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Virginia Regulatory Town Hall
Department of Education
Guidance Document Change: The Model Policies for the Treatment of Transgender Students in Virginia’s Public Schools guidance document was developed in response to House Bill 145 and Senate Bill 161, enacted by the 2020 Virginia General Assembly, which directed the Virginia Department of Education to develop and make available to each school board model policies concerning the treatment of transgender students in public elementary and secondary schools. These guidelines address common issues regarding transgender students in accordance with evidence-based best practices and include information, guidance, procedures, and standards relating to: compliance with applicable nondiscrimination laws; maintenance of a safe and supportive learning environment free from discrimination and harassment for all students; prevention of and response to bullying and harassment; maintenance of student records; identification of students; protection of student privacy and the confidentiality of sensitive information; enforcement of sex-based dress codes; and student participation in sex-specific school activities, events, and use of school facilities.
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1/5/21  11:18 pm
Commenter: Kara Zinchuck

Parents have the legal right- via the Family Educational Rights and Privacy Act (FERPA, 1974),

In regards to the "Draft Model Policies of the Treatment of Transgender Students" I am deeply concerned for the wellbeing of my children, the children in my community (Greater Fulton in Richmond's 7th District) and the children of our State. I'm deeply concerned for the children of our State who identify as transgender - and I do not approve of many of the guildelines proposed in the "Draft Policies" and "Recommended Standard."  Both of these, based on radical social theories, eradicate valuable distinctions between male and female (1)(2)(3)(..and more), remove parents' protections for their own kids through reducing/denying communication to parents (4)(7)(8)(9), place undue burden on teachers and administrators, (5)(6) and try to remake basic social constructs that have been foundational building blocks of stable civilizations for milennia. 

Just like we value and protect race and ethiniciy -because it is given by God and is sacred, we need to value and protect sex/gender -because it is also given by God and is sacred.

I'm deeply concerned that these draft policies not only erode the sacredness of an individual's sexuality, they go far beyond paving the way for ample opportunity to penalize those who do value it as an inate, biological reality and sacred. (10) 

Thank you for your consideration of my comments.


(1) “Access to facilities such as restrooms and locker rooms that correspond to a student’s gender identity shall be available to all students.” (Draft Policy, p.18)

(2) “School staff should not confront students about their gender identity upon entry into the restroom.” (Recommended Standard, p.18)
(3) “Students have a right to dress in a manner consistent with their gender identity or gender expression. Schools shall administer and enforce dress and grooming codes consistently across the student body, regardless of actual or perceived gender identity or gender expression.  Requirements for attire for school-related programs, activities, and events shall be gender-neutral.” (Draft Policy, p.16)

(4) “School divisions will need to consider the health and safety of the student in situations where students may not want their parents to know about their transgender status … There are no regulations requiring school staff to notify a parent or guardian of a student’s request to affirm their gender identity...” (Recommended Standard, p.12)

(5) “A student is considered transgender if, at school, the student consistently asserts a gender identity different from the sex assigned at birth… it does not necessarily require any substantiating evidence nor any required minimum duration of expressed gender identity ...” (Recommended Standard, p.12) 

(6) “Schools shall allow students to assert a name and gender pronouns that reflect their gender identity without any substantiating evidence.” (Draft Policy, p.13)

(7) “In addition to adhering to all legal standards of confidentiality, school personnel shall treat information relating to a student’s transgender status as being particularly sensitive, shall not disclose it to other students and parents, and shall only disclose to other school personnel with a legitimate educational interest.” (Draft Policy, p.12)

(8) “Any incident or complaint of discrimination, harassment, or bullying shall be given prompt attention, including investigating the incident and taking appropriate corrective action, by the school administrator. …The [School Division’s Designated Contact] shall be available to hear concerns from students or parents when complaints are not resolved at the school level.” (Draft Policy, p.10) -Parents need to be notified AT THE SCHOOL LEVEL if there are alleged infractions to policies, not just if accusations of their child are unresolved at the school level.

(9) “School staff should be prepared to support the safety and welfare of transgender students when their families are not affirming. … Whenever school personnel suspects or becomes aware that a student is being abused, neglected, or at risk of abuse or neglect by their parent due to their transgender identity, they should report those concerns to Child Protective Services immediately.” (Recommended Standard, p.13)

CommentID: 88520