STATE OF CONNECTICUT
OFFICE OF THE CHILD ADVOCATE
18-20 TRINITY STREET, HARTFORD, CONNECTICUT 06106

Sarah Healy Eagan, J.D.
Child Advocate
October 4, 2019
VIA E-mail Delivery: mpassero@ci.New-London.CT.US
Mayor Michael Passero
Office of the Mayor
181 State Street
New London, CT 06320
Re:

New London Public School: OCA Investigation Status Update

Dear Mayor Passero:
This letter will provide you with a brief status update and preliminary recommendations from the
Office of the Child Advocate (“OCA”) with regard to our ongoing investigation into the New London
Public School District (“NLPS”), which investigation was initiated at your request following a series
of allegations of abuse and neglect of students and alleged failure to report suspected abuse or neglect
by various NLPS employees. The publicly reported allegations are similar to those made against a high
ranking Hartford Public School employee and the Hartford Public School District in 2017, which was
also the subject of a comprehensive investigation conducted by the OCA. The results of the OCA’s
investigation and resulting recommendations were published in a Report in December of 2017,
available on the OCA’s website.
As a foundational matter, OCA notes that concerns of sexual abuse/harassment arise in all child
serving systems and programs. It is essential that communities appreciate that child sexual abuse is
both more prevalent and less likely to be reported than people may realize. A nationwide survey of 8th
to 11th graders conducted in 2004 revealed that nearly 7% of students reported having been the
recipient of physical sexual contact from an adult in their school; and nearly 10% of students reported
being the victim of educator sexual misconduct without touching such as sharing of pornography,
sexual talk or sexual exhibitionism (Shakeshaft, 2004).
With that prevalence information in mind, OCA conducts this work with an eye toward providing
NLPS as well as other school districts with recommendations that will assist school personnel and
school communities in their efforts to prevent child abuse and promote safe and positive school
climates. Schools are first and foremost child-serving organizations and therefore must have a
sophisticated understanding of child safety and abuse prevention.

Phone (860) 566-2106 ● Toll Free (800) 994-0939 ● Web Site: www.ct.gov/oca
An Affirmative Action/Equal Opportunity Employer

 At this time, the OCA has completed its initial review of NLPS’ policies and practices with regard to
mandated reporting of suspected abuse or neglect and the District’s policies and practices regarding
compliance with federal Title IX obligations--inclusive of the District’s framework for the prevention
of, and response to concerns of sexual discrimination, harassment or abuse within the school
community. Specifically, OCA reviewed District documents related to the following:
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Mandated reporting training, including information regarding quality assurance activities and
discipline for failure to participate in training or report concerns of abuse or neglect.
Child abuse and neglect prevention activities.
Educator sexual misconduct prevention.
Title IX compliance activities and complaints by students and staff.
Training curriculum for staff and students.
Employee-specific personnel records, job descriptions, supervisory notes, investigation
records, human resource activities.

OCA’s preliminary review also included extensive examination of child welfare records relating to
DCF conducted school-based investigations over a three year period in New London, as well as
conversations with various stakeholders across the state to discuss concerns of sexual abuse in schools
and begin to develop prevention recommendations. While these state-wide conversations are ongoing,
we wanted to provide you with an update to ensure that we are being responsive to your priorities and
concerns.
We appreciate that District and New London officials share a commitment to student safety and are
engaged in a local process of review and remediation. We are in receipt of information from the
District regarding its personnel policy and practice changes as well as new curriculum and innovations
designed to support healthy student development and promote positive school culture. At this stage
of OCA’s work, and to complement those local activities, this letter summarizes for you the activities
we have undertaken, outlines a preliminary set of issues for ongoing review and discussion, and
proposes times for us to meet in the coming weeks to further discuss these matters more fully and
develop recommendations for additional activities that may be undertaken to support student safety
and well-being. As OCA’s investigation activities are not complete, please accept this letter as an interim
communication meant to update you and assist with local efforts. It is not a findings letter. OCA notes
however that various news outlets’ reporting and the results of these outlets’ Freedom of Information
Act requests have to date revealed a number of historical and urgent concerns regarding the efficacy
of District hiring practices and activities to ensure student safety. The complete OCA report will
address those specific concerns more fully.
As a general matter, the OCA recommends that the state convene a working group to help create an
effective multi-tiered, multi-disciplinary abuse prevention framework for school communities, with
the working group to include participation from educators, parents, child abuse prevention experts,
necessary state agencies, positive school climate/social-emotional learning curriculum experts, social
media professionals and human resource professionals.
The OCA further recommends that the State Department of Education help establish model
misconduct prevention policies, accountability measures, and a mechanism for tracking abuse

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 prevalence to ensure effective local school district implementation of child abuse prevention and Title
IX compliance frameworks.
Based on OCA’s review, we have identified several areas for administrative consideration and
oversight that are relevant to ensuring a safe and supportive environment for students enrolled in the
NLPS District and in other school districts as well. At this time, the list is illustrative, but not
exhaustive.
1. Sexual Abuse Prevention Policies and Positive School Climate—A multi-tiered
approach to prevention and student safety
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Multiple reporting access points for students. Students must know where to go and
who to talk to if they have a concern about abuse or harassment. The District should
ensure it has multiple developmentally appropriate access points for students,
depending on age and communication ability, to report questions or problems to
district personnel, a district or community-based ombudsperson, or to an outside
agency like DCF. Because youth may be more likely to tell a trusted adult in their family
or community about a problem at school, community and family members should
know how to report concerns to district personnel, leadership or DCF.

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Policies must address heightened risk of victimization for highly vulnerable students.
The District should ensure that students with disabilities have meaningful access to all
aspects of the district’s abuse/harassment prevention system. District policies and
practices must effectively address the unique vulnerability of students with disabilities
to abuse and neglect, as research shows that such students are at statistically greater
risk of maltreatment. Data shows that people with intellectual disabilities (youth and
adult), are the victims of sexual assaults at rates more than seven times those for people
without disabilities (Justice Department data, NPR investigation). While the District
must regularly review its multi-tiered abuse prevention framework to ensure efficacy
and reliability as to the general population of students, it is critical that the District
ensure competent efforts on behalf of highly vulnerable cohorts of students. Districts
must also ensure that training and information is available to students with limited
English language proficiency as well.

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Meaningful Title IX Training. Students, families, school personnel, and Board of
Education members should receive meaningful training and information regarding the
District’s Title IX policies and sexual abuse prevention framework, including the
purpose of such policies as well as avenues that students or adults can take to report
concerns and receive support. Training should be provided annually, in-person, and
be scenario-based. As sexual abuse is underreported and often unseen, training should
include information/data about sexual abuse/harassment prevalence to help combat
cognitive dissonance and denial that can undermine prevention efforts.

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Open and continuous dialogue with District personnel. District/s should meet with
teachers and other school personnel at regular intervals to facilitate an open dialogue

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 regarding concerns or challenges in the creation of a positive school climate and abuse
prevention framework.
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Independent Ombudsperson. In general, school districts should consider the potential
utility of an independent ombudsperson to hear concerns and questions from
students, families or school employees. An ombudsperson can also identify trends and
concerns, bring such trends to executive leadership, identify training needs and other
areas for additional review or technical support.

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Specific policies regarding student/staff interaction and corresponding progressive
discipline. The District should have written policies regarding relationships between
staff and students, including descriptions of educationally appropriate touching,
limitations on closed-door, after-hours activities with only one student, required
reporting by other teachers and employees, and required chaperones for off-site trips.
Policies should address leisure time with students, transportation rules and electronic
communication. Electronic communication should be limited to district-sponsored
learning platforms so that administrators and parents can monitor. After-school
district-sponsored activities must be closely monitored.
Policies should specify how breaches and boundary crossing will be addressed, even
where sexual abuse is not suspected. Progressive discipline policies must be integrated
into a multi-tiered, multi-disciplinary abuse prevention framework. The District should
assess barriers to effective progressive discipline to determine needed remedies that
will support safe school climate while ensuring due process for school personnel.

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Specific attention to policies and trainings regarding grooming behaviors. District
training and codes of conduct must specifically address and define grooming
behaviors, and such training should be scenario-based to give participants the
opportunity to practice responses. Adults should be knowledgeable about what their
role is in supporting student safety, identifying grooming red flags, and knowing how
to respond if a youth discloses abuse or concerns.

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Acknowledge importance of relational and nurturing learning environment while
being cognizant of need for abuse/misconduct prevention. Training regarding abuse
prevention and positive school climate must emphasize the benefit of positive and
nurturing interactions between students, while carefully explaining risks and exploitive
behavior with regard to vulnerable children and reviewing specific district policies
regarding staff-student relations and conduct. Training should acknowledge
participant concerns or confusion regarding how to have safe and appropriate
relationships in the school environment. Emphasis should also be placed on ensuring
building and district leaders receive ample training in abuse prevention and educator
sexual misconduct. Training should specifically address the unique vulnerability of
certain cohorts of students, such as students with disabilities and English language
learners.

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Abuse prevention training cannot be limited to training regarding mandated reporting.
Training cannot be limited to mandated reporter training or even how to respond to
abuse concerns (i.e. “minimal facts” trainings for school support personnel.) Such
trainings do not address prevention needs. The legislature or the State Department of
Education may need to help support school districts import and facilitate effective
sexual abuse prevention training. See also the “Enough Abuse” campaign for more
information about prevention activities schools can participate in.
http://www.enoughabuse.org/.
Training regarding abuse prevention cannot be approached as a discrete activity,
distinct and separate from other initiatives regarding safe school climate and socialemotional learning. Prevention activities must be connected and integrated.
The District should ensure that there are clear standards for training regular volunteers,
part-time or temporary employees, including coaches and mentors, regarding the
district’s sexual abuse prevention framework and expectations for adults working with
students.

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Evaluate efficacy of District’s sexual abuse prevention curriculum. The District should
periodically evaluate, with outside technical support if needed, the efficacy/fidelity of
its sexual abuse prevention curriculum for students, required by Connecticut law since
2016. OCA will also be recommending that the State Department of Education
consider expanding its capacity to provide districts or connect districts with technical
assistance necessary to support sexual abuse prevention activities.

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Collect data regarding abuse/harassment and efficacy of prevention efforts. Data
collection/survey instruments regarding positive school climate and/or adolescent
risky behavior that are utilized in the District should be amended to include questions
relevant to abuse prevention. This change will allow the District to collect critical
information from students and adults regarding prevalence of sexual misconduct or
other forms of harassment or abuse in the school community and prospectively inform
goals for prevention.
The district may consider the use of a centralized team to respond to all incidents of
educator sexual misconduct, which would also allow patterns of behavior to be
detected and greater protection for students.

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Seek outside technical assistance where needed. State commissions or communitybased organizations may be helpful in providing further technical assistance, including,
but not limited to: The State Department of Education, the Commission on Women,
Children and Senior, The Department of Children and Families, and the Connecticut
Chapter of Prevent Child Abuse America.

2. Ensure Investigations into Allegations of Sexual Abuse or Misconduct are
Consistent with Title IX Requirements

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 The District should take any necessary steps to ensure that employees implementing the Title IX
compliance framework are well trained, supported and supervised with regard to investigating
allegations of sexual misconduct. The State Department of Education is a necessary partner in this
work and can support the District’s ongoing efforts to strengthen Title IX compliance via training
and ongoing technical assistance. Ensure that appropriate supports and information are provided to
staff, parents, and students during and at the completion of investigations.
3. Ensuring Adequate Practices Regarding The Hiring, Training, And Supervision
Of Non-Certified Or Temporary Employees In The District
It is vital to ensure that District practices regarding the recruitment, hiring and retention of employees
who will work one to one with students, particularly vulnerable students with disabilities, are
comprehensive, consistent with state and federal law requirements regarding necessary qualifications
and background checking, and regularly audited for quality assurance purposes. It is also critical that
employees hired to support the educational, safety and well-being needs of students, with or without
disabilities, are provided structured pre- and in-service training, inclusive of child-specific training
where applicable, and direct supervision by highly qualified teachers and administrators. The District
should develop a quality assurance framework for reviewing hiring and supervision practices with
regard to various categories of school personnel who work with vulnerable students. The District may
also want to consider conducting a needs-assessment regarding the utilization of paraprofessional
personnel in the district, as well as recruitment and retention challenges. Ongoing audit activities being
conducted by the District and its consultants should also include examination of whether
paraprofessional employees and other non-certified educational staff are provided adequate
compensation, training and supervision to support high quality work with vulnerable students.
4. Ensure Required Background Checks Are Completed
The District’s ongoing audit and review of its hiring practices should continue to emphasize
examination of background check practices, including criminal and child welfare background checks
where applicable, whether applicants have appropriate certifications and permits (where required) for
the positions that they seek, and when previous employers will be contacted. As with other aspects
of a multi-tiered prevention framework, human resource practices must reflect the unique risks and
vulnerability to harm of highly vulnerable students such as young children and children with
disabilities to ensure that individuals who work with such students are carefully screened. The District
should employ a thoughtful framework for consideration of an individual’s application for
employment where such individual has a criminal record. OCA supports criminal justice and general
public policy reforms that facilitate re-entry of formerly incarcerated individuals into the community
and the workforce. Rather than barring individuals with criminal records from employment, childserving agencies, local and state, should have a clearly delineated process for how criminal histories
are reviewed, including who must be part of the review process and what criteria are utilized to
determine the applicant’s suitability for employment, particularly in a child-serving capacity.
5. Ensure Appropriate Hiring and Supervision Protocols for Employees Whose Jobs
Include Individual/Alone Time with Students
While OCA strongly supports state and local efforts to create nurturing, relational, and traumainformed learning environments, districts’ multi-tiered abuse prevention frameworks must include

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 specific attention to circumstances that create greater opportunity for exploitation and abuse.
Individual relationships between staff and students, while important and at times appropriate, also
create avenues for grooming and eventual misconduct by adults who have an interest in exploiting a
student for personal reasons. The district must have clear protocols regarding staff-student interaction,
documentation of student interactions, close supervision for employees who frequently meet alone
with students, and attention to the areas of the building/s where staff and students meet for one-onone interactions (e.g., how are hallways and empty classrooms monitored/lit/accessible?).
6. Ensure A Working Framework For Compliance With State Mandated Reporter Laws
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Districts must ensure that all employees are trained to understand that it is not the role of the
employee to evaluate or investigate an allegation of suspected abuse or neglect, it is only their
obligation to report “reasonable suspicion” to law enforcement or DCF. Districts must utilize a
quality assurance framework that ensures training goals are met, and violations of district policy
relevant to mandated reporting are quickly identified and addressed.

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The District should consider the value of developing Memorandum of Understanding with local
law enforcement and child welfare agencies, inclusive of clear communication protocols with such
agencies, to clarify and coordinate investigative activities and responsibilities shared by the
District with local and state officials.

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The District should also establish periodic meetings with the leadership team from the
Norwich/New London DCF office to discuss strategies that support child safety and well-being,
and identify any program/building concerns or recommendations.

With regard to the OCA’s ongoing investigation activities, we anticipate more records will be
submitted by NLPS, including a Human Resources audit and additional information in response to
follow-up questions from OCA. Meetings with NLPS administrators in the next several weeks are
anticipated to discuss the OCA’s preliminary review, identified concerns and future recommendations.
Currently, we are available November 5, 6, or 12 for meetings with New London and District
representatives.
Please do not hesitate to contact me at any time with any questions, concerns, or comments about the
subject matter of this communication.
Sincerely,
Sarah Healy Eagan
Child Advocate, State of Connecticut
cc:

Cynthia Richie, Superintendent, New London Public School District
Kevin Roy, J.D., Shipman & Goodwin LLP
Dr. Miguel Cardona, Commissioner, State Department of Education,
Charlene Russell-Tucker, State Department of Education
Jeanne Milstein, City of New London

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