This study was designed to assess the (score) construct-related validity of an instrument called the School-Wide Cultural Competence Observation Checklist (SCCOC). The instrument was developed to use as a tool in conducting culture audits as a means of assessing school-wide cultural competence, or how well a school's programs, policies, and practices reflect the perspectives and experiences of diverse groups. An exploratory factor analysis was used to identify the factor structure of the SCCOC. Results revealed that the SCCOC contained two factors that explained 72.1% of the total variance. These factors, called Policy (22 items) and Practice (11 items), yielded score reliability coefficients of 0.97 and 0.89, respectively. Recommendations for incorporating a school-wide cultural competence assessment as part of a school counseling program are then discussed. (Contains 1 table.)