Equity and Access Services

Office of the President

Non-Compliance Procedures

Site Visits

The Protection of Minors staff may conduct site visits to review the Program for compliance with the university’s Safety and Protection of Minors Policy. Site visits may be announced or unannounced and will take place during the Program. The reviewer will take notes and provide feedback to the Program Supervisor to make any adjustments for compliance purposes. If a Major violation is found during a site visit, the Program Supervisor may need to take immediate remedial steps to improve the safety of Minors within the Program. 

Definitions

Moderate violation: A Moderate violation is a violation of the Safety and Protection of Minors Policy which does not cause active harm to a Minor but which violates registration, documentation, or other requirements of the Policy. 

Major violation: A Major violation is a violation of the Safety and Protection of Minors Policy which causes active harm to a Minor, poses an immediate risk to the health or safety of a Minor, or puts one or more Minors at an increased risk for harm or abuse due to lack of mandated training, screening, or supervision.

Non-Compliance

Programs found in non-compliance will receive follow-ups and sanctions based on the severity of the Policy violation.

  1. In the event of a Moderate violation, the Protection of Minors Office will notify the Program Supervisor by email and include a noncompliance form describing the violation and required remedy. Repeated Moderate violations may result in a Probationary Period.

Examples of Moderate violations include, but are not limited to:

  • Program was not registered prior to Minor participation.
  • Program did not upload required documentation.
  • Program staff with gaps of compliance due to expired training during the Program.
  1. A Major violation or repeated Moderate violations will result in a Probationary Period for the Program, and the Program Supervisor and a unit head will be notified via email from the Protection of Minors Office. 

Examples of Major violations include, but are not limited to:

  • Program staff who began interacting with Minors without compliance requirements.
  • Minors engaging in unsupervised or unsafe activities during the Program.
  • Minors participating in an activity that is immediately dangerous to their health or safety, e.g. swimming without a supervising lifeguard.
  • Active abuse of a minor.

Based on the severity of the violation, further sanctions may occur. These sanctions could include:

  • Required change in programming or staffing by a set date.
  • Immediate removal of offending Program staff member(s).
  • Halting of Program if Program cannot continue without threat of harm.
  • Inability to register future Programs on campus for a set amount of time.

Reporting of Major violations:

All individuals interacting with minors, both VCU employees and third parties, are required by Virginia Law to report suspicions of child abuse or neglect to the Virginia Department of Social Services at (800) 552-7096 immediately, but no longer than 24 hours after having reason to suspect a reportable offense of child abuse or neglect. 

In addition, the following entities must be notified as soon as possible of any behavior that represents a physical threat to a minor or by a minor to another individual within a Program (see VCU Violence Prevention and Threat Assessment Management Policy):

  • VCU Police: 804-828-1234
  • Protection of Minors Office: youth@vcu.edu or 804-828-1524 

VCU employees are also encouraged under the VCU Duty to Report Policy to report child abuse or neglect to the Office of Integrity and Compliance via the Helpline at 1-888-242-6022 or the office directly at 804-828-2336. 

Probationary Period

  • The Probationary Period is assessed to both the Program and the Program Supervisor. 
  • The Probationary Period will last six months or until the completion of the next Program of either the same nature or run by the same Program Supervisor, whichever is later. Programs are allowed to continue during the Probationary Period.
  • The Program Supervisor will be required to meet with the Protection of Minors Office for additional training and assistance.
  • The Program and Program Supervisor’s compliance will be reassessed at the end of the Probationary Period.
    • If the Program has met compliance requirements, the Probationary Period will end.
    • If the Program has made measurable progress but has not met all compliance requirements, the Probationary Period will extend for another six months or until the completion of the next Program of either the same nature or run by the same Program Supervisor, whichever is later, and the unit head will be notified.
    • If the Program has not made measurable progress, the Probationary Period will extend for another six months or until the completion of the next Program of either the same nature or run by the same Program Supervisor, whichever is later, and both the unit head and department head will be notified via email.

FAQ regarding the Non-Compliance Procedures can be found here.