Testimony Before the Council of the District of Columbia Committee on Health on the Department of Behavioral Health’s Comprehensive Plan for the School-Based Behavioral Health Program
By Nicole Travers
Good morning, Chairperson Henderson and members of the Committee. My name is Nicole Travers, and I am the Senior Director of Strategic Partnerships at the DC Charter School Alliance, the local non-profit that advocates on behalf of public charter schools to ensure that every student can choose high-quality public schools that prepare them for lifelong success. I also proudly serve as a member of the School Behavioral Health Coordinating Council.
Thank you for inviting us to discuss efforts to improve mental health services in our schools. I want to acknowledge Dr. Bazron, Dr. Scott, and Dr. Sullivan for their work to ensure more schools have access to clinicians and for including charter schools in the School Mental Health ARROW working group.
I and other Alliance staff have appeared before this committee repeatedly over the last five years to discuss ongoing challenges, including high vacancy rates, in the school-based mental health program. DBH data from October shows that 47% of charter schools have no SBMH clinician supporting their students. I am here today to address the persistent and unacceptable number of vacancies of school-based mental health clinicians in charter schools and to share our concerns with the flawed methodology used by DBH in its environmental scan that informed the FY26 School Behavioral Health Program Comprehensive Plan. To be clear, we take no position on the recommendations of the Comprehensive Plan to bring clinical services in-house at DBH because we have not yet had an opportunity to review the recommendations thoroughly and discuss them with our member schools. Our concern is that too few students get the services they need.
Glaring Issues with Environmental Scan
Rather than utilizing a data-based survey, the DBH environmental scan relied on interviews with school behavioral health coordinators. This process proved labor-intensive and required school coordinators to provide information they weren’t likely to know without pulling data, such as student services focus, staff tenure, licensure levels, and current caseload capacity. Schools never had an opportunity to verify if their input was correctly recorded by DBH interviewers, and school-based coordinators were also unaware that their interview responses were going to be used to formulate the recommended support levels that their school receives under the proposed Comprehensive Plan.
These interviews were conducted through May, when leaders' answers were based on that school year's enrollment and staffing levels rather than the current year, despite our highly transient student populations. Especially given the new mental health challenges many students are experiencing this year related to heightened federal law enforcement and immigration activity, if this information is to be used to determine DBH service levels, surveys should be conducted annually. The timing also coincided with high-priority end-of-year assessments, causing many schools not to have an opportunity to participate.
Additionally, DBH proposes to categorize schools in levels of support based on existing staffing levels and school partnerships recorded during these interviews. We are deeply concerned by this methodology since it does not seem to take into account when the LEA has invested UPSFF or other funds for mental health services. Under this proposal, it appears that schools that invested in securing additional mental health support when none were provided by DBH would now be penalized and deprioritized for support. For example, a school that chose to invest in an additional social worker and forgo a reading specialist while awaiting a CBO clinician placement could be deemed “well-supported” and would not receive DBH clinical support.
Recommendations
While we understand the District’s fiscal challenges, this program has served fewer charter school students every year, while program funding has grown. We are not necessarily opposed to program changes, but we are concerned by DBH's flawed process that is informing the plan. We recommend:
First, conduct an additional data collection effort this school year to ensure any changes to the SBMH program are informed by current and accurate information about student mental health needs across all schools.
Second, host feedback sessions to help define the four model criteria and rubric for assigning service models. Schools should have input on their preferred model and an opportunity to provide data supporting their level of clinical needs.
Third, inform schools of service model changes at least one school year in advance, so they can plan and staff appropriately. For context, our schools are already coping with receiving only one week's notice in late September, so that if they had a clinician vacancy or were not matched with a CBO, they would not get DBH support for the school year, effective September 30.
Lastly, allow school leaders to participate in interviewing and selecting school-based clinicians to ensure alignment with school culture and mission. We also know that ongoing shortages of well-qualified clinicians will continue to be a challenge regardless of service model, and we recommend the District continue to invest in pipeline programs and pursue reciprocity agreements with surrounding jurisdictions to enhance the available pool of providers.
Moving Forward
The DC Alliance remains committed to partnering with our schools and the District to ensure all students have timely and equitable access to mental health support. We urge the District to learn from bringing school nurses in-house at DOH, where staffing gaps have persisted. As we consider a similar transition, we must address DBH's hiring capacity, competitive salaries, and the likelihood that not all CBO clinicians will choose to transition into a DBH role. Open communication is essential to avoid additional service disruptions. Thank you for your time. I welcome your questions.
