The number of persons who may have contact with children and vulnerable adults is extensive. Countless different professions and types of organizations serve these populations. Given the need to protect children and vulnerable adults from abuse in a variety of settings and the significant differences in organizational purpose, staffing needs, and available resources, these guidelines present a decisionmaking model rather than a list of screening practices to be used in every circumstance. The model poses questions to ask when deciding which background screening practices to utilize. The model assumes that screening for any position will include at least a written application with a signed statement, professional and personal reference checks, and an interview. Supplemental screening measures may also be warranted.

The decisionmaking model provides a framework for analyzing when to conduct supplemental screening practices. As a framework to assist States, organizations, and others in developing screening policies, the model reflects the desire of Congress to encourage screening practices while maintaining deference to the States on this issue.¹⁹ The decisionmaking model is designed to facilitate a serious, careful examination focusing on opportunities for harm. This model is not the only set of steps that could be developed. States, coalitions, associations, and organizations are encouraged to develop screening practices for use in particular settings. Screening for specific settings and types of workers (employees or volunteers) could also incorporate evaluations of competence for particular tasks; however, this model does not directly address competence goals.

Further, screening must be placed in context. It is one tool aimed at preventing harm. Others include education (of staff and volunteers, parents and guardians, children and vulnerable adults) and abuse prevention policies (discouraging opportunities for abuse and encouraging children and vulnerable adults to voice concerns about inappropriate behavior). Appendix C, Some Suggestions for Implementing Screening in the Organization, and Appendix E, Posthiring Practices, present additional information that may be useful. These are suggestions for consideration; there may be many other ways to implement screening.

Preparation steps before using the model
Review tasks and positions
Reviewing the types of positions in the organization and the general tasks and characteristics of each is useful before beginning to assess the screening required for a particular type of position. Screening to prevent harm should supplement selection procedures aimed at evaluating the qualifications of an applicant for a particular task or job. This decisionmaking model focuses on the former.

Review harms
Before beginning to use the model, it is also useful to ask: What are the harms that are being screened against? Physical, sexual, and emotional abuse? Theft and other property offenses? Arson, assault, or murder? A clear understanding of the specific potential for harm associated with particular positions will help to focus the discussion of screening issues. For example, concerns about theft may be especially important for certain programs serving the elderly.

The model
Step 1: Assessment of triggers
The screening decisionmaking model includes three major steps. The first step requires an assessment of the presence and degree of screening "triggers." These triggers can be divided into three categories -- those involving the setting, those pertaining to the worker's contact with the adult or child, and special considerations.

Setting considerations:

• Will others (adults or children) be present during the contact (the opportunity for abuse is increased if no one else is present)?

• Who are those other people (the opportunity for abuse may still be exceptionally high if young children or certain vulnerable adults are the only others present)?

• Will the worker be closely monitored and supervised?

• What is the precise nature of the worker's involvement with the organization and with the client population (whether the worker is an employee or volunteer may be part of this assessment)?

• What is the physical location of the contact (e.g., in a classroom, a camp, anywhere -- care should be taken in considering all activities and their different physical locations, including transportation to and from events)?

Contact considerations:

• The duration of the contact (how much time is spent with the client per occasion).

• The frequency of the contact and the length of the relationship (e.g., one-time only, once a week for a year).

• The type of contact (e.g., does the worker have direct contact with children or vulnerable adults or does he or she have administrative or other duties that support the activities of the organization? With the latter, is there in fact one-on-one contact?).

Special considerations. Are there special circumstances that should be factored into the screening decision? At this point, an examination of the vulnerability of the individuals served is important. Those whose ability to communicate is impaired because of age, infirmity, life history, or other reasons may be exceptionally vulnerable to abuse. For example, children with certain learning disabilities or those with a history of abuse or neglect may fall into this category.

There may also be State laws or regulations that require certain screening practices to be used, triggering the use of a certain screening method. For example, States may require that State or Federal criminal record checks be done. If a State license or certification is required, statutory or regulatory requirements may also be in place.

Step 2: Evaluation of intervenors to decisionmaking
With the triggers in mind, consideration moves to the second step of evaluating "intervenors," or items that may limit or affect the screening decision:

• Unavailable or inaccessible information. Certain screening mechanisms may not be available. For example, a number of States simply do not authorize criminal record checks for a number of types of persons serving children, the elderly, or individuals with disabilities.

• Unexpected absences or departures. An immediate need for staff may also "intervene" in the screening decisionmaking process.²⁰

• Liability concerns. The risk of liability may affect screening decisions. Federal, State, or local laws may give applicants and employees certain legal rights. For example, certain questions may not be asked during an interview/application process, and generally all inquiries must be relevant to the task or position at hand. Liability concerns could also stem from negligent hiring torts; organizations have been sued when a client was injured by an employee or volunteer they selected.

• Presence of other risk-reduction measures. A consideration of other risk-reduction measures in place is helpful in evaluating the need for specific screening practices. However, risk-reduction measures as intervenors do not necessarily obviate the need for supplemental screening. Rather, their presence is a pragmatic consideration in evaluating the screening practices used. Risk-reduction measures may include training programs or levels of supervision.

• Financial or human resources. The practical impact that financial and human resources may have on screening is also a factor to be considered.

Step 3: Analysis and selection of screening practices
The third step puts information gleaned from steps 1 and 2 together with various screening options. The model assumes that, based on this information, supplemental screening practices may be warranted. The advantages and disadvantages of each screening practice should be reviewed at this time.

As the extent and number of triggers increase, supplemental screening measures are appropriate. For example, circumstances in which repeated one-on-one contact occurs between one worker and one child or dependent adult, often in very private surroundings, will merit supplemental screening practices.²¹ Supplemental screening practices might include the following:

• Confirmation of a person's educational status (this may be particularly appropriate for young workers for whom a professional reference may not be available or for situations in which the educational degree is relevant to the task to be performed by the applicant).

• Motor vehicle record check.

• Local, State, or FBI criminal record check.

• Check of the central child or dependent adult abuse registries.

• Sex offender registry check.

• Home visits.

• Psychological testing.

• Alcohol or drug testing.

• Psychiatric history check.

An example using the decisionmaking model
A mentoring program in which mentors are matched with children offers a good illustration of the use of the decisionmaking model. The goal is to foster one-on-one relationships between children and supportive nonfamilial persons to build the children's self-esteem and expand their view of the world. This example assumes that the mentoring program is an offshoot of another organization and is limited to one city in one State. The program has an extremely limited budget with very few paid staff (mostly a percentage of the time of three individuals who have other duties as well). All of the mentors are volunteers.

Step 1: Assessment of triggers
Setting considerations:

• Will others be present during the contacts? Although mentor programs vary widely, assume that in this case, the contacts are set up directly by the mentor and child -- perhaps the first Saturday afternoon of the month for outings. Although the organization encourages educational or sports activities (e.g., visits to the library, museum, bowling) in which other adults or children are generally present, these "public" activities need not take place. The mentor and child might choose to go hiking or sit in a park and play cards.

• Who else might be present? Under this scenario, it could be anyone or no one.

• Will the mentor be closely monitored and supervised? In this case, assume that the initial meeting between a mentor and child takes place with someone from the sponsoring organization. After that, the mentor will check in with someone at the organization, at least by telephone, to report on how the visits with the child are going. Every few months, the mentor meets with this "monitor." In addition, the mentor and child attend group events that may be sponsored by the organization. For example, a picnic takes place during the summer. These events occur once or twice a year. Further, the mentor picks the child up for each visit and drops the child off afterward and may briefly see the child's guardian at those pickup and dropoff times. More often at first, and then every few months, someone at the sponsoring organization calls the child and his or her parent or guardian to see how the visits are going.

• How will the mentor be involved with the organization? In this case, the mentor will be a volunteer who spends at least several hours once a month with a child. Some additional time will be spent conversing with staff at the sponsoring organization about how the visits are going and how best to work with a child of that age.

• Where will the visits take place? Because the mentor picks up and drops off the child, the visits will include several different physical locations: the child's residence; the mentor's vehicle (or a bus or cab); and a variety of other locations such as a restaurant, sports facility, park, hiking trail, zoo, museum, or movie theater. The visits could, in fact, take place at the mentor's home (for example, the mentor and child decide they want to learn to make pizza).

Contact considerations:

• How much time will the mentor spend with the child on each visit or outing? Under this scenario, anywhere from 1 to 6 hours.

• What will the scope and frequency of the contacts be? At least once a month for a period of a year.

• What type of contact will the mentor have? Each mentor will have direct, one-on-one contact with a single child.

Special considerations. In this scenario, the children are preteen youth. Generally, they have experienced some neglect or abuse and have been referred to the sponsoring organization for matching with an adult through social service workers, foster parents, and school counselors. Their personal histories may make them particularly vulnerable to abuse.

Summary of step 1: Assessing the presence and degree of screening triggers. In reviewing the answers to the series of questions that constitute the first step, it becomes clear that in this case, several factors would trigger supplemental screening practices: repeated, direct, one-on-one contact over a period of a year; limited ability of the organization to monitor the visits; and children who may be particularly vulnerable to abuse.

Step 2: Evaluation of intervenors
The second step is to examine the factors that may "intervene" and affect the ability to screen. This scenario assumes that certain information -- State central child abuse registry and sex offender registry information -- is not available. Likewise, it assumes that State criminal record checks (done by name, not fingerprint) are not required but are available for a fee of $5 per name. In this example, Federal (fingerprint) checks are not authorized by State statute.

Step 3: Analysis and selection of screening practices
The basic screening practices should be utilized. In addition, under the scenario outlined above, supplemental screening is warranted. The repeated one-on-one contact, which may take place anywhere at various times of the day, presents risks. Because there is limited ability to monitor the mentor and the fee assessed for a State criminal check is relatively modest, use of this check would appear to be warranted. A check with the Department of Motor Vehicles (if the information is available in the State) may also be appropriate.

A different set of facts might lead to a different decision. For example, if the applicants were high school students (generally age 15 to 17 at the time they applied), some evaluators might find that criminal checks were not warranted. Others would view the cost as being minimal (and able to be passed on to the applicant without causing the loss of volunteers) and would proceed with the criminal check.

OJJDP Summary: Guidelines for the Screening of Persons Working with Children, the Elderly, and Individuals with Disabilities in Need of Support, April 1998