D. Stafford & Associates has significant expertise with the Drug Free Schools & Communities Act of 1989 (DFSCA). The U.S. Department of Education’s Office of Federal Student Aid is responsible for monitoring and enforcing compliance with this law, which requires institutions to develop a written Drug and Alcohol Abuse Prevention Program (DAAPP), annually distribute the DAAPP to current students and employees, and conduct a biennial review to determine the DAAPP’s effectiveness and ensure consistency of sanction enforcement (the biennial review must be documented in the form of a Biennial Review Report).
D. Stafford & Associates (DSA) offers the following services related to DFSCA compliance.
DAAPP Development
DSA can work remotely with institutional officials to develop institution-specific Drug and Alcohol Abuse Prevention Program (DAAPP) materials that includes all required components. This service includes an introductory webinar (up to 2 hours) that provides an overview of the DFSCA’s requirements concerning the DAAPP as well as a discussion of the steps involved in developing the initial DAAPP draft. DSA will provide detailed instructions to the institution for compiling institution and jurisdiction-specific information that must be included in the DAAPP. Upon receipt of this information from the institution, DSA will develop a draft DAAPP for the institution’s review and finalization (noting any lingering questions, comments, or gaps based on materials provided). A final web-based meeting (up to 2 hours) will be conducted with appropriate institutional personnel to discuss the draft DAAPP and facilitate a discussion about the procedures and practices that the institution needs to implement to ensure on-going compliance with the DFSCA requirements. (Note: A second review of the DAAPP that focuses on any changes made by the institution in response to our feedback can be added to the scope of work at the request of an institution).
Deliverables:
- An introductory webinar (up to 2 hours) that provides an overview of the DFSCA’s requirements concerning the DAAPP as well as a discussion of the steps involved in developing the initial DAAPP draft;
- A draft DAAPP (in Microsoft Word) that identifies any comments or issues that require resolution by institutional officials prior to finalizing and distributing the DAAPP; and
- A final web-based meeting (up to 2 hours) will be conducted with appropriate institutional personnel to discuss the draft DAAPP and facilitate a discussion about the procedures and practices that the institution needs to implement to ensure on-going compliance with the DFSCA requirements.
DAAPP Review
DSA can conduct an off-site review of the materials used by the institution as its Drug and Alcohol Abuse Prevention Program (DAAPP) for students and employees. We will begin by presenting an introductory webinar (up to 2 hours) that provides an overview of the DFSCA’s requirements, focusing on required components of a compliant DAAPP. DSA will then use Microsoft Word’s “track changes” and “comments” features to identify recommended enhancements and modifications that will improve the clarity and comprehensiveness of the DAAPP. A written report summarizing our main findings and recommendations will be provided to the institution along with a track-changed version of the DAAPP to assist the institution in bringing the DAAPP into full compliance with the requirements of the DFSCA. DSA will conclude the project with a web-based meeting (up to 2 hours) involving appropriate institutional personnel to discuss any questions about our feedback. (Note: A second review of the DAAPP that focuses on any changes made by the institution in response to our feedback can be added to the scope of work at the request of an institution).
Deliverables:
- An introductory webinar (up to 2 hours) that provides an overview of the DFSCA’s requirements concerning the DAAPP;
- A track-changed DAAPP that identifies any comments or issues that require revisions or enhancements by the institution to bring the DAAPP into full compliance with the requirements of the DFSCA;
- A written report outlining DSA’s findings and recommendations for enhancing the DAAPP; and
- A final web-based meeting (up to 2 hours) with appropriate institutional personnel to discuss any remaining questions or concerns regarding our feedback on the institution’s current DAAPP.
DAAPP Distribution Review
Often combined with our DAAPP Development or DAAPP Review service, DSA can review the existing process for distributing the DAAPP to all students and employees. The review will include any existing written procedures pertaining to the DAAPP’s distribution as well as interviews of key personnel involved in the DAAPP’s distribution. Based on our document analysis and interviews, we will help the institution develop a draft protocol to distribute the DAAPP to all students and employees, including those students who enroll, or employees who are hired, after the DAAPP’s initial distribution.
Deliverables:
- A written report outlining DSA’s findings and recommendations for distributing the DAAPP; and
- A draft protocol for distributing the DAAPP to students and employees of the institution.
Biennial Review Report Review
DSA will review the most recent Biennial Review Report completed by the institution to ensure it includes the information required by statute (20 U.S.C. 1145g), the implementing regulations (34 C.F.R. §86), and the U.S. Department of Education when it conducts DFSCA compliance reviews. (Note: DSA can also review a draft report the institution has prepared pursuant to an in-progress review).
The review will begin with a web-based meeting (up to 1 hour) with all individuals involved in the most recent biennial review to determine the process utilized to conduct the review and to discuss how the report was developed. At the institution’s request, this meeting can include a webinar (up to 1 hour) that provides an overview of the biennial review requirements and essential report components.
Following the web-based meeting, DSA will conduct an off-site review of the report and prepare a draft report of our findings and recommendations. Following submission of a draft report, DSA will conduct a meeting (up to 1 hour) with appropriate officials to address any questions or concerns about DSA’s draft report and recommendations prior to submitting a final report to the institution.
Deliverables:
- (optional) A webinar (up to 1 hour) that provides an overview of the biennial review requirements and essential Biennial Review Report components;
- A written report outlining DSA’s findings and recommendations concerning the institution’s Biennial Review Report; and
- A final web-based meeting (up to 1 hour) with appropriate institutional personnel to discuss any remaining questions or concerns regarding our feedback on the institution’s Biennial Review Report.
Biennial Review Process Assistance
DSA can provide instructions and resources that will assist institutions in developing a compliance-aware approach to conducting a biennial review of the effectiveness of the institution’s drug and alcohol abuse prevention program and consistency of sanction enforcement.
To accomplish this goal, DSA will conduct an introductory webinar (up to 2 hours) for appropriate institutional stakeholders that will be involved in the review. The webinar will provide an overview of the biennial review requirements, recommended steps for conducting a review, and an overview of biennial review report requirements. Following the webinar, DSA will provide the institution with written guidance to help the institution conduct its review and develop a draft Biennial Review Report. (Note: The specific research methods and data analysis tools used to complete the review will be wholly decided and implemented by the institution, not DSA).
Following submission of a draft Biennial Review Report to DSA by the institution, DSA will review the draft report to ensure it includes the information required by statute (20 U.S.C. 1145g), the implementing regulations (34 C.F.R. §86), and the U.S. Department of Education when it conducts DFSCA compliance reviews. We will prepare a draft report of our findings and recommendations concerning the institution’s draft Biennial Review Report.
Following submission of DSA’s draft report to the institution, DSA will conduct a meeting (up to 1 hour) with appropriate officials to address any questions or concerns about DSA’s draft report and recommendations. After this meeting, DSA will submit a final report to the institution outlining our findings and recommendations concerning the institution’s draft Biennial Review Report.
Deliverables:
- A webinar (up to 2 hours) that provides an overview of the biennial review requirements, recommended steps for conducting a review, and an overview of biennial review report requirements;
- A written report outlining DSA’s findings and recommendations concerning the institution’s draft Biennial Review Report; and
- A final web-based meeting (up to 1 hour) with appropriate institutional personnel to discuss any remaining questions or concerns regarding our feedback on the institution’s Biennial Review Report.
(optional) A written policy or operating procedure to ensure that all biennial reviews are fully documented, inclusive of all required information, conducted on the appropriate schedule, and maintained for the required duration.
On-Site or Virtual DFSCA Training Classes for Institutions, Consortia, or Systems of Higher Education
D. Stafford & Associates provides on-site or virtual training classes for individual institutions of higher education as well as consortia or systems that wish to bring DFSCA training to their employees/members. DSA will suggest the involvement of various campus administrators, depending on the identified needs of the institution.
Training options include a 2 hour, half-day or full-day training. Training can be customized to meet the needs and interests of the institution/system but will generally cover:
- the content that must be included in each institution’s Drug and Alcohol Abuse Prevention Program (DAAPP);
- requirements and strategies for annually distributing the DAAPP to students and employees; and
- conducting biennial reviews and preparing biennial review reports.
As part of the full-day training option, participants will have an opportunity to evaluate the adequacy of their institution’s DAAPP and its distribution via exercises facilitated by the instructor. Furthermore, for consortia or systems of higher education that engage DSA to provide a full-day training, a survey of participating institutions will be distributed prior to the session to provide the instructor with insights regarding current compliance practices at participating schools to help inform the training’s content, focus, and/or exercise facilitation (if applicable).