I’ve heard constant echoes of one thing over the past year: we need more supports in our schools for our high-needs students. But what happens when that call is heard but we may get far more than we ever bargained for? What if the services provided become very invasive in scope?
The Delaware Department of Health and Social Services (DHSS) put out a request for proposal (RFP) for all nineteen school districts in Delaware and the thirty-two high schools within them. The goal of the vendor contracts would be to increase the role of wellness centers in schools. The funding was already put in place in the FY2017 budget. A few high schools wouldn’t begin these kind of contracts until FY2018 because they didn’t already have existing wellness centers in the schools.
I have grave concerns with how much DHSS wants to happen in our high schools. I understand why the bid for this is coming out of DHSS, but this is an education matter. I fully understand that some students may not have access to medical treatment so I am not explicitly against these types of centers in high-needs schools. But the amount of private student data involved is astounding. Under HIPAA, that is merely a consent for information to go out from a health provider to another entity. Parents need to understand exactly what they are signing consent for. Where this gets confusing is the differentiation between HIPAA and FERPA. FERPA only applies to educational records. The data from these health centers in our high schools would not fall under FERPA. Or at least they shouldn’t.
There are several terms in the above picture that worry me. “Prevention-oriented multidisciplinary health care”… I’m all for prevention, but prevention against what? Where is the line drawn? What if one of these multidisciplinary measures goes against a student’s religion? What if the student is not aware of that but a parent becomes upset when they find out? “Integration with primary care”… what does that even mean? Integration would mean a data system cross-referencing the health information between a primary physician and the school-based health provider. Does that information flow both ways? Serious data privacy concerns here folks!
“The delivery of medical and mental health services”… If a student needs immediate treatment, is a school even equipped to act as a triage type unit? Is that the eventual goal here? In terms of mental health services, I have long thought it was a good idea for school districts to have psychiatrists or neurologists on hand for IEP meetings. All too often, psychologists are used to determine “behavior” issues but a psychiatrist or neurologist would be able to give more explanation of what is going on neurologically when a student manifests disabilities. A psychologist can’t prescribe medicine and as a result, they may not have up to date knowledge of what different medicines do and how they metabolize with the human body.
Students come into our schools with trauma. Of that, no one seems to be in disagreement. If families aren’t able to provide students with safe and supportive environments at home, then the school setting would be ideal for students to get the help they need to deal with those issues. But my concern is this becoming available for ALL students eventually. All too often parents are denied health information about their child on certain things when it comes to the existing wellness centers. With this program increasing in scope like this, I can picture that becoming a much bigger issue.
In private practices, these types of services are not cheap. But that is where the best in their fields tend to go. With this plan, how many would leave existing private practices to come work in schools? Not too many I am afraid. As a result, we would most likely get younger, fresh out of college mental health providers without the experience. They would get paid less and as a result an inequity would develop between students who come from stable and wealthier home environments and those who come from low-income or poverty families. Those who come from the stable homes would most likely continue to go to private practices.
DPH is the Division of Public Health. They would provide partial funding for this project. But what happens when the project becomes mainstream? All too often, our school districts become the financial bearer of state mandated programs. Yes, the funding exists now, but what happens when it isn’t available? Do they cut these programs out of schools entirely or do local school districts bear the financial burden for paying for these programs?
My first question: what is the School-Community Health of Michigan entity that appears to house school-based health information? How secure is this data? If one of the vendors chooses to implement the two years to develop their plan for data reporting, how safe is that data in the meantime? Should all student risk assessments be standardized? I would think students with disabilities, those coming from broken homes, or those dealing with poverty would tend to fall lower on a standardized scale as opposed to their peers.
I don’t mind a culture of health. Lord knows we can be healthier in this country. But when I see “How youth and parents would be involved in the “planning, operation, and promotion of the SBHC,” that seems like a lot of emphasis put on parents. If these services are for high-needs students whose parents aren’t big on family engagement, this would result in parents of regular students doing the pushing for these programs. Will they want to do that if it isn’t for their own child? “Potential partners and key stakeholders”… as defined by who? And as we all know, data flows to “partners” quite a bit with education records. Would parents be given consent forms to send their child’s medical data to entities who really don’t need that information at all? It mentions HIPAA here, but this is a very slippery slope. I need a lot more information here. What is a “diversified funding base”? Since, invariably, all of this would be paid for by the taxpayers of Delaware, will they really want to pay for other students health services? We already do, to some extent, but this would increase those costs.
I’m sorry, but did that really say “if the SBHC intends to be a Title X/family planning provider”? For those who may not be familiar with Title X, the U.S. Department of Health and Human Services describes this program on their website:
Family planning centers offer a broad range of FDA-approved contraceptive methods and related counseling; as well as breast and cervical cancer screening; pregnancy testing and counseling; screening and treatment for sexually transmitted infections (STIs); HIV testing; and other patient education and referrals.
I hate to even bring this up, but if this could in any way lead to abortions being provided in schools that would cause a nuclear war between parents and schools. No matter what your views on abortion might be, I would tend to think the school would be the last place anything like that should happen. For that matter, the various “screenings” allowed under Title X could lead to serious contention as well. For the “5 performance measures for the basis of evaluation”, based on federal guidance I imagine, does that mean every single school-based health center would be required to perform these five measures? Chlamydia testing can be done by urine samples for both males and females, but sometimes they are performed for females as vaginal swabs. I would hope that isn’t the method being proposed in this contract. With all seriousness, I do know chlamydia is a very serious sexually transmitted disease and among the most common. I don’t know if school-based health centers currently screen or test for chlamydia. If anyone has information on this, please let me know. I reached out to a few people who were shocked this would be included in this.
Once again, my biggest concerns with all this surround student data. This goes way beyond my concerns with existing student data. Parents should seek answers for this. I know I will be! Please read the entire RFP, seen below. I need to know your thoughts on this. This is very big and I don’t feel Delaware citizens are even aware of this going on without our knowledge. The transparency on something of this scope has obviously not been present. Please share this with everyone you know in Delaware. Get feedback from your friends or those in the medial profession. Is this too much? I have seen a lot of “futurist” lingo talking about how our schools will become “community schools” in the truest sense of the word based on things like this coming to fruition. Does the term “the whole child” include aspects that will eventually take authority away from parents when it comes to their children’s health? How much will parents be able to opt out of these programs?
The Season Of Myths 