TITLE IX: Dot the i s and Cross the t s By: Harben, Hartley and Hawkins Law Firm

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1 April 2016 TITLE IX: Dot the i s and Cross the t s By: Harben, Hartley and Hawkins Law Firm Inside This Issue In 1972, Title IX was passed by Congress and signed by President Nixon. It simply prohibits discrimination on the basis of sex in any educational program receiving federal monies. Many greeted the statute with great expectation and others with great consternation, both generated by the much discussed impact that the statute would have on athletics, particularly at the university level. More than forty years later, it seems clear that football and other athletic programs in the country s universities and colleges have survived, many would say Public schools are committed to equity for all students, but knowing how OCR interprets the laws and regulations in place and having in place procedures that address those interpretations can help school districts avoid costly and time consuming investigations. thrived. It is equally clear that the opportunities available to female athletes have increased substantially. It did not take long for the inequity arguments related to athletics to move from the university level to high schools throughout the country. In fact, inequities or perceived inequities in the funding and treatment of girls athletic programs versus boys athletic programs in public high schools remains perhaps the major source of complaint to the United States Department of Education Office for Civil Rights under Title IX. Continued on page 4 GA Work Comp How does it work? Safety Consortium Long County uses Safety Grant Barrow, Bleckley & Hart Counties join the Funds Member Spotlight Director s Message on Field Trips and On- Campus Events 5120 Sugarloaf Parkway Lawrenceville, GA

2 Georgia School Boards Association Risk Management Services March 2016 Director s Message By: Trudy Sowar, Director of Risk Management Services There are definite advantages to being a mature woman aka old lady. Having started my career as a paraprofessional, there are very few things in education that I have not seen or done. I was my principal s worst nightmare as a teacher and I was equally as imaginative and enthusiastic as a principal and central office administrator. From taking a hundred students on a trip to Winston Salem, North Carolina for their fifth grade trip, having a helicopter land on my playground with seven hundred children standing in a big circle around the field, organizing a high school vs central office staff basketball game, a whitewater kayak trip for the alternative school students, and other activities and adventures I m too embarrassed to admit to. Most ended well, but not all. Several students discovered a bottle of spirits in their hotel room, a central office administrator broke her wrist and another staff member had a bum knee for a few weeks from the basketball game. It got a little rough and tumble. I totally understand why educators do some of the things they do. I did them. I approved them. I encouraged them! Times have changed though. We live and work in a much more litigious environment. Today I look at this from a very different perspective; a risk perspective. We never want to discourage creativity and enthusiasm in our staff. We want to support your efforts to expand your students experiences and provide fun activities for the students, staff and communities you serve. We just implore you to look at these activities through a risk management lens. The GSBA Risk Management Team is always available to talk with you about a planned activity or event and offer suggestions for best practices. Many of us come from the education world and have likely had similar experiences. Whether it is a field trip or an on-campus event we offer our assistance. We have a saying at our office; just because something is covered by your insurance doesn t make it a good idea. What could possibly go wrong? Ask yourself that question the next time you are asked to approve a trip, an activity, a fundraiser. It may just save a headache later. Department Directory for GSBA Risk Management Services Administration Director - Trudy Sowar Assistant Director - John Shore Administrative Asst. - Mary Bailey Claims Management Workers Comp Claim Manager - Olan Hembree Risk Specialist - Jill Smith Membership Development Member Advocate (South GA) - Ricky Brantley Member Advocate (NW GA) - Lori Sours Member Advocate (NE and Central GA) Roger Mathews Risk Information Services Underwriting Manager - John Shore Consultant - Cliff Hood Assistant - Rodean Wilson Risk Control Services Risk Control Coordinator - David Colvard PAGE 2

3 Georgia Workers Compensation 101: How does it work? Article By: Cliff Hood, Consultant for GSBA Risk Management Services. Hood was a Trustee on the Board of the Workers Compensation Fund for 18 years and was the Chair on that Board for 8 years, he was also a Trustee of the Risk Management Fund for 11 years. He served as a White County Board of Education member for 23 years. He is a Certified Public Accountant. As I work with School Systems around Georgia, I find that there is a lot of confusion about Workers Compensation and the Georgia Workers Compensation law. This is not surprising because it is a complicated issue and unlike most other insurance coverage it is based on statutory and case law. The Georgia legislature passed the first workers compensation act in Prior to that time injured workers were required to bring a common law claim against an employer and the employer could assert many defenses. Under the workers comp law employers gave up many of their defenses. In exchange, injured workers gave up their ability to seek more substantial civil claims. In essence the law was a compromise where employees receive benefits as opposed to damages. Basically, employers in Georgia, with three or more full time employees, are required to provide workers comp insurance as a benefit. Injuries sustained by an employee while fulfilling their employment duties is compensable in Georgia. Granted, the details surrounding the accident or injury can become complicated and sometimes subject to court review. In Georgia, these reviews are provided by Administrative Law Judges or ALJs as opposed to Superior or State Courts. Employee benefits can be in the form of medical benefits and/or income which is called indemnity benefits. It also provides medical treatment and physical therapy related to the workplace injury. In the event of death, workers comp provides survivor benefits to the employee s dependents. Employers are required to post, in an accessible location, a panel of physicians of at least six medical providers, from which an employee can choose medical assistance. Although the minimum requirement is six physicians it s recommended to maintain a panel consisting of seven physicians so this way if a physician stops accepting workers compensation patients your panel would still be valid while we search for a replacement. The employers panel of physicians must consist of at least one orthopedic surgeon, one minority physician, with no more than two physicians from industrial clinics (see O.C.G.A ). An employee may also seek an independent evaluation at their own expense or at the expense of the employer as long as it takes place within 120 days of receipt PAGE 3 of any indemnity benefits. As with any other law, there can be complications and gray areas. It is important for the employer to continually monitor the progress of their injured employees and try to get them back to work as soon as practical. Statistics show that the longer a case lingers, the greater the chances that the employee will never return. A good employer return to work program can be very helpful in this endeavor. Some larger employers may be self- insured and may either manage their own claims or use the services of a Third Party Administrator or TPA. If the employer is represented by an insurance company or Self Insured Fund, like GSBA, their claims are managed by the insurance company or Fund. Again, insurance companies and Funds may either manage their claims in-house or use the services of a TPA. How does an employer obtain Workers Compensation coverage for their employees? In Georgia there are three basic options. If an employer meets the size and liquidity requirements they can apply to the Ga. Department of Insurance and the State Board of Workers Compensation for permission to become self-insured. Most employers, including most school systems, purchase Comp from an insurance company or join an industry work-alike fund where they are pooling their resources Continued on page 8

4 Georgia School Boards Association Risk Management Services March 2016 Title IX Continued from page 1 Despite the long history of this statute s implementation, there remains significant misunderstanding about its application to school athletics. The primary criteria applied is equality of opportunity for all students, without regard to sex. While this certainly means that equivalent sports should receive equal treatment, it does not necessarily mandate an exact dollar for dollar equivalency between the amount of money expended on boys sports versus girls sports. Many factors come into play, including the number of students actually interested in participating, but the school district must ensure equal treatment and opportunity. In certain areas, such as facilities and equipment, it is difficult, perhaps impossible, to justify any significant difference. In other areas, such as the total number of students participating or the amount of coaching supplements between two specific sports, there may be legitimate, non-gender based justification for differences, but those justifications must be applied equitably among all sports. If the boys basketball coach is paid more because of greater years of experience and a proven record of success, the girls softball coach should be paid more if the same criteria applies in that sport versus baseball. In Georgia, boards of education, school administrators, and athletic directors are aware of the state Equity in Sports Act. This state law has the same purpose as it relates to athletics as Title IX at the federal level and many of the provisions are very similar. However, there are some differences in enforcement practices which become very significant if a claim is filed. While school athletics remains a major source of Title IX complaints, two cases from Georgia led to a dramatic expansion of the impact of Title IX on public schools. In Franklin v. Gwinnett County Public Schools, the United States Supreme Court first held that a school district could be monetarily liable to a student who was the victim of sexual harassment by a staff member, but only if it could be proven that a person with the ability to act on behalf of the school district and who could do something about the alleged harassment actually knew that it was taking place and, in the face of that knowledge, was deliberately indifferent, in essence doing nothing, about it. Several years later, the case of Davis v. Monroe County Board of Education, similar reasoning was applied to studenton-student sexual harassment. Not only did these decisions result in a significant increase in litigation involving allegations of sexual discrimination or harassment against students, but OCR began investigating administrative complaints even in situations where lawsuits had not yet been filed. Most significantly, the current OCR has interpreted its administrative enforcement of Title IX to apply not just when the school district has actual notice, but when it should have known PAGE 4 about potential harassment. Similarly, the administrative standard has become, not just did the district do something to prove it was not deliberately indifferent, but did the school district do enough to stop the harassment and cure the hostile environment? While courts continue to apply the more strenuous standard of the Franklin and Davis decisions, OCR investigations often result in findings where the school district is allegedly negligent, a much lesser standard. Further, OCR has pushed the courts to expand their interpretation of Title IX to be more consistent with the administrative interpretation, thus far without success. However, it remains persistent in this endeavor. Finally, the current OCR has reinterpreted Title IX not just to apply to discrimination and harassment involving differences in sex, but also to apply to allegations of harassment or discrimination based on sexual orientation and gender identity. Thus what school districts formerly would interpret as bullying or hazing can become prohibited harassment under Title IX if it involves name-calling with any type of sexual connotation or any type of sexual taunting or conduct, even if directed between students of the same sex. Most recently, OCR has adopted an active approach toward the protection of transgender students arguing that they should be treated in accordance with their sexual preference of choice, regardless of biology. Continued on page 10

5 GSBA RMS Assists with New Safety Consortium Social Circle School System recently began the process of establishing a safety consortium with other nearby school systems. Sara Lynn Holbert, Assistant Superintendent for Social Circle led the process of getting representatives together for the initial meeting held at the Blue Willow Restaurant in Social Circle. Representatives from the following county school systems and agencies were invited: Barrow, Clarke, Jackson, Morgan, Newton, Oconee, Oglethorpe, Social Circle City Schools, Taliaferro, Wilkes County, Walton, Walton County Sheriff s Department, Social Circle Police Department, Georgia Emergency Management Agency (GEMA) School Safety Division and Georgia School Boards Association (GSBA) Risk Management Services (RMS). Dr. Todd McGhee, the Superintendent of Social Circle Schools, welcomed everyone and reminded the group of the importance of safety daily for all students, staff and visitors. David Colvard, Safety and Risk Control Coordinator of GSBA-RMS spoke to the group on the top three safety issues facing school districts and to provide some tips and suggestions for the development of the safety consortium. The consortium will meet at least quarterly to discuss and share items related to safety and risk control for the school districts. Member Spotlight from Glynn County Schools Al Boudreau is the Executive Director of Operations for the Glynn County School District in Brunswick, Georgia. His numerous responsibilities include: facilities, maintenance, grounds, custodial, warehouse, transportation, school police, athletics, and energy and risk management. Boudreau holds a B.S. Degree in Science Education from East Carolina University. He also has multiple certifications from the Association of Energy Engineers. According to Boudreau, In addition to the basic safety and risk management protocols which we have in place, I have pursued a special interest in the potential for damages caused by mold, mildew and poor indoor air quality. By utilizing building science, we have been able to reduce the potential for indoor air quality issues. The challenge comes from Glynn County s geographic location, in which the weather is very hot and humid. Our goal is to reduce risk to all faculty, staff and students, who work and attend Glynn County Schools to avoid the costly remediation of an unhealthy indoor environment. Trudy Sowar, Director of GSBA Risk Management Services, stated, We are very proud of the work that Al Boudreau does in Glynn County in terms of limiting their risks. He is very active within our group of great risk managers throughout the state. He attends practically every meeting we have and provides great insight on a variety of topics. Safety Consortium met at Blue Willow Restaurant in Social Circle PAGE 5

6 Georgia School Boards Association Risk Management Services March 2016 Long County uses Safety Grant to Enhance Food Service Safety Six member districts insured by the GSBA Funds were awarded safety grants at the Annual Member Meeting in October. Out of the thirty districts that applied for the grants, Elbert County, Franklin County, Long County, Wayne County, White County and Colquitt County, were awarded reimbursement grants to help improve a specific area of safety and risk control in their districts. Long County had experienced an increase in claims in their food service department. Their safety grant proposal was written with a focus to provide additional safety protection for all food service personnel. Equipment was purchased that would help to prevent or eliminate injuries related to strains, lifting, cuts, burns and falls. Scotty Hattaway, Director of Support Services, said By utilizing the funds of GSBA s safety grant, we hope to improve the work environment of our food service employees. We feel this will have a major impact on employee morale, productivity and safety. Stephanie Fox, Director of Food Services added, As the director I will continue to ensure that all measures are taken to provide proper employee training on the correct use of safety equipment and tools. Long County provided photos of some of the new safety equipment in use. Also, we couldn t help but notice how shiny, clean and organized the kitchen is! Good job, Long County! Safety Equipment Models from Long County are: Top - Elke Bell Left - Michelle Morris Right - Karen Stafford PAGE 6

7 Hart County Schools seeks Pooling Benefits Joins the GSBA Risk Management Fund On December 2, 2015 David Seagraves, Hart s Director of Operations, contacted Member Advocate Roger Mathews stating he was relatively new to the field of school system administration and was unaware of the availability of coverage thru GSBA until today. David, having years of experience as a Risk Manager for a healthcare organization, had knowledge of the pricing stability and support services pooling brings as an alternative to commercial insurance. After a brief conversation about the GSBA-Risk Management Fund, David committed to gathering his District s exposure data for a January 1st coverage date. John Shore, the Risk Management Services Assistant Director and Underwriting Manager, immediately committed to provide a proposal to be ready for delivery on December 14th, Hart s Superintendent, Jay Floyd, met with David Seagraves and Roger Mathews to review the coverage enhancements offered and the feasibility of binding coverage for their goal of January 1st. Hart s coverage authorization documents were returned to GSBA on December 23rd and the GSBA team delivered Coverage Declarations and Auto ID cards on December 28th, providing Hart County Schools with new coverage for the New Year. Hart s Board offices are located in Hartwell, GA. The current five member Board, Chairperson Richard Sutherland, Vice Chair Matthew Honiotes, Stephanie Burton, Greg Fleming, and Angie McGee, oversee six campuses with just over 3500 students. Hart County is bordered in part by Lake Hartwell and two other Member Districts; Elbert County Schools and Franklin County Schools. As a side note Hart is the only county in Georgia named after a woman, Nancy Morgan Hart, who was a heroin of the American Revolutionary War and the subject of this month s South Hart Fourth Grade presentation of Nancy s Revenge. Barrow County Schools Starts 2016 With a Move to the GSBA Workers Compensation Fund Shortly after the FY16 school year began, Barrow County Schools determined a need to explore options for their Workers Compensation coverage. They explained to GSBA-Risk Management Services a desire to improve service and coverage for their growing staff, now numbering over 1,600 employees. John Shore, GSBA-RMS Assistant Director and Underwriting Manager, communicated with Barrow s Accounting Coordinator Judy Roberts to identify specific delivery points for the New Year and beyond. John and Judy focused on custom claim reports, professional response to the injured worker, loss control and safety educational options, and prompt payment of medical expenses. When asked why Barrow chose to invite GSBA-Risk Management Services to the business table Barrow said, it was because several districts that are existing Workers Compensation Fund Members referred them. Barrow County Schools made their decision to partner with GSBA in early December and the reporting transition was implemented by Judy Roberts and her Barrow team member Kaila Harkins who follows all of the District s injured workers through the entire claim process. The Barrow Board office is located in the County seat, Winder, GA. Barrow County finds itself pinched between Gwinnett and Clarke Counties and has experienced a 50% growth in population between the census data of 2000 and that of Barrow s nine member Board, Chairman Mark Still, Vice-Chair Lynn Stevens, Rolando Alvarez, Suzanne Angle, Rickey Bailey, Garey Huff Sr., Debi Krause, Michael Shelley and Connie Wehunt, governs Georgia s 28th largest School District with a current student count of 13,482. Superintendent Dr. Chris McMichael oversees the education provided in Barrow s (8) Elementary, (4) Middle and (3) High Schools. PAGE 7

8 Georgia School Boards Association Risk Management Services March 2016 Work Comp 101 Continued from page 3 with other similar employers. Whether purchasing insurance or joining a Fund, the process is similar. How much does it cost? Since Comp is statutory, insurance companies and Funds file standard rates with the State. These rates become the basis of your premium or contribution. Comp is priced as a function of payroll and the rates are quoted as a rate per $100 of payroll paid to employees. The rates are broken down into subrates based on the classification of the employee. In Georgia, schools are usually quoted based on three Classification Codes. One is for drivers and garage employees and would cover the bus drivers and mechanics. The second is for professional and administrative and would cover classroom, office, administrative and classroom support personnel. The third is other and would cover non-professional such as custodial, maintenance, cafeteria and etc. The codes are established by The National Council on Compensation Insurance (NCCI), which is a non-profit serving the insurance industry. The codes are usually rated based on actuarial studies of jobs and workers comp claims and obviously the codes with a higher risk of injury are rated higher than the jobs with less risk of injury. Simplified, your premium is based on your payroll per classification divided by $100, multiplied by the classification rate. All the code rates are totaled to arrive at your Manual Premium or Manual Contribution. There is one other factor that can influence your premium. It is called an Experience Modification Factor or Experience Mod for short. The Mod is generally based upon the employers last three years of claims experience and is multiplied times their total rates to determine their modified rate. If an employer has good claims experience their Mod is usually around 1.0 and has little effect of the rating. If an employer has better than average claims history then the Mod can be less than 1.0 and can lead to a lower premium calculation. Conversely, if an employer has poor claims history then the Mod will be in excess of 1.0 and will lead to a higher premium calculation. This is one area where an employer can help control their Workers Comp costs. History and statistics have shown that the implementation of a pro-active loss control and safety program can lower Comp costs. One benefit you receive as a Member of the GSBA Comp Fund is guidance and resources to help you implement a sound loss control and safety program. It works. Try it! One question is asked frequently. Since Workers Comp is based on payroll, how do you determine my rates in advance? Good question! An insurance company or Fund will ask you to provide a payroll estimate by Class, at the beginning of the year, and this estimate will be used to determine your estimated premium or quote, for the coming year. At year end you will again be asked to submit the total actual payroll, by Class for the year. This will be compared to your estimated payroll and any variance will lead to either a refund or an additional amount due. One other factor comes into play in Georgia. Historically, under Georgia case law, an employer may in certain circumstances be held liable for the Workers Comp benefits of a non-employee contractor that is injured while performing duties for the employer. This is why it is so important for employers that hire non-employee contractors to obtain a valid Certificate of Insurance from the contractor, in advance of any work being done. This will give the employer an additional defense in case the contractor or their employees are injured while working for you. Realistically, as a school system, many of your contractors are individuals such as contract teachers, consultants and therapists and they will most likely not have Comp coverage but they are in a Classification with a very low rate. However, most of your other contractors such as maintenance, building construction, roofers, HVAC, lawn maintenance, security, officials and custodial contractors should have Comp, especially if they have more than three employees. And they are engaged in occupations with a much higher degree of risk than the professional Classification. If you have any questions about this process, please contact your Member Advocate or other GSBA Fund staff. How can I control the cost of Work Comp in our district? Continued on page 9 PAGE 8

9 Work Comp 101 Continued from page 8 Bottom line is that you CAN have an impact on your Workers Compensation rates by doing the following: Implement, with the help of GSBA, an effective loss control and safety program Monitor your claims and make sure injured employees get good care and get them back to work as soon as possible Obtain valid Certificates of Insurance for non-employee contractors, especially in the higher risk occupations Provide accurate payroll and contractor estimates when you complete your renewal application Provide quality and comprehensive audit documents so that we can properly and accurately complete your year-end audit Bleckley County Joins Risk Management Fund The Risk Management Fund is excited to welcome a new Middle Georgia member. Bleckley County pushes the combined membership in the GSBA Funds to 99 members. While the Bleckley County school district is new to the RMF, its Superintendent Steve Smith is very familiar with the unique services of the GSBA Funds having served as superintendent for another member district before returning home to Bleckley. Bleckley County is located in middle Georgia and shares county lines with RMF Members Houston and Pulaski Counties. While the city of Cochran is the county seat, it is surrounded by the beautiful communities of Allentown, Cary, and Empire. The county is rich in Georgia history and home to some of the best farmland and a favorite spot for some of the state s best fishing and hunting activities. Bleckley County was formerly home to Middle Georgia College, the oldest twoyear public college in the nation. In 2013 it merged with Macon State College, now known as Middle Georgia State University. Steve Smith is the Superintendent of Schools for Bleckley County and works with School Board Members: Chair Kim Wright, Vice-Chair William Baldwin, Members Derek Bellflower, Mildred Bloodworth, and Amy Williams. The school district has earned both academic and athletic honors in recent years. The 2,500 Bleckley County students attend classes at one of the following school sites: Bleckley Learning Center, Bleckley County Primary School, Bleckley County Elementary, Bleckley County Middle School, Bleckley County High School, Bleckley, and Bleckley County Success Academy. We are delighted to add new member Bleckley County to our Risk Management Fund, commented Member Advocate Dr. Ricky Brantley. Ricky speaks so complimentary of the leadership and work of Bleckley Superintendent Steve Smith, the Bleckley School Board, and school district staff, and all they are doing to provide excellent educational programs for their students. During membership enrollment he especially noted the hard work of Superintendent Steve Smith and the assistance of his Administrative Assistant Debbie Arnold. Steve and Debbie played a major role in providing valuable information about the school district and communicating to the Board,the unique service the GSBA Fund offers. Bleckley County is a valuable addition to the Fund and I am so excited about the opportunity to work with them, remarked Dr. Brantley. PAGE 9

10 Georgia School Boards Association Risk Management Services March 2016 Title IX from page 4 investigation. On April 24, 2015, OCR issued a Dear Many school districts have Colleague letter to school experienced an investigation by districts across the country OCR into allegations of prohibited and a separate letter to Title IX Title IX harassment. Others have coordinators describing in great seen OCR use the same type of detail its expectations for Title analysis to apply to Title VI (racial IX coordinators. It is certainly and national origin) and Section safe to say that very few Title 504 (disability) claims. A few IX coordinators or school straightforward suggestions or districts understand the role words of advice garnered from in the way described in these those experiences may be useful letters. It is crucial that if there to school districts and school is an investigation, the Title administrators. IX coordinator understands 1. All three of the civil rights these letters and does the best statutes require a local possible job articulating how complaints procedure which the Title IX coordinator carries allows students, parents, and out these duties. even citizens a vehicle to file an 3. While most school districts internal complaint when there have a complaints procedure is a belief that students are and coordinator, they come being treated in violation of the up empty when OCR asks statute. Most school districts for documentation of would have such a procedure complaints filed with and under JAA, applicable to investigations conducted by students, and/or GAAA, usually the coordinator. This may applicable to employees and be obvious by now, but many others. incidents that occur in the 2. Title IX and its corresponding normal middle school or high statutes require each school school involving two or more district to have a designated students could be described coordinator. This person bears by one student or the other primary responsibility for or one set of parents or the implementing the mandates of other as involving some form the statute within the school of illegal harassment. Kids district and investigating often use race, national origin, complaints filed in accordance sex, and disabilities as focal with the internal complaints points for teasing, arguments, policy. It is important not only and disagreements. In trying to have such an individual to determine where the time designated, but to ensure and emphasis of the Title IX that this individual is aware coordinator should be focused, of his or her responsibilities we would suggest three groups and can articulate how those of complaints or incidents. responsibilities are carried First, there are obviously out if OCR is involved in an those serious matters such as those involving the sexual assault of a student or a gang fight with racial implications that seem apparent. However, sometimes, school administrators forget to dot the i s and cross the t s of compliance with its Title IX or Title VI procedures in addressing these major events. Second, there are parents that school administrators simply know are most likely to pursue an OCR or other type of legal complaint. Even though it sometimes seems unfair, fixing these issues or at least documenting clear compliance with school district procedures requires some priority, simply to avoid the time and expense of responding to an OCR complaint. Finally, in today s media and social media world, there are those claims that may seem trivial but are unusual enough that they are guaranteed to go viral on social media and perhaps even become prominent on CNN or Fox News. The more prominent an incident, the more likely a complaint to be filed with OCR. Avoiding these or addressing them quickly and thoroughly is especially important. Public schools are committed to equity for all students, but knowing how OCR interprets the laws and regulations in place and having in place procedures that address those interpretations, can help school districts avoid costly and time consuming investigations. PAGE 10

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