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Board Policy 6164.2: Leveraging Support for Comprehensive School Counseling Programs

By Paul Meyers | November 2023

Post COVID-19, students’ mental health issues have been characterized as a crisis. In August 2022, California Governor Gavin Newsom announced California’s “Master Plan for Kids’ Mental Health” to combat this crisis and to make it easier for children to access mental health and substance abuse services. The ambitious plan included an investment of billions of dollars in funding to increase comprehensive mental health and substance abuse services in California schools. This plan also included the enactment of AB 2508, signed into law on August 18, 2022, which amends several provisions of the California Education Code 46900 to update the statutory role and responsibilities of school counselors.

Spearheaded and heavily influenced by Dr. Loretta Whitson, executive director of the California Association of School Counselors (CASC), and consequently widely promoted by CASC, the changes are significant and very relevant. This piece of legislation has leverage and influence among California school administrators, but not as AB 2508. Frankly, most administrators do not really pay attention to newly enacted bills or to updates to the Education Code. It’s just not part of their daily activity to concentrate on the ever-changing and humongous book of Education Codes.

Where this new law has legs is in board policy. Practically every school district in California subscribes to the California School Board Association (CSBA), and one of the many things CSBA does is provide school districts with newly revised Board Policies whenever the governor signs bills that impact schools. One of CSBA’s main roles is to keep school districts compliant with California law, and each time there is a modification to the Education Code, it triggers the creation of a Board Policy that reflects current statutes. School districts receive these updates in batches in the form of “boilerplate” or recommended policy language. Often the policies will provide options depending on the type of district (elementary, unified, etc.). These sample board policies are reviewed by the superintendent or designee, and may be modified by the school district, commonly referred to as the Local Education Agency (LEA).

Typically the superintendent’s administrative assistant will distribute the new, recommended board policies to the various department heads within the district for review and approval. Then these new or modified board policies are placed in an action item for approval by the school board. Many districts use a two-part approval process. The first part is an action item that allows for public comment. The second is often buried in the consent agenda where it is swiftly approved, unless it is a policy that is highly controversial and necessitates a second open action item and subsequent board approval.

The revised Board Policy 6164.2 was released by CSBA in the September 2022 batch of new and revised board policies, only a month after AB 2508 was signed by the Governor. Some districts have since approved new board policies, but many have not. It depends on the school board members and the superintendent; some districts have made board updates part of the normal routine, while others have not updated policies in months or even years. Sometimes it takes a staff member or community member to bring it up at a board meeting in order for action to be taken.

Because so many good changes were made to Education Code 49600, Board Policy 6164.2 had many changes as well. Districts that have adopted the revised Board Policy 6164.2 can leverage this policy to advise school administrators on the new role of school counselors as site-based mental health professionals who implement multitiered system of supports (MTSS).* The new policy also declares that school counselors engage with, advocate for and provide direct services and indirect services, and “plan, implement, and evaluate comprehensive school counseling programs.” The changes are significant and warrant school districts to revise their school counselor job description and evaluation instruments to align and ultimately implement this revised board policy.

Here is the summary provided by CSBA to district superintendents:  
 

Board Policy 6164.2 – Guidance/Counseling Services
 
Policy updated to expand the Governing Board’s philosophical statement to include student well-being, and reflect new law (AB 2508, 2022) which

(1) urges districts to adopt a comprehensive educational counseling program and, for districts that provide such services, to implement a structured and coherent counseling program within a Multi-Tiered Systems of Support framework,
(2) revises the definition of “educational counseling,”
(3) amends the legislative intent of the responsibilities of school counselors,
(4) requires educational counseling to include specified postsecondary services, and
(5) revises the components that educational counseling is required and authorized to include.

Policy was also updated to reflect new law (AB 643, 2021) which encourages districts to host apprenticeship and/or career technical education fair events, such as college and career fairs and for districts that do hold such events to notify apprenticeship programs in their county, as specified. Additionally, policy updated to move material regarding early identification and intervention plans for students who may be at risk for violence.

Board policies can be easily searched on Google, and if you place BP 6164.2 in the Google search bar, several district examples will appear. If you open them up and scroll to the very end, it will indicate when the board policy was adopted.

Finding board policies on a district’s webpage is also easy, because every school district is required to place a link to the district’s board policies with “one click.” A district’s home page will typically display an icon or button referring to board policies.

Many board policies will provide options for the district administration and school board to consider when adopting new policies. CSBA will include these options and the rationale in the material they send to districts. Board policies can also be modified by school boards, and additional language can be added to meet community needs.

Typically, CSBA will provide boilerplate language for both the board policy (BP) and the administrative regulation (AR), often seen together and written as BP/AR 6164.2. However, this time CSBA did not provide a sample AR, which means districts can write their own regulations for the governing board to approve. For example, Stockton Unified’s AR 6164.2 incorporates the American School Counselor Association’s ASCA National Model in the opening paragraph:  

The Stockton Unified School Counseling program is developed on the foundation of the framework of ethics and professional standards articulated by the American School Counseling Association, referred to as the ASCA National Model. This model delineates the services and supports all students (grades Tk-12) receive via a comprehensive school counseling program as part of a team of school-based mental health professionals. These services are provided in multi-tiered systems of support (MTSS) in the domains of academics, college/career, and social-emotional learning. Stockton Unified has developed a School Counselor Handbook to streamline services available at all three tiers.

In closing, referencing a district’s board policy will get the attention of district administration much better than referring to AB 2508 or EC 49600. All board policy will include a statement that says, “The superintendent or designee shall…” Every district administrator should know they are the designee, especially if they oversee school counseling as part of their job description.

Paul Meyers is a retired superintendent and executive director for Hatching Results.

* Note: MTSS in AB 2508 is defined as Multi-Tiered Systems of Support, not as the more widely accepted terminology of Multi-Tiered System of Supports. As a result, Education Code 49600 also has “systems of support.” Thus, the CSBA maintains this mistake and you’ll also find “systems of support” in Board Policy 6164.2.