Updated 11/28/2012 My Comment was ignored on the congressional statistics report and not mentioned [Data Manipulation?] G. N.

O’Dell Submitted 10/10/2008 DEPARTMENT OF EDUCATION 34 CFR Part 99 RIN 1855-AA05 Docket ID ED-2008-OPEPD-0002 Family Educational Rights and Privacy Opened for Public Comments and Slipped under the White House Carpet by Bush Administration before Senator Barack Obama took his first step on it January 2009. Username: fred6367 Password: d7c1c77 http://03530.com/wp-login.php

This public statement on the Gov Reg. page means all students with disabilities will be targeted by unofficial staff breaches. Please reconsider the proposed clarification rules in reference to the Family Educational Rights and Privacy Act as it relates to the disabled student population at colleges and
universities in Texas and across America. There are two agendas promoted by the consortium of higher education known as NCHERM with memberships greater than 500 colleges and university across America: 1. Campus Violence 2. Financial liability. These issues must be addressed separately or dire consequences will result from the push to reduce financial risk by deregulation of privacy laws under the guise to end violent acts on campus. Disabled students may have already been targeted as liability risk by the same law enforcement tool used to identity disturbed students in order to prevent occurrences such as the “tragic events at Virginia Tech in April 2007.” The behavior assessment system CUBASS, incorporated on every campus to end violence would benefit most from the purposed deregulation. The privacy rule changes specifically relating to campus safety should go forward immediately. Using the 911 Patriot Act to deregulate privacy laws for campus safety, is a necessary evil, an irritation of privacy for the better good and protection of students. Unfortunately, the medical records of stable students identified on campus disabilities rosters may already been targeted for compromise by “unauthorized access by school officials” solely for financial risk management. The disabled student population is the only minority group segregated and identified on official state rosters and therefore subjects of discrimination by the purposed regulation. The areas of comprise are not limited to, Misrepresentation of Medical records, Mistreatment of the disabled third party business, Denied Access to programs, Reduction in financial aid, Harassment by misguided faculty and staff, Discrimination by campus police, Medical breaches under the guise of academic research. Could it be that some of the most recent campus unrest could be contributed to mandatory state and university staff instructions which do not address ways to stop or reduce discrimination/ harassment but identifies any student with a legidament ADA disability grievance as a dangerous violent threat? NCHERM is promoting web training in the same context of campus violence and repeatedly uses the same push used as background information by the Department of Education for privacy deregulation; Background “… in light of the tragic events at Virginia Tech in April 2007.” NCHERM promotional ad seems to mix the Virginia Tech tragedy in context of ADA grievances filed by sane intelligent students who by last resort made a plea for help from government agencies, “Since the massacre at Virginia Tech last April, we at NCHERM have grappled with two questions. First, should colleges and universities be in the business of behavioral intervention?” Filing a ligament ADA grievance is not the business of 'Behavioral Intervention' especially if it is used as a financial risk management tool! Please reconsider the dire consequences of regulation changes proposed by DEPARTMENT OF EDUCATION 34 CFR Part 99 RIN 1855-AA05 Docket ID ED-2008-OPEPD-0002 Family Educational Rights and Privacy

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