oversight

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)

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 nowickij@gao.gov. Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff 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




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(103492)




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