The purpose of the District Audit Report (DAR) is to provide key results of the safety and security audits completed by Texas public school districts. The Texas Education Code (TEC) requires districts to complete safety and security audits of their facilities once every three years (§37.108(4)(b)), in accordance with procedures developed by the Texas School Safety Center (TxSSC) or a person included in the registry established by the TxSSC (§37.108(b)). Districts then submit a summary of the findings to the TxSSC (§37.207(b)), where reviewers aggregate data into a statewide report for the public (§37.207(a)(3)).

The TxSSC provides guidance for districts to develop safety and security audit procedures as well as tools to assist in the assessments (§37.207(1)). The TxSSC School Safety and Security Audit Toolkit includes step-by-step guidance and job aids for conducting audits, as well as comprehensive district facility audit checklists. The toolkit contains a series of spreadsheets with specific evaluation statements for a variety of facilities and functions. These statements are a combination of best practices, promising practices, and/or requirements appropriate for certain types of facilities. Model safety and security audit procedures developed by the TxSSC are available for use by districts or contractors to conduct safety and security audits. Neither the TEC nor administrative rules require that school district personnel conducting the audit hold a specific certification. Whether districts decide to conduct their own audit or hire someone from the Texas School Safety and Security Registry, it is a best practice to ensure the audit is reviewed from various disciplines or perspectives and include a cross-functional group of school personnel and collaborative community partners (e.g., local first responders).

While the term "audit" is included in TEC §37.108 and used throughout this report for consistency, the process was developed as an ongoing self-assessment of a district’s safety and security. Audits should be an ongoing process of identifying specific district, campus, or facility hazards, threats, and vulnerabilities and making improvements in safety and security plans and processes.

Method

The DAR provides a summary of safety and security information, which is an aggregate of self-reported data submitted by Texas public school districts, for the reporting cycle of September 1, 2017 through October 31, 2020 (deadline extended due to COVID-19). The Texas Legislature authorizes the TxSSC to determine the method used to collect audit results. Data were collected via the DARtool, an online reporting mechanism developed by the TxSSC and deployed using Qualtrics (an online survey programming software). The DARtool allowed district superintendents or their designees to report specific audit information electronically. Data from the DARtool were analyzed and reported at an aggregate level.

The TxSSC did not substantiate the totality of the data reported by districts and the accuracy of responses received from each district was presumed. The TxSSC does verify some aspects of the reported data to assess district safety and security in relation to legislative mandates. The TxSSC took measures to safeguard the confidentiality of each reporting district by structuring the questionnaire to protect against identification. According to TEC §37.108(c-1), safety and security audit information is not subject to disclosure. However, certain exceptions regarding disclosure are permitted under TEC §37.108(c-2).

The TxSSC attempted to collect audit information from 1,022 public school districts including Independent School Districts (ISDs), Common School Districts (CSDs), the Texas School for the Deaf, and the Texas School for the Blind and Visually Impaired.

A total of 1,022 (100.0%) districts reported audit results via the DARtool for this cycle (2017-2020). The following section provides key findings and recommendations from the safety and security audits of school districts in Texas.

Key Findings and Recommendations

As evidenced by the 2017-2020 District Audit Report, Texas school districts continue to work persistently toward creating safe and supportive school environments. The data collected during this reporting period suggest most Texas public school districts are implementing safety and security measures required under Chapter 37 of the Texas Education Code, as well as guidance and best practices.

Since 2005, the Texas Education Code has required every school district to adopt and implement a multi-hazard emergency operations plan (EOP). Beginning in 2020, the TxSSC conducted a cursory overview of the statewide status of all 1,022 K-12 public school EOPs. The review criteria included evaluating whether each district had an EOP, and furthermore, whether the EOP was sufficient.

The following recommendations, which are based on a cross-comparison between findings from the district audit report and the EOP reviews, are proposed to further assist schools in their pursuit of safe and secure learning environments.

1. School districts must continue to develop and implement a multi-hazard emergency operations plan.
   

   The audit findings indicate 986 districts reported having adopted an EOP. However, of the 1,022 districts in the EOP review process, the TxSSC determined that 162 districts did not have an existing EOP. Further, only 67 districts statewide had an EOP that was deemed sufficient, meaning it met the common or best practices necessary to be a viable EOP.

2. School districts must ensure they have a chain of command that includes a primary, secondary, and tertiary designee.

   The audit findings indicate 973 districts reported they have designated personnel responsible for making final decisions during a disaster or emergency, as well as other individuals responsible for making those decisions if the designated person is unavailable. Of the 1,022 district EOPs reviewed by the TxSSC, 304 did not have a designation and 126 had an insufficient designation.

3. School districts with a campus within 1,000 yards of a railroad track must implement a train derailment policy.

   The audit findings showed 486 districts reported they have a campus located within 1,000 yards of a railroad track and 415 districts reported they have a non-instructional facility located within 1,000 yards of a railroad track. Based on our EOP review, we determined that 545 school districts have a campus and/or non-instructional facility within 1,000 yards of a railroad track. Of these 545 districts, only 189 districts had a complete railroad policy as part of their EOP. Of the remaining 356 districts, 305 districts did not have any form of a policy and 51 had a policy that was insufficient.
   

4. School districts must develop an active shooter policy that should be part of an overall active threat annex.

   Through the audit reporting process, a total of 939 districts reported their EOP includes a policy for responding to an active shooter emergency. However, the EOP review indicated that of the 1,022 districts reviewed, only 200 had a viable active shooter policy. Of the remaining 822 districts, 626 districts did not have a policy in place and 196 districts had an insufficient policy.
   

5. School districts should develop a comprehensive hazard analysis.
   

   Through the audit reporting process, districts reported whether they had conducted a threat and hazard identification and risk assessment (THIRA). A total of 693 districts indicated they had completed this assessment. In our EOP review process, reviewers determined if a district had conducted a comprehensive hazard analysis, even if it was not labeled as a THIRA. The review showed that 541 districts had completed a comprehensive hazard analysis, while 284 had not. Further, 197 districts had an insufficient hazard analysis.

6. School districts should develop a continuity of operations plan as part of their multi-hazard emergency operations plan.

   In the audit report, a total of 852 districts indicated their EOP contained a continuity of operations plan (COOP). As part of the EOP review process, the TxSSC did an in-depth review of each district’s COOP. The TxSSC determined that 269 districts had a complete and viable COOP. Of the remaining 753 districts, 512 districts did not have a COOP and 241 districts had an insufficient COOP.

7. School districts should develop a communicable disease annex.
   

   Through the audit reporting process, districts reported whether they had a plan in place to address communicable disease prior to the COVID-19 pandemic and if they have a plan in place now. A total of 512 districts indicated they had a plan in place prior to COVID-19, and a total 857 districts responded that they currently have a plan. As part of the EOP review process, the TxSSC did an in-depth review of each district’s communicable disease annex (CDA). The EOP review process revealed that 488 districts had a viable CDA, 423 had no CDA, and 166 had an insufficient CDA.