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Occurrence Is Not Available, but Key State Laws and Nationwide 
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Testimony: 

Before the Committee on Education and Labor, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 9:00 a.m. EDT:
Thursday, May 20, 2010: 

Concussion In High School Sports: 

Overall Estimate of Occurrence Is Not Available, but Key State Laws 
and Nationwide Guidelines Address Injury Management: 

Statement of Linda T. Kohn:
Director, Health Care: 

GAO-10-569T: 

GAO Highlights: 

Highlights of GAO-10-569T, a testimony before the Committee on 
Education and Labor, House of Representatives. 

Why GAO Did This Study: 

Participation in school sports can benefit children but also carries a 
risk of injury, including concussion. Concussion is a brain injury 
that can affect memory, speech, and muscle coordination and can cause 
permanent disability or death. Concussion can be especially serious 
for children, who are more likely than adults both to sustain a 
concussion and to take longer to recover. These factors may affect 
return-to-play decisions, which determine when it is safe for an 
athlete to participate in sports again. 

GAO was asked to testify on concussion incurred in high school sports. 
This statement focuses on (1) what is known about the nationwide 
occurrence of concussion, (2) federal concussion prevention programs, 
(3) the components of key state laws related to the management of 
concussion, and (4) the recommendations of voluntary nationwide 
concussion management guidelines. To do this work, GAO conducted 
literature searches; reviewed injury databases, state laws, and 
documents from federal agencies and organizations that conduct work in 
high school athletics or sports medicine; and interviewed federal 
officials and experts who identified key state laws and nationwide 
guidelines and provided other information. GAO shared the information 
in this statement with the relevant federal agencies. 

What GAO Found: 

GAO identified three national databases that, as part of broader data 
collection efforts, collect information on the occurrence of 
concussion in high school sports, but they do not provide an overall 
national estimate of occurrence. Although the High School Reporting 
Information Online database provides national estimates of occurrence 
of concussion, it covers only 20 sports for high schools with 
certified athletic trainers. It may underestimate occurrence because 
some athletes may be reluctant to report symptoms of a possible 
concussion to avoid being removed from a game. The Consumer Product 
Safety Commission’s (CPSC) National Electronic Injury Surveillance 
System provides national estimates only on concussions treated in an 
emergency room. The National Center for Catastrophic Sports Injury 
Research database provides information only on cases of concussion 
with serious complications and cannot provide national estimates of 
the occurrence of all concussions. 

The Centers for Disease Control and Prevention’s program, Heads Up: 
Concussion in High School Sports, which began in September 2005, is 
the primary federal prevention program directed toward concussion. In 
addition, CPSC carries out prevention initiatives that include 
distributing educational materials, but these initiatives are directed 
more broadly at sports and recreation safety, such as appropriate 
helmets for football, baseball, and bicycling. 

The three key laws regarding the management of concussion in high 
school sports that were identified by federal officials and experts—
those of Oregon, Texas, and Washington—all address concussion 
education and return to play, but their specific requirements vary. 
The education requirements vary with respect to who is to receive the 
education. For example, the Washington law targets coaches, athletes, 
and parents, while the Oregon law targets coaches only. There is also 
variation with respect to the content and frequency of education. The 
return-to-play requirements vary in the conditions under which 
athletes may return to play and in who may authorize it. For example, 
the Texas requirements apply specifically to athletes who lose 
consciousness, which excludes many concussions, and the Washington law 
requires return-to-play authorizations to be made by health 
professionals specifically trained in the evaluation and management of 
concussion. 

GAO found five sets of voluntary nationwide guidelines, which were 
developed by organizations that conduct work in high school athletics 
or sports medicine, that address the management of concussion in high 
school sports. All recommend monitoring an athlete with a concussion 
on the sidelines and assessing cognitive function regularly for signs 
of deterioration. All guidelines also recommend returning an athlete 
to play on a gradual basis, tailored to an individual’s recovery and 
based on symptoms and the results of memory, cognition, and balance 
tests. 

View [hyperlink, http://www.gao.gov/products/GAO-10-569T] or key 
components. For more information, contact Linda T. Kohn at (202) 512-
7114 or kohnl@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss concussion incurred in 
competitive high school sports. More than 7.5 million high school 
students participated in high school sports in 2008-2009, according to 
the National Federation of State High School Associations (NFHS). 
[Footnote 1] Participation in school sports can benefit children, but 
it also carries a risk of injury, including concussion. Concussion is 
an injury to the brain that results in the temporary loss of normal 
brain function and can have serious, long-term consequences. 
Concussion among athletes has recently received increased attention, 
and the long-term effects of concussion among professional football 
players has been the focus of several congressional hearings. 

Concussion is caused by a bump or blow to the head or by a jolt to the 
body that causes the head to move rapidly back and forth. Even a mild 
blow to the head could result in a concussion. Concussion can affect 
memory, judgment, reflexes, speech, balance, and muscle coordination 
and can result in serious complications, such as swelling, bruising, 
or bleeding of the brain, which can cause permanent disability or 
death. Most concussions, however, do not result in a loss of 
consciousness, and some athletes may not experience symptoms until 
hours or days after sustaining a concussion. Therefore, according to 
the Centers for Disease Control and Prevention (CDC), all coaches, 
parents, and athletes need to learn concussion signs and symptoms and 
what to do if a concussion occurs. 

Several factors may affect decisions about when it is safe for an 
athlete to participate in sports again, which are referred to as 
return-to-play decisions. For example, research has shown that 
athletes who have sustained one concussion are at increased risk of 
sustaining another concussion.[Footnote 2] An athlete who sustains a 
repeat concussion before the brain recovers from the first--within 
hours, days, or weeks--may recover more slowly or may have increased 
likelihood of long-term consequences. Research has also shown that 
children and adolescents are more likely than adults to sustain a 
concussion and take longer to recover from one, although the reasons 
for this difference remain unclear.[Footnote 3] 

Several federal agencies have responsibility for working to promote 
the health and wellness of children and youth, such as by developing 
programs for the prevention or management of injuries. Within the 
Department of Health and Human Services (HHS), CDC is responsible for 
promoting the health and well-being of the U.S. population, including 
creating policies to prevent unintentional injuries among children and 
adolescents and to minimize the consequences of these injuries. These 
responsibilities encompass conducting research and developing programs 
and educational initiatives related to the prevention and management 
of injuries, such as concussion. HHS's National Institutes of Health 
(NIH) is responsible for conducting and supporting medical research to 
improve health and save lives, including developing strategies to 
prevent childhood illness and death and developing techniques and 
technologies for the rehabilitation of individuals with physical 
disabilities resulting from injuries, such as concussion. HHS's Health 
Resources and Services Administration (HRSA) is responsible for 
strengthening the maternal and child health infrastructure in concert 
with states, communities, and private partners, including promoting 
children's health and increasing access to comprehensive services for 
patients with severe head injuries. 

Other federal agencies that have responsibilities for promoting the 
health and wellness of children and youth are the Department of 
Education (Education) and the Consumer Product Safety Commission 
(CPSC). Education has responsibility for administering programs that 
promote the health and well-being of students, including a 
discretionary grant program related to physical education. CPSC 
regulates thousands of consumer products, including sports equipment, 
with the goal of protecting the public from unreasonable risks of 
serious injury or death. 

In addition to these federal efforts, several private organizations 
and states have either studied the occurrence of concussion in high 
school sports or developed concussion prevention and management 
guidelines. For example, research on sports injuries has been 
conducted by the Center for Injury Research and Policy at Nationwide 
Children's Hospital in Columbus, Ohio, through the National High 
School Sports Related Injury Surveillance Study's High School 
Reporting Information Online (High School RIO). In addition, the 
National Center for Catastrophic Sports Injury Research (NCCSI) at the 
University of North Carolina, Chapel Hill, studies catastrophic sports 
injuries in high school and college athletes. Some states have passed 
laws related to concussion incurred in school sports. In addition, 
several organizations that conduct work in high school athletics or 
sports medicine have developed voluntary guidelines for the management 
of concussion. 

You expressed interest in obtaining information on concussion incurred 
by young athletes. My statement today focuses on concussions incurred 
by students while playing or practicing competitive high school sports 
[Footnote 4] and addresses the following questions: (1) What is known 
about the nationwide occurrence of concussion incurred in high school 
sports? (2) What federal programs are directed specifically at the 
prevention of concussion incurred in high school sports? (3) What are 
the components of key state laws regarding the management of 
concussion incurred in high school sports? (4) What are the 
recommendations of voluntary nationwide guidelines for the management 
of concussion incurred in high school sports? 

To determine what is known about the nationwide occurrence of 
concussion incurred in high school sports, we conducted a literature 
search of social science and medical databases to find articles 
published from 1999 through 2009 that discuss or report national data 
from public or private programs for tracking the occurrence of 
concussion in high school sports. We reviewed documentation and 
interviewed officials from CPSC, the Center for Injury Research and 
Policy, and NCCSI. The interviews focused on information about data 
collection methods and the generalizability, strengths, and 
limitations of the data that these organizations collect. We also 
conducted interviews with federal officials and experts from 
organizations that conduct work in the area of high school athletics 
or sports medicine to obtain assistance in identifying relevant data 
sources and to obtain information about the strengths and limitations 
of existing data sources.[Footnote 5] We identified these 
organizations from interviews with federal officials, literature we 
reviewed, and interviews with other experts. We then examined the 
characteristics of the national databases we identified, including how 
data are collected, the target population, and the sports studied. We 
did not analyze the data to generate and report incidence statistics, 
but rather to determine the manner in which the data are collected and 
to analyze how this affects the availability of data on nationwide 
occurrence. To determine what federal programs are directed 
specifically at the prevention of concussion incurred in high school 
sports, we searched federal Web sites to identify prevention programs 
related to concussion in high school sports. We also interviewed 
federal officials to identify federal prevention programs and to 
obtain information and program materials, and we reviewed these 
materials to determine when these programs were developed, how 
educational materials are disseminated, and who the target audience is. 

To describe the components of key state laws regarding the management 
of concussion incurred in high school sports, we interviewed federal 
officials and experts who provided assistance in identifying relevant 
state laws. We then reviewed the laws and identified their key 
components, similarities, and differences. The state laws we reviewed 
were those identified to us by federal officials and experts and do 
not necessarily constitute a complete list of all state laws that 
might address, specifically or in a broader context, the management of 
concussion incurred in high school sports. To describe the 
recommendations of voluntary nationwide guidelines for the management 
of concussion incurred in high school sports, we interviewed federal 
officials and experts to obtain assistance in identifying nationwide 
guidelines and to obtain information about the development of the 
guidelines. We excluded those guidelines that focused on one sport 
only or were developed prior to 1995. We then reviewed the guidelines 
and relevant documents and identified the guidelines' key 
recommendations and the similarities and differences across 
guidelines. The guidelines we reviewed were those identified to us by 
federal officials and experts and do not necessarily constitute a 
complete list of all nationwide guidelines that might address the 
management of concussion incurred in high school sports. 

We shared the information in this report with CDC, CPSC, Education, 
HRSA, and NIH. The agencies provided technical comments, which we 
incorporated as appropriate. 

We conducted our work from October 2009 through May 2010 in accordance 
with all sections of GAO's Quality Assurance Framework that are 
relevant to our objectives. The framework requires that we plan and 
perform the engagement to obtain sufficient and appropriate evidence 
to meet our stated objectives and to discuss any limitations in our 
work. We believe that the information and data obtained, and the 
analysis conducted, provide a reasonable basis for any findings and 
conclusions in this product. 

Available Information about the Occurrence of Concussion in High 
School Sports Cannot Provide an Overall National Estimate: 

We identified three national databases that, as part of broader data 
collection efforts, collect information on the occurrence of 
concussion in high school sports, but they do not provide an overall 
national estimate of occurrence. These databases are the NCCSI 
database, the CPSC's National Electronic Injury Surveillance System 
(NEISS), and the Center for Injury Research and Policy's High School 
RIO. (See table 1 for descriptions of the databases.) 

Table 1: Characteristics of Concussion Occurrence Databases: 

Database: National Center for Catastrophic Sports Injury Research 
(NCCSI) database; 
Managing organization: University of North Carolina at Chapel Hill; 
Information characteristic: Data gathered: Injury information about 
cases of catastrophic injuries in high school and college athletes, 
including concussions with serious complications; 
Information characteristic: Sources used to identify injuries: Media 
reports obtained through Internet searches and questionnaires sent to 
state high school associations to identify catastrophic injuries; 
Information characteristic: Methods used to collect data: Researchers 
review published accounts and contact the school, coach, doctor, and 
family of the injured athlete. 

Database: National Electronic Injury Surveillance System (NEISS); 
Managing organization: Consumer Product Safety Commission (CPSC); 
Information characteristic: Data gathered: Information on injuries 
related to a consumer product for all patients--including those 
diagnosed with a concussion--treated in emergency departments[A]; 
Information characteristic: Sources used to identify injuries: Random 
national sample of approximately 100 hospitals with 24-hour emergency 
services, stratified by size; 
Information characteristic: Methods used to collect data: Hospital 
staff conduct chart reviews and assign a code for the type of injury 
the patient sustained and a code based on the product or activity 
associated with the injury, if applicable. 

Database: National High School Sports Related Injury Surveillance 
Study (High School RIO); 
Managing organization: Center for Injury Research and Policy, 
Nationwide Children's Hospital, Columbus, Ohio; 
Information characteristic: Data gathered: Participation and injury 
information, including concussion, for 20 high school sports; 
Information characteristic: Sources used to identify injuries: Random 
national sample of 100 high schools with certified athletic 
trainers[B] who have volunteered to participate, stratified by 
geographic location and size; 
Information characteristic: Methods used to collect data: Athletic 
trainers report information online weekly. 

Source: GAO analysis of NCCSI, CPSC, and Center for Injury and 
Research Policy database operations documents. 

[A] In addition, since 2000 CDC has provided funding through an 
interagency agreement with CPSC to expand NEISS to collect information 
from about two-thirds of the hospitals in the sample on all types and 
causes of nonfatal injuries, including those not related to consumer 
products, for all patients treated in their emergency rooms. 

[B] Certified athletic trainers are health care professionals who have 
a bachelor's or master's degree in and are board certified in athletic 
training. 

[End of table] 

According to experts and federal officials, while none of the 
databases can provide a national estimate of the occurrence of 
concussion in high school sports, two of them provide national 
estimates of the occurrence of concussion for the populations they 
study. High School RIO provides national estimates of the occurrence 
of concussion in 20 sports for high schools with certified athletic 
trainers,[Footnote 6] based on its sample of 100 high schools with 
certified athletic trainers.[Footnote 7] Because it collects data on 
participation in the sports it studies, High School RIO also 
calculates injury rates by sport and by sex. NEISS provides national 
estimates of the occurrence of concussion treated in hospital 
emergency departments, based on its random national sample of 
approximately 100 hospitals with 24-hour emergency services.[Footnote 
8] The third database, NCCSI, provides information on cases of 
concussion with serious complications, but it cannot provide national 
estimates of occurrence of all concussions. 

According to experts and federal officials, High School RIO and NEISS 
have certain strengths. The information collected by High School RIO 
is timely, as athletic trainers in the sample schools report data on a 
weekly basis. According to CPSC officials, the information collected 
by NEISS is also timely, in that hospitals in the sample report 
information on a daily basis and NEISS receives approximately half of 
the data within 4 days of the patient's being seen in the emergency 
department. In addition, both High School RIO and NEISS collect 
information in ways--such as through certified athletic trainers and 
through review of medical charts, respectively--that experts report to 
produce more reliable information than other methods. 

Experts and federal officials have noted that notwithstanding these 
strengths, the national estimates provided by High School RIO and 
NEISS may be underestimates of the overall national occurrence of 
concussion in high school sports. For example, High School RIO gathers 
information only on concussions that are reported to or observed by a 
certified athletic trainer, but, according to officials from an 
athletic trainers' association, athletes may be reluctant to report 
symptoms of possible concussions to athletic trainers to avoid being 
removed from play. In addition, the athletic trainers cannot be 
present at all practices and games and the coaches and parents who are 
present may not recognize the signs or symptoms of a concussion, 
resulting in an underestimate of the actual number of concussions in 
the schools studied. Further, some athletes may consult their family 
physician about signs and symptoms of a possible concussion without 
reporting it to the athletic trainer. These concussions would not be 
included in the database. In addition, because High School RIO 
collects information on only 20 sports, its data cannot be used to 
estimate the occurrence of concussion in all sports. Similarly, NEISS 
gathers information only on concussions in patients who are treated in 
emergency departments, but not all athletes with a concussion go to an 
emergency department for treatment. Furthermore, the medical charts 
that are reviewed by hospital staff for NEISS may not always indicate 
detailed circumstances of the concussion, and therefore the staff may 
miss some concussions that were sustained during athletic 
participation. 

Experts and federal officials identified additional features of the 
databases that may lead to further uncertainty and thus preclude the 
use of the data to provide comprehensive national estimates of 
concussion in high school sports. For example, High School RIO does 
not collect data from schools that do not have certified athletic 
trainers, and researchers do not know how the occurrence and reporting 
of concussion in schools with athletic trainers differ from schools 
without athletic trainers or what effect any difference would have on 
estimates of occurrence. In addition, according to CPSC officials, 
NEISS cannot always indicate whether a concussion was sustained during 
participation in a sport or simply involved sports equipment. For 
example, NEISS would count a concussion sustained by a person who was 
hit on the head with a baseball bat as a sports-related concussion, 
regardless of whether or not the injury was incurred during a baseball 
game or practice. 

The Primary Federal Program Directed Specifically at Preventing 
Concussion in High School Sports Is CDC's Heads Up: Concussion: 

CDC's Heads Up: Concussion in High School Sports is the primary 
federal program directed specifically at preventing concussion in high 
school sports. The program, which is one of CDC's educational 
initiatives, is intended to provide educational materials for coaches, 
athletic trainers, athletic directors, parents, and athletes to 
prevent concussion.[Footnote 9] The Heads Up: Concussion in High 
School Sports tool kit includes a concussion guide for coaches with 
information on signs and symptoms and strategies for preventing 
concussions, a coach's quick-reference wallet card, a coach's 
clipboard sticker with concussion facts and space for emergency 
medical contacts, two fact sheets--one for parents and one for 
athletes--in English and Spanish, an educational DVD, posters for 
school gymnasiums, and a disc that contains additional resources. 
According to CDC officials, the Heads Up: Concussion in High School 
Sports materials were developed by a panel of experts from CDC and 
outside the federal government. 

CDC rolled out the Heads Up: Concussion in High School Sports program 
in September 2005 to coincide with the beginning of the school year. 
As part of the agency's promotional activities for its national roll-
out, CDC developed press kits and other promotional materials, and to 
promote the program, it partnered with 14 public and private 
organizations, including Education, physician associations, and other 
organizations that conduct work in high school athletics or sports 
medicine. CDC also conducted a targeted media campaign consisting of e-
mails and telephone calls to local, regional, and national media 
outlets, regional and national newspapers, and general and specialty 
magazines. In addition, the Surgeon General served as a key 
spokesperson and participated in radio interviews with program 
officials.[Footnote 10] CDC estimates that it distributed 20,000 tool 
kits within the first 3 months of the program and reached 6 million 
listeners and readers through the targeted media campaign.[Footnote 
11] Agency officials estimate that CDC distributed more than 300,000 
Heads Up: Concussion in High School Sports materials overall by the 
end of December 2009.[Footnote 12] 

CDC has continued to update and expand its Heads Up: Concussion in 
High School Sports materials. CDC plans to release updated Heads Up: 
Concussion in High School Sports materials in spring 2010 to coincide 
with the release of free online training for high school coaches 
developed by CDC and NFHS, which will include downloadable Heads Up: 
Concussion materials and an educational video. CDC has also continued 
to expand its Heads Up programs to target broader audiences.[Footnote 
13] In addition, CDC officials told us that the agency created sports- 
specific materials in conjunction with the national governing bodies 
for youth and high school football, lacrosse, and ice hockey[Footnote 
14] based on the Heads Up: Concussion in High School Sports and other 
materials. The sports-specific materials include prevention and safety 
information related to each sport and its equipment. The agency plans 
to continue developing specific materials for additional sports. 

Other federal agencies administer programs related to concussion, but 
most of these programs are not directed specifically at the prevention 
of concussion in high school sports. CPSC carries out initiatives that 
include developing educational materials such as brochures and fact 
sheets. These initiatives are not targeted exclusively at high school 
sports, but are directed more broadly at sports and recreation safety 
for youth and adults. For example, CPSC developed a brochure on which 
helmets to wear for a variety of activities, such as football, 
baseball, and bicycling, to prevent head injuries, including 
concussion. HRSA and NIH administer grant programs related to 
concussion and brain injury from all causes and for all age groups. 
HRSA grants focus on high-risk groups including youth ages 15-19, and 
NIH grants have supported some research on concussion in high school 
sports. However, neither agency administers programs specifically for 
the prevention of concussion in high school sports. According to 
department officials, Education does not administer any programs 
related to the prevention of concussion. 

Concussion Education and Return-to-Play Requirements Are the Focus of 
Key State Laws, but Exact Requirements Differ: 

The three key state laws regarding the management of concussion that 
were identified by federal officials and experts all include 
requirements related to concussion education and athletes' return to 
play. (See table 2.) The education components of the key state laws-- 
those of Oregon, Texas, and Washington[Footnote 15]--vary in terms of 
targeted group and frequency of training. The return-to-play 
requirements of the key state laws vary with respect to the conditions 
under which the requirements apply and the personnel who may authorize 
return to play. 

Table 2: Components of Key State Laws Regarding the Management of 
Concussion Incurred in High School Sports: 

Education requirements: 

Components: Schools covered; 
State (Year enacted): Oregon (2009)[A]: School districts[D]; 
State (Year enacted): Texas (2007)[B]: Public schools and any other 
schools subject to University Interscholastic League (UIL) rules[E]; 
State (Year enacted): Washington (2009)[C]: School districts[F]. 

Components: Targeted group(s); 
State (Year enacted): Oregon (2009)[A]: Coaches; 
State (Year enacted): Texas (2007)[B]: Coaches, trainers, physicians 
who assist with activities, sponsors of extracurricular activities, 
and athletes[G]; 
State (Year enacted): Washington (2009)[C]: Coaches, athletes, and 
parents. 

Components: Content; 
State (Year enacted): Oregon (2009)[A]: Recognizing symptoms of 
concussion and knowing how to seek medical treatment; 
State (Year enacted): Texas (2007)[B]: Recognizing symptoms of 
potentially catastrophic sports injuries, including concussion[H]; 
State (Year enacted): Washington (2009)[C]: Understanding the nature 
and risk of concussion and head injury, including the risk of 
continuing to play after a concussion or head injury. 

Components: Frequency; 
State (Year enacted): Oregon (2009)[A]: Annual; 
State (Year enacted): Texas (2007)[B]: Not specified, but an annual 
safety drill is required. A UIL official reported that UIL requires 
education for coaches and students annually; 
State (Year enacted): Washington (2009)[C]: Not specified for coaches; 
athletes and parents must sign an information sheet annually. 

Components: Return-to-play requirements: 

Components: Conditions under which return-to-play requirements apply 
following injuries; 
State (Year enacted): Oregon (2009)[A]: Presence of signs, symptoms, 
and behaviors consistent with concussion following an observed or 
suspected blow to the head or body or diagnosis of concussion; 
State (Year enacted): Texas (2007)[B]: Loss of consciousness for any 
reason; 
State (Year enacted): Washington (2009)[C]: Suspicion of concussion. 

Components: Removal from play; 
State (Year enacted): Oregon (2009)[A]: Athlete removed from any event 
or training on day of injury; 
State (Year enacted): Texas (2007)[B]: Athlete removed from play on 
day of injury. According to a UIL official, these decisions are made 
by personnel designated by the school, typically a coach or athletic 
trainer; 
State (Year enacted): Washington (2009)[C]: Athlete removed from play 
at the time of injury. According to the Washington Interscholastic 
Athletic Association (WIAA), removal is the responsibility of the 
coach. 

Components: Return-to-play requirements; 
State (Year enacted): Oregon (2009)[A]: Athlete may return to play no 
sooner than the day after the athlete sustained the blow to the head 
or body and only after the athlete (1) no longer exhibits signs, 
symptoms, or behaviors that are consistent with concussion; 
and (2) receives a medical release from a health care professional; 
State (Year enacted): Texas (2007)[B]: Athlete may not (1) return to 
the practice or competition during which the athlete became 
unconscious, or (2) participate in any extracurricular athletic 
activity until the athlete receives written authorization from a 
physician; 
State (Year enacted): Washington (2009)[C]: Athlete may not return to 
play until the athlete is evaluated by and receives written clearance 
to return to play from a licensed health care provider trained in the 
evaluation and management of concussion. 

Sanctions: 

Components: Possible sanctions for failure to comply with law; 
State (Year enacted): Oregon (2009)[A]: The law does not provide 
sanctions; 
State (Year enacted): Texas (2007)[B]: The law provides that schools 
shall be subject to a range of penalties determined by UIL. According 
to UIL, penalties range from reprimand to disqualification and can 
affect individuals, such as a coach, or the school; 
State (Year enacted): Washington (2009)[C]: The law does not provide 
sanctions. WIAA rules state that students cannot participate in 
competitive district athletics without having a signed concussion 
information sheet on file with the school district. 

Source: GAO analysis of key state laws and relevant implementation 
guidelines. 

[A] 2009 Or. Laws, ch. 661. The law does not specify a particular 
association or other entity to assist in implementation. The law first 
applies to the 2010-2011 school year. 

[B] 2007 Tex. Sess. Law. Serv., ch. 1296 (West). The Texas 
Commissioner of Education adopted the Extracurricular Activity Safety 
Training Program of UIL as the safety training program to be provided 
under this law. Implementation guidelines for this program are 
provided by UIL. 

[C] 2009 Wash. Sess. Laws, ch. 475. Implementation guidelines are 
developed by school districts in concert with the Washington 
Interscholastic Activities Association (WIAA). 

[D] According to an official from the Oregon Department of Education, 
this term does not apply to private schools. 

[E] UIL is a voluntary-membership, nonprofit organization created by 
the University of Texas at Austin to provide leadership and guidance 
to public school debate and athletic teachers. According to a UIL 
official, the league has 1,300 member schools, all but 2 of which are 
public schools. 

[F] The Washington State Superintendent of Public Instruction has 
issued a memo indicating that, while the law does not mention private 
schools directly, WIAA directs all member schools to follow the new 
requirements. WIAA has 800 public and private member high schools and 
junior high or middle schools, approximately 10 percent of which are 
private schools, according to a WIAA official. 

[G] The Texas law also requires directors of school marching bands to 
complete the education program. 

[H] Among other potentially catastrophic sports injuries that the law 
mentions are heatstroke and cardiac arrest. 

[End of table] 

All three state laws include requirements for education on concussion, 
but they vary in the groups targeted and the content and frequency of 
the education. The educational requirements of the Oregon law are 
targeted at coaches. In addition to coaches, the Texas law specifies 
that additional persons--such as athletic trainers, sponsors of 
extracurricular athletic activities, physicians who assist with 
activities, and athletes--also must complete an education program. 
[Footnote 16] The Washington law is the only one that requires that 
parents, in addition to coaches and athletes, receive education. The 
Oregon law is unique in that it requires that coaches receive 
education on concussion symptoms annually. The Texas and Washington 
laws are silent on how often coaches should complete such an education 
program.[Footnote 17] 

The Washington law is the only state law we examined that requires 
school districts to work with a state athletic organization to develop 
guidelines, forms, and educational materials. School districts in 
Washington worked with the Washington Interscholastic Activities 
Association (WIAA) to develop a document, which athletes and parents 
must sign annually, that contains information on the risks of 
concussion and on how to recognize the signs and symptoms of 
concussion.[Footnote 18] By signing the document, parents and athletes 
are acknowledging their understanding that the athlete will be removed 
from play or practice by the coach if he or she is suspected of having 
a concussion. WIAA also developed fact sheets and an educational video 
for coaches that describe the signs and symptoms of concussion and 
propose a management strategy for coaches to follow. Much of the 
information distributed by WIAA is modeled after CDC's Heads Up: 
Concussion materials. 

The Texas law requires the Commissioner of Education to develop and 
adopt a safety training program, and the Texas Commissioner of 
Education adopted the extracurricular athletic activity safety 
training program provided by the University Interscholastic League 
(UIL).[Footnote 19] The UIL training manual includes a section on 
recognizing the signs of concussion and one on reducing head and neck 
injuries. The latter section states that an athlete with signs of head 
or neck trauma should receive immediate medical attention and not be 
allowed to return to play or practice without permission from proper 
medical authorities. UIL has also developed a parent information 
manual that includes a section on concussion signs and management. In 
addition, UIL has contracted with the Brain Injury Association of 
America to provide to schools and coaches 25,000 palm cards for the 
management of sports-related concussion, which outline the protocol 
that every school must follow when dealing with possible head injuries 
that occur in practice or play of all UIL activities.[Footnote 20] 

The Oregon law requires that the State Board of Education establish 
rules regarding the required concussion education for coaches. An 
official from the Oregon Department of Education told us that these 
rules have not yet been established, as the law first applies to the 
2010-2011 school year. 

The return-to-play requirements of the key state laws vary with 
respect to the conditions under which the requirements apply. The 
return-to-play requirements of the Texas law apply only to athletes 
with injuries that result in a loss of consciousness and therefore 
exclude many concussions. In contrast, the return-to-play requirements 
of the Oregon and Washington laws apply to athletes with symptoms of 
or suspicion of concussion. 

While each state law requires that an athlete removed from play 
receive written permission from a health care professional before 
returning to play, the laws vary in the types of health professionals 
who can provide such permission. The Texas law requires clearance from 
a physician, and the Oregon law requires clearance from a health care 
professional. The Washington law requires that an athlete suspected of 
having a concussion be evaluated and cleared to return to play by a 
health professional specifically trained in the evaluation and 
management of concussion. WIAA's Web site indicates that such 
professionals include medical doctors, doctors of osteopathy, advanced 
registered nurse practitioners, physicians' assistants, and licensed 
certified athletic trainers. According to the WIAA Web site, the 
organization is considering whether other licensed health care 
providers have sufficient training to qualify them to authorize return 
to play. The Oregon law is the only one of the three we reviewed that 
specifically prohibits an athlete removed from play or practice from 
returning to play or practice on the same day. 

Voluntary Nationwide Guidelines for Managing Concussion Incurred in 
High School Sports All Recommend Assessing Concussion on an Individual 
Basis, with Gradual Return to Play: 

Federal officials and experts we spoke with identified five sets of 
voluntary nationwide guidelines that address the management of 
concussion in sports.[Footnote 21] (See table 3.) One set specifically 
targets high school sports, while the other four contain broad 
recommendations for the management of concussion in athletes of all 
ages.[Footnote 22] All five sets of guidelines contain similar 
recommendations for assessing concussion and managing the athlete, 
including making return-to-play decisions. For example, all sets of 
guidelines recommend that an athlete suspected of sustaining a 
concussion should be monitored closely on the sidelines following the 
injury and his or her cognitive function assessed at regular intervals 
for signs and symptoms of deterioration--such as fluctuating levels of 
consciousness, balance problems, headaches, or nausea. All sets of 
guidelines also recommend returning an athlete to play on a gradual 
basis, tailored to the individual athlete's recovery and based on the 
athlete's signs and symptoms and the results of various concussion 
assessment tools, such as tests of memory, cognition, balance, and 
physical exertion. The set of guidelines that specifically targets 
high school sports, which was developed by NFHS, recommends a gradual 
increase in mental activity appropriate to high school students, such 
as attending an abbreviated school day and engaging in short periods 
of reading. If the athlete remains symptom-free, this is to be 
followed by a gradual increase in low-impact physical activity once 
the athlete has returned to a full school day. In addition, this set 
of guidelines recommends that high school athletes playing high-risk 
or collision sports or having a history of previous concussions should 
undergo tests of cognition, memory, and balance prior to the start of 
season to serve as a baseline in case an injury occurs. 

Table 3: Concussion Management Guidelines: 

Title: Concussions (Mild Traumatic Brain Injury) and the Team 
Physician: A Consensus Statement[A]; 
Source: American Academy of Family Physicians, the American Academy of 
Orthopaedic Surgeons, the American College of Sports Medicine, the 
American Medical Society for Sports Medicine, the American Orthopaedic 
Society for Sports Medicine, the American Osteopathic Academy of 
Sports Medicine; 
Publication year: 2006; 
Intended end user: Team physicians; 
Focus on high school sports: No; contains broad recommendations for 
all athletes[B]. 

Title: Consensus Statement on Concussion in Sport, 3rd Annual 
International Conference on Concussion in Sport[C]; 
Source: International and domestic experts, including those from the 
International Olympic Committee and experts affiliated with the 
American College of Sports Medicine and the National Athletic 
Trainers' Association; 
Publication year: 2009; 
Intended end user: Physicians, therapists, certified athletic 
trainers, health professionals, coaches, and others involved in the 
care of athletes; 
Focus on high school sports: No, but includes special considerations 
for young athletes[D]. 

Title: National Athletic Trainers' Association Position Statement: 
Management of Sport-Related Concussion[E]; 
Source: National Athletic Trainers' Association; 
Publication year: 2004; 
Intended end user: Certified athletic trainers and sports medicine 
professionals (physicians and medical personnel caring for athletes); 
Focus on high school sports: No, but includes special considerations 
for young athletes[D]. 

Title: Practice Parameter: The Management of Concussion in Sports[F]; 
Source: American Academy of Neurology; 
Publication year: 1997; 
Intended end user: Neurologists; 
Focus on high school sports: No; contains broad recommendations for 
all athletes. 

Title: Sports Medicine Handbook, Concussion chapter[G]; 
Source: National Federation of State High School Associations; 
Publication year: 2008; 
[Empty]; 
Intended end user: School administrators, coaches, and high school 
sports medicine staff; 
Focus on high school sports: Yes. 

Source: GAO analysis of guidelines. 

[A] S.A. Herring, J.A. Bergfeld, A. Boland, L.A. Boyajian-O'Neil, R.C. 
Cantu, E. Hershman, P. Indelicato, R. Jaffe, W.B. Kibler, D.B. McKeag, 
R. Pallay, and M. Putukian, "Concussion (Mild Traumatic Brain Injury) 
and the Team Physician: A Consensus Statement," Medicine & Science in 
Sports & Exercise, vol. 38, no. 2 (2006). 

[B] According to the lead author, the consensus statement is primarily 
intended to guide the management of concussion in the amateur or high 
school athlete, rather than the college, elite, or professional 
athlete. 

[C] P. McCrory, W. Meeuwisse, K. Johnston, J. Dvorak, M. Aubry, M. 
Molloy, and R. Cantu, "Consensus Statement on Concussion in Sport, 3rd 
International Conference on Concussion in Sport Held in Zurich, 
November 2008," Clinical Journal of Sport Medicine, vol. 19, no. 3 
(2009). 

[D] This set of guidelines recommends managing young athletes more 
conservatively than adults but does not provide any more specific 
recommendations. 

[E] K.M. Guskiewicz, S.L. Bruce, R.C. Cantu, M.S. Ferrara, J.P. Kelly, 
M. McCrea, M. Putukian, and T.C. Valovich McLeod, "National Athletic 
Trainers' Association Position Statement: Management of Sport-Related 
Concussion," Journal of Athletic Training, vol. 39, no. 3 (2004). 

[F] American Academy of Neurology, Quality Standards Subcommittee, 
Practice Parameter: The Management of Concussion in Sports Summary 
Statement (St. Paul, Minn., 1997). According to officials, the 
association is currently in the process of updating the practice 
parameter and anticipates publishing it in spring 2011. 

[G] National Federation of State High School Associations, 
"Concussion," Sports Medicine Handbook, Third Edition (Indianapolis, 
Ind., 2008). 

[End of table] 

Officials from three of the organizations that developed guidelines 
told us that their members received information about the guidelines 
in a variety of ways. For example, NFHS officials told us that the 
association sent its set of guidelines to its member high schools upon 
publication and planned to include information on the management of 
concussion in its sports rule books, which it publishes every year for 
17 sports, beginning with the 2010-2011 school year. Officials from 
the American College of Sports Medicine and the National Athletic 
Trainers' Association told us that concussion management is a frequent 
topic of discussion at their meetings and that their guidelines were 
also published in each organization's respective journal. 

Mr. Chairman, this concludes my prepared statement. I would be happy 
to answer any questions that you or other members of the committee may 
have. 

GAO Contact and Staff Acknowledgments: 

For further information about this statement, please contact Linda T. 
Kohn at (202) 512-7114 or kohnl@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. Key contributors to this statement 
were Helene F. Toiv, Assistant Director; Kate Blackwell; George 
Bogart; Shana R. Deitch; Carolyn Feis Korman; and Roseanne Price. 

[End of section] 

Footnotes: 

[1] National Federation of State High School Associations, 2008-2009 
High School Athletics Participation Survey (Indianapolis, Ind., 2009). 
NFHS leads the development of education-based sports and activities 
for its member associations. NFHS membership consists of the high 
school athletic or activity associations of the 50 states and the 
District of Columbia, from which it collects information on the 
numbers of students participating in high school sports. 

[2] According to scientific literature, the increased risk may be due 
to the athlete's style of play or to changes in the brain resulting 
from the previous concussion. 

[3] M. Field, M.W. Collins, M.R. Lovell, and J. Maroon, "Does Age Play 
a Role in Recovery from Sports-Related Concussion? A Comparison of 
High School and Collegiate Athletes," Journal of Pediatrics, vol. 142, 
no. 5 (2003). M.W. Kirkwood, K.O. Yeates, and P.E. Wilson, "Pediatric 
Sport-Related Concussion: A Review of the Clinical Management of an 
Oft-Neglected Population," Pediatrics, vol. 117, no. 4 (2006). J. 
Gilchrist, K.E. Thomas, M. Wald, and J. Langlois, "Nonfatal Traumatic 
Brain Injuries from Sports and Recreation Activities, United States, 
2001-2005," Morbidity and Mortality Weekly Report, vol. 56, no. 29 
(2007). 

[4] For the purposes of this statement, we are excluding sports played 
as part of physical education classes. 

[5] Specifically, we interviewed officials from CDC, CPSC, Education, 
HRSA, NIH, the American Academy of Pediatrics, the American College of 
Sports Medicine, the National Athletic Trainers' Association, NFHS, 
and others. We also interviewed officials from these federal agencies 
and organizations to answer our remaining research questions. 

[6] E.E. Yard and R.D. Comstock, "Compliance With Return to Play 
Guidelines Following Concussion in US High School Athletes, 2005-
2008," Brain Injury, vol. 23, no. 11 (2009). 

[7] Certified athletic trainers are health care professionals who have 
a bachelor's or master's degree in and are board certified in athletic 
training. The National Athletic Trainers' Association estimates that 
approximately 42 percent of high schools have access to a certified 
athletic trainer. Schools may have a full-time certified athletic 
trainer on staff, share a trainer with other schools, or receive the 
services of a trainer who volunteers on a part-time basis. 

[8] J. Gilchrist, K.E. Thomas, M. Wald, and J. Langlois, "Nonfatal 
Traumatic Brain Injuries From Sports and Recreation Activities--United 
States, 2001-2005," Morbidity and Mortality Weekly Report, vol. 56, 
no. 29 (2007). 

[9] CDC officials told us that the agency developed the Heads Up: 
Concussion in High School Sports program to follow up on its Heads Up: 
Brain Injury in Your Practice program, which CDC released in 2002 for 
primary care physicians. 

[10] The Surgeon General, whose office is in the Office of the 
Secretary of HHS, has responsibilities for public health education and 
promotion, including the promotion of special departmental health 
initiatives, among other duties. 

[11] CDC conducted an evaluation of the Heads Up: Concussion in High 
School Sports initiative in 2008, in which the agency surveyed 
eligible high school coaches who received the tool kit from September 
2005 to July 2006. More than one-third of responding coaches reported 
that they learned something new about concussions from the tool kit, 
and half of responding coaches noted that the tool kit made them view 
concussions more seriously. 

[12] CDC also makes the materials available for download on its Web 
site. 

[13] In 2007, CDC launched the Heads Up: Concussion in Youth Sports 
program to provide educational prevention materials for coaches of 
youth athletes ages 5 through 18 participating in organized and 
unorganized sports. In March 2010, CDC released the Heads Up to 
Clinicians program to provide emergency department health 
professionals with information on the management of brain injuries in 
adults. In addition, CDC is planning to release in spring 2010 its 
Heads Up to Schools: Know Your Concussion ABCs program for grades K 
through 12 school professionals--such as school nurses, counselors, 
and administrators--and parents. 

[14] These governing bodies may also provide support, skill 
development, and education to college or adult amateur athletes. 

[15] 2009 Or. Laws, ch. 661; 2007 Tex. Sess. Law. Serv., ch. 1296 
(West); and 2009 Wash. Sess. Laws, ch. 475. Other states may have laws 
or may be considering legislation related to concussion incurred in 
high school sports. 

[16] The Texas law requires education on the recognition of a broad 
range of potentially catastrophic injuries, including but not limited 
to concussion. 

[17] According to a WIAA official, the association is incorporating 
concussion education into a cardiopulmonary resuscitation (CPR) course 
that coaches are required to take every other year. The official told 
us that WIAA mandated that in 2010 all coaches take the CPR course 
with the concussion information, regardless of whether they are 
current on their CPR training. 

[18] WIAA is a private, nonprofit organization and rule-making body 
formed in 1905 to create equitable playing conditions between high 
school teams in Washington. The association has approximately 800 
member high schools and middle schools, both public and private. 

[19] UIL is a voluntary-membership, nonprofit organization created by 
the University of Texas at Austin to provide leadership and guidance 
to public school debate and athletic teachers. The purpose of UIL is 
to organize and properly supervise contests. UIL provides services to 
its member schools in the organization and administration of regional 
and state championships in 14 sports. 

[20] UIL policy states that failure to comply with UIL rules can 
result in a variety of sanctions ranging from reprimand to 
disqualification from UIL activities and competitions. 

[21] The American Academy of Pediatrics published an additional set of 
guidelines for the management of concussion among children. However, 
an official from this association told us that the guidelines, which 
were published in 1999, are no longer in use, and that the association 
was in the process of developing a clinical report on sports-related 
concussion. 

[22] These sets of guidelines were all developed by organizations that 
conduct work in the area of high school athletics or sports medicine; 
officials and experts did not identify any guidelines developed by 
federal agencies. 

[End of section] 

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