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Student Identification Cards and CA Law: Private School Perspective
The interplay between California private schools and state mandates for resources on student identification cards has a multi-year history that illustrates the nuance and tension between private schools and state regulations. As SB 1063 becomes the governing law for all schools, including private schools, for the 2025-2026 academic year, it provides an opportunity for CAPSO to share a history of the interactions between state legislators and the California Association of Private School Organizations (CAPSO) on the topic of pupil IDs.
In 2018, SB 972 was introduced. This piece of legislation sought to add section 215.5 to the CA Education Code, reading "commencing July 1, 2019, a public school, including a charter school, or a private school, that serves pupils in any of grades 7 to 12, inclusive, and that issues pupil identification cards shall have printed on either side of the pupil identification cards... The telephone number for the National Suicide Prevention Lifeline, 1-800-273-8255."
CAPSO discussed this piece of legislation in 2018 and did not oppose the bill because there was a tolerance for the inclusion of a national resource that would provide immediate service and subsequent resources that were responsive to student needs.
In 2019, AB 624 was proposed to add to section 215.5 of the CA Education Code. This bill intended to require all schools, including private schools, that issued student ID cards, "to have printed on either side of those identification cards the telephone numbers for the National Sexual Assault Hotline and a local resource that provides sexual and reproductive health care information that meets certain requirements."
CAPSO registered opposition to the "local resource that provides sexual and reproductive health care information" portion of this bill, stating in part that “if AB 624 were enacted, the state would compel private religious schools to furnish pupils with what amounts to an endorsement of viewpoints and practices that contradict certain faith-based principles and teachings common to many such schools... In so doing, CAPSO believes the state is overstepping its regulatory authority.” As a result of this engagement, private schools were removed from the opposed portion of the bill.
In 2024, SB 1378 aimed to require that all schools, including private schools, issuing student ID cards to pupils in grades 7 to 12, be required to include on the student ID card "the telephone number for the Title IX Coordinator for the public school or, for a private school, the appropriate contact, and would authorize those public and private schools to have printed on the identification cards certain other telephone numbers of resources for Title IX assistance."
In advance of formally registering opposition, CAPSO drew attention to the analysis and subsequent action for AB 624 (2019) and clarified that only private schools that had accepted federal funds were required to comply with Title IX. While CAPSO's primary concern focused on how this would likely cause confusion for students, a secondary concern was the trend for continued interaction and dictation of the state on private school pupil identification cards. As a result of this engagement, private schools, except those in receipt of federal funds and therefore beholden to Title IX regulations ("as applicable"), were removed from the bill’s language.
In 2024, SB 1063 sought to amend section 215.5 of the CA Education Code by requiring all schools, including private schools, to replace the initial requirement from SB 972, requiring inclusion of the telephone number for the National Suicide Prevention Lifeline, 1-800-273-8255 "with the number for the 988 Suicide and Crisis Lifeline".
CAPSO did not oppose this change as it mirrored the initial legislation and preserved the intent while updating the resource to ensure access to timely and meaningful support for students in crisis. This law is in effect for the 2025-2026 school year.
In 2025, AB 727 intended to add an additional section to 215.5 of the CA Education Code that would require all schools, including private schools, to "have printed on either side of the pupil identification cards The Trevor Project’s 24 hours per day, 7 days per week suicide hotline that is available through both of the following options: (A) Telephone number: 1-866-488-7386. (B) Text line, which can be accessed by texting START to 678-678.
In advance of formally registering opposition, CAPSO issued a letter of concern and partnered with the author's office and the education committee staff to bring attention to the concerns voiced in 2019 about AB 624, namely that AB 727 would "compel private religious schools to furnish pupils with what amounts to an endorsement of viewpoints and practices that contradict certain faith-based principles and teachings common to many such schools by mandating the inclusion of the Trevor Project on official school documents. In so doing, CAPSO believes the state is overstepping its regulatory authority." As a result of this engagement, private schools were removed from the bill's language.
The history of state-mandated requirements on private school's issuance of student identification cards illustrates the tension between reasonable regulation and the limits of the state's regulatory authority over private schools.
A few reminders:
- These requirements only apply to schools that choose to issue student identification cards to pupils in grades 7-12. Private schools are not required to issue student ID cards.
- Private schools may choose to include additional information on student ID cards.
- Schools may first deplete the existing inventory of ID cards as printed.
- Private schools are cautioned to think critically about the potential disadvantages of adding QR codes to student ID cards, as it opens up limitless opportunities for additional mandated resources (priority and space are eliminated as considerations).
Private school leadership is encouraged to review California Education Code section 215.5 to ensure understanding and compliance with the components applying to private schools in the state.
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