Illinois Mental Health Screening:
What School Leaders Need to Know About PA 104-0032
Illinois school leaders: Mental health screening for grades 3-12 will be required starting in the 2027-2028 school year.
You have time to plan strategically—or you can wait until 2027 and scramble.
The districts that will succeed are treating this as an opportunity to build the mental health infrastructure they need anyway, not just a compliance burden to delay.
PA 104-0032 Requirements:
What You Actually Need to Know
Timeline:
- Law signed: August 2024
- Implementation required: 2027-2028 school year
- ISBE releasing model procedures: September 2026
- Extension available with justification
Who Must Screen:
- All students in grades 3-12
- Public schools (required)
- Charter schools (required)
- Private schools (optional)
Student Self-Report Requirement:
This is the critical piece many schools miss: the screening must be student-completed.
- Cannot be an observation-only assessment
- Cannot be teacher-completed on the student’s behalf
- Must offer student self-report option
- Students report on their own mental health indicators
What Information Must Be Captured:
The law requires screening for specific mental health indicators.
Your chosen method must capture student self-report data on:
- Depression symptoms
- Anxiety indicators
- Overall mental well-being
- Other mental health concerns as defined by ISBE guidance (Sept 2026)
What the Law Does NOT Require:
- Use of any specific state-provided tool (contrary to some interpretations, Illinois is not providing a mandated screening tool)
- Daily or weekly screening (frequency is the district’s choice)
- Specific intervention protocols
- Universal mental health services
- Specific privacy standards beyond existing student data laws
The requirement is about WHAT data you collect (student self-report on mental health), not HOW you collect it.
Privacy and Compliance Considerations
Student Data Privacy:
Your mental health screening approach must comply with:
- FERPA (Family Educational Rights and Privacy Act)
- COPPA (Children’s Online Privacy Protection Act) – if digital
- SOPPA (Student Online Personal Protection Act) – Illinois-specific
- Local policies regarding student health information
HIPAA compliance is not technically required for schools, but choosing HIPAA-compliant systems provides additional protection for sensitive mental health data.
Access and Confidentiality:
The law requires the results go to the appropriate school personnel. You determine:
- Which staff roles have access
- How results are stored and transmitted
- Parent notification and opt-out procedures
- Confidentiality protocols
Key consideration: Student mental health data requires more stringent protections than general educational records. Plan accordingly.
Strategic Planning Timeline
2027-2028 feels far away. It’s not.
Why Strategic Districts Are Planning Now:
Spring 2026: |
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Fall 2026 – Spring 2027: |
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Fall 2027: Compliance Deadline |
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Strategic Planning Approach:
Now – Summer 2026: |
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Fall 2026 – Spring 2027: |
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Fall 2027: |
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The advantage of early planning: Better options, smoother implementation, staff buy-in through gradual rollout instead of abrupt change.
Two Approaches to Consider
Districts are taking two different philosophical approaches to compliance:
Approach 1: Periodic Screening Focused on Compliance
What it is:
Standalone mental health screening conducted periodically (quarterly, biannually, annually) specifically to meet PA 104-0032 requirements.
When it makes sense:
- District wants focused mental health intervention separate from daily classroom routines
- Limited staff capacity for daily implementation
- Privacy concerns prioritize minimal data collection
- Preference for mental health data going only to counselors
Approach 2: Integrated Daily Mental Health Monitoring
What it is:
Mental health screening is integrated into daily student check-ins, combining compliance with ongoing progress monitoring and SEL culture-building.
When it makes sense:
- District already invested in SEL infrastructure
- Want progress monitoring over time, not just compliance snapshots
- Building a culture of student voice is a strategic priority
- Teachers are prepared for visibility into student well-being patterns
Both approaches can meet PA 104-0032 requirements. The choice is strategic and philosophical, not compliance-driven.
How Class Catalyst Supports Illinois Districts
We offer solutions for both strategic approaches:
For districts choosing periodic screening:
Standalone mental health assessment that meets all PA 104-0032 requirements with privacy-first design and minimal implementation burden.
For districts choosing an integrated approach:
Daily check-ins with mental health screening built in, combining compliance with SEL culture, progress monitoring, and early intervention infrastructure.
Both are compliant with COPPA, FERPA, and SOPPA. Both provide student self-reports on required mental health indicators. Both give you flexibility in frequency and implementation.
Learn more about both options: [Link to Mental Health Solutions product page]
Next Steps for Illinois School Leaders
Download Free Resources:
Illinois PA 104-0032 Compliance Checklist:
- Complete requirements breakdown
- Strategic planning timeline
- Decision framework for approach selection
- Board communication template
- Parent notification samples
Schedule Strategic Consultation:
Discuss your district’s specific situation:
- Which approach aligns with your philosophy and capacity
- Implementation timeline for pilot programs
- Staff training and rollout planning
- Privacy and compliance questions specific to your context
Compliance as a Strategic Opportunity
PA 104-0032 is coming. You can treat it as a burden or an opportunity.
The districts planning now are asking: “How do we use this compliance requirement to build mental health infrastructure that serves our broader student support goals?”
That’s the difference between reactive compliance and strategic planning.