Eden Central School District – Mental Health Training Component of the New York SAVE Act (S9-21-28) (full text)

4 DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY REPORT OF EXAMINATION | S9-21-28 Eden Central School District Mental Health Training Component of the New York SAVE Act JUNE 2022

Contents Report Highlights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Mental Health Training. . . . . . . . . . . . . . . . . . . . . . . . . . . 2 What Is the Mental Health Component of the SAVE Act Training for All Staff?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 District Training Did Not Include All Recommended Mental Health Components . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 What Do We Recommend? . . . . . . . . . . . . . . . . . . . . . . . 4 Appendix A – Response From District Officials . . . . . . . . . . . . . 5 Appendix B – OSC Comment on the District’s Response. . . . . . . . 7 Appendix C– Audit Methodology and Standards . . . . . . . . . . . . 8 Appendix D – Resources and Services. . . . . . . . . . . . . . . . . . 9

Report Highlights Eden Central School District Audit Objective Background Determine whether the Eden Central School District (District) used District resources to provide the mental The District is located in Erie health component of the New York Safe Schools Against County, and is governed by an Violence in Education Act (SAVE Act) training requirement elected nine-member Board of to staff. Education (Board). The Board is responsible for Key Findings the general management of the The District did not provide mental health training to any District. staff for the 2020-21 school year by September 15, 2020 The Superintendent serves as required by New York State Education Department at the Board’s direction and (SED) regulations. is responsible for day-to-day ll Trainings offered did not provide any of the 12 management. recommended components of mental health that The Superintendent is the educators should know. Chief Emergency Officer and is responsible for coordinating Key Recommendation emergency plan training for staff. Provide mental health training to all staff and ensure it is Quick Facts completed by September 15, as required. Such training 2020-2021 School Year should address recognition of the warning signs, whom Staff 412 to turn to for assistance, and how to access appropriate services. Students 1,310 School Buildings 3 District officials generally agreed with our recommendation and indicated they will take corrective action. Appendix B includes our comment on the District’s response. Audit Period July 1, 2020 – June 30, 2021 Of f ic e of t he New York State Comptroller 1

Mental Health Training The SAVE Act was introduced to help improve school safety. The SAVE Act requires school districts to develop a comprehensive district-wide school safety plan (safety plan) that addresses crisis intervention, emergency responses and management. The safety plan developed by each district must include, among other things, policies and procedures for annual school safety training for staff and students. School districts must certify to the SED Commissioner that all staff have undergone the school safety training, which must include a component on mental health.1 SED requires that the certification to the SED Commissioner states that all staff have undergone the annual training by September 15 of each year. What Is the Mental Health Component of the SAVE Act Training for All Staff? The SAVE Act requires all districts to provide staff annual emergency response plan training with a component on mental health. School personnel are often the first to notice mental health problems, and, to support the mental health of a district’s students. While the SAVE Act and SED requirements state that the annual school safety training must include a component on mental health, neither the SAVE Act nor SED requirements directly address what topics should be included within the mental health training component. Rather, SED issued guidance to all school districts that included resources relating to mental health. Included within the resources was information from the U.S. Department of Health and Human Services (DHHS) addressing “what educators should know” regarding warning signs of mental health problems, “whom to turn to,” and “how to access crisis support and other mental health services” (Figure 1). FIGURE 1 What Educators Should Knowa a) United States Department of Health and Human Services 1 8 NYCRR Section 155.17[c][1][xiii] 2 Of f ic e of t he New York State Comptroller

Based on SED guidance, as a best practice, at a minimum staff should be trained on the DHHS recommended mental health components of “what educators should know.” District Training Did Not Include All Recommended Mental Health Components The Superintendent certified to SED that all staff received training on the emergency response plan on September 2, 2020, which must also include training on a component of mental health. However, our review of the training records and materials presented by officials found the District did not provide training to any staff on a component of mental health as a requirement of the annual emergency response plan training. The Superintendent told us two trainings that included Figure 2: District’s “Dignity for All Students mental health content were Act” and “Discrimination and Harassment provided by the District through for Employees and Supervisors” Trainings a third-party service provider: Mental Health Components Included “Dignity for All Students Act” Whom to Turn to x and “Discrimination and Harassment for Employees How to Access Support and Services x and Supervisors.” We Warning Signs reviewed the materials Anxiety Disorders x presented for these trainings and found that none of the Behavioral Disorders x 12 recommended mental Eating Disorders x health components were included (Figure 2). The Mood Disorders x training included content Obsessive-Compulsive Disorder x on harassment, bullying Personality Disorders x and discrimination, not the recommended mental health Psychotic Disorders x warning signs, “whom to turn Substance Use Disorders x to” and “how to access crisis support and other mental Suicidal Behavior x health services.” Trauma and Stress Related Disorders x The Superintendent told us he began employment with the District in July 2020 and the impact of COVID-19 shifted priorities with a greater emphasis and focus on reopening schools with five-day, in-person school weeks. The Superintendent also indicated that the District was not fully aware of the requirements and deadline for the mental health training. Furthermore, the Superintendent told us that the training provider did Of f ic e of t he New York State Comptroller 3

not have any training specific to mental health, however; the District is currently working with its Board of Cooperative Educational Services to implement mental health training for staff. It is imperative, especially during the COVID-19 pandemic, that staff be provided training on warning signs that may be an early indicator of mental health issues and concerns. Training staff can assist in identifying mental health issues in students early on to get help when needed and potentially avoid having to react to crisis situations or emergencies. What Do We Recommend? District officials must: 1. Provide mental health training to all staff and ensure it is completed by September 15, as required. Such training should address recognition of the warning signs, whom to turn to for assistance, and how to access appropriate services. 4 Of f ic e of t he New York State Comptroller

Appendix A: Response From District Officials See Note 1 Page 7 Of f ic e of t he New York State Comptroller 5

6 Of f ic e of t he New York State Comptroller

Appendix B: OSC Comment on the District’s Response Note 1 As indicated in the response, officials became aware of the District's Mental Health First Aid training after the completion of our audit fieldwork. We reviewed this subsequent training information and found that the Mental Health First Aid training offered to the 49 teachers occurred in 2018, not during our audit period. In addition, the Superintendent told us an additional training session occurred in January 2022 for 38 staff members. Therefore, our audit finding that the District did not provide annual mental health training to any staff for the 2020-21 school year by September 15, 2020, as required by SED regulations, is accurate.  Of f ic e of t he New York State Comptroller 7

Appendix C: Audit Methodology and Standards We conducted this audit pursuant to Article V, Section 1 of the State Constitution and the State Comptroller’s authority as set forth in Article 3 of the New York State General Municipal Law. To accomplish our audit objective and obtain relevant audit evidence, our procedures included the following steps: ll We selected the District for audit using a random number generator applied to a list of districts, broken out by five geographic regions (excluding NYC schools), not currently in the OSC audit process at the time of selection. The list was broken out by geographic region for an even representation of school districts across the State for this multi-unit audit. ll We interviewed District officials to gain an understanding of the process for creating, disseminating and monitoring mental health training for staff. ll We reviewed relevant State laws and regulations, and guidance from SED and the United States Department of Health and Human Services. We reviewed District policies to gain an understanding of required mental health training. ll We reviewed Board minutes for the 2020-21 school year to determine the Board action taken related to the District-wide safety plan or required mental health training. ll We requested and reviewed records supporting the District’s 2020-21 certification to SED that required annual training with a component of mental health. ll We reviewed and tested the mental health training materials provided by the District to determine if training on mental health followed guidance. ll We determined the total number of individuals employed by the District during our audit period, by obtaining and reviewing an employee listing. We conducted this performance audit in accordance with generally accepted government auditing standards (GAGAS). 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 objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective. The Board has the responsibility to initiate corrective action. A written corrective action plan (CAP) that addresses the findings and recommendations in this report must be prepared and provided to our office within 90 days, pursuant to Section 35 of General Municipal Law, Section 2116-a (3)(c) of New York State Education Law and Section 170.12 of the Regulations of the Commissioner of Education. To the extent practicable, implementation of the CAP must begin by the end of the fiscal year. For more information on preparing and filing your CAP, please refer to our brochure, Responding to an OSC Audit Report, which you received with the draft audit report. The CAP should be posted on the District’s website for public review. 8 Of f ic e of t he New York State Comptroller

Appendix D: Resources and Services Regional Office Directory www.osc.state.ny.us/files/local-government/pdf/regional-directory.pdf Cost-Saving Ideas – Resources, advice and assistance on cost-saving ideas www.osc.state.ny.us/local-government/publications Fiscal Stress Monitoring – Resources for local government officials experiencing fiscal problems www.osc.state.ny.us/local-government/fiscal-monitoring Local Government Management Guides – Series of publications that include technical information and suggested practices for local government management www.osc.state.ny.us/local-government/publications Planning and Budgeting Guides – Resources for developing multiyear financial, capital, strategic and other plans www.osc.state.ny.us/local-government/resources/planning-resources Protecting Sensitive Data and Other Local Government Assets – A non-technical cybersecurity guide for local government leaders www.osc.state.ny.us/files/local-government/publications/pdf/cyber-security-guide.pdf Required Reporting – Information and resources for reports and forms that are filed with the Office of the State Comptroller www.osc.state.ny.us/local-government/required-reporting Research Reports/Publications – Reports on major policy issues facing local governments and State policy-makers www.osc.state.ny.us/local-government/publications Training – Resources for local government officials on in-person and online training opportunities on a wide range of topics www.osc.state.ny.us/local-government/academy Of f ic e of t he New York State Comptroller 9

Contact Office of the New York State Comptroller Division of Local Government and School Accountability 110 State Street, 12th Floor, Albany, New York 12236 Tel: (518) 474-4037 • Fax: (518) 486-6479 • Email: [email protected] www.osc.state.ny.us/local-government Local Government and School Accountability Help Line: (866) 321-8503 STATEWIDE AUDIT – Julie Landcastle, Chief Examiner Utica State Office Building, Room 604 • 207 Genesee Street • Utica, New York 13501 Tel (315) 793-2484 Like us on Facebook at facebook.com/nyscomptroller Follow us on Twitter @nyscomptroller