A SEXUAL ABUSE PREVENTION BEST PRACTICES AUDIT IN THE LOWER KUSKOKWIM SCHOOL DISTRICT
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JANET N. BARRY, Ed.D.
Mobile and VM: 206-618-9888 | Email: janetbarry1@comcast.net
A SEXUAL ABUSE PREVENTION
BEST PRACTICES AUDIT
IN THE LOWER KUSKOKWIM SCHOOL DISTRICT
Bethel, AK
reviewing student protections in policies, regulations, hiring, training,
supervision, K-12 curriculum, parent/student communications
and administrative response to situations
Kimberly Hankins, Superintendent
LKSD School Board
Clarence Daniel, President
John O. Mark, Vice President
Felix Albert
Hugh Dyment
Mike Husa
Deanna Latham
Richard L. Long
Wassilie Pleasant
Bessie Weston
August 2020
revised/updated
10/9/20, 1/13/21, 1/31/21A SEXUAL ABUSE PREVENTION
BEST PRACTICES AUDIT
IN THE LOWER KUSKOKWIM SCHOOL DIOSTRICT
Bethel, AK
_________
TABLE OF CONTENTS
Introduction 3
Professional Background of the Auditor 6
Audit Design 7
Audit Areas of Focus (Table) 9
LKSD Audit Summary Table 10
Audit Findings and Recommendations 11 – 22
1.0 Policy Protections 11
2.0 Human Resources 12
2.1 Hiring
2.2 Staff Training
2.3 Staff Supervision
3.0 Student Curriculum – Sexual Abuse Awareness 16
3.1 Grade-level content
3.2 Special Education
3.3 Sexual Harassment
4.0 General Communications with Parents and Students 18
4.1 Complaint Procedures
4.2 Local Resources and Advisory School Boards
5.0 Administrative Response to Situations 20
5.1 Written Guidance for Responsive Duties
5.2 Investigations
6.0 Fidelity of Process 21
6.1 Superintendent Oversight
6.2 Accountability to the Board
Barry – LKSD – Sexual Abuse Prevention Audit 2INTRODUCTION Like many school systems throughout the country, Alaska’s school districts are working to protect students from sexual abuse by school employees. The actual number of predators among school employees in the U.S. is very small, but abusers can be serial offenders who cause outsized harm to children; they are often highly regarded by students, staff and families; they appear to know how to gain the trust, affection and loyalty of both adults and children, and discovery of their crimes generally causes shock and creates feelings of betrayal throughout a school community. This was the case in the Lower Kuskokwim School District in Bethel, AK. In December 2019, an FBI sting led to federal charges against an elementary principal who was trusted and beloved by many in this rural school community. A grand jury indicted the principal on two counts of attempted coercion and enticement of a minor, one count of possession of child pornography, and one count of attempted transfer of obscene material to a minor. For those close to him, the information was hard to absorb. The principal had worked for 16 years in two nearby villages and then in Bethel for five years. District staff, parents and students felt betrayed by a leader they believed they knew well and esteemed as a dedicated and exceptionally positive force in local life. Before the indictment that rocked their community, the Lower Kuskokwim School District possessed and used knowledge and tools that are standard practice throughout the country for protecting students from sexual abuse by school employees. Administrators were following long-established policies to protect the district’s students, so they were stunned by revelations about their principal in the indictment. District leaders recognized a need to reach beyond existing methods and resources. They sought to learn and build current best practice in sexual abuse prevention into school district policy and regulations, daily norms, community support, and social-emotional student learning. To grow from the generally accepted standard of care into current best practice in 2020, the school board sought new, proactive policy protections for students that are fundamentally different from the policies on which most public school districts have relied for decades. The LKSD School Board is adding those new protections in their study and adoption of BP/AR 5141.42 – a board policy with administrative regulations that creates requirements not only new to the district, but to all Alaska. While individual staff members likely know and instinctively practice best prevention behaviors, it will take still more to achieve full, effective district-wide implementation of this new policy—which has been proving its efficacy in Barry – LKSD – Sexual Abuse Prevention Audit 3
Washington since 2010.1 Achieving full benefit of the district’s new 5141.42 will take conscious
new thinking and committed behavior from a school board, administration and staff members
acting with shared knowledge and common purpose.
Reactive policies (i.e., policies that compel and set standards for administrative response to
victim complaints and/or other indicators of abuse) continue to meet critical needs. They can
stop misconduct, begin to remediate its effects, and prevent retaliation against those who
report. Examples are LKSD’s board policy 5141.41, mandating child abuse reporting, and
5145.7, prohibiting sexual harassment. These are necessary, but they are limited in two
important ways. First, they are predicated upon allegations of misconduct that has already
occurred, so they do not prevent initial abuse. Secondly, they are limited by the fact that many
victims, for many reasons, do not report their abusers, and some go to great lengths to shield
abusers from discovery by even the most diligent investigators.
As a new, proactive policy protection, BP 5141.42, Professional Relationships of Staff with
Students, aims at preventing employee sexual misconduct by focusing on the daily interactions
between educators and students. The policy’s central requirement is that all staff/student
interactions must have a legitimate health, safety or educational purpose, and employees must
avoid any appearance of impropriety in their conduct with students. This proactive policy calls
for conscious adherence to professional boundaries and requires transparency in staff
interactions with students – particularly in their 1:1 exchanges.
To gain the benefits of this new policy, a school district must lead staff to new understandings
and methods, helping them to remain caring and relatable in their work with students without
crossing into physical or emotional “risk behaviors.” Staff will need:
(a) an understanding of professional boundaries and how to maintain them in staff-student
relationships,
(b) methods for creating transparency in employee interactions with students, both on and
off campus,
(c) explicit and consistent administrative supervision for certain common conditions in the
arrangement of school buildings and management of staff-student relationships, and
(d) clear understanding of the duty to report to administration any student boundary
invasion by another employee that is or appears to be inappropriate.
_____________________________________________________________________________
1
In data provided by the Office of the Superintendent of Public Instruction in Washington State, 2010 was a
turning point in the incidence of teacher sexual misconduct with students. In May 2010 the Washington State
School Directors’ Association (WSSDA) published Model Policy 5253, Staff/Student Relationships, a prototype of
Alaska’s new BP/AR 5141.42. Most or all Washington districts adopted and began policy trainings in the several
years that followed. As implementation grew steadily, and certificated employees in the state increased by more
than 9,000 between 2010 and 2019, the average number of certificated employees investigated and disciplined for
sexual misconduct with students was reduced by 50% after 2010-11—down as an annual average from 15.2 to 7.6.
As Washington has no statewide methodology for collecting data on classified employee misconduct, the data
pertain to certificated employees only.
Barry – LKSD – Sexual Abuse Prevention Audit 4Requirements such as these demand formal training for all employees—but because they must
be built on widely held understandings within the school community, training is not enough.
They must be absorbed into the culture of the school district as shared values. In fact, setting
new cultural norms may be the most important factor in eliminating “risk behaviors” from
adult/student relationships in school life. This will happen through frequent, informal
discussion, problem-solving, coaching and supportive but unrelenting supervision. As new
measures reduce and largely eliminate the sexual abuse of students in school settings, the
benefits to children, families and communities will more than justify the effort, while they also
protect individual educators and the school districts willing to do this work.
THE DISTRICT’S DECISION TO AUDIT
The harsh lesson of Lower Kuskokwim and too many other districts is that sexual abusers often
embed themselves in schools as excellent, caring, even life-changing personalities. They can be
talented, highly valued contributors to the lives of children in isolated communities. For these
reasons, and because many predators use cunning, gradual methods to groom young victims for
sexual abuse, they are disturbingly hard to detect before they do harm. The challenge for any
student to disclose that s/he has been sexually abused is great, but the challenge is unthinkably
great if one has been abused by a well-regarded adult in a remote, tight-knit community.
School administrators are trained to follow standard procedures to stop questionable hires at
the door – but a growing professional understanding of unmet need calls for still closer attention
to the details of employment applications. A trained and attentive screener may find important
red flags in the hiring process that mask concerns about an applicant’s past misconduct.
Care in hiring is the gateway step. After that, best practice depends upon how school boards
sponsor and support the work of the superintendent and all administrators engage their
employees in new shared work (i.e., how they train, supervise, communicate, deepen cultural
belief about their common responsibilities, and create accountability). The means to a safe
school is not to target individual staff members, but to even-handedly prohibit—and thus to
eliminate from school—the risk behaviors an abuser would use to exploit vulnerable students).
Parents and Advisory School Boards have important roles to play, advancing the knowledge and
values that must drive new, district-wide behavior and community understanding. Students
must know, not only their rights and resources, but also what it means for teachers, coaches,
counselors, principals, social workers and other staff to maintain professional relationships with
them, avoiding even the appearance of impropriety.
When their popular elementary principal was indicted in December 2019, district leaders asked,
“How could this have happened?” Then they asked, “How can we keep this from ever happening
again?” And then, “How prepared are we to put best practices to work in our district?” The
board and administration wanted to do the work to find out.
Barry – LKSD – Sexual Abuse Prevention Audit 5They agreed on the adoption of new policy that has proved to be an important deterrent over
the past ten years in Washington state. They have already undertaken a first round of new
training with school principals in February 2020. Now, with important new knowledge, they
have decided upon external help to audit the district’s baseline preparation. Thereafter, they
will have an instrument to measure their district’s progress toward best practices in sexual
abuse protections for students and the knowledge and tools needed for continuous growth.
This audit is designed to respect the organizational structure and other particular conditions of a
PK-12 district of 29 schools serving more than 4,200 students across roughly 22,000 square miles
of western Alaska; however, the 21 audit elements examined here can be adapted with relative
ease to the conditions of other districts. Because content and methodology draw upon the
auditor’s years in the profession and her multiple perspectives on PK-12 education, a brief
profile of her experience is provided below.
PROFESSIONAL BACKGROUND OF THE AUDITOR
K-12 leadership. Following five years as a classroom teacher, Janet Barry served 30+ years in
school and district administrative roles, including 14 years as superintendent of two large school
systems in the Puget Sound region: Central Kitsap School District in Silverdale, WA, and Issaquah
School District in Issaquah, WA. Across her full administrative career in four school districts and
two states, she has served as Assistant Principal, Principal, Assistant Superintendent for
Operations and Resources, Associate Superintendent for Curriculum and Instruction, Associate
Superintendent with deputy responsibilities, and Superintendent. In 1996 she was named
National Superintendent of the Year by the American Association of School Administrators
(AASA). In that role she conducted workshops and consulted with school boards and
administrators throughout the country, including Alaska.
Superintendent preparation. From 2007-2017, Dr. Barry served on faculty for the
Superintendent Certification Program at Washington State University, preparing approximately
50 school administrators per year for K-12 superintendent credentialing. The program included
practical issues, problem-solving and case studies for superintendents, often focusing on
employee supervision and the standard of care owed to students. The WSU program has
historically credentialed one-third to one-half the superintendents in Washington state.
Executive search leadership. As a senior associate of Hazard, Young & Attea, a national
executive search firm, Dr. Barry worked closely with school boards on the procedures, training,
vetting, interviewing and consensus-building necessary to employ quality superintendent and
principal candidates. In this role from 2007-2014, she screened more than 200 applicants and
performed confidential reference checks on all who rose to semi-finalist and finalist levels.
K-12 standard of care consulting. Dr. Barry has provided services as a standard of care expert in
school district litigation since 2010. In this role she has provided analysis, reports and/or
testimony on 55 civil cases, 35 of which were based on allegations of sexual misconduct at
school. Of those 35 cases, ten brought complaints of student-to-student sexual misconduct. All
the rest – 25 – alleged sexual harassment or abuse by a school employee.
Barry – LKSD – Sexual Abuse Prevention Audit 6THE AUDIT
Design. This audit looks for the separate efforts that will function together in schools to greatly
increase protections for students against potential sexual abuse by a school employee. Most
importantly, it identifies conditions that do the most to eliminate risk behaviors that can hide
sexual abuse. By design, it presses educators to set new norms. In this way the audit is itself a
reminder that new norms are necessary to solve some of our schools’ most difficult challenges.
The audit identifies:
Objectives. Key objectives are tested in six areas of focus, setting forth protections for
students against employee sexual abuse in PK-12 schools. They reflect best known
practices as well as current requirements in law and policy. Some identify current work in
most school districts; some introduce new work to advance overall prevention efforts.
Method of review. Methods tell how each element will be examined – whether by external
review, external/internal partner review, or external review with a district contact person
to provide and/or interpret materials. When a partner review is specified, the actual means
of performing the review is determined by the individuals partnering (i.e., the auditor
indicates what is needed; the district partner determines the means of access and best
timing, provides context and facilitates the work as necessary).
Date of review. The dates assigned to audit tasks are meant to serve a school district’s
calendar. In order to provide for key tasks before and after the school year, July 1 – June 30
audit cycles may be most efficient. The Superintendent’s input is essential for
developing a workable audit calendar.
Findings. Findings show the status of each objective at the time of audit on the following
three-point scale:
1 - Achieves desired status. Beyond a finding of “1,” an optional indicator of “1+” may
be used to denote work viewed as exemplary and, therefore, recommended for
sharing and replication.
2 - In development. Work that is new at the time of initial audit is marked as “2” and
scheduled for review in August 2021. (That date can be modified at a later time.)
Ongoing work clearly targeted to the objective but not complete will also be marked
as “in development” with recommended completion dates.
3 - Not in evidence or not sufficiently targeted to objective. Items marked “3” are
those for which evidence cannot be found or those judged insufficient in current
form to support the needed next steps. All marks of “3” will be accompanied by
recommendations.
Barry – LKSD – Sexual Abuse Prevention Audit 7Recommendations. Recommendations may suggest sharing and replication, next
steps for elements not fully achieved, or possible ways to streamline tasks. They will offer
redirection for district consideration on any element marked “3.” Overall, they are meant to
foster the fullest collaboration for continuous improvement. The board report that concludes
an audit cycle will provide general recommendations for continued district progress.
Baseline and future practice vs. historical data collection
Unless specifically noted, data to be collected in the initial audit relates to policies, practices
and conditions as of August 2020, which will provide baseline data. The 2020 audit is not an
historical review of screening, hiring, training or supervision practices prior to the current year.
Because research and learning are ongoing and best practices emerge over time, the audit is
meant to be renewed periodically. New elements may be added; methods, including
technology, may change; and the district’s information needs may change over time.
Timing
The audit schedule is intended to provide a status report for study and discussion early in the
2020 school year, in keeping with the Superintendent’s guidance regarding the district’s
calendar. During 2020-21, as new work moves the district to achieve the audit’s objectives,
progress reports to the LKSD School Board, administration, advisory school boards and others,
including feedback loops, are recommended.
Because new work in 2020-21 is identified for review in a second audit cycle, and the audit is
intended to create new norms, a second full audit is recommended in 2021-22. Thereafter, the
superintendent and board may prefer to bring some elements back for review each year and
others in three-year cycles. With committed, aligned leadership and emphasis, the LKSD Board,
administration and local advisory school boards should see new norms take root in their schools
within the year and greater value placed on this domain of work in their school communities.
Summary View
The table that follows on page 9 presents a thumbnail of the audit’s six areas of focus. These
are meant to come together operationally and should be understood as a system that creates a
strong foundation of shared knowledge and purpose throughout a school community. The
separate parts of such a system may be laid out differently from one locale to another, but any
school district plan of sexual abuse protections must provide supports for three critical
elements: (1) a professional boundaries policy and regulations, (2) hiring protocols that keep
individuals with “red flag” histories from gaining access to schools, and (3) training of all staff to
recognize and report adult behaviors with the potential for sexual grooming. In this audit,
these three essential elements are treated up front in the first two focus areas; the remaining
four areas operationalize and support them and ensure administrative oversight.
Barry – LKSD – Sexual Abuse Prevention Audit 8LKSD AUDIT AREAS OF FOCUS
1.0 POLICY PROTECTIONS [critical]: Adopt, maintain and update key policies and regulations to
protect students from child abuse and/or neglect, sexual harassment and sexual abuse, including
the potential for sexual grooming and abuse by school district employees. Satisfy applicable laws
and consider where to exceed requirements for student safety. The policies named here must be
in place. Others may contribute.
2.0 HUMAN RESOURCES [critical]: Hire, train and supervise all staff to foster and ensure a district
culture in which all adults recognize signs of child abuse and maintain clear, professional
staff/student boundaries for the safety of all students.
3.0 STUDENT CURRICULUM – SEXUAL ABUSE AWARENESS: As part of the district’s Health and
Safety curriculum, teach all students in age-appropriate, culturally appropriate contexts to
know and make safe, informed choices that will help them recognize and avoid sexual abuse.
Per BP 5141.41, content should include:
(a) students’ rights to live free from abuse
(b) useful resources to help students remain safe from sexual abuse
(c) self-protection techniques
(d) how to obtain help and disclose incidents of abuse
4.0 PARENT/STUDENT COMMUNICATIONS: Ensure that parents and students have access to
complaint procedures and resources as needed re: harassment, intimidation and bullying (HIB),
boundary invasions, sexual harassment or sexual abuse of students by district employees.
5.0 ADMINISTRATIVE RESPONSE TO SITUATIONS: Prepare district and site administrators to respond
effectively to reports of inappropriate boundary invasions or suspected child abuse by employees.
6.0 FIDELITY OF PROCESS: Ensure fidelity of process through superintendent leadership with clear
sponsorship by and accountability to the board. Board/superintendent leadership should be visibly
unified around two purposes:
(a) Develop, reinforce and improve efforts that directly protect students from sexual abuse
(b) Bring separate efforts together as a functioning system.
The summary table that follows on page 10 provides a thumbnail of the total audit, showing the
areas to be examined; how they are examined, by whom, and when each is reviewed. It shows
target dates and findings at a glance and notes whether the review has produced specific
recommendations in each area of work. The green shaded areas are not scheduled for review
until August 2021 because they call for developmental work during the current school year.
Barry – LKSD – Sexual Abuse Prevention Audit 9LKSD AUDIT SUMMARY TABLE – 2020
OBJECTIVE METHOD WHO? WHEN? STATUS REC
1.0 POLICY PROTECTIONS
1.1 – 1.15 ER Barry 8/1/20 2 Yes
2.0 HUMAN RESOURCES
2.1.Hiring
2.1.1 Screening practices Ext / Int Barry, Engbretsen 9/25/20 2 Yes
2.1.2 Security checks Ext / Int Barry, Engbretsen 9/25/20 2 Yes
2.2. Training
2.2.1. Per policies
2.2.1.1 Child abuse/sexual abuse ER / C Barry, S/D 9/15/21 2 Yes
2.2.1.2 Professional Boundaries ER / C Barry / Wu / Hankins 8/1/21 2 Yes
2.3 Staff Supervision
2.3.1 Professional boundaries
2.3.1.1 At school Ext / Int Auditor TBD, S/D 8/1/21 2 Yes
2.3.1.2 School-related Ext / Int Auditor TBD, S/D 8/1/21 2 Yes
2.3.1.3 Informal problem-solving Ext / Int Auditor TBD, S/D 8/1/21 2 Yes
3.0 CURRICULUM—SEX ABUSE AWARE
3.1 General Ed Ext / Int Barry/ Grant/ Schalk/ 8/15/20 1+ Yes
Robbins / Baucus
3.2 Special Ed Ext / Int Barry / Crace 9/25/20 2 Yes
3.3 Sexual harassment per BP 5145.7 ER Barry 8/15/20 1 Yes
4.0 PARENT/STUDENT COMMS
4.1 Complaint procedures
4.1.1 Personnel ER Barry 8/1/20 1 No
4.1.2 Sexual harassment - Title IX ER / C Barry 10/25/20 2 Yes
4.1.3 HIB ER / C Barry 10/25/20 1
4.2 Local resources
4.2.1. Advisory School Boards Ext / Int Barry, S/D 8/15/21 2
4.2.2 Community resources Ext / Int Barry, S/D 10/15/20 1+ No
5.0 ADMIN RESPONSE TO SITUATIONS
5.1 Written guidance for admin
5.1.1 General ER / C Barry / Hankins 10/15/20 1 Yes
5.1.2 Investigations ER / C Barry / Hankins 8/15/21 2 Yes
6.0 ASSURING FIDELITY OF PROCESS
6.1 Superintendent oversight
6.1.1 Review evidence of key work Ext/Int Barry, S/D 8/15/21 2 Yes
6.2 Accountability to Board
6.2.1 Periodic updates and trainings Ext / Int Barry / Hankins Ongoing 2 Yes
6.2.2 End-of-cycle report Ext / Int Barry / Hankins 8/1/21
Key to abbreviations: Status indicators:
ER External review 1+ Exemplary; recommended for sharing or
ER/C External review with a district contact person replication
Ext/Int External/internal partner review 1 Achieves desired status
S/D Superintendent or designee 2 In development
REC Are recommendations provided? (Yes/No) 3 Not in evidence; insufficiently targeted
Barry – LKSD – Sexual Abuse Prevention Audit 10AUDIT FINDINGS AND RECOMMENDATIONS
1.0 POLICY PROTECTIONS: Adopt, maintain and update key policies and regulations to protect students
from child abuse and/or neglect, sexual harassment and sexual abuse, including the potential for sexual
grooming and abuse by school district employees. Satisfy applicable laws and consider where to exceed
requirements for student safety. The policies named here provide important protections. Others may
contribute.
1.1 BP 5141.41 Child Abuse Prevention / Sexual Abuse, Assault, Dating Violence
1.2 AR 5141.4 Child Abuse and Neglect/Mandatory reporting
1.3 BP 5141.42 Professional Boundaries of Staff with Students
1.4 AR 5141.42 Professional Boundaries of Staff with Students
1.5. BP 5145.7 Sexual Harassment
1.6 AR 5145.7 Sexual Harassment (list of prohibited behaviors)
1.7 BP 5145.3 Non-discrimination
1.8 BP 4111 Recruitment and Selection of Employees
1.9 AR 4112.5 Security Checks (classified personnel)
1.10 AR 1312.1 Complaints Against Personnel
1.11 BP 1312.1 Complaints Against Personnel
1.12 E 6161.4 Acceptable Use Policy: Social Networking for Faculty and Staff
1.13 E 6161.4 Acceptable Use Policy: Social Networking for Students
1.14 BP 5131.43 Harassment, Intimidation and Bullying
1.15 AR 5131.43 Harassment, Intimidation and Bullying
METHOD: External review: policy and administrative regulations inventory and content;
AUDITOR(S): Janet Barry
COMPLETION DATE: 8/1/2020
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
(1) Make periodic reports to the school board and local advisory boards on implementation of new
BP/AR 5141.42 to deepen staff and community understanding and support.
(2) Include a list of inappropriate boundary invasions in AR 5141.42 to clarify prohibited behavior.
This is important for consistent leadership; staff and community understanding and support.
(3) Communicate with AASB re: model policy updates the agency anticipates in 2020-21.
(4) Note change to A.S. 47.17.020 re: mandatory reporting of child sexual abuse to law enforcement
as of 9/20 for all affected.
(5) Urge AASB model policy revisions as below. If AASB does not forecast movement, consider local
BP and/or AR changes to exceed state requirements as follows:
(a) BP 5141.4(a) meets current AK law, but require all personnel to recognize and report suspected
child abuse; train all employees as mandatory reporters on an appropriate periodic schedule.
(b) E 6161.4: Add a requirement re: professional boundaries in electronic communications with
students to the Acceptable Use Policy: Social Networking for Faculty and Staff; cross-
reference and add digital communications guidance to AR 5141.42 (examples of inappropriate
boundary invasions).
Barry – LKSD – Sexual Abuse Prevention Audit 112.0 HUMAN RESOURCES: Hire, train and supervise all staff to foster and ensure a district culture in which
all adults recognize signs of child abuse and maintain clear, professional staff/student boundaries for the
safety of all students.
2.1 Hiring
2.1.1 Screen all applicants for red flags in employment history, noting in particular:
(a) successive short stays (less than 3 years) in previous positions
(b) vague or unsupported reasons for leaving previous positions
(c) eligibility for continuing employment or rehire in former districts
(d) local/social media reports from previous communities
(e) weaknesses cited by former supervisors in confidential reference checks
(f) questions identified for follow-up if candidate advances
METHOD: External/internal partner review of hiring protocols, practices, standard reference
check forms, standard guidance to interview teams. Audit by file review and phone/video
conference.
AUDITOR(S): Janet Barry, Andrea Engbretsen
COMPLETION DATE: 9/25/2020
FINDINGS: 2 – best practices in development
RECOMMENDATIONS: Standard screening system is in place. Gateway protections can be
strengthened by expanded inquiries re: “red flag” departures from prior employment, if any.
Recommendations are as follows:
(1) For both certificated and classified applicants, look for “red flag” departures from prior
employment.
(2) Develop system to ensure completion of files if documentation of pre-hire reference checks
is missing or incomplete.
(3) Obtain legal advice to confirm best disclaimer language re: continuation of an employee
contract based upon employee’s completion of credentialing and background checks.
(4) Strengthen reference check forms and procedures, including local and social media checks
where possible.
2.1.2 Perform, document and retain security checks on new classified employees.
METHOD: External/internal partner review: pre-hire checks on 2020 hires. Audit by file review
and phone/video conference.
AUDITOR(S): Janet Barry, Andrea Engbretsen
COMPLETION DATE: 9/25/2020
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
(1) In addition to “Court View” documentation, reinstitute and refine form and process for
classified reference checks with prior employers. Consider whether both print and
electronic versions are needed.
(2) In review of recommendations, seek more clarity on respondent’s relationship to applicant.
(3) Include an inquiry that probes: “Is there anything more we should know about
this applicant before placing him/her in a position in proximity to children?”
Barry – LKSD – Sexual Abuse Prevention Audit 122.2 Staff Training
2.2.1 Train staff per requirements of LKSD policies that specifically protect students from
employee sexual abuse.
2.2.1.1 Per BP 5141.41 – Child Abuse/Sexual Abuse Prevention, train K-12 Child Abuse
Prevention Program teachers in the following:
(a) physical and behavioral indicators of abuse
(b) crisis counseling techniques
(c) community resources
(d) mandatory reporters’ duties and protections
(e) post-report care of child.
METHOD: External review
AUDITOR(S): Janet Barry
COMPLETION DATE: 8/15/2021
FINDINGS: 2 – best practices in development (pending state-level action)
RECOMMENDATIONS:
Build on strengthened AASB policies or seek LKSD board action to expand and strengthen
staff training and student protections in local policy:
(1) In partnership with school board, communicate with AASB to assess plans and
timeline for policy updates/revisions; seek LKSD board action as appropriate
(2) Based on policy recommendations under 1.0 above, establish and document training
for all staff in (a) physical and behavioral indicators of abuse, and (b) mandatory
reporting duties.
2.2.1.2 Per AR 5141.42 – Professional Boundaries, train all staff on “Guidelines for
Preventing Sexual Abuse of Students” (BP 5141.42, Ex 2) and newly developed district slide
presentation as follows:
(a) all staff and volunteers at least every three years
(b) new staff and volunteers within three months of employment or start of service
METHOD: End-of-cycle review of training materials, 2020-21 schedule of trainings and
completion records for all personnel
AUDITOR(S): External auditor TBD, S/D
COMPLETION DATE: 8/1/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
(1) During 2020-21, develop training plan and schedule for all staff, volunteers,
substitutes, board and advisory board members on BP/AR 5141.42
(2) Develop system for documentation of training
(3) Plan for absentee and late hire “make-up” training
Barry – LKSD – Sexual Abuse Prevention Audit 132.3 Staff Supervision
2.3.1 Routinely supervise to create a culture of common beliefs and practices that maintains
professional boundaries while also avoiding the appearance of staff/student impropriety.
2.3.1.1. Perform frequent admin walk-throughs before, during and after school hours to
ensure open doors, unobstructed line-of-sight conditions, safe arrangements for 1:1
meetings with students, appropriate classroom norms and professional boundaries. Log
findings and follow up with individuals as appropriate. Retain logs for year-end summary.
METHOD: End-of-cycle review: Site administrators’ summaries of walk-through logs
AUDITOR(S): Janet Barry, S/D
COMPLETION DATE: 8/1/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
(1) Discuss with site administrators the critical value of this supervision activity.
(2) Plan for periodic review of logs during current year supervisory and/or evaluation
meetings and second audit cycle.
(3) With advice of site administrators and representative staff, develop simple, standard
forms for use by site administrators in logging and reporting information.
2.3.1.2. Site administrators set expectations, observe school-related activities as possible,
including student transportation. Log observations and follow up as appropriate with
staff to ensure safe, transparent conditions and professional staff/student boundaries in
less structured activity settings on and off campus.
METHOD: End-of-cycle review: Site administrator summaries of activity supervision logs
AUDITOR(S): Janet Barry, S/D
COMPLETION DATE: 8/1/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
(1) As a follow-up to training, district and site administrators clarify expectations for
staff/student boundaries in activity supervision; clarify and problem-solve with
local transportation personnel and school activity supervisors to develop common
understanding of boundary expectations in activity supervision.
(2) Consider and seek appropriate consistency in practices across the district.
(2) Site administrators develop and check for “two-deep” activity supervision to avoid 1:1
staff/student situations.
(3) District supervisors and site administrators review observations and progress in
periodic supervisory and/or evaluation meetings.
(4) Encourage use of simple, standard forms to log observations.
Barry – LKSD – Sexual Abuse Prevention Audit 142.3.1.3. Provide for informal learning and problem-solving to help all personnel maintain
professional boundaries with students while remaining caring and relatable in their roles.
METHOD: Focus group discussion with school administrators and teachers; review of site
administrators’ end-of-year summaries
AUDITOR(S): Janet Barry, S/D
COMPLETION DATE: 8/1/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
Site administrators should work to foster shared values and eliminate risk behaviors in
the following ways:
(1) Provide supportive, informal discussion and problem-solving with staff, peers,
ASB’s and community leaders
(2) Encourage staff to hold “pre-problem” discussions with supervisors to explore ways
to create transparency in unique situations with students.
(3) Provide guidance to employees who have dual relationships with students within and
outside of school.
(4) Summarize and share effective practices in brief end-of-year reports and group
discussions.
Barry – LKSD – Sexual Abuse Prevention Audit 153.0 STUDENT CURRICULUM – SEXUAL ABUSE AWARENESS: As part of the district’s Health and Safety
curriculum, teach all students in age-appropriate, culturally appropriate contexts to know and make safe,
informed choices that help them recognize and avoid sexual abuse. Per BP 5141.41, content should
include:
(a) students’ rights to live free from abuse
(b) useful resources to help students remain safe from sexual abuse
(c) self-protection techniques
(d) how to obtain help and disclose incidents of abuse
3.1. Review grade-level content for treatment of (a) through (d) above and other sexual abuse
awareness topics in The Great Body Shop, Second Step, and other LKSD curricular materials.
Supplement as needed.
METHOD: External/internal partner review: curriculum content
AUDITOR(S): Janet Barry / Segue Grant / Erin Schalk / Christina Robbins / Jennifer Baucus
COMPLETION DATE: 9/15/2020
FINDINGS: 1+ Exemplary – recommended for sharing and replication
RECOMMENDATIONS: The district should consider ways to provide leadership and serve as a
resource for implementation of a coordinated K-12 program of sexual abuse awareness and
prevention. Notable strengths of the LKSD program are as follows:
• Use of engaging, age-appropriate lessons and activity formats
• Skillful coupling of child/youth awareness, guidance for prevention and SEL skill-building
• Staff have outstanding curriculum maps, materials, instructional coaching and assistance
• Students learn from both teachers and social workers
• Knowledgeable staff recognize strengths and gaps in the various curricula and how to
supplement for best effect, application, growth and retention by students
• Translation of K-3 SEL materials into the Yupik language serves developing English speakers
Note: At this time, the audit is focused on evidence of available, coordinated and supported
curriculum, both required and supplementary. It includes informal, anecdotal review of
“delivered curriculum” and evidence of student learning. A full, meaningful examination of
delivered curriculum and student learning would require more extensive and discrete
measurement than this audit can provide.
Barry – LKSD – Sexual Abuse Prevention Audit 163.2 For special education students not taught the general education curriculum referenced in 3.1, use
IEP’s and/or Life Skills curriculum and/or classroom procedures to ensure appropriate, essential
learning about personal safety, personal boundaries, self-protection and how to get help if needed.
METHOD: External/internal partner review of Special Ed materials and practices / IEP goals
AUDITOR(S): Janet Barry / Ashley Crace
COMPLETION DATE: 9/25/2020
FINDINGS: 2 – best practices in development
RECOMMENDATIONS: Special education staff currently have no IEP students with sexual
abuse prevention goals; however, they tailor Life Skills and Second Step lessons to meet
individual student needs, including personal boundaries and safety. Because special
education students can be uniquely vulnerable to abuse, and instruction in 3.0 (a-d) should
reach all students, the following are recommended for further development in 2020-21:
(1) Focus more intentional effort on appropriate learning related to personal boundaries and
safety, self-protection, how to report problems and get help from adults when needed.
(2) Identify and index teaching resources and methods for reaching all self-contained special
education students with relevant content.
3.3 Per BP 5145 – Sexual Harassment, provide age-appropriate instruction to all students
including guidance not to endure any form of sexual harassment and to report sexual
harassment immediately to a trusted adult at school.
METHOD: External review: curriculum content and Parent/Student Handbook
AUDITOR(S): Janet Barry
COMPLETION DATE: 8/15/2020
FINDINGS: 1 – achieves desired status
RECOMMENDATIONS: As noted in 3.1 above, district K-12 curriculum is effective in meeting
instructional requirements including sexual harassment as set forth in BP 5145.7. In addition,
Page 71 of the most current (2019) version of the LKSD Parent/Student Handbook provides a
basic prohibition against sexual harassment and encourages reporting. School handbooks
provide more easily accessible explanations and prohibitions of sexual harassment. While
current presentations meet the objective, the district could make the information more
meaningful at the district level by making it more readily accessible. See also recommendations
under 4.1.2 -- Sexual harassment / Title IX.
Barry – LKSD – Sexual Abuse Prevention Audit 174.0 GENERAL COMMUNICATIONS WITH PARENTS AND STUDENTS: Ensure that parents and students have
access to procedures for making complaints of harassment, intimidation and bullying (HIB), boundary
invasions, sexual harassment or sexual abuse of students by district employees.
4.1 Complaint Procedures
4.1.1 Per BP/AR 1312.1, publish clear procedures online and in print by which parents and/or
students can bring complaints re: school personnel.
METHOD: External review: Parent/Student Handbook, school handbooks and additional
notices, if any
AUDITOR(S): Janet Barry
COMPLETION DATE: 8/1/2020
FINDINGS: 1 – achieves desired status
RECOMMENDATIONS: None. This is standard.
4.1.2 Provide clear, accessible parent/student information for making a sexual harassment
complaint against a student or adult in the school district. Parents and students should
be informed that a report may be initiated through a trusted school employee who will
assist in providing the complaint to the appropriate administrator and Title IX Coordinator.
METHOD: External review: Parent/Student Handbook, school handbooks and additional
notices, if any
AUDITOR(S): Janet Barry, Ed Pekar
COMPLETION DATE: 1/7/21
FINDINGS: 2 – best practices in development
RECOMMENDATIONS: Information on sexual harassment protections is clear and easy to
locate in school handbooks and is available online at both district and school levels. The
communication of these protections, availability of help in making a complaint, and guidance
in resolving complaints are the most important Title IX duties in the overall context of sexual
abuse prevention. To this end, it is recommended that the Title IX Compliance Officer do the
following:
(1) Seek online resources and/or training available on Title IX duties that focus on
prevention and elimination of sexual discrimination in the form of sexual harassment.
(2) Improve general access to Title IX information on the district website, ensuring that
parents, students, administrators, staff and others know how to contact the Title IX
officer for information or guidance in filing, assisting with or responding to a
complaint.
Barry – LKSD – Sexual Abuse Prevention Audit 184.1.3 Provide clear, accessible parent/student information for making a complaint of harassment,
intimidation or bullying (HIB) against a student or adult in the school district. Procedures
should provide the option of reporting to a trusted school employee who will assist in bringing
the complaint to the appropriate administrator(s).
METHOD: External review: Parent/Student Handbook, school handbook and website
communications on HIB
AUDITOR(S): Janet Barry
COMPLETION DATE: 10/25/2020
FINDINGS: 1 – achieves desired status
RECOMMENDATIONS: Policy and regulations 5141.43 prohibiting harassment, intimidation
and bullying, including cyberbullying, are readily available to students and the school
community. The availability of local assistance from trusted adults and trained staff (e.g.,
behavior interventionist, social worker and/or counselor) are made clear. It is recommended
that the district also post contact information for the Title IX/HIB Coordinator for reference by
parents, students, administrators, staff or others who seek assistance with an HIB issue.
4.2 Local Resources
4.2.1 Support Advisory School Boards as community liaisons re: the purpose, implementation
and expected benefits of new BP/AR 5141.42. This effort should include trainings,
discussion, periodic administrative updates and opportunities to share feedback
from the school community.
METHOD: External/internal partner review: Various ASB documents
AUDITOR(S): Janet Barry, S/D
COMPLETION DATE: 8/1/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS: Provide timely training to ASB’s on BP/AR 5141.42 in preparation for
optimal interaction at the district’s 2021 ASB conference on the role ASB’s can take to support
policy implementation in their communities.
Barry – LKSD – Sexual Abuse Prevention Audit 194.2.2 Identify community resources for child abuse prevention. Per BP 5141.41, link parents
and/or students to resources as needs and opportunities arise.
METHOD: External review of local and online resources provided
AUDITOR(S): Janet Barry
COMPLETION DATE: 10/15/2020
FINDINGS: 1+ – Exemplary
RECOMMENDATIONS: None. The district does an exceptional job of identifying local
resources, online research, guidance and resources for child abuse prevention. The district’s
social workers and other trained staff are key assets to students, parents and staff in the LKSD
communities for child abuse prevention.
(Note: At this time, the audit has not included a review of specific services to individuals,
which are typically private. This dimension can be added in appropriate ways in another cycle,
if desired.)
5.0 ADMINISTRATIVE RESPONSE TO SITUATIONS: Prepare district and site administrators to respond
effectively to reports of inappropriate boundary invasions or suspected child abuse by staff members.
5.1 Prepare written guidance for superintendent and potential designees to understand and
perform responsive duties effectively.
5.1.1 With assistance of legal counsel, establish written guidance for the superintendent and
others for leading the district’s response to situations. Guidance should cover assessment
of the situation and its requirements, safety measures for affected students, reporting
duties, if any; nature and structure of investigations, employee rights per collective
bargaining agreement and communications to staff and community, if appropriate.
METHOD: External review: documents on file with Superintendent
AUDITOR(S): Janet Barry, Kimberly Hankins
COMPLETION DATE: 10/15/2020
FINDINGS: 1 – achieves desired status
RECOMMENDATIONS: Effective written guidance is on hand from legal counsel in the form of
BP 5141.42, Ex 2 and has already served as a valuable resource to the superintendent. The
superintendent and her team may also find it helpful to capture topline information from the
document in a visually simplified format as a “checklist-style reminder” in an emerging
situation.
Barry – LKSD – Sexual Abuse Prevention Audit 205.1.2 Prepare selected personnel to conduct appropriate, effective internal investigations;
prepare selected district-level personnel to oversee external investigations when
necessary and act upon findings to resolve issues related to boundary invasions
and alleged sexual abuse.
METHOD: Interview with Superintendent/designee; review of documents
AUDITOR(S): Janet Barry, Kimberly Hankins
COMPLETION DATE: 8/15/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS: Note: As the district is developing supervisory guidance and tools
for site administrators who will oversee the implementation of BP/AR 5141.42, and a
three-person committee has been newly established to conduct investigations at the district
level, written guidance should be developed to ensure consistent, appropriate investigations
and follow-up.
6.0 FIDELITY OF PROCESS: Ensure fidelity of process through superintendent leadership with clear
sponsorship by and accountability to the board. Board/superintendent leadership should be visibly unified
around two purposes:
(a) develop, reinforce and improve efforts that most directly protect students from sexual abuse
(b) bring separate efforts together as a functioning system.
To this end, the superintendent should receive reports and work samples needed to evaluate the
systemic prevention effort, reinforce or redirect staff as appropriate, and make periodic open reports
to the school board as agreed upon by the superintendent and board.
6.1 Superintendent oversight
6.1.1 Local and district administrators assemble evidence of key work throughout the district, as
recommended above, for review by the superintendent. The following are listed as
examples of work products that should be verified at the superintendent level to ensure
fidelity of process:
(a) Standard written guidance to staff who screen employment applications
(b) Standard forms for confidential reference checks created from best hiring practices
(c) Documentation of confidential references and security checks for new employees
(d) Documentation of training of all staff and volunteers in established cycles and time
frames per BP/AR 5141.42 for eliminating risk behaviors from schools
(e) Documentation of consistent, continuing supervision for maintenance of
professional staff/student relationships
METHOD: Interview with Superintendent/designee; review of documents
AUDITOR(S): Janet Barry, Kimberly Hankins
COMPLETION DATE: 8/1/2021
FINDINGS: 2 – best practices in development
RECOMMENDATIONS:
Barry – LKSD – Sexual Abuse Prevention Audit 216.2 Accountability to the Board
6.2.1 Provide periodic updates to the Board including training as provided to all staff on BP/AR
5141.42.
METHOD: Interview with Superintendent/designee; review of documents
AUDITOR(S): Janet Barry, Kimberly Hankins
COMPLETION DATE: Various dates TBD
FINDINGS: 2 – ongoing
RECOMMENDATIONS: The board has completed policy review and adoption and received
informal administrative reports and updates since the initiation of the audit on July 30, 2020.
The auditor has also made a formal presentation to the board on November 19, 2020 and a
second formal presentation is tentatively scheduled for March 3, 2021. With a first review
cycle complete, the following steps are recommended:
(1) Following administrative review, provide the audit document to the board for study by
February 1, 2021.
(2) Seek board questions for the superintendent, communications consultant and/or
auditor by February 15, 2021, as focus for the March 3 report.
(3) Continue periodic updates on a schedule agreed upon by the board and superintendent.
(4) Plan end-of-cycle report, to be scheduled on a specific date after 8/1/2021 and formatted
to provide for both the superintendent’s and auditor’s summaries.
6.2.2 Provide end-of-cycle report to the Board, including both auditor’s and superintendent’s
summaries. Superintendent’s report should include site summary information and plans
for next cycle.
METHOD: External/internal partner report
AUDITOR(S): Janet Barry, Kimberly Hankins
COMPLETION DATE: TBD after 8/1/2021
FINDINGS:
RECOMMENDATIONS:
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