UPR003526-15 Manual 2942.0 SHSM Vol I DRAFT master

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DoDEA School Health Services Manual 2942.0 Volume 1 Revised: 2016 DRAFT
consent from the sponsor/parent/guardian to administer medication and
individual medication administration logs for both routine and as-needed
medications;
7. Primary care manager/providers’ orders, correspondence, evaluation reports,
copies of treatment records, institutional or agency records and discharge
summaries from outside health care providers or hospitals that have been
released by the sponsor/parent/guardian to assist in planning individualized
school health care or programs;
8. Specialized assessments, such as neurologic tests;
9. IHPs or EAPs for students with special health care needs, including routine
and emergency interventions and methods for evaluating student outcomes;
and
10.Health-related goals and objectives, a Section 504 Accommodation Plan or an
IHP contained within a student’s IEP for students whose health conditions
affect their educational needs.
C-3-4 Protecting Student Health Information
A. Private Data
Student health records are records that contain PII that merit special protection
against public disclosure by Federal law. They are among the group of records that are
retrieved by name of personal identifier and are therefore classified as PA-protected
records. In the public schools, the governing statute is FERPA. Under the FERPA and
the PA, only the sponsor/parent/guardian or student has a right to access this data.
Beyond the right of access, disclosure rules under the FERPA and the PA often differ
and school nurses must understand the PA rules.
For example, under the PA, unlike the FERPA that allows access to anyone with a
legitimate educational interest, PA-protected records may be disclosed within the school
to another person who has a need to perform an official duty (correspondingly similar
to FERPA’s legitimate educational interest). However, unlike the FERPA that allows
nonconsensual disclosure to anyone in any school or educational activity with a
legitimate educational interest, DoDEA’s PA protection allows disclosure within DoDEA
or DoD to a person who can demonstrate an official need to know. If DoDEA collected
the information in its files for a purpose that is consistent with the requesting DoD
official’s need to know to perform an official duty. Moreover, the PA forbids DoDEA
from disclosing information to anyone outside DoD without the written consent of the
sponsor/parent/guardian or the eligible student, except as authorized by published
“routine uses” in a DoDEA, DoD, or government-wide SORN. (See System of Records
Notice 26 at: