Report of the Vermont State Auditor DOUGLAS R. HOFFER Vermont State Auditor Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required December 16, 2019 Due to corrected information submitted by a supervisory union, on December 17, 2019 SAO reissued this report to update the total number of supervisory unions/districts that did not request CPR checks for all required categories. The revised numbers are on pages 3, 7, 9, and 16. Rpt. No. 19-06 Report of the Vermont State Auditor Mission Statement The mission of the Auditor’s Office is to hold state government accountable. This means ensuring that taxpayer funds are used effectively and efficiently, and that we encourage the prevention of waste, fraud, and abuse. DOUGLAS R. HOFFER Vermont State Auditor This report is a work of the Office of the State Auditor, State of Vermont, and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from the State of Vermont or the Office of the State Auditor. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Please contact the Office of the State Auditor if you have questions about reproducing this report December 16, 2019 Rpt. No. 19-06 DOUGLAS R. HOFFER Vermont State Auditor 132 STATE STREET • MONTPELIER, VERMONT 05633-5101 (802) 828-2281 • TOLL-FREE IN VT: (877) 290-1400 • FAX: (802) 828-2198 AUDITOR@VERMONT.GOV • WWW.AUDITOR.VERMONT.GOV Dear Colleagues, The Child Protection Registry (CPR) is used to help safeguard Vermont’s children by screening the backgrounds of those who work with and care for them. The CPR contains a list of people with substantiated incidents of child abuse or neglect, even if no criminal conviction resulted. The Agency of Education (AOE) is required by law to request and obtain checks of the CPR when educators apply and reapply for licensure. Superintendents are similarly required by statute to obtain CPR checks for job applicants and others who may have unsupervised access to children at schools. The Department for Children and Families (DCF) performs these checks and provides the results to authorized individuals at the requesting organization. This audit focused on whether AOE and supervisory unions and districts were checking the CPR and what they did when they identified an individual with a substantiated record of child abuse or neglect. We have also released a companion report on the use of the CPR by the Agency of Human Services departments, contractors, and grantees. The objectives of this audit were to determine: 1. Whether selected entities made required checks of the CPR in calendar year 2018; and 2. What actions were taken, if any, by entities required to check the CPR when an individual was listed in the registry. While AOE and supervisory unions/districts made many CPR checks in 2018, there were significant failures in determining whether individuals had substantiated records for child abuse or neglect. Of the 1,990 licenses issued in 2018, AOE missed or conducted flawed checks 8 percent of the time. These failures were caused by reliance on a system that did not include controls to ensure that CPR checks were performed prior to issuing a license. After we brought our results to AOE, a licensing official stated that they had generally, or would be, submitting requests for CPR checks for the individuals they missed or for whom they submitted incorrect information. Eleven of 56 supervisory unions/districts (20 percent) did not obtain CPR checks for any individuals. Seven supervisory unions/districts (13 percent) did not check contractors and contractors’ employees as required by statute, though they did check others, such as job applicants. The most common reason cited by the 11 supervisory unions/districts that did not request CPR checks was that they were unaware of the requirement. Ten of these 11 supervisory unions/districts reported that they planned to obtain some or all missed CPR checks. One supervisory union reported that it will not check current employees (as of June 2019) but would submit CPR checks in the future. This decision was supported by the supervisory union board. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 DOUGLAS R. HOFFER Vermont State Auditor 132 STATE STREET • MONTPELIER, VERMONT 05633-5101 (802) 828-2281 • TOLL-FREE IN VT: (877) 290-1400 • FAX: (802) 828-2198 AUDITOR@VERMONT.GOV • WWW.AUDITOR.VERMONT.GOV By failing to check the CPR, an organization could unknowingly license or employ individuals who have abused or neglected children in the past. We also examined the actions taken by these organizations when the CPR check returned a substantiated record. For the period 2016 through 2018, we looked at the cases of four individuals checked by AOE and 50 individuals checked by the six selected supervisory unions/districts. Regarding the AOE cases, the Agency revoked one individual’s license while in another the individual’s CPR record had been expunged and the license issued. In the remaining two cases, AOE’s legal section decided to issue a license to the individual with a current substantiated record of abuse or neglect. According to AOE, they concluded that approving the licenses in these cases would not put students at risk. In 33 out of 50 cases at the supervisory unions/districts, the person with the substantiated CPR record was not hired, retained, or allowed to volunteer. For those who were employed or allowed to volunteer, the supervisory union/district generally added a safeguard, such as not allowing individuals to have unsupervised contact with children. Under 16 V.S.A. §212, AOE is responsible for ensuring compliance with laws relating to public schools and for arranging trainings for superintendents. However, AOE (1) does not monitor compliance with the statute requiring superintendents obtain CPR information and (2) has not held a training session or issued guidance pertaining to the CPR. We made several recommendations to the Agency of Education, such as confirming that the supervisory unions/districts that did not check the CPR for all required categories are now doing so and periodically issuing guidance and holding a training for superintendents on the CPR. In responding to a draft of this report, the Secretary of Education outlined actions that AOE has taken or plans to take in response to our recommendations. I would like to thank the staff at DCF, AOE, and the supervisory unions/districts for their cooperation during this audit. This report is available on the state auditor’s website, http://auditor.vermont.gov/. Sincerely, DOUGLAS R. HOFFER State Auditor December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 DOUGLAS R. HOFFER Vermont State Auditor ADDRESSEES 132 STATE STREET • MONTPELIER, VERMONT 05633-5101 (802) 828-2281 • TOLL-FREE IN VT: (877) 290-1400 • FAX: (802) 828-2198 AUDITOR@VERMONT.GOV • WWW.AUDITOR.VERMONT.GOV The Honorable Mitzi Johnson Speaker of the House of Representatives The Honorable Tim Ashe President Pro Tempore of the Senate Mr. Adam Greshin Commissioner, Department of Finance and Management Mr. Daniel French Secretary, Agency of Education The Honorable Phil Scott Governor December 16, 2019 14 September 2014 Ms. Susanne Young Secretary, Agency of Administration Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Contents Page Highlights 1 Objective 1: AOE and Certain Supervisory Unions/Districts Failed to Obtain Many Required CPR Checks in 2018 7 Background AOE Supervisory Unions/Districts Objective 2: AOE and Supervisory Unions/Districts Acted on Substantiated Results 6 7 8 11 AOE 12 Other Matters 14 Supervisory Unions/Districts Conclusions Recommendations Management’s Comments Appendix I: Scope and Methodology Appendix II: Abbreviations Appendix III: Supervisory Unions/Districts Categories Checked, with Enrollment Data Appendix IV: Examples of Tracking Mechanisms Appendix V: Comments from Management December 16, 2019 14 September 2014 13 15 16 16 17 20 21 23 25 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Highlights In response to the 2008 murder of a young girl in Vermont, the State Legislature passed Act 1 (2009) mandating that the Agency of Education (AOE) and school superintendents check whether certain individuals are listed in the Child Protection Registry (CPR). For example, CPR checks are required for individuals applying for an educator’s license or a school job. The CPR contains a record of child abuse and neglect investigations by the Agency of Human Services’ (AHS) Department for Children and Families (DCF) that have resulted in a substantiated report on or after January 1, 1992. A substantiated report is defined in statute as one that DCF has determined by investigation to be “based upon accurate and reliable information that would lead a reasonable person to believe that the child has been abused or neglected.” An individual does not have to be convicted of a crime to have a substantiated record in the CPR. Organizations usually submit CPR check requests through the Adult Abuse and Child Protection Registries Automated Checking System website. DCF conducts the checks and posts the results on this website, which can be retrieved by authorized users. A decade after Act 1 of 2009 was passed, the Vermont State Auditor’s Office (SAO) decided to audit educational organizations’ compliance with the requirement to check the CPR. 1 Our objectives were to determine: 1. Whether selected entities made required checks of the CPR in calendar year 2018; and 2. What actions were taken, if any, by entities required to check the CPR when an individual was listed in the registry. 2 The subjects of this audit were (1) AOE and (2) 53 supervisory unions and supervisory districts as well as three technical centers. 3 Objective 1 Finding: Did selected entities make required checks of the CPR in calendar year 2018? Although AOE and supervisory unions/districts made many required checks of the CPR in calendar year 2018, there were significant exceptions. By failing to check the 1 2 3 1 A companion report, Child Protection Registry: Agency of Human Services – Room for Greater Compliance in Checking the Registry by Agency and Selected Contractors and Grantees (SAO report 19-05, December 16, 2019), is available on the SAO website. Appendix I details the scope and methodology of the audit. Appendix II contains a list of abbreviations used in this report. For ease of use, SAO will use the term supervisory union/district in the remainder of the report. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required CPR, AOE and a supervisory union/district could unknowingly license or employ individuals who have abused or neglected children in the past. According to statute, AOE is required to obtain information from the CPR for individuals: (1) applying for an initial license as a professional educator, (2) seeking renewal of a license, or (3) requesting reinstatement of a license. Of the 1,990 licenses issued in 2018, AOE: • • • • Submitted the correct identification information and reviewed the CPR results for 1,828, Did not submit a CPR check for 56, Submitted incorrect identification information (e.g., reversed the individual’s first and last name) for the CPR check for 72, which could have resulted in DCF drawing an incorrect conclusion, and Submitted a CPR check but lacked evidence that the result was reviewed by the licensing specialist for 34. Thus, 8 percent of the CPR checks AOE was supposed to perform in 2018 were missing or flawed. After we brought our results to the attention of AOE, a licensing official stated that generally they had, or would be, submitting requests for CPR checks for the individuals that they missed or for whom they submitted incorrect information. The identified gap in compliance was caused by a flawed process that did not effectively ensure that CPR checks were performed before licenses were issued. Vermont statute also requires superintendents to obtain information from the CPR for the following types of individuals: (1) those they are prepared to hire, (2) student teachers, (3) contractors who may have unsupervised contact with children, and (4) employees of contractors who may have unsupervised contact with children. The SAO analyzed a data file from DCF, which contained supervisory union/district CPR requests submitted in 2018 to determine whether they submitted CPR checks. We also reviewed written attestations by these organizations about which categories they requested checks for (e.g., new hires, student teachers, etc.). As Figure 1 shows, this analysis determined that about two-thirds of the supervisory unions/districts made CPR checks for each required category (Appendix III contains more detail). In contrast, 11 supervisory unions/districts did not obtain any CPR checks. Ten of these 11 supervisory unions/districts reported that they planned to obtain some or all missed CPR checks. One supervisory union reported that it will not check current (as of June 2019) employees but would submit CPR checks in the future. This decision was supported by the supervisory union board. 2 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Figure 1: Number and Percentage of Supervisory Unions/Districts Making Required Checks of the Child Protection Registry, 2018a 38 (68%) Made CPR Checks for Each Required Category 11 (20%) Did Not Make Any CPR Checksᵇ 7 (13%) Made CPR Checks in Some, But Not All, Required Categoriesᶜ a b c Percentages do not add to 100% due to rounding. One supervisory union did not make any checks of the CPR in 2018 but one of its six schools checked the CPR for four individuals. These supervisory unions/districts reported that they did not check contractors and contractors’ employees, which is required by statute. The reasons supervisory unions/districts gave for not checking the CPR varied, but the most common was that they were not aware of the statutory requirement. Objective 2 Finding: What actions were taken, if any, by entities required to check the CPR, when an individual was listed in the registry? AOE and six selected supervisory unions/districts took various actions when DCF informed them that an individual was listed in the CPR (i.e., had a substantiated record of child abuse or neglect). For AOE, between 2016 and 2018, four individuals had substantiated records in the CPR. In one case, AOE revoked the individual’s license while in another the individual’s CPR record had been expunged. In the remaining two cases, AOE’s legal section decided to issue a license to the individual with a current substantiated record of abuse or neglect. 4 3 For six supervisory unions/districts, 4 DCF reported that 50 individuals that applied for employment, to be a contractor, or to volunteer at schools had substantiated records between 2016 and 2018. Figure 2 summarizes the actions taken by the supervisory unions/districts in addressing these results. In most cases, the We selected these supervisory unions/districts because they had the highest number of substantiated records between 2016 and 2018. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required individual was not hired or allowed to volunteer. For those who were employed or allowed to volunteer, the supervisory union/district generally added a safeguard, such as not allowing individuals to have unsupervised contact with children. Figure 2: Reported Actions Taken by Supervisory Union/District for Individuals with Substantiated CPR Records, 2016 - 2018 Employeda or Allowed to Volunteer after DCF Later Determined Not Listed in the CPR: 3 (6%) Did Not Use Safeguard or Know If One Used: 3 Did not Employa or Allow to Volunteer: 33 (66%) a Employeda or Allowed to Volunteer When Listed in the CPR: 14 (28%) Used Safeguard: 11 Employed includes both employees of the supervisory unions/districts and contractors and/or employees of a contractor. Other Matters One quarter of the 56 supervisory unions/districts told us that they would like additional guidance or training on the CPR. At a December 2018 conference on preventing child abuse, some educators expressed concern about the lack of clarity on how to best deal with information that comes from the CPR. Participants in this conference recommended that AOE “create an education program for key administrators” on this issue. This recommendation is in keeping with AOE’s statutory authority. In particular, under 16 V.S.A. §212, AOE is responsible for ensuring compliance with laws relating to public schools and for arranging conferences and summer schools for superintendents. However, AOE (1) does not monitor compliance with the statute requiring superintendents to request and obtain CPR information despite the Agency’s legal obligation to ensure compliance with public school laws and (2) has not held a training session or issued guidance pertaining to the CPR. 4 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Recommendations We made recommendations to the Agency of Education, such as confirming that the supervisory unions/districts not checking the CPR for all required categories are now doing so and periodically issuing guidance and holding a training for superintendents on the CPR. 5 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Background DCF’s Family Services Division investigates allegations of mistreatment of children to determine whether the allegation is substantiated. 5 According to 33 V.S.A. §4912(16), a substantiated report means that the DCF commissioner or designee “has determined after investigation that a report is based upon accurate and reliable information that would lead a reasonable person to believe that the child has been abused or neglected.” In 2018, DCF investigated 3,173 allegations of child abuse or neglect, of which it substantiated 999. 6 All substantiated records of child abuse or neglect on or after January 1, 1992 are maintained in the CPR, unless they have been overturned or expunged. 7 Vermont statute defines a registry record as consisting of the name of the individual substantiated for child abuse or neglect, at least one other identifier to avoid the possibility of misidentification, the date of the finding, and the nature of the finding. In addition, for individuals placed on the CPR after July 1, 2009, the record contains a child protection level related to the risk of future harm to children. An individual does not need to be convicted of a crime in order to have a substantiated record in the CPR. Organizations can request checks for CPR records electronically or via a paper request form once they have obtained the consent of the individual being checked. Electronic requests for CPR checks are the most common and are submitted using an AHS website (the Adult Abuse and Child Protection Registries Automated Checking System). 8 DCF staff members process CPR check requests and notify the applicable organization when the result is available and accessible to authorized users on the website. 5 6 7 8 6 DCF’s Family Services Policy 56, Substantiating Child Abuse and Neglect contains criteria on how it makes substantiation decisions. This policy can be found at https://dcf.vermont.gov/sites/dcf/files/FSD/Policies/56.pdf. 2018 Report on Child Protection in Vermont (DCF/Family Services Division). 33 V.S.A. §4916a and §4916b, contain criteria and processes for individuals to challenge their placement in the CPR. 33 V.S.A. §4916c, and §4916d contain criteria and processes for the expungement of CPR records. These can be found at https://legislature.vermont.gov/statutes/section/33/049/04916. Organizations can use this system to request checks against both the Department of Disabilities, Aging and Independent Living’s Adult Abuse Registry and the CPR. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Objective 1: AOE and Certain Supervisory Unions/Districts Failed to Obtain Many Required CPR Checks in 2018 Contrary to statutory requirements, in 2018, AOE failed to correctly check many license applicants against the CPR and 11 of the 56 supervisory unions/districts (20 percent) did not check any individuals. Meanwhile, seven supervisory unions/districts (13 percent) reported that they did not check the CPR for contractors and contractor employees as required. AOE AOE’s failures were caused by reliance on a system that did not include controls to ensure that CPR checks were performed prior to issuing a license. In the case of the 11 supervisory unions/districts that did not obtain any CPR checks, the most common reason cited was that they were unaware of the requirement. By failing to check the CPR, AOE and a supervisory union/district could unknowingly license or employ individuals who have verified records of abusing or neglecting children. Generally, an educator employed in a Vermont public school must obtain an educator license from AOE 9 and apply for renewal after either three or five years. 10 As part of this licensing process, 16 V.S.A. §254 requires the Secretary of Education to request and obtain information from the CPR for any person: (1) applying for an initial license as a professional educator, (2) seeking renewal of a license, or (3) requesting reinstatement of a license that has lapsed. For licenses issued in calendar year 2018, AOE submitted the correct identification information and reviewed the CPR results for 1,828 out of 1,990 individuals. 11 For the remaining 162 license applicants, AOE: • 9 10 11 7 Did not submit a CPR check for 56, Rules Governing the Licensing of Educators and the Preparation of Educational Professionals, Rule Series 5100 (issued by the Vermont Standards Board for Professional Educators). Examples of individuals not required to hold licenses are student and substitute teachers. Individuals with Level I and Level II licenses must seek renewal after three and five years, respectively. These numbers exclude AOE decisions on applicants seeking additional license endorsements that AOE identified in reviewing our preliminary analysis of exceptions because AOE is not required to check the CPR for these types of applications. According to Vermont statute, an endorsement means the grade level and field in which an educator is authorized to serve. The data file provided by AOE that we used to identify possible exceptions did not indicate whether an application was for an endorsement so it is possible that some of the 1,828 applicants checked against the CPR included endorsement applications. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required • • Submitted incorrect identification information in the Adult Abuse and Child Protection Registries Automated Checking System for 72 (e.g., reversed the individual’s first and last name, spelled the individual’s name wrong, entered the wrong date of birth), which could have caused DCF to issue a false determination about whether a license applicant did or did not have a substantiated record in the CPR, and Submitted a CPR check but lacked evidence that the result was reviewed by the licensing specialist for 34. AOE’s missing or flawed checks of the CPR (8 percent of the educator licenses issued in 2018) could have led AOE to unknowingly issue licenses for individuals substantiated for child abuse or neglect. After we brought our results to their attention, an AOE licensing official stated that generally they had, or would be, submitting requests for CPR checks for the individuals that they missed or for whom they submitted incorrect information. 12 AOE’s process did not effectively ensure that CPR checks were performed before licenses were issued. Each licensing specialist keeps their own list of check requests submitted and received. Licensing specialists are supposed to manually enter a notation indicating that the individual cleared the CPR check into AOE’s licensing system’s “registry status” field when the check is completed along with the date. However, the system does not enforce this requirement. Specifically, the system does not (1) require that the status field indicate that the CPR check has been performed before issuing the license or (2) report when licenses are issued without a CPR check. (i.e. an exception report). Therefore, AOE cannot effectively identify when licensing specialists have missed a CPR check. Supervisory Unions/Districts 16 V.S.A. §255 requires that superintendents request and obtain information from the CPR for: (1) any person recommended for hiring, (2) student teachers, (3) any person directly under contract who may have unsupervised contact with school children, and (4) any employee of a contractor who is in a position that may result in unsupervised contact with school children. We analyzed a data file from DCF to determine whether supervisory unions/districts were checking the CPR in 2018. Because DCF does not ask organizations to submit the reason for a CPR check request, the data file does not include information on why a request was made (e.g., whether it was for a 12 8 In cases such as when the educator’s license is currently expired, AOE will not be submitting a CPR check. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required new hire or a contractor’s employee). To gather this information, we asked each supervisory union/district to self-report the categories they check. The results of that analysis were mixed (see Appendix III for specific information on each supervisory union/district). In total, 27 percent of students enrolled in Vermont’s public schools in the 2017-2018 school year were in supervisory unions/districts that did not check the CPR for all or some required categories. • • • 13 14 15 9 Checked all required categories. Thirty-eight supervisory unions/districts (68 percent) submitted requests for checks of the CPR and reported that they checked all the required categories. For the 2017 – 2018 school year, these supervisory unions/districts had an enrollment of 62,678 students. Did not check the CPR. Eleven supervisory unions/districts (20 percent) did not check the CPR at all. 13, 14 Of these, seven stated that they were unaware of the requirement to obtain CPR information, two submitted requests for CPR checks but did not review the results of the checks, one obtained consent forms from individuals, but requests were never entered into the online system because the supervisory union did not realize they needed to submit the requests to DCF, and one did not know the reason because the superintendent was new to the position. For the 2017 – 2018 school year, these supervisory unions/districts had an enrollment of 13,935 students. Of these 11 supervisory unions/districts, seven reported that they will check all existing employees against the CPR, two reported that they will submit and/or review checks for a specific time period, and one reported that it will submit requests for individuals not checked. In contrast, one supervisory union (Windsor Southeast Supervisory Union) reported that they will not check current (as of June 2019) employees but would submit CPR checks in the future. 15 The superintendent received agreement for this plan from the supervisory union board. Checked some, but not all categories. Seven supervisory unions/districts (13 percent) reported that they checked job applicants and student teachers but did not request checks for contractors and contractor One supervisory union did not check the CPR in 2018 but one of its six schools obtained information from the CPR for four individuals. Several of these supervisory unions/districts stated that they performed criminal background checks and believed these were sufficient and/or all that was required. However, an individual does not need to be convicted of a crime to be listed with a substantiated record in the CPR. According to AOE, this supervisory union had 238.25 full-time equivalent staff in fiscal years 2016-2017 (the last for which data was available). December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required employees as required by statute. For the 2017 – 2018 school year, these supervisory unions/districts had an enrollment of 8,930 students. Supervisory unions/districts are not required, but could, check whether volunteers have a substantiated record in the CPR. The statute that addresses school volunteers (16 V.S.A. §260) requires school boards to adopt policies on supervision of volunteers but is silent on use of the CPR to check whether a volunteer has a substantiated record of child abuse or neglect. However, supervisory unions/districts could request CPR checks of volunteers under 33 V.S.A. §4919, which allows DCF to disclose such records to employers for volunteers if such information pertains to an individual providing care, custody, treatment, transportation, or supervision of children or vulnerable adults. Schools use volunteers to perform activities, such as chaperoning, that would bring them into direct contact with children. Forty-one of the 56 supervisory unions/districts (73 percent) reported that they were checking whether volunteers were listed in the CPR. Supervisory unions/districts that are not checking whether individuals are listed in the CPR could unknowingly hire individuals or admit volunteers who have abused or neglected children in the past. One way to increase the likelihood of compliance with the CPR requirements is to implement an effective internal control framework. An internationally recognized internal control framework by the Committee on Sponsoring Organizations of the Treadway Commission (COSO), 16 advises that organizations should deploy control activities through policies that establish expectations and procedures that put expectations into practice. In addition, having policies and procedures in writing is important because they contribute to risk mitigation. Unwritten policies or procedures can be easier to circumvent, cost the organization if there is a change in personnel, and reduce accountability. As shown in Figure 3, supervisory unions/districts often did not possess written policies or procedures explicitly requiring checks of the CPR. 16 10 2013 Internal Control – Integrated Framework© Committee of Sponsoring Organizations of the Treadway Commission (COSO). All rights reserved. Used with permission. COSO is a joint initiative of accountants, financial executives, and internal auditors dedicated to providing guidance to improve organizational performance. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Figure 3: Did Supervisory Unions/Districts Have Written Policies or Procedures Explicitly Requiring CPR Checks? Numbers Presented by Category Yes No 60 50 40 30 20 10 0 a b Applicants for Employment Student Teachers Contractorsᵃ Contractor Employeesᵃ Volunteersᵇ Twenty-four supervisory unions/districts’ policies or procedures required checking the CPR only for those contractors and contractor employees who were expected to have unsupervised contact with children, which is consistent with state statute. Five supervisory unions/districts’ policies and procedures required checking only those volunteers expected to have unsupervised contact with children. The procedure for one supervisory union/district explicitly required CPR checks only for volunteers that would be supervised by school personnel. The policies and procedures for two supervisory unions/districts stated that checking volunteers was optional. Organizations can also use tracking mechanisms to help ensure that they request and obtain checks of the CPR. The supervisory unions/districts most often reported they used spreadsheets (41 percent) and/or checklists (14 percent) to perform such tracking. Appendix IV shows examples of a spreadsheet and a checklist used by supervisory unions/districts. An additional 11 supervisory unions/districts reported using only paper files and binders to track requests and results. Objective 2: AOE and Supervisory Unions/Districts Acted on Substantiated Results When informed that an individual had a substantiated record in the CPR, AOE and six selected supervisory unions/districts took a variety of actions. 11 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Between 2016 and 2018, DCF reported that AOE had few individuals with substantiated records in the CPR, and the Agency acted on those results. Supervisory unions/districts had many more individuals with substantiated records in this time, and they mostly decided not to hire or allow these individuals to volunteer. AOE If, after a check of the CPR, DCF finds that an individual has a substantiated record, DCF provides authorized users at the requesting entity with the person’s name, substantiation date, and abuse type. 17 It is up to the organization to decide what to do with this information. While 33 V.S.A. §4911(5) recognizes the importance of balancing the need to protect children with the potential employment consequences of a substantiated record, neither this statute nor the statutes requiring AOE and superintendents to check the CPR include criteria or specify actions they should take regarding individuals with such records. When AOE licensing specialists determine that license applicants have substantiated records, the specialists notify their supervisor, who then alert AOE’s legal section. The legal section makes the determination of whether to issue a license. For the period from 2016 to 2018, AOE received six reports from DCF on four individuals who had substantiated records in the CPR. In one case, AOE revoked the individual’s license. In the other three cases, AOE issued the individual a license for the following reasons: • • 17 12 AOE reported that, upon investigation by AOE’s legal department, one individual did not have a substantiated record of child abuse or neglect. However, AOE did not have supporting documentation that showed that the individual did not have a substantiated record. DCF reported in lateOctober 2019 that this individual has been listed in the CPR with a substantiated record since 2014. One individual had their criminal case dismissed. Therefore, AOE’s legal department authorized the license. According to DCF, this individual’s CPR record has been expunged. Abuse types include sexual abuse, physical abuse, neglect, risk of physical harm, risk of sexual abuse, abandonment, and emotional maltreatment. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required • One individual was issued a license because AOE’s legal department determined the incident did not affect the license. In responding to a draft of this report, AOE stated that they concluded that students would not be put at risk by issuing licenses to these individuals with substantiated records of child abuse or neglect. AOE does not have a policy that specifies what actions to take when they receive a substantiated record. According to AOE’s general counsel, they rely on 16 V.S.A. §1698 and 16 V.S.A. §254(e) to decide. 16 V.S.A. §1698 does not specifically reference the CPR but states that licensing actions, such as a revocation, may be caused by grossly negligent conduct or moral unfitness. 16 V.S.A. §254(e) states that a person denied a license based on CPR information may appeal the denial but does not provide criteria for AOE to use in deciding whether to issue a license. Policies can help ensure consistency in decision-making by providing direction, such as whether individuals with different abuse types (e.g., neglect vs. physical or sexual abuse) will be treated the same or differently. Without a policy, AOE has no assurance that it is handling individuals with substantiated records in a consistent and equitable manner. One example of a policy that provides guidance on how to evaluate substantiated CPR records is used by AHS. 18 Specifically, AHS’s hiring standard states that candidates for positions will generally be disqualified due to a history of abuse, neglect, or exploitation, but that exceptions can be made based on mitigating factors such as the nature and seriousness of the substantiation and the amount of time that has passed. Supervisory Unions/Districts Between 2016 and 2018, DCF notified six supervisory unions/districts that 50 individuals had substantiated records in the CPR. 19 As shown in Table 1, supervisory unions/districts did not employ20 or allow to volunteer 33 of the 50 individuals (66 percent). In 14 cases, supervisory unions/districts employed or allowed individuals to volunteer even though the individual was listed in the CPR (28 percent). In most cases, they added safeguards. Examples of safeguards included prohibiting unsupervised contact with children, limiting volunteer activities to those with other adults, and working under contract when school was not in session. 18 19 20 13 Hiring Standards (Agency of Human Services, Chapter 4.02, effective December 7, 2009). These individuals accounted for 54 notifications of a substantiated record to the six selected supervisory unions/districts. This includes both employees of the supervisory unions/districts and contractors and/or employees of a contractor. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Table 1: Summary of Actions taken by Supervisory Unions/Districts When Notified of a Substantiated CPR Record, 2016 - 2018 Organization Franklin Northwest Supervisory Union Barre Unified Union School District Greater Rutland County Supervisory Union Lamoille North Supervisory Union North Country Supervisory Union Windham Northeast Supervisory Union a # of Individuals Supervisory Unions/Districts # of Individuals Employeda or Allowed to Volunteer # Not Originally a Employed or DCF Later Reported Reported as Not Allowed Determined Reported Safeguard Not Substantiated Used to Volunteer Not Listed in Used or Did Not by DCF Safeguard CPR Know If Used 11 9 1 0 1 10 7 0 2 1 10 7 0 3 0 8 7 1 0 0 6 2 0 3 1 5 1 1 3 0 Total 50 33 3 11 3 Percent 100% 66% 6% 22% 6% Employed includes both employees of the supervisory unions/districts and contractors and/or employees of a contractor. Clearly written policies and procedures can help supervisory unions/districts to make decisions in a consistent and equitable manner. Only eight of the 56 supervisory unions/districts (14 percent) had policies or procedures that explicitly detailed what to do when an individual in each of the categories required to be checked had a substantiated CPR record. For example, two supervisory unions/districts had policies for licensed educators, level III volunteers, 21 and others who had regular and direct contact with children. The policies prohibited these types of individuals from serving or continuing to serve when they had a substantiated CPR record. Other Matters 21 14 One quarter of the 56 supervisory unions/districts told us that they would like additional guidance or training about the CPR. In addition, at a December 2018 conference, “Preventing Child Sexual Abuse: Renewing Vermont’s A level III volunteer provides direct services to students that involves extensive unsupervised contact with school children (e.g. over-night chaperone, volunteer coach/advisor, student mentors, etc.). Level 1 volunteers do not have unsupervised contact with school children, and level II volunteers have contact with school children under direct supervision; neither is required to undergo a CPR check. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required Commitment,” some educators indicated the need for clarity on how to best deal with information that comes from the registry check process. Participants in the conference recommended to AOE that it “create an education program for key administrators” on this issue. Per 16 V.S.A. §212, AOE is responsible for ensuring compliance with laws relating to public schools and for arranging conferences and summer schools for superintendents with suitable speakers, lecturers, and instructors. AOE has not used this authority to verify compliance or assist supervisory unions/districts in implementing 16 V.S.A. §255, the statute requiring superintendents to request and obtain CPR information. AOE also has not held a training session or issued guidance pertaining to the CPR. In the 10 years since Act 1 (2009) was enacted, the Vermont Superintendents Association and the Vermont School Boards Association have provided guidance related to the CPR. However, this guidance was issued many years ago and is silent on some issues. • • In 2011, the Vermont School Boards Association recommended a model policy for personnel recruitment which states that superintendents should request information from the CPR prior to making employment decisions on job applicants, student teachers, and contractors and their employees. This policy is silent on how to handle the situation when an individual has a substantiated record. In addition, the Association’s 2015 model policy pertaining to volunteers does not address whether volunteers should be checked against the CPR. In 2012, the Vermont Superintendents Association and the Vermont School Boards Association prepared and disseminated a document entitled, “Criminal Record and Abuse Registry Checks in Vermont Public Schools.” This guidance did not address what to do when an individual has a substantiated record. Conclusions AOE and supervisory unions/districts are statutorily mandated to request and obtain information from the CPR, which contains records about individuals with substantiated reports of child abuse or neglect. Checking the CPR can help education organizations mitigate the risk of unknowingly putting individuals with a history of child abuse or neglect into contact with children. While AOE and most of the supervisory unions/districts generally checked the CPR, there were significant exceptions to the statutory mandates. Specifically, for 2018: (1) AOE missed checking many license applicants, (2) 11 supervisory unions/districts (20 percent) did not check the CPR at all, and 15 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Child Protection Registry: Public Education Agency of Education and Supervisory Unions & Districts Failed to Obtain Many Registry Results as Required (3) seven supervisory unions/districts (13 percent) checked some (but not all) required categories. One way to improve these results is the creation and use of policies and procedures that detail when checks of the CPR are required and how to handle substantiated results. Such policies and procedures were often lacking. In addition, while AOE is statutorily responsible for ensuring compliance with public school laws and providing training to superintendents, the Agency has not taken such action regarding CPR checks. Recommendations We make the recommendations in Table 2 to the Secretary of the Agency of Education. Table 2: Recommendations to the Secretary of the Agency of Education Recommendation 1. 2. 3. 4. Develop a mechanism to identify when a CPR check has not been performed prior to issuance of an educator license. Confirm that all supervisory unions/districts that were not checking the CPR for all required categories are now doing so and direct those that are not compliant to adhere to the law. Develop criteria to use when making licensing decisions for individuals with substantiated CPR records. Periodically issue guidance and hold trainings for supervisory unions/districts about implementing 16 V.S.A. §255. Report Pages 8 9 13 15 Issue We identified instances where educator licenses were issued despite the absence of CPR checks, which is not in compliance with State statute. According to Vermont statute, AOE is responsible for ensuring compliance with laws relating to public schools. In 2018, there were 11 supervisory unions/districts that did not check the CPR registry at all and seven that did not check the registry for all required categories. AOE did not have a policy that specifies what actions to take when they are notified that a license applicant is listed in the CPR. Supervisory unions/districts and educators have stated that they would like additional guidance or training on the CPR. Per 16 V.S.A. §212, AOE is responsible for ensuring compliance with laws relating to public schools and for arranging conferences and summer schools for superintendents with suitable speakers, lecturers, and instructors. But this authority has not been used to help supervisory unions/districts utilize the CPR. Management’s Comments On December 12, 2019, the Secretary of the Agency of Education provided comments on a draft of this report (reprinted in Appendix V). In these comments, the Secretary outlined actions that AOE has taken or plans to take in response to our recommendations. 16 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix I Scope and Methodology To address our objectives, we first developed an understanding of the statutes and rules governing the CPR and how and when information from the CPR can be disclosed by reviewing: 1. State statutes, including 33 V.S.A. Chapter 49, Subchapter 2, and 16 V.S.A. Chapter 5, Subchapter 4; and 2. The Code of Vermont Rules, such as CVR-13-172-300 Child Protection Registry and Administrative Review Process, and CVR 13-172-800 Child Protection Registry. We gained an understanding of how CPR checks are requested and processed by reviewing guidance and training materials and by interviewing the applicable DCF director and the information technology deputy director who supports DCF. We obtained files of CPR checks, both paper and online, from DCF for the period 2016 through 2018. These files included the name and other identifying information of the individual being checked, the organization requesting the check, and the results of all CPR checks processed during this timeframe. We performed procedures to ascertain the reliability of this data. Because we planned to confirm the results of our preliminary CPR analysis with selected entities, and we planned to limit our conclusions to those entities, we deemed that limited procedures such as reviewing the data to ensure that it was reasonable and accorded with the data requested, with appropriate entries in each field and expected ranges of values were appropriate. We performed these limited procedures and concluded we could use the data for the purposes of the audit. For objective 1, we compared this CPR file to a file of licenses issued in 2008 obtained from AOE to identify individuals who may have received a license without a CPR check. We sent that list of preliminary exceptions to AOE for confirmation that a check had not been performed and for explanations of the reason for exceptions. 22 We interviewed staff at AOE’s educator licensing organization and participated in a walk-through of the process of checking the CPR and recording the results in the educator licensing system. We also reviewed AOE’s written procedures on CPR checks. 22 17 In addition, we used the CPR file to identify supervisory unions/districts that did not appear to be making checks (i.e., that there were no records of checks During this process AOE identified cases in our preliminary analysis of exceptions that related to applicants seeking additional license endorsements. AOE reported that it is not required to check the CPR for these types of applications, so we excluded them from our analysis. However, since the data file provided by AOE that we used to identify possible exceptions did not indicate whether an application was for an endorsement it is possible that there were additional endorsement applications that were not identified in the analysis. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix I Scope and Methodology submitted by the entity). For these supervisory unions/districts, we asked for additional information about why they were not checking and if they had plans to check individuals for whom CPR checks had not been obtained. We sent all supervisory unions/districts a data collection form to gather further information on their use of the CPR and to obtain relevant policies and procedures. We compiled responses to identify trends in policies or procedures and tracking and to identify any other supervisory unions/districts that were not making required CPR checks. We also reviewed the policies and procedures and tracking documents to verify that they addressed checking the CPR. For objective 2, we used the file of CPR data for the period 2016 through 2018 to determine how many individuals checked by AOE had substantiated records. We then used our data analysis software to cross-reference this data to the list of currently licensed individuals to identify licensees with substantiated CPR records. We sent our results to AOE for confirmation and explanation. We used the file of CPR data to identify those supervisory unions/districts with the largest number of individuals with a substantiated record in the period 2016 through 2018. We selected the six supervisory unions/districts that were notified of six or more substantiated records in the period. We asked each of these supervisory unions/districts to (1) provide information on each individual, such as the purpose for the background check (for example, was the individual applying for employment or for volunteer work), (2) explain what actions were taken, and (3) specify, if the individual was hired or allowed to volunteer, whether and what safeguards were put in place. We did not validate the information we received in response to this request except that we confirmed whether the individual was or was not employed by reviewing the employment records of that organization. Additionally, we reviewed supervisory unions/districts policies or procedures to determine whether they addressed substantiated CPR records. We limited our internal control work to obtaining and reviewing organizations’ policies and procedures and examples of tracking mechanisms, as previously described. Our audit work was conducted between November 2018 and November 2019 at DCF offices in Waterbury and AOE offices in Barre. We conducted this performance audit in accordance with generally accepted government auditing standards, which require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the 18 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix I Scope and Methodology evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. 19 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix II Abbreviations AHS AOE COSO CPR DCF V.S.A. 20 December 16, 2019 14 September 2014 Agency of Human Services Agency of Education Committee of Sponsoring Organizations of the Treadway Commission Child Protection Registry Department for Children and Families Vermont Statutes Annotated Rpt. No.No. 19-06 Rpt. 13-03 Appendix III Supervisory Unions/Districts Categories Checked, with Enrollment Data 16 V.S.A. §255 requires that superintendents request and obtain information from the CPR for any person recommended for hiring, student teachers, and contractors or their employees who may have unsupervised contact with school children. This statute does not require the CPR be checked for volunteers but 33 V.S.A. §4919 allows employers to check whether volunteers who provide care, custody, treatment, transportation, or supervision of children have records in the CPR. Table 3 lists the categories of CPR checks that 56 supervisory unions/districts reported that they obtained. There have been several mergers and name changes of these entities in the past few years. This table reflects the name of the organization with whom we corresponded. Supervisory unions/districts that did not obtain CPR checks for some or all categories are shaded. Table 3: Information on CPR Checks Performed by Supervisory Unions/Districts Categories of Individuals Checked Enrollment Applicants Student Contractors’ Supervisory Union/District 2017-2018a Contractors Volunteers for Jobs Teachers Employees Addison Central School District 1,900 Did not check CPR at all in 2018 Addison Northwest School District 964 yes yes yes yes yes Barre Supervisory Union 2,394 yes yes yes yes yes Battenkill Valley Supervisory Union 422 Did not check CPR at all in 2018 Bennington Rutland Supervisory Union 1,340 yes yes yes yes yes Burlington School District 3,902 Did not check CPR at all in 2018 Caledonia Central Supervisory Union 855 yes yes yes yes yes Central Vermont Supervisory Union 1,308 yes yes yes yes yes Champlain Valley School District 4,273 yes yes yes yes yes Chittenden East Supervisory Union 2,658 yes yes yes yes yes Colchester School District 2,350 yes yes yes yes yes Essex North Supervisory Union 190 yes yes yes yes yes Essex Westford School District 3,951 yes yes yes yes yes Franklin Northeast Supervisory 1,665 Did not check CPR at all in 2018 Union Franklin Northwest Supervisory Union 2,149 yes yes yes yes yes Franklin West Supervisory Union 1,718 yes yes yes yes no Grand Isle Supervisory Union 668 yes yes yes yes yes Greater Rutland County Supervisory 1,546 yes yes no no yes Union Hartford School District 1,509 Did not check CPR at all in 2018 Harwood Unified Union School District 1,915 yes yes yes yes yes Kingdom East School District 1,349 yes yes no no yes Lamoille North Supervisory Union 1,805 yes yes yes yes no Lamoille South Supervisory Union 1,711 yes yes yes yes yes 21 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix III Supervisory Unions/Districts Categories Checked, with Enrollment Data Categories of Individuals Checked Enrollment Applicants Student Contractors’ Supervisory Union/District 2017-2018a Contractors Volunteers for Jobs Teachers Employees Maple Run Unified School District 2,698 yes yes yes yes yes Mill River Unified Union School District 901 yes yes no no yes Milton Town School District 1,714 yes yes yes yes yes Montpelier Roxbury Public Schools 1,236 yes yes yes yes yes Mount Abraham Unified School District 1,506 yes yes yes yes yes North Country Supervisory Union 2,595 yes yes yes yes yes Orange East Supervisory Union 1,637 yes yes yes yes yes Orange Southwest Supervisory District 847 yes yes yes yes yes Orleans Central Supervisory Union 1,134 yes yes yes yes yes Orleans Southwest Supervisory Union 1,044 yes yes yes yes yes Patricia A. Hannaford Regional 392 Did not check CPR at all in 2018 Technical School District Rivendell Interstate School District 491 yes yes no no yes River Valley Technical Center School 224 yes yes yes yes yes District Rutland City Public Schools 2,170 yes yes yes yes yes Rutland Northeast Supervisory Union 1,509 yes yes yes yes yes SAU 70/Norwich School District 330 yes yes yes yes yes Slate Valley Unified Union School 1,345 yes yes yes yes yes District South Burlington School District 2,767 yes yes yes yes yes Southwest Vermont Supervisory Union 3,007 yes yes yes yes yes Southwest Vermont Regional 523 Did not check CPR at all in 2018 Technical School District Springfield School District 1,303 yes yes yes yes yes St. Johnsbury School District 713 Did not check CPR at all in 2018 Two Rivers Supervisory Union 1,073 Did not check CPR at all in 2018b Washington Central Supervisory Union 1,564 yes yes yes yes yes Washington Northeast Supervisory 529 yes yes yes yes yes Union White River Valley Supervisory Union 1,380 yes yes yes yes no Windham Central Supervisory Union 820 yes yes no no yes Windham Northeast Supervisory Union 1,225 yes yes no no yes Windham Southeast Supervisory Union 2,598 yes yes no no no Windham Southwest Supervisory 617 Did not check CPR at all in 2018 Union Windsor Central Supervisory Union 1,016 yes yes yes yes yes Windsor Southeast Supervisory 1,219 Did not check CPR at all in 2018 Union Winooski School District 874 yes yes yes yes yes a b 22 Enrollment figures are from AOE’s student enrollment report for school year 2017-2018, combining individual school enrollments for the supervisory unions/districts as they existed in 2017-2018 and data from the three technical centers. Although this supervisory union did not check the CPR in 2018, one of its six schools checked four individuals. December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix IV Examples of Tracking Mechanisms Example of spreadsheet used for tracking requests submitted and results received. Agency of Human Services State of Vermont Adult Abuse and Child Protection Registry Checking Status of requests submitted from 01/01/2018 - 12/31/2018 Date Submitted by Name Request ID Submitted Stearns, Anjanette "Annie" 484906 12/14/2018 Susan Anderson-Brown Addison Northwest SD Salley, Stanley 484905 12/14/2018 Susan Anderson-Brown Addison Northwest SD Mugford , Holly  484648 12/12/2018 Susan Anderson-Brown Addison Northwest SD Barrows , Carrie  484647 12/12/2018 Susan Anderson-Brown Addison Northwest SD Verburg , Joann 484646 12/12/2018 Susan Anderson-Brown Addison Northwest SD Jarmel , Melissa 484629 12/12/2018 Susan Anderson-Brown Addison Northwest SD Buskey , Emily  484626 12/12/2018 Susan Anderson-Brown Addison Northwest SD Mullin , Cara 484623 12/12/2018 Susan Anderson-Brown Addison Northwest SD McLaren , Laurie 484622 12/12/2018 Susan Anderson-Brown Addison Northwest SD Gevry , Pamela  484621 12/12/2018 Susan Anderson-Brown Addison Northwest SD Atkins , Ally  484618 12/12/2018 Susan Anderson-Brown Addison Northwest SD Kruse , Christian  484615 12/12/2018 Susan Anderson-Brown Addison Northwest SD Quesnel , Alexis  484614 12/12/2018 Susan Anderson-Brown Addison Northwest SD Kayhart , Reagan  484610 12/12/2018 Susan Anderson-Brown Addison Northwest SD Jones , Wayne  484609 12/12/2018 Susan Anderson-Brown Addison Northwest SD Pouliot , Joy  484606 12/12/2018 Susan Anderson-Brown Addison Northwest SD Gebo , Brian  484595 12/12/2018 Susan Anderson-Brown Addison Northwest SD 23 December 16, 2019 14 September 2014 Address Date adult processed Adult results Date child processed Type Child results NCPA - Volunteer 528 Jersey Street 12/17/2018 No records found 12/14/2018 No records found 1382 South Middlebrook Road 12/17/2018 No records found 12/14/2018 No records found 38 North Pleasant St 12/12/2018 No records found 12/12/2018 No records found 14 Sunset Drive 12/13/2018 No records found 12/12/2018 No records found 1495 Basin Harbor Road 12/13/2018 No records found 12/12/2018 No records found 76 Groundnew 12/13/2018 No records found 12/12/2018 No records found PO Box 107 12/13/2018 No records found 12/19/2018 No records found 1087 Vermont Route 17E 12/13/2018 No records found 12/12/2018 No records found 2700 Fuller Mountain 12/13/2018 No records found 12/19/2018 No records found 3851 Vermont Route 22A 12/13/2018 No records found 12/12/2018 No records found 325 Haigis Lane 12/13/2018 No records found 12/12/2018 No records found 15 Hopkins Road 12/13/2018 No records found 12/12/2018 No records found 489 Richville Road 12/12/2018 No records found 12/12/2018 No records found 199 Jockey Lane 12/13/2018 No records found 12/12/2018 No records found 1753 Panton Rd 12/13/2018 No records found 12/12/2018 No records found 606 Tri Town Road 12/13/2018 No records found 12/12/2018 No records found 12/13/2018 No records found 12/12/2018 No records found NCPA - Volunteer 1110 Green Street Employment Employment NCPA - Volunteer NCPA - Volunteer NCPA - Volunteer NCPA - Volunteer NCPA - Volunteer NCPA - Volunteer NCPA - Volunteer Employment NCPA - Volunteer Employment Employment Employment Employment n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a Rpt. No.No. 19-06 Rpt. 13-03 Appendix IV Examples of Tracking Mechanisms Example of checklist used for tracking requests submitted and results received. 24 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix V Comments from Management The following is a reprint of management’s response to a draft of this report. 25 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix V Comments from Management 26 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03 Appendix V Comments from Management 27 December 16, 2019 14 September 2014 Rpt. No.No. 19-06 Rpt. 13-03