TRAINING CONSIDERATIONS

The knowledge and skills imparted through training are critical for ensuring that everyone on staff is accountable for preventing adult sexual misconduct (ASM) and responding appropriately when it is suspected. In choosing content, schools should consider the specific training implications for several types of school personnel. The preventive measures a teacher will take might be different from those of an administrator. The examples and illustrations used should reflect these varying roles within the school (U.S. Government Accountability Office [GAO], 2014). For this reason, schools may decide to provide training to administrators and nonadministrative staff separately. Specialized training should be provided to the Title IX coordinator(s).

All-Staff Training Content

Training content that is necessary for all staff members is listed below. The content should do the following:

• Include a working definition of ASM.
• Explain the school’s ASM policies, underscoring the fact that some ASM behaviors (e.g., those meeting the legal definition of child sexual abuse) are criminal acts. Therefore, ASM behaviors may lead to termination of employment and punishment under the law.
• Identify the warning signs of the effects of ASM on children, providing examples, when possible, from reported cases.
• Explain the role and legal responsibilities of mandatory reporters and the school’s internal reporting procedures.
• Point out the consequences for failing to report ASM, as well as protections for those who report in good faith when incidents of suspected ASM turn out to be unsubstantiated.
• Describe how school policy prohibits the making of intentionally false ASM complaints and the repercussions for doing so. Emphasize that protecting the reputation of innocent educators is a high priority for the school.
• Identify perpetrator patterns of behavior, providing examples from local and national media accounts or case studies that are relevant to the school setting.
• Describe policies and procedures involving transportation, the physical school environment, toileting, and electronic communications, including social media.
• Take time to address questionable, but not criminal, behaviors (i.e., the “gray areas”) in both in-person and electronic interactions with students.
• Include information about which students are likely to be ASM targets and what school personnel can do to protect these at-risk students.
• Identify a school and/or district Title IX coordinator(s) and describe their roles, pointing out the location of their office(s) in the school or district and providing contact information.
• Discuss the steps school personnel are expected to take to reduce the risk of ASM in the physical environment. For example, some schools regularly monitor locked classrooms, storage rooms, and offices.
• Consider distributing a handout during training that describes the school’s policies and asking staff members to sign it.
• Conduct a post-training assessment mechanism, such as a survey, to gauge the impact of the training, and determine the need for adjustments in content, approach, or format.

Administrator Training Content

As leaders in ASM prevention and response, school administrators are charged with specific mandates and face some issues that are different from those faced by other school personnel (GAO, 2014). Therefore, in addition to addressing the content described for all-staff ASM training, a separate training for administrators can consider the following additional topics:

• State laws and mandates specific to ASM prevention and response
• Title IX policies and procedures pertaining to ASM
• Oversight of the Title IX coordinator
• Strategies for ensuring prevention and response compliance by other school personnel
• Complaint processes and critical communication protocols within the school
• The threat- and hazard-specific annex(es) relating to ASM
• Policies for placing alleged perpetrators on administrative leave and maintaining confidentiality during internal and external investigations
• Guidelines for working with local law enforcement
• Measures to promote school recovery after an ASM incident
• ASM recordkeeping, data management, and accountability

Culture of Zero-Tolerance. Administrators set the tone for school conduct and model appropriate adult behavior. Checking off a list of requirements to comply with ASM directives will not bring about the cultural changes necessary to preventing ASM. Rather, the driving force behind cultural changes should be a sense of responsibility for protecting students and providing them with a safe and nurturing learning environment (National Coalition to Prevent Child Sexual Abuse and Exploitation, 2012).

Title IX Coordinator Content

School districts that receive Federal funds must designate an employee to oversee Title IX requirements, act as a point-of-contact for sexually related complaints, and coordinate investigations (GAO 2014). This individual, known as the Title IX coordinator, is critical to the prevention of and appropriate response to ASM. School administrators should carefully consider the selection of these personnel. Title IX coordinators should not have other job responsibilities that could create a conflict of interest. Employees whose job responsibilities may conflict with a Title IX coordinator’s duties include directors of athletics, deans of students, and any employee who serves on the judicial/hearing board or to whom an appeal might be made. The best way to avoid a conflict of interest is to designate a full-time Title IX coordinator (GAO, 2014).

The need for specific training in Title IX coordinator responsibilities was highlighted by the GAO (2014) when they interviewed experts who worked with school districts to provide training on ASM prevention. These experts noted that some school administrators were not aware of the requirements of Title IX, who the Title IX coordinator was, or the coordinator’s responsibilities. The following list of responsibilities from the U.S. Department of Education’s guidance on Title IX should be addressed in the training for this position (Office for Civil Rights, 2014). A Title IX coordinator is responsible for the following:

• Overseeing the school’s response to Title IX reports and complaints.
• Identifying and addressing any patterns or systemic problems revealed by the reports and complaints.
• Understanding the requirements of Title IX, the school’s own policies and procedures on ASM, and all complaints that raise Title IX issues in the school.
• Remaining trained on and informed of all reports and complaints raising Title IX issues, even if the report or complaint was initially filed with another individual or office, or if the investigation will be conducted by another individual or office. The school should ensure that the Title IX coordinator is given the training, authority, and visibility to fulfill these responsibilities.
• Providing training to students, faculty, and staff and information to families and guardians on Title IX issues.
• Conducting Title IX investigations, including analyzing the facts relevant to a complaint, determining appropriate sanctions against the perpetrator, and deciding on interim measures to protect the complainant when an allegation of ASM is made.
• Ensuring that policies and procedures are in place for working with local law enforcement, and coordinating services with local victim advocacy organizations and service providers, including rape crisis centers.

Making Training Mandatory

ASM prevention and response experts advise making training mandatory for all school personnel who have direct contact with students. This ensures that all members of the school community hear the same messages about ASM and are knowledgeable about the school’s policy, as well as prevention and response measures (Shakeshaft, 2004b).

Format and Frequency of Training

Most schools require ASM training for at least some of their personnel, often at the beginning of the school year (GAO, 2014). For example, as of 2014, Texas Education Code § 38.0041 requires that all district and school employees — including grades K–5 teachers, campus principals, and bus drivers — receive training on how to prevent and recognize sexual abuse and other forms of child maltreatment (Texas Education Agency, 2014). During the planning process, schools should identify areas that call for ongoing training and identify staff members who will begin employment after the school year is underway so that they can be trained upon arrival.

To create ASM training, school districts should incorporate state mandates and can work with established training models used by other schools or designed by field experts (such as those included in the list of ASM training resources later in this chapter). They may use a single format or approach or combine several of them — for example, in-person, interactive training, as well as online learning modules.

Interactive, scenario-based training provides participants with opportunities to practice responses and may boost motivation (GAO, 2014). Online training modules offer convenient and self-paced learning opportunities that often include tracking and reporting tools for compliance with district policies and training protocols. When considering online training, experts caution against courses that are simply reading-based, with quizzes that test for reading comprehension and short-term content retention. Training assessments should determine the extent to which a participant is able to apply what he or she has learned to real ASM scenarios (Andrews and Haythornthwaite, 2007).

Addressing Training Challenges

Anticipating and accounting for training challenges will ensure that districts are prepared to manage the challenges that invariably arise. Training challenges vary depending on the size of the school and district, the depth and format of the training, and the school’s or district’s budget. For schools with high staff turnover, ongoing screening and training can seem daunting. Standardizing new employee training and placing it in the context of the district’s commitment to safeguarding children can help allay pressure from those pushing for a quick start date for the training. Some schools face disinterest from staff members who believe their school or district does not have an ASM problem (GAO, 2014). In such cases, presenting ASM statistics for the county or region, along with media accounts of local incidents can help to counter these beliefs.

Regardless of the obstacles to standardized training, it should serve as the foundation of ASM prevention and response.

Requiring that staff members read a handbook of policies and procedures on ASM prevention will not achieve the intended results.