Policy for the Mandatory Reporting of Suspicion of Child Abuse, Maltreatment, or Neglect

Applicability 
All employees, contractors, and volunteers who are employed or engaged by Prep and interact  with, supervise, chaperone, or otherwise oversee minors during the program or in any Prep sponsored activity are covered persons under this policy.  

Definitions 

• • Child or minor means an individual under the age of 18.
  • Child abuse includes physical abuse, physical neglect, sexual abuse, and emotional abuse. New York law defines these types of abuse as follows:
    • Physical abuse: Non-accidental physical injury of a child that ranges from superficial  bruises and welts to broken bones, burns, serious internal injuries, and in some cases,  death. It includes actions that create a substantial risk of physical injury to the child.
    • Physical neglect: Withholding, or failing to provide, adequate food, shelter, clothing,  hygiene, medical care, education, or supervision, such that the child’s physical, mental, or  emotional condition is impaired or at imminent risk of being impaired.
    • Sexual abuse: When an individual commits a sexual offense against a child or allows a  sexual offense to be committed, such as rape, sodomy, or engaging a child in sexual  activity or in a sexual performance.
    • Emotional abuse: Acts or omissions that cause or could cause serious conduct, cognitive,  affective, or other mental disorder such as torture, close confinement, or the constant  use of verbally abusive language. This may include emotional neglect, such as  withholding physical and emotional contact to the detriment of the child's normal  emotional or even physical development.
  • Covered person means all employees, contractors, and volunteers who are employed or engaged by Prep and interact with, supervise, chaperone, or otherwise oversee minors during the program  or in any Prep-sponsored activity.*
  • Covered employee means any covered person who is employed by Prep. 
  • Maltreatment (including Neglect) means that a child’s physical, mental, or emotional condition  has been impaired, or placed in imminent danger of impairment, by the failure of the child’s  parent or other person legally responsible to exercise a minimum degree of care by:
    • Failing to provide sufficient food, clothing, shelter, or education; 
    • Failing to provide proper supervision, guardianship, or medical care (refers to all medical  issues, including dental, optometric, or surgical care); or
    • Inflicting excessive corporal punishment, abandoning the child, or misusing alcohol or  other drugs to the extent that the child was placed in imminent danger.
  • Reasonable cause to suspect child abuse or maltreatment means that, based on your rational observations, professional training and experience, you have a suspicion that a parent, a  guardian, or a caregiver of a child is abusing or maltreating that child. Under Prep’s policy,  reasonable suspicion of child abuse or maltreatment also includes situations where you  reasonably suspect that an adult who interacts with, supervises, chaperones, or otherwise  oversees minors in a Prep program or activity is abusing or maltreating a child. It is enough that  you have a suspicion, backed by a reason, that a child with whom you work is being  harmed. Your reasonable suspicion can be based upon:
    • Witnessing a single incident
    • What a child says
    • What an adult with a reasonable suspicion tells you about a child
    • Distrusting an explanation for an injury
    • A pattern or combination of concerning behaviors
  • Student means any current student participant in either Prep or PREP 9, regardless of age. For the avoidance of doubt, this means students in the Preparatory Component, post-placement students, and undergraduate students.

Policy Statement & Procedure
This policy requires covered persons to report immediately in situations where they have reasonable cause to suspect abuse or maltreatment of any child who is affiliated with the Prep community. This includes children under the age of 18 who are undergraduate students.

• If a child is in immediate danger or you require emergency assistance, call 911. 
• Notify your Component Director. 
• Your Component Director will work with you to make a report to the New York State Child Abuse & Maltreatment Hotline: 800-342-3720. When calling the NY State Child Abuse & Maltreatment Hotline, make sure to obtain an ID number and the name of representative contacted. Oral reports must be followed by completing this form from the Office of Children and Family Services, and promptly sending it to the local child protective services where the incident(s) occurred. 
• You must also notify the Director of Mental Wellness, Alejandro Luciano, 212-579-1390, aluciano@prepforprep.org.
• You must fill out a Prep incident report, available on the Prep wiki page.

If you have reasonable cause to suspect that a child affiliated with the Prep community has been  abused, maltreated, or neglected by a member of the Prep community and the abuser is  someone other than a parent or caregiver, you must take the following steps: 

• If a child is in immediate danger or you require emergency assistance, call 911.
• If the child is not in immediate danger, notify your Component Director. Your Component Director will consult with you on next steps.
• You must also notify the Director of Mental Wellness, Alejandro Luciano, 212-579-1390,  aluciano@prepforprep.org.
• You must fill out a Prep incident report, available on the Prep wiki page. 

Covered persons may also speak with a supervisor prior to making a report and may be assisted by such individual while making a report. 

Any question or uncertainty as to whether an action or behavior should be reported shall be  resolved in favor of reporting.
 
Covered persons should endeavor to maintain and respect the confidentiality and privacy of  students implicated in such reports to the extent practicable and as permitted by law.

Special Situations  
In some situations, the New York State Child Abuse & Maltreatment Hotline might decline to  take a report for reasons including because the alleged abuse or maltreatment did not occur at  the hands of a caregiver, because it occurred in a different state, or because the NYPD Special  Victims Bureau or another law enforcement agency may be a more appropriate agency for  receiving the report. In these situations, the Director of Mental Wellness is available to assist in  identifying the appropriate external agencies to contact.

Acknowledgment & Training 
Covered persons are required to read and acknowledge applicable policies and procedures as  directed by Prep.  

Covered employees are required to complete this online, two hour, web-based online training  course sponsored by the New York State Office of Children and Family Services. This course  meets the New York State Education Department mandatory requirements for Training in Child  Abuse Identification and Reporting.  

Prep may hold additional required trainings, with topics including but not limited to: the  obligation to report inappropriate behavior including the mandatory reporting requirements  under New York law, Prep’s policies providing for the safety of its students, and legal  requirements regarding safeguarding children.  

Recordkeeping
In the event a report is made, the relevant Component Director and the Director of Mental  Wellness shall notify the Chief Executive Officer. The Chief Executive Officer will inform the  President(s) of the Board of Trustees. 

All incident reports shall be maintained by the Executive Director.  

Retaliation is Prohibited
Prep will not allow any form of retaliation against individuals who make a report or raise  concerns related to this policy.
Retaliation is any form of intimidation, reprisal, bullying, or harassment directed against an  employee, student, or third party who makes a mandatory report, provides information during a  mandatory report, or otherwise assists in the enforcement of this policy.

Additional Resources for Mandated Reports 

• Summary Guide for Mandated Reporters in New York State
• New York State Mandated Reporter Resource Center 
• NYC Administration for Children’s Services Mandated Reporter Information 
• Centers for Disease Control and Prevention resources about recognizing and responding to child  abuse and neglect

Questions 
Questions or concerns about this policy should be directed to the Director of Mental Wellness.