[DATE]

California Department of Education
Special Education Division
1430 N Street, Suite 2401
Sacramento, CA 95814-5901
EMAIL: speceducation@cde.ca.gov

Re:	URGENT/EXPEDITED Compliance Complaint against [SCHOOL DISTRICT NAME] for denying Reasonable Mask Accommodations 

Dear California Department of Education:

I am writing to you to file a compliance complaint against [SCHOOL DISTRICT NAME] because [SCHOOL DISTRICT NAME] is violating federal law, state law and agency guidance on mask accommodations related to COVID-19. This complaint alleges that [SCHOOL DISTRICT NAME] is violating:

1.	Individuals with Disabilities Education Act
2.	Section 504 of the Rehabilitation Act 
3.	Title II of the Americans with Disabilities Act
4.	Guidance from the California Department of Public Health 
5.	Guidance from the Centers for Disease Control and Prevention 

My child attends [SCHOOL NAME] which is a school in [SCHOOL DISTRICT NAME]. My child is [AGE OF CHILD] and is in [GRADE LEVEL]. My child’s date of birth is [MONTH DAY, YEAR]. My child requires a reasonable mask accommodation in order to be able to attend school. My child is not able to access distance learning because of my child’s unique needs.  [SCHOOL DISTRICT NAME] is refusing a mask accommodation, and as a result my child cannot attend in person school. 

I.	Facts

My child, [STUDENT NAME], is a student at [SCHOOL DISTRICT NAME]. My child attends [SCHOOL NAME]. My child’s home address is [HOME ADDRESS].

My child has [IDENTIFY DISABILITY/DISABILTIIES] and is a student with an Individualized Education Program (IEP).  (IF APPLICABLE: [STUDENT FIRST NAME] is also a Regional Center client.)  

[IN THIS SECTION, INCLUDE INFORMATION ABOUT YOUR CHILD’S DISABILITY-RELATED NEEDS THAT MAKE IT DIFFICULT FOR YOUR CHILD TO WEAR A MASK. ALSO INCLUDE WHAT SCHOOL STAFF HAVE TOLD YOU ABOUT MASK REQUIREMENTS AND REQUESTS FOR ACCOMMODATIONS, INCLUDING DENIALS OF ACOMMODATION REQUESTS]

II.	Allegations

My child’s special needs require that my child be allowed a mask accommodation. Distance learning is not appropriate for my child. My child cannot access education through distance learning. I have explained my child’s needs extensively to [NAMES OF SCHOOL STAFF]. They told me [WHAT SCHOOL STAFF HAVE TOLD YOU ABOUT MASK REQUIREMENTS/ACCOMMODATIONS].

I have provided [IDENTIFY AND INCLUDE ANY DOCUMENTS LIKE A DOCTOR’S NOTE THAT YOU HAVE PROVIDED TO THE SCHOOL DISTRICT].  

I believe that this is discriminatory and also a violation of the following laws:

1.	Individuals with Disabilities Education Act
2.	Section 504 of the Rehabilitation Act 
3.	Title II of the Americans with Disabilities Act
4.	Guidance from the California Department of Public Health 
5.	Guidance from the Centers for Disease Control and Prevention

I ask that the CDE take direct state intervention over my disability discrimination claims. My child is suffering immediate and irreparable harm as a result of the district’s unlawful mask policy, and filing with the school district would be futile.

All of the guidance and information I have seen states that mask accommodations should be provided. I am attaching to the back of this complaint all of my evidence for you to review. [FOR EVIDENCE, ATTACH ANY REQUESTS FOR A MASK ACCOMMODATION FOR YOUR CHILD AND ANY RESPONSES FROM THE SCHOOL DISTRICT. YOU MAY WANT TO INCLUDE A DOCTOR’S NOTE TOO.]

III.	Proposed Resolutions

1.	I would like for CDE to prioritize my complaint and to require [SCHOOL DISTRICT NAME] to allow my child to attend school with a mask accommodation. 
2.	I would like for CDE to prioritize my complaint and require [SCHOOL DISTRICT NAME] to train its staff members that mask accommodations must be approved.  

Please contact me with any questions or concerns.  

Sincerely,
Parent/Guardian/Educational Rights Holder Name: ____________________________________________________________

Address: ____________________________________________________________

Telephone Number: ____________________________________________________________

Email Address: ____________________________________________________________

CC:	[SUPERINTENDENT NAME], [SUPERINTENDENT’S EMAIL ADDRESS]
	[SCHOOL PRINCIPAL NAME], [SCHOOL PRINCIPAL’S EMAIL ADDRESS]