R Accuracy of Restraint and Seclusion Data Enclosure 1: Comments from the Department of Education Page 12 GAO-19-551R Accuracy of Restraint and Seclusion Data Page 13 GAO-19-551R Accuracy of Restraint and Seclusion Data Page 14 GAO-19-551R Accuracy of Restraint and Seclusion Data (103492) Page 15 GAO-19-551R Accuracy of Restraint and Seclusion Data This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. 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K-12 Education: Education Should Take Immediate Action to Address Inaccuracies in Federal Restraint and Seclusion Data [Reissued with revisions on July 11, 2019.]
Published by the Government Accountability Office on 2019-07-11.
Below is a raw (and likely hideous) rendition of the original report. (PDF)