Form M-17D Interview Guide: Program Director

OMB 0970-0564 [valid through MM/DD/2026]

Page 97

OFFICE OF REFUGEE RESETTLEMENT
PREVENTION OF SEXUAL ABUSE
COMPLIANCE AUDIT TOOL
ICF INTERVIEW GUIDE
FOR
PROGRAM DIRECTORS

THE PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) STATEMENT OF PUBLIC BURDEN: The purpose of this information collection is to
interview and document responses from care provider program directors during site visits. PSA audits are required in the Interim Final Rule on
Standards to Prevent, Detect, and Respond to Sexual Abuse and Sexual Harassment Involving Unaccompanied Children (45 CFR Part L). Public
reporting burden for this collection of information is estimated to average 1 hour per response for the care provider and 1 hour per response for the
contractor performing the audit, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the
collection of information. This is a mandatory collection of information (Homeland Security Act, 6 U.S.C. 279). An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of information subject to the requirements of the Paperwork Reduction Act of
1995, unless it displays a currently valid OMB control number. If you have any comments on this collection of information please contact
[email protected].

Interview Details

Facility Name: ___________________________________________________________________________________________________
Name of person interviewed: __________________________________________________________________________________
Title of person interviewed: ___________________________________________________________________________________
Date of interview: _______________________________________________________________________________________________
Interviewer: ____________________________________________________________________________________________

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GUIDELINES FOR AUDITORS: INTERVIEWS
Informing the individual you are interviewing of the compliance audit’s purpose
and the reason for their requested participation:
Prior to interviewing each individual, the auditor should communicate (in your own style and
cadence) the following:
“Thank you for meeting with me. My name is [NAME]. I work for ICF, which has a contract with
the Office of Refugee Resettlement (ORR) to assess whether or not this care provider is in
compliance with standards that have been established by the federal government to prevent
sexual abuse and sexual harassment.”
“I have been approved by ORR to conduct this assessment. As a matter of professional
conduct, I will do my very best to protect the confidentiality of the information you provide to me.
Under no circumstances can I be required to turn over my interview notes to the care provider if
they ask me for them. As I conduct my interviews, I will not be discussing what you tell me with
any facility staff. However, you should be aware that I will have to provide this information to
ORR upon their request.”
“You should also know that for the final report that I will give to the care provider at the end of
this compliance audit, I am prohibited from including any personally identifying information of
yours. If you experience any negative consequences for talking with me, such as retaliation or
threatened retaliation, please do not hesitate to contact me. I can be reached at [THIS SHOULD
BE THE SAME CONTACT INFORMATION PROVIDED IN ADVANCE OF THE COMPLIANCE
AUDIT VISIT THAT SOLICITS UC COMMENTS].”
“Do you have any questions? Do I have your permission to ask you some questions?”
IF YES TO PERMISSION, GO TO QUESTION 1. Keep in mind you want to ask the
questions in your own style and cadence. These questions are NOT intended to be asked
verbatim. You will want to ask questions that help establish rapport while obtaining the
necessary information for the audit. The questions below are provided to you as a guideline
and represent the various types of information needed for the audit. Examples have been
provided for how you might ask a more open-ended question and what you will need to be
listening for as an auditor. Should you not get the information needed in the open-ended
question format, you will need to formulate a question, or questions, so you are able to get
the information needed to assist in your determination of compliance with the standard and
ORR policy.

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Instead of asking these questions directly, you could say: “Describe how your facility’s staffing plan is
developed to ensure the safety of the unaccompanied children placed here.” With the open-ended
question, you would be listening to hear for the elements noted in 1-4. If they don’t include information
about the staffing ratios in their answer, you will need to ask something like: “What are the staffing ratios
for the facility?”
Another way of introducing the question could be, “We would like to learn more about how the facility is
staffed to ensure the safety of the children in its care. Could you tell us about your facility’s staffing plan?
Tell me how you consider the physical layout of the facility? And the composition of the UC population?
The prevalence of incidents or any other relevant factors?”

1.

Does your facility regularly develop a staffing plan? (§411.13(a))
a. Are adequate staffing levels to protect unaccompanied children (UC) from sexual
abuse and sexual harassment considered in this plan, and if so, how?
b. Is video monitoring part of this plan?
c. Is the staffing plan documented, and if so, where?

2.

When assessing adequate staffing levels and the need for video monitoring, please explain
if and how the facility staffing plan considers: (§411.13(b))
a. The physical layout of the facility
b. The composition of the UC population
c. The prevalence of substantiated and unsubstantiated incidents of sexual abuse and sexual
harassment
d. Any other relevant factors

3.

How do you check for compliance with the staffing plan? (§411.13(a))

4.

What staffing ratio is required by the state licensing agency? (§411.13)
a. If the same ratios as in section 4.4.1 of ORR’s Policy Guide (1:8 during waking
hours and 1:16 during sleeping hours): How do you ensure the facility
maintains appropriate staffing ratios?
b. If different ratios: Probe about how the care provider implements these ratios.

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Instead of asking these questions directly, you could ask them if they do rounds during the shifts. Through
your question, you should be listening for the elements in 5-6. Another approach might be, “We want to
understand if and how the staff complete rounds during the shifts.”

5.

Do staff conduct unannounced rounds? (§411.13(c))

6.

How do you prevent staff from alerting other staff that rounds are occurring? (§411.13(c))

7.

How does the program consider the effects of such changes on its ability to protect UC from sexual
abuse when designing, acquiring, or planning substantial modifications to the care provider facility?
(§411.17(a))

8.

How has the care provider considered using technology such as a video monitoring
system or electronic surveillance to enhance their ability to protect UC from sexual
abuse and sexual harassment while maintaining their privacy and dignity when installing
or updating such monitoring technology? (§411.17(b))

9.

When you learn that a UC is subject to a substantial risk of imminent sexual abuse or
sexual harassment, what immediate protective action does the care provider take?
(§411.62)

10.

What is the expectation for how quickly staff should respond to protect UC at
substantial risk of imminent sexual abuse or sexual harassment? (§411.62)

11.

For allegations of sexual abuse or sexual harassment, can you describe the different
measures you take to protect youth and staff from retaliation? (Probes: Housing
changes or transfers, removal of alleged abuser or harassers from contact with victims,
emotional support services, and cooperating with investigations.) (§411.65(b))

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Instead of asking these specific questions, you could say: “Please describe / Can you
describe any circumstances in the last 12 months where the program took measures to
ensure the safety and security of a UC victim of sexual abuse or harassment.” You should be
listening for the required elements in 12- 15. Additional probing may be needed.

12.

Please describe any recent (within the last 12 months) circumstances in which multiple
protection measures were employed to ensure the safety and security of a UC victim of sexual
abuse or sexual harassment. (§411.68(b))

13.

Please describe any recent (within the last 12 months) circumstances in which a transfer
was used to protect a UC who was alleged to have suffered sexual abuse or sexual
harassment. Why was the victim transferred? (§411.68(b))

14.

What is the policy regarding placement of UC victims in the least restrictive housing?
(§411.68(a))

Instead of asking the following questions, you could ask them to describe the facility’s process
for one-on-one supervision. You should be listening for the required elements in 15-16.

15.

Please describe any recent (within the last 12 months) circumstances in which 1:1
supervision was used to protect a UC who was alleged to have suffered sexual abuse or
sexual harassment. Why was 1:1 supervision used for the victim? (§411.68(c))

16.

How long, usually, are victims placed on 1:1 supervision? What is the expectation for how
quickly staff should complete a reassessment before taking a UC victim off 1:1
supervision? (§411.68(c))

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Instead of asking the following questions, you could ask them to describe the facility’s reporting
process and what their responsibilities are. In their answer, you should be listening for the
required elements in 16-21.

17.

When the care provider receives an allegation of sexual abuse, to what designated state
or local agencies do you report the allegation? (§411.61(d) and §411.22(a))

18.

On average, how long after notification of an alleged incident of sexual abuse or sexual
harassment does the facility report the allegation to the appropriate oversight entities,
including ORR? (§411.61)

19.

How long does the care provider maintain documentation of all reports and referrals of allegations of
sexual abuse and sexual harassment? (§411.22)

20.

How does the care provider make notifications to the following parties?
a. Parents/legal guardians or sponsors
b. Attorney or legal service providers
c. Child advocate, if applicable (§411.61(e) and §411.61(f))

21.

On average, how long after notification of an alleged incident of sexual abuse or sexual
harassment does the care provider make the notifications to the above parties? (§411.61(e)
and §411.61(f))

22.

How does the care provider provide UC with reasonable and confidential access to
their attorneys or other legal representation? (§411.55(a))

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23.

How does the care provider provide UC with reasonable access to parents or
legal guardians? (§411.55(b))

24.

How is information related to sexual abuse or harassment handled within the facility?
(§411.61(c))

25.

What happens when your care provider receives an allegation from another care provider
that an incident of sexual abuse or sexual harassment occurred in your facility?
(§411.63(a))

26.

Are there examples of another facility or agency reporting such allegations? What happens in these
cases? (§411.63(c))

27.

In response to an incident of sexual abuse, what is the care provider’s plan to coordinate
actions among staff first responders, medical and mental health practitioners, outside
investigators, and care provider leadership? (§411.65(a))

28.

Please describe how the care provider remains informed of any external investigation related to sexual
abuse or sexual harassment. (§411.22(a))

29.

How are decisions made regarding the appropriate intervention for minors who engage in UC-on-UC
sexual abuse? (Probe: Is the goal to promote improved behavior by the minor and ensure the safety of
other UC? Do the decisions consider the social, sexual, emotional, and cognitive development of the
minor?) (§411.83)

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30.

How do you monitor to see if there are facts that may suggest possible retaliation by youth or
staff? (Probe: UC disciplinary reports, housing or program changes, negative performance
reviews, or reassignments of staff) How do you remedy retaliation? (§411.67)

31.

How does the program provide UC with disabilities and UC who are limited English/Spanish
proficient equal opportunity to participate in or benefit from all aspects of the care provider’s
efforts to prevent, detect, and respond to sexual abuse and sexual harassment? (§411.15)

32.

Do staff perform pat-down searches at this facility?
a. If YES, are cross-gender pat-down searches prohibited except in exigent
circumstances? (§411.14(a))
b. If YES, are pat-down searches conducted in the presence of another staff
member unless there are exigent circumstances? (§411.14(b))
c. If YES, are youth care worker staff trained in proper procedures for conducting
pat-down searches, including cross-gender pat-down searches and searches of
transgender and intersex UC? (§411.14(f))

33.

In the case of a substantiated allegation of sexual abuse or sexual harassment, what
disciplinary action is taken against a staff member, contractor, or volunteer? (§411.81
and §411.82)

34.

In the case any violation of agency sexual abuse or sexual harassment policies by a
staff member, contractor, or volunteer, what disciplinary actions or remedial measures
does your care provider take? (§411.81 and §411.82)

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Instead of asking the specific questions, you could ask them to describe the facility’s
process for reviewing sexual abuse and sexual harassment incidents including code of
conduct incidents? During their answer you should be listening for the elements required in
35-37.

35.

What is the facilities process for reviewing sexual abuse and sexual harassment
incidents? (§411.101)

36.

How often are these reviewed? (§411.101)

37.

How is the information from the sexual abuse and sexual harassment incident
reviews used by the facility? (§411.101)

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