The Allegheny County
Department of Human Services and Pittsburgh Public Schools took a major step
last year toward closing a knowledge gap that prevents schools and human
service agencies around the country from developing a deeper understanding of
the children in their systems and collaborating on more effective, better
targeted strategies for improving children’s academic performance and overall
After more than a year of research
and negotiation, county human services and city public school officials reached
a memorandum of understanding that enables them to integrate previously
segregated data on students enrolled in the city’s public schools.
Integrating data on issues
ranging from student achievement and attendance to housing, child welfare, and
mental health services offers several potential advantages. It could, for
example, help school officials better understand circumstances outside of school
that influence the performance and behavior of students in school. Child
welfare caseworkers could more reliably monitor how their young clients are
doing academically and whether they are attending school regularly. A research
partnership could lead to a better understanding of the impact interventions
have on children’s education. And it could provide the basis for richer
analyses, which, in turn, could help identify areas of need and suggest new
approaches to addressing them.
The concept of integrating
data was fairly straightforward. However, finding a way to do so was a
challenge that had deterred previous attempts to negotiate an agreement. Among
the major obstacles were state and federal laws that protect the
confidentiality of personal education and health information whose web of
restrictions made sharing data a daunting legal challenge.
The Data Sharing
The memorandum of
understanding (MOU) provides the framework for integrating school district and
Department of Human Services (DHS) data, including confidentiality provisions,
responsibilities of the parties, and the type of information that can be shared
and for what purposes.
Provisions within the MOU
include the following:
- DHS is responsible for
performing the actual integration and analysis of student data.
- The school district’s
responsibilities include providing DHS with directory information and
educational records of those students for whom DHS has legal custody.
- The school district also
provides certain information for other students enrolled, including personal
identifiers, such as names and home addresses; achievement data, such as grade
point averages; attendance; and data on students in special programming,
including the district’s Student Assistance Program, special education, and
- All student data provided
by the school district is considered confidential, and state and federal laws
that apply to student records govern its release.
- All reports prepared from
the data that contain personally identifiable information are considered to be
- DHS agreed to seek parental
consent for releasing student records when the data suggest students might
benefit from additional intervention and direct collaboration between DHS and
the school district.
A key provision of the
agreement authorizes the use of the data for conducting an "action research"
project, a problem-solving process in which DHS and the school district work
toward improving the way they address certain issues involving students of
DHS uses the data to
prepare analytical reports related to students in the city schools who receive
human services for the purpose of identifying attributes and indicators related
to academic successes and challenges. The analyses serve as the basis for
collaborative efforts to develop strategies for improving the way DHS and the
public schools address the needs of students and their families. DHS and the
schools are charged with creating, implementing, and evaluating the strategies.
The agreement also calls
for DHS and Pittsburgh Public Schools to engage community stakeholders,
including the Youth Futures Commission, which convenes leaders in the public
and private sectors around developing and implementing strategies for preventing
youth violence and improving opportunity for children and youth.
The emergence of the Youth
Futures Commission in Allegheny County was a key factor in moving the concept
of integrating DHS and school district data from a topic of periodic discussion
to reality. The commission, created in 2007, evolved from a similar initiative,
the Youth Crime Prevention Council, which was established 13 years earlier at
the urging of former U.S. Attorney for the Western District of Pennsylvania
Frederick Thieman to better organize prevention efforts and law enforcement to
address juvenile crime and violence.
One of the commission’s
first subcommittees was assigned the task of investigating the issue of
cross-systems data sharing, but the idea initially met with skepticism. School
officials, in particular, expressed doubt that a data-sharing arrangement with
DHS was feasible.
Early discussions, however,
underscored the need for such an agreement, said Thieman, Youth Futures Commission
co-chair and president of the Buhl Foundation. “You would hear someone say, ‘We
don’t know who the homeless students are.’ Or, ‘We don’t know if our kids have
been arrested.’ Or, on the county side, ‘We don’t know if someone we are
providing services to is going to school or not.’ This was the reason why
something like the Youth Futures Commission should exist. Its whole purpose is
to try and address issues that can’t be addressed by less than a coordinated
and concerted effort. It seemed a logical place to go.”
The knowledge gap was also
apparent to others. John Wallace realized the implications when he sought
information about the children in the city neighborhood of Homewood, where he
was organizing the Homewood Children’s Village. The initiative, modeled after
the Harlem Children’s Zone in New York, concentrates community support and
comprehensive services to improve children’s educational outcomes, health, and
social and physical well being.
Without integrated school
and DHS data, constructing a holistic portrait of Homewood’s children was not
possible. No one, for example, was able to explain why one Homewood girl went
from earning straight “A”s through 8th grade to having a 1.7 grade point
average in her senior year, which left her ineligible for the district’s
Pittsburgh Promise scholarship program.
happened in this young woman’s life to cause her to go from a straight-A
student down to a 1.7,” said Wallace, president of the Homewood Children’s
Village board, and associate professor of social work at the University of
Pittsburgh. “Part of the Homewood Children’s Village task is to remove to the
extent possible nonacademic barriers to kids’ academic success. As it stands
now, we don’t know what those things are. And unless you have a relationship
with a kid you may never know.”
Reaching a data sharing agreement
between the school district and DHS meant overcoming challenges that had frustrated
previous efforts. Four stood as major obstacles.
- Attitudes toward data
disclosure. After years of being inundated with requests for student data from
outside researchers, school officials had grown cautious about doing so. Key
concerns were the confidentiality of personally identifiable information and
whether the release of data would benefit the district and its students.
- Legal. Laws restricting the
release of student data include the federal Family Educational Rights and
Privacy Act of 1974 (FERPA), which controls disclosure of education records. In
most cases, student or parent consent is needed to disclose records such as
grades, test scores, and behavior information. About 30 laws protect DHS-held
data, including the 1996 Health Insurance Portability and Accountability Act
(HIPAA). Consent is almost always necessary to disclose child or family health
data, including information about mental health and drug and alcohol issues and
- Technical. Integrating the
data included merging school information on 26,000 students with information in
the DHS data warehouse related to human services, such?as child welfare and
mental health, as well data from juvenile probation and other outside sources.
Key issues included system compatibility and the capacity to mine data to gain
insight into students of mutual interest.
- Cost. Financial issues
included start-up costs of integrating, processing, and analyzing the data,
operational costs and who would pay for them.
Thieman assumed the role of
a neutral third-party facilitator and was able to gain the support of top
school district and DHS leadership for sharing data, which was critical to overcoming
the obstacles to reaching a legal agreement.
Pathways to the
The launch of the
Pittsburgh Promise in 2007 gave the Pittsburgh Public Schools additional
motivation for gaining a more complete profile of its students and their
families. The scholarship program offers all city public school graduates who
meet residency, academic and attendance requirements up to $10,000 a year
toward the cost of attending a college, university, or technical school in
It led to a district-wide
initiative to help students become “Promise ready” and a goal of having at least
80 percent of graduates finish college or a workforce certification program.
Under Pathways to the Promise, the district put in place programs to strengthen
teaching, counseling, curriculum, administration, and other areas critical to
improving the educational environment and preparing students to earn
scholarships and continue their education.
The potential benefits of
integrating data with DHS include developing a more effective accounting of
students receiving human services, the types of services they receive, how they
are performing in school, whether there are other students in need of support
who have not been identified, and other information that would help marshal
resources to improve student outcomes.
Gap in DHS Data
Some 230,000 Allegheny County
residents are involved with the DHS network, which includes mental health, drug
and alcohol, child protection, at-risk child development and education, housing
for the homeless, and other services. The majority of those involved in such
services live in the city of Pittsburgh.
Many are of school age and
attend Pittsburgh Public Schools. More than 13,600 students—about 49 percent of
the students in the district—have been involved in a DHS service at some point
in their lives. Some 39 percent of the 11,990 children in the child welfare
system in 2008 lived in the school district, as did 36 percent of the children
who received mental health services. Children living in the city also account
for 44 percent of the youths involved in drug and alcohol services as well as
41 percent of the youths involved in the Juvenile Court system.
More than a decade ago, DHS
began a series of reforms built on openness to new ideas, integration, and
multi-system collaboration, which has led to innovative initiatives and earned
Allegheny County standing as a national model for human services. The reform
efforts were supported by significant contributions from the region’s
foundation community. For example, contributions made by 16 foundations led to
the creation of the Human Services Integration Fund to support the coordinated,
comprehensive delivery of services.
A data warehouse was
created with nearly $3 million from the Human Services Integration Fund in 2000
as a central repository of human services data. The data warehouse staff and
computer architecture enable DHS to process and analyze millions of client
records to improve services and delivery and to better inform decision making.
The data warehouse grew to include more than 25 different data systems.
However, data from school districts remained elusive.
“School districts have
always been a high priority because so many of the kids we deal with are in the
schools and it would be helpful to know more about them in school,” said Marc
Cherna, DHS director. “But for many years it was very difficult to even have
any conversations about that. They were not inclined to share their
information. They would quickly talk about FERPA and why they couldn’t do it.”
Following an assessment of
the issues that had frustrated past efforts to draft a data-sharing agreement,
Thieman met with Pittsburgh Public Schools Solicitor Ira Weiss and a strategy
emerged. “In our discussions, we agreed that the legal issues were significant,
but where there was the will there was a way to deal with the legal issues,”
Thieman said. “We also felt that the place to start was with the cost and
Getting the most
comprehensive picture of Pittsburgh Public School students involved with DHS
requires integrating huge amounts of data. Key DHS data includes information
from Children, Youth and Families—the county’s child welfare system—as well as
from mental health, homeless services, and drug and alcohol services.
School-related data includes names, addresses, the schools students attend,
grade-point averages, standardized test scores, behavior-related issues, and
student involvement in special programs and services.
Technical issues included
the capacity to manage a large volume of data and to integrate data from dozens
of different information systems. Another was the analytical capacity to mine
the data in ways that would enable DHS and the school district to gain insight
into students of mutual interest, identify gaps in services, evaluate the
effectiveness of interventions, and to inform decisions, such as where to
target limited resources, how to coordinate service delivery, and whether new
interventions are needed to address unmet needs.
The DHS data warehouse
offered the capacity to perform such tasks and was a key factor in resolving
the issue of technical feasibility. The data warehouse contains more than 15
million records from DHS programs and outside systems, including the state
Department of Public Welfare, housing authorities, juvenile justice, Head
Start, and the Allegheny County Jail.
“The strength of the
technical capacity was on the DHS side,” said Erin Dalton, DHS deputy director
in charge of the Office of Data Analysis, Research and Evaluation. “We’ve
continued to invest in improving the system. We have the technical
infrastructure and analytic expertise. We have a matching algorithm that seeks
to uniquely identify and align records and we’ve had 13 years of experience
The issue of who would pay
the start-up and operating costs of the proposed data-sharing system was also
resolved relatively quickly. Given the existing resources at the DHS data
warehouse it was determined that the cost of the new initiative would not be
significant, and Thieman and DHS Director Cherna assured the school district
they would find the funds to support the initiative. The foundations involved
in Human Services Integration Fund agreed to release funds to cover costs such
as data integration and a dedicated analyst.
“The school district didn’t
have the money and we didn’t want resources and finances to be a barrier,” said
Cherna. “Having those private sector partners makes all of the difference in
the world. Without that resource, this wouldn’t have happened.”
Reaching a data sharing
agreement also required gaining the confidence of school district officials,
particularly the school board. “The biggest concern—the one everyone asked
about over and over and over—was making sure that no one would be allowed to
get into that information without proper authority,” said Theresa Colaizzi,
president of the Pittsburgh Public Schools Board of Directors.
In addition to
confidentiality, other concerns included the integrity of research and making
sure that the district would not simply be providing subjects for study, but
would be gaining knowledge useful to improving student outcomes, which had not
always been the case in the past. A series of meeting with school officials,
DHS officials, and Thieman helped ease those concerns.
Interest among school
officials in learning the specifics of how student data would be used and the
types of interventions that would result from integration presented another
challenge. Among the ways the issue was resolved was discussing ideas with school
officials about the types of analyses that might be possible and providing data
that showed that nearly 40 percent of the children DHS serves live within the
boundaries of Pittsburgh Public Schools.
confidentiality concerns of school officials were worked out by school district
and DHS attorneys who worked for nearly a year to strike a balance between
adequately protecting student information and providing a level of access that
would make sharing data a useful and effective tool for improving the outcomes
A data sharing agreement
similar in scope to the one proposed for DHS and the Pittsburgh Public Schools
had never been drafted elsewhere in the United States. Likely reasons include
confidentiality laws that apply to schools and the fact that urban districts,
in particular, attract numerous requests to conduct research on their student
populations. “They’re a Petri dish for all sorts of things,” said Weiss. “So
you often have a cautious reaction.”
The general legal challenge
was to find enough flexibility in confidentiality laws to make data sharing
feasible. For example, consent is generally required to release education and
health data under FERPA and HIPAA, but obtaining consent for thousands of
students would be difficult, time-consuming and uncertain.
“At first it seemed like we
were at a log jam and it would be impossible,” said Paul Molter, assistant
county solicitor with DHS. “But we both said rather than saying what can’t we
do let’s focus on what can we do. And we were eventually able to get most of
the functionality we wanted and comply with the laws.”
Restrictions contained in
HIPAA and more than two dozen other laws and regulations made it difficult for
DHS to integrate data with the school district without explicit consent. The
course chosen was to find a way to entrust DHS with school district data and
build into the agreement protections against unauthorized disclosure.
Attorneys also identified
data that could be shared without consent, such as the release of school
directory information, including name, age, address, and school the student
attends. Certain DHS data could also be shared. For example, the release of
school information about a child could be authorized, if DHS was his/her
appointed legal custodian. And, in general, explicit consent is not necessary
to share student data when the data are presented in aggregate without
information that can identify individual students.
But creating a more robust
data-sharing arrangement required access to an even broader pool of student
information. Attorneys found the solution in a recent amendment to FERPA, which
provided a more detailed description of the law’s research exception. Under the
law, consent is not required to release student data to organizations
conducting certain studies for the district.
The exception allowed the
school district to integrate data without consent as part of an “action
research” project undertaken with DHS to identify indicators of academic and
behavior successes and deficits, prepare statistical analyses, and develop and
implement strategies and interventions for improving service delivery and
student academic outcomes. Positioning the data-sharing arrangement as such a
research project enabled attorneys to draft an agreement that was the first of
its kind in the nation.
School data was flowing
into the DHS data warehouse by the summer of 2010 and select data sets were
analyzed to test the system’s capabilities.
A few months later, the
first research project was defined from an analysis of shared data, which
identified 99 students in grades 6 through 9 with some level of involvement in
DHS who scored well on standardized proficiency tests, but are performing
poorly at school as measured by GPA and attendance. The data revealed, for
example, that 80 percent of the students had been involved in mental health
services, 60 percent in the child welfare system, and 27 percent had been
involved in the juvenile justice system at some point in their lives.
Researchers hope to
determine the problems that beset these children and the effectiveness of
existing interventions, and create strategies for improving attendance,
academic performance, and the students’ chances of graduating with a level of
achievement that would earn them Pittsburgh Promise scholarships.
Without the ability to
share data the opportunity to direct those students toward the success they
have shown the potential to achieve would likely have been missed, said DHS
Director Cherna. “We wouldn’t have picked up on any of these kids—we would have
Fraser, J. (2011).
Framework for Collaboration: The Memorandum of Understanding between Allegheny
County DHS and Pittsburgh Public Schools. Pittsburgh, PA: Allegheny County
Department of Human Resources. www.alleghenycounty.us/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=32826