DALLAS — When was your first menstrual period? When was your most recent? How many periods have you had in the past year?
These are among the questions Texas student-athletes are asked on forms when they register to play a sport in middle or high school.
The menstrual cycle questions have led to controversy in at least one other state in light of heightened concerns for transgender athletes and new laws criminalizing abortion. Florida officials are reconsidering what student-athletes are asked about sensitive medical information including questions about girls' menstrual periods after parents in Palm Beach and three other Florida counties recently raised medical privacy concerns, The Palm Beach Post reported.
Most Texas school districts use the same annual physical form that prompted controversy in the Sunshine State, but officials say the practice hasn’t come under similar scrutiny in Texas.
Several Texas school districts, including Austin, Dallas, Houston and Fort Worth, use a form that mirrors Florida’s form — except the “females only” questions aren’t indicated as optional.
A three-page physical form asks a series of questions about students’ medical histories, such as whether they have asthma or a history of fainting, as well as optional questions pertaining to students’ menstrual periods.
Like some Florida districts, Texas schools also use a similar, but different third party to upload, organize and store that information — a move that has heightened concern among parents, who argue this type of information should be kept between an athlete and her doctor.
District officials contend the forms are required by Texas’ University Interscholastic League (UIL) — the governing organization for most of the state’s K-12 athletic programs — but the UIL’s Deputy Director Jamey Harrison says that’s not quite true.
Meanwhile, some doctors say schools should not be privy to this type of information, saying menstrual periods are unlikely to have an effect on athletic performance.
And some worry that questions about menstrual cycles or testicles could “out” transgender student-athletes, even though a new Texas law passed in 2022 already bars transgender student-athletes from competing on school sports teams that align with their gender identity. Student-athletes must compete under the sex noted on their birth certificate.
The health and safety of student-athletes is the UIL’s top priority, Harrison recently told The Dallas Morning News.
The league requires all student-athletes to undergo a physical examination prior to participating in sports, at least in their first year of middle school and the first and third years of high school, Harrison said. Many school districts require physicals annually.
Student-athletes are required to submit a “pre-participation physical evaluation and medical history form” signed by a physician.
The medical history forms created by the league that inspire most districts’ versions are informed by the UIL’s Medical Advisory Committee, a panel of pediatric and sports medicine doctors created by the legislature in 2001, Harrison said.
“Since then, anything related to the health and safety of student-athletes comes to the UIL’s committee for review and recommendation,” Harrison said.
Though the committee doesn’t make rules or policies, 100% of its recommendations have been accepted so far, Harrison added.
The form most Texas schools use is consistent with UIL recommendations and national recommendations, Harrison said. The current version of the form, which includes questions about an athlete’s period has been in use since at least January 2009.
Student-athletes have been required to undergo physicals for decades. Schools often even host free or low-cost sports physical nights or help connect students to medical providers who could clear their athletes to play.
Such screenings are important, sports officials and medical providers agree.
And some of the information asked about and collected should certainly be shared with coaches, Dr. Anne-Marie Amies Oelschlager, the chief of pediatric and adolescent gynecology at Seattle’s Children Hospital and the vice-chair of the American College of Obstetricians and Gynecologists’ clinical consensus committee, said.
The big issues physicians look at when screening adolescent athletes include a history of cardiac conditions and arrhythmias or irregular heartbeats, which are medical issues important for coaches to know about, Amies Oelschlager said.
Asthma, seizure disorders, having only one kidney or a history of other conditions could also be important.
It is important for medical providers to consider menstrual cycles, as irregular cycles can indicate possible hormonal imbalances, thyroid issues and even a well-known, albeit rare condition that could affect a range of an athlete’s abilities called “relative energy deficiency in sport,” or RED-S, when evaluating a student’s overall health, but in the absence of rare conditions, information about a student’s menstrual cycle is not relevant to coaches, Amies Oelschlager.
And many of the invasive questions are likely to make some students uncomfortable, especially students who might have a range of conditions that could affect their menstrual cyclee, an intersex condition or were born without a uterus.
“I think they could feel very uncomfortable, particularly with the menstrual period information being asked or if they have health issues they don’t necessarily want to discuss,” she said.
Blanket clearance from a physician could suffice for most adolescents to play, some say.
And how that information is stored and who has access to it is also important.
In Florida, parents who first raised concerns about the menstrual period information being collected from their students were also concerned about the third-party vendor, Aktivate, used to collect and store athlete information, including medical histories. Aktivate was created in September 2021, but only a handful of districts currently require students to register and upload their medical information to the system, The Post reported.
But whether the company is FERPA or HIPAA — laws that govern privacy around student or medical data — compliant is unclear. Apps that are based in the U.S. can be subject to subpoena and Aktivate’s privacy policy says it, too, can turn over student data to legal authorities.
Several Texas districts including Dallas ISD and Fort Worth ISD, use their own version: Rank One Sport.
The medical history forms, including answers to questions about menstrual periods, lists of medications and other sensitive information are uploaded and stored on the platform.
The company’s website boasts that it is both HIPAA and FERPA compliant, but Rank One Sport’s privacy policy says it also can turn over student data to legal authorities as well as to other third parties, “including but not limited to schools, military bases, and athletic departments” the company does business with.
In Dallas ISD schools, coaches and athletic trainers also review and have access to the forms, district spokesperson Caren Rodriguez said in an email. The same is true in Houston ISD.
School officials in Austin and Fort Worth did not return requests for comment.
But Harrison says much of how the information is handled is up to the local district. The UIL doesn’t officially require the sample form it provides and doesn’t have a relationship with Rank One Sport.
“What the student has to have (to play) is clearance from the medical provider,” Harrison said. “How that works between the student and the doctor is up to them.”
But some school districts won’t accept physical forms that aren’t completely filled out.
Houston ISD student-athletes must submit the district-provided medical form annually with all portions filled out, district spokesperson Luis Morales said in an email. The forms are stored “district facilities” and reviewed by district trainers and coaches.
Dallas ISD students are also required to submit the same district-provided form, Rodriguez said. She pointed to the UIL’s website, citing a UIL requirement for athletes to submit such a form.
Neither district will accept a letter from a physician giving an athlete clearance.
Adolescents deserve extra safeguards when it comes to their medical information, Amies Oelschlager argues, especially in states where access to reproductive health care — or where questions around sexuality or gender identity can have significant repercussions — is difficult.
But Harrison said the UIL isn’t aware of any concerns around the menstrual information collected from Texas students, calling it a “non-issue.”
He can only think of one instance where a parent raised concerns about a district’s practice, but not with the state’s policies themselves.
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