POLICY:
Volunteers of America Delaware Valley’s Behavioral Health and Re-entry Services Division will cooperate fully with all investigations conducted.
PROCEDURE:
1.An investigation may occur for administrative, fiscal or programmatic reasons.
2.An investigation may be prompted by a complaint or other concerns with regard to Volunteers of America.
3.If the Program Director is not on site at the time that Officials arrive to begin the investigation, he/she should be notified immediately.
4.Staff is to ascertain the legitimacy of the investigators by inspecting their identification and any documents explaining the reason and scope of the investigation.
5.Staff is to cooperate in any investigation and will be given direction by Program Director or designee.
6.No files or any documents are to be destroyed during an on-going investigation.
7.The Program Director is to keep Executive Management informed of the status of the investigation.
8.Staff is to direct all inquiries about the investigation to the Program Director.
9.Allegations of sexual abuse from clients are reported to local law enforcement as well as the NJ Department of Corrections Office of Community Programs and the NJ Department of Corrections Special Investigation Division.
10.The facility shall report all allegations of sexual abuse and harassment including third party and anonymous reports to the NJDOC. Documentation will be kept on all investigations and referrals made for investigations.
11.Requests for medical examination and treatment are made to the regional institution. All medical examinations shall be conducted by the regional institution and requests will be made for the regional to follow all PREA standards.
12.First responders to allegations of sexual abuse are required to follow procedures under 300.06
13.In instances of sexual abuse or harassment, the agency shall:
- Determine whether staff actions or failures to act contributed to the abuse
- Complete an administrative incident report describing all facts and findings
- Retain all reports regarding the allegations
- Cooperate with all criminal investigators related to the allegation
- Not impose a standard higher than a preponderance of evidence in determining whether the allegations are substantiated
- Review the conclusion of the investigation within 30 days with the COO, Human Resources and investigation
14.A review of an administrative investigation for sexual abuse or harassment will include:
- Whether changes are needed in policy or practices of the agency
- Whether the incident was motivated by race, ethnicity, gender identity, lesbian, gay, bisexual, transgender or intersex identification status or perceived status, gang affiliation or was motivated by other group dynamics at the facility
- Assessment of area in the facility where the incident occurred to determine whether physical barriers may enable abuse
- Assessment of staffing levels during different shifts
- Assessment of monitoring technology
- A written summary