August 18, 2025

Dana Carr

U.S. Department of Education
400 Maryland Ave SW, Room 4B210
Washington, DC 20202-6450

Re: Comment on The Department of Education (Department) proposes priorities, requirements, and definitions under the Mental Health Service Professional Demonstration Grant Program (MHSP), Assistance Listing Number (ALN) 84.184X.  Docket ID ED-2025-OESE-0153

Dear Ms. Dana Carr,

We provide these comments on the Department’s proposed supplemental priorities related to school-based mental health professionals and psychologists. Student mental health should be a core value in education. When mental health is prioritized by education agencies, students’ well-being increases, subsequently leading to reductions in chronic absenteeism and improved academic outcomes. While these areas reflect important investments in student support systems, the proposed approaches require changes to ensure the variety of needs of all students are met, particularly those who are traditionally underserved. Our comments outline opportunities for federal investment and the critical adjustments needed to strengthen equity in mental health services and ensure all students have access to culturally affirming, high quality support.

The Importance of School Psychologists

We support the Department’s recognition of the urgent need to expand the pipeline of credentialed school psychologists and applaud efforts to incentivize recruitment and specialization pathways. School psychologists are vital to creating healthy learning environments, addressing trauma, and ensuring students’ mental health needs are met. However, recruitment alone is not enough. It is essential that new and existing school psychologists receive training in culturally responsive practices and equity-centered frameworks. Without an informed approach, professionals may interpret culturally influenced behaviors as problematic, overlook the impact of racial disparities, and fail to build trust with students and families. This can also lead to misdiagnosis, inappropriate interventions, disengagement from support services, and eventually, school all together. The best way is to support students according to their needs. EdTrust’s report, How to Prioritize Funding for Students shares how Texas Education Association invested in support and guidance to LEAs on how to maximize existing and newly hired mental-health professionals on their campuses, including resources and guidance on mental health screening, connecting to local or regional mental health resources, and providing information resources on the impacts of grief and trauma-informed care.

Without these, the increase in staffing could inadvertently replicate or worsen disparities in how students—particularly students of color, multilingual learners, LGBTQ+ students, and students with disabilities—experience school based mental health services.

The Role of Culturally Affirming Educators and Mental Health Professionals

As the Department continues its work on student mental health and related issues, we urge a strong investment in educators and school-based professionals who are not only credentialed but also prepared to create culturally affirming environments. Research confirms that students thrive when they feel seen, valued, and connected. Mental health professionals who understand their students’ cultural backgrounds, build meaningful relationships, and affirm students’ identities are essential for fostering the conditions that support academic success. This includes training educators and mental health professionals in healing-centered engagement, restorative practices, and culturally responsive communication. It is especially critical to invest in professional development that equips school staff to respond to students’ lived experiences with empathy and respect to meet expectations.

Concerns About Restrictive Language and Its Impact on Equity and Belonging

We are deeply concerned about the proposed language prohibiting the use of program funds for “promoting or endorsing gender ideology, political activism, racial stereotyping, or hostile environments for students of particular races.” Policies that discourage inclusive and equitable practices stifle honest conversations about race, gender, and identity do not create safer environments. Instead, they risk isolating students, invalidating their experiences, and breaking the trust that is foundational to strong school communities. The American Psychologists Association found that only 5% of psychologists are Black and only 8% are Hispanic. Ensuring that all students have representation should be a priority, especially when students tend to seek help from professionals who can relate to their experiences. If it is the intent of the administration to recruit more professionals to support the mental health of students, this language in the proposed priorities will only widen the gaps of under-representation for psychologists of color.

All students need to feel supported by school-based mental health professionals who understand their lived experiences and affirm their identities. When school psychologists and other mental health staff are not trained in culturally responsive practices, students may feel misunderstood, unsafe, or invisible in the very spaces meant to support them. This not only harms their mental health and sense of belonging but also impacts their willingness to attend school regularly and engage in learning. We urge the Department to remove this language and revise with; “ensure students are in supportive learning environments that are inclusive where all students are affirmed and connected.”

As outlined above, ensuring all students feel seen, valued and connected are proven practices that support their mental health and well-being. By training school psychologists in a culturally responsive manner, expected outcomes will be improved student experiences and academic success. We are happy to provide support here should the department desire to learn more on this important issue.

Signed,

American Atheists
EDGE Partners
EdTrust
League of United Latin American Citizens (LULAC)
National Center for Learning Disabilities
National Urban League
Parents for Public Schools
Students Engaged in Advancing Texas
StudentsFirstNY
The Center for Learner Equity