Overview
EEC did not require its programs to provide staff members with trainings that aim to prevent or screen for child abduction, sexual exploitation, or trafficking. We found that 30 (75%) of the 40 sampled residential programs’ Runaway Policies did not have a procedure in place for staff members to screen runaway children for signs of sexual exploitation or human trafficking. (See the "Trainings to Recognize Trafficking” section of this report.)
If EEC does not ensure that its programs have comprehensive Runaway Policies in place, then there is a higher-than-acceptable risk that instances of sexual exploitation or human trafficking may go undetected for children in EEC’s care.
Authoritative Guidance
The Massachusetts Interagency Human Trafficking Policy Task Force published a report in 2013 highlighting that training for educators on identification and screening of missing or runaway children is a key component to the prevention and detection of sexual exploitation or human trafficking. The report recommends that entities involved in child welfare, such as residential programs licensed by EEC, implement comprehensive policies and training programs aimed at preventing and identifying signs of sexual exploitation and human trafficking among children. We believe these recommendations serve as best practices for the expected level of vigilance and proactive measures in child welfare institutions to ensure the safety and security of vulnerable children.
Reasons for Lack of Training
EEC did not give a reason that its current training for programs does not cover this area. Additionally, EEC did not have any policy requiring programs to screen children who are found or return to residential programs.
Recommendations
- EEC should require residential programs to include trainings for staff members to recognize the signs of, and screen to prevent, sexual exploitation or human trafficking of children in their care.
- EEC should monitor residential program staff members to ensure that they are completing the recommended trainings.
Auditee’s Response
EEC recognizes the importance of addressing the issues of abduction, sexual exploitation, and human trafficking. Under EEC’s licensing regulations, all programs are required to submit runaway procedures. See 606 CMR 3.03(1)(a)(3) and 606 CMR 3.07(10). The current licensing regulations regarding runaway procedures do not require screening. See id. Additionally, all programs have runaway plans within LEAD and specific language regarding missing and exploited children may be in a program’s contractual language. EEC is also currently in the process of revising its residential program regulations, including proposed regulatory changes and updates in this area.
Auditor’s Reply
By not requiring residential programs to include this specific training for their staff members, EEC may be missing critical opportunities to protect children who are at risk. EEC cites licensing regulations 606 CMR 3.03(1)(a)(3) and 606 CMR 3.07(10) that require programs to submit runaway procedures; however, as EEC itself notes, these regulations do not mandate staff training on screening for signs of sexual exploitation or human trafficking. The absence of these training requirements means that employees may not be equipped to identify or respond appropriately to these critical issues when children return after running away. Therefore, despite the cited regulations, EEC should include screening procedures in its runaway policies to protect vulnerable children in residential programs.
EEC stated it is in the process of revising its residential program regulations, including proposed changes and updates in this area. We strongly recommend that these revisions incorporate requirements for residential programs to provide its employees with training to recognize the signs of, and screen to prevent, sexual exploitation or human trafficking of children.
| Date published: | November 25, 2024 |
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