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There are four key concepts related to program management after an allegation of child abuse and neglect. These are: patron notification, cooperation with investigations, documentation, and staffing. It is important that you understand and follow procedures related to these four topics. First, these concepts will be presented for allegations of familial abuse or neglect. Then the concepts will be presented for allegations of institutional abuse or neglect.

Allegations of Familial Abuse or Neglect

Patron Notification Procedures

It is not unusual for families to want information about allegations of child abuse or neglect. If a child who attends the program was harmed, families might want or need guidance about how to talk to their children.

It is part of a manager’s role to communicate with families and to provide them with information that relates to their child’s care and education. However, you must carefully follow guidance provided to you about communication.

When the allegation of abuse or neglect relates to familial abuse, confidentiality is of utmost importance. Ensure that you and staff members respect the family’s privacy. You cannot share information about the allegation, investigation, or circumstances surrounding the report or recovery with anyone other than investigators and those with a professional need to know (FAP, law enforcement, CPS, etc.). Violating confidentiality can, in some cases, be grounds for disciplinary action, impact the investigation, and make the program vulnerable to legal action from the family. Privacy for the family must be maintained. They decide when and with whom any information is shared. If a child has been seriously harmed or killed, however, it is expected that the other children and families might need guidance and support. Call your Family Advocacy Program and Social Work Services. They can help provide counseling and/or educational events for families about processing emotions, talking to children about trauma, and recovering as a community. You should also re-evaluate your ����Dz�������’s services to families around the protective factors at times like these. Are you doing everything you can to help families build resilience, develop social connections, learn about child development and parenting, gain access to concrete supports, and build the social and emotional competence of their children?

Cooperating with Investigations

Allegations of abuse and neglect can be stressful on many levels, for many individuals. As a manager, you will need to cooperate fully with any investigations that involve families or staff members in your program. Cooperating with an investigation may involve the following components:

• Provide access to administrative files, attendance records, work schedules, video footage, incident reports, family addresses and phone numbers to those with an official need to know.
• Provide access to personnel for interviews.
• Take notes, make observations, and record relevant management information during the investigation.

Maintaining Documentation

The work you do every day to maintain accurate and thorough program records is vital in investigations of child abuse and neglect. As mentioned above, you might be required to provide access to program records such as attendance records, staff schedules, incident reports, video footage, and the like. Having the systems in place to maintain these records is critical. You and staff members may also be asked to contribute additional records to the investigation. It can be helpful for staff to maintain:

• Records of child health screenings or illnesses
• Observational records
• Communication logs with families
• Records of reports of abuse or neglect

All records of suspected abuse and neglect should be stored separately from the regular program files. This helps maintain a child and family’s confidentiality.

Maintaining Staffing and Accountability

It is possible that allegations of familial abuse or neglect may impact staffing. You will need to cooperate fully with investigations, and this might include scheduling out-of-the classroom time for staff members. For example, staff may be asked to participate in interviews with FAP, law enforcement, or CPS during the workday, or it might be necessary to allow a staff member to ride along with children for medical care.

In all cases, you must ensure that accountability for children is maintained at all times. Maximum group sizes should not be exceeded, and adult-to-child ratios must always be maintained. You should design your schedule carefully and also have back-up plans in place for emergency situations. You or other members of the leadership team (Training & Curriculum Specialists, etc.) should be prepared to provide coverage in classrooms or programs when necessary. Consistency of care is also critical. To the maximum extent possible, make sure children experience consistency in adult staff members.

Allegations of Institutional Abuse or Neglect

Patron Notification Procedures

For allegations of abuse or neglect that took place in the program (allegations of institutional abuse or neglect), families might have very valid concerns about their child’s safety. They might want to know what has happened to the staff member, whether there is any risk their child was involved, whether the children are safe now, and what steps have been taken. They may even withdraw their child from the program.

In allegations of institutional abuse, patrons should be notified only in accordance with guidance provided by the installation Commander and the Public Affairs Office. You should be available to talk to families in accordance with the guidance provided by FAP and the installation Commander. Counseling for families should be made available through installation behavioral health services or family advocacy resources. Also contact your Family Advocacy Program about education services that can be provided to families. FAP can assist families to get the support and help they need, either through installation behavioral health resources, FAP counseling services, or civilian resources.

You should also make sure that the alleged individual suspected of abuse or neglect maintains confidentiality. They should not discuss the accusation during the investigation with other staff members, volunteers, providers, families, or the victim. Make it clear to all staff members that this is the expectation and the requirement. It is natural for staff members to be curious about the situation and to want details. You must set the expectations that staff members will behave professionally during this difficult time and that they will not discuss the allegation. Set the expectation that they will not engage in gossip, hearsay, and misinformation that can damage the program and its reputation. Remind them to refer families with questions to the Family Advocacy Program or social workers.

Cooperating with Investigations

In allegations of institutional or “out of home” abuse, there may be additional reporting requirements aligned to the investigation. You may be required to provide:

• Chronology of events (who, what, where, when, dates, times, agencies contacted)
• Background check documentation
• Materials requested from the program (photos, video surveillance system footage, military police report, etc.)
• Notification to NAEYC with supporting documentation (critical event report form or serious incident report form)
• Notification of anticipated or actual media coverage

Your Service may require additional reporting procedures for allegations of institutional abuse. Follow any guidance your Service provides about notification through the chain of command and higher headquarters reporting.

Your Service may require additional reporting procedures for allegations of institutional abuse. Follow any guidance your Service provides about notification through the chain of command and higher headquarters reporting.

Your Service may require additional reporting procedures for allegations of institutional abuse. Follow any guidance your Service provides about notification through the chain of command and higher headquarters reporting.

Your Service may require additional reporting procedures for allegations of institutional abuse. You should ensure that the Reporting Point of Contact and local CPS (if located in CONUS) are always contacted, and follow any guidance your Service provides about notification through the chain of command and higher headquarters reporting.

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Maintaining Documentation

The same guidelines described above are important in cases of suspected institutional abuse or neglect. Staffing schedules and observational records can be of critical importance during investigations. You and staff members may also be interviewed.

In substantiated cases of institutional abuse, it is important that you document the reporting procedures that were followed. Following reporting protocols is the most important thing you can do to prevent the individual from being hired elsewhere, so you should make sure your program protects itself by documenting its actions. This means following your �������������’s ����Dz�������’s guidelines to ensure that the information about the abuse is documented and maintained. Future employers are responsible for conducting thorough background checks, but your records could be important.

Maintaining Staffing and Accountability: Institutional Abuse or Neglect

Staffing and accountability is most relevant to allegations of institutional abuse or neglect. In those cases, a staff member must be immediately reassigned to a position without child contact while the investigation is under way. You must design your schedule carefully and have back-up plans in place for these types of situations so that classrooms are fully covered. You or other members of the leadership team (T&CSs, etc.) should be prepared to provide coverage in classrooms or programs when a staff member is reassigned because of an investigation. You will need to cooperate fully with investigations. This might include scheduling out-of-the classroom time for staff members to complete interviews with FAP, law enforcement, and CPS during the workday or updating the program schedule to ensure appropriate coverage if a staff member is removed from direct contact with children.