Form M-17E Interview Guide: PSA Compliance Manager

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

OFFICE OF REFUGEE RESETTLEMENT
PREVENTION OF SEXUAL ABUSE
COMPLIANCE AUDIT TOOL
ICF INTERVIEW GUIDE
FOR
PSA COMPLIANCE MANAGERS

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 PSA compliance managers 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 everyone, the auditor should communicate the following (in your
own style and cadence):
“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 this care
provider is following 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 that 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 the 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.

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1.

Do you feel you have enough time to manage all your prevention of sexual abuse
responsibilities? Do you feel empowered to bring up any issues with policies,
training and staffing to leadership? (§411.11(d))

2.

Discuss how you coordinate your care provider’s efforts to comply with the Interim
Final Rule (IFR) standards and ORR policies and procedures.

3.

If you identify an issue in complying with an IFR standard or ORR policy, what
actions/process do you undertake to work towards compliance?

Instead of asking the following questions directly, you could ask, “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 4-8. 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?”
4.

Does your facility regularly develop a staffing plan? (§411.13(a))
a.

In the plan, do you consider whether the staffing levels are adequate to
protect unaccompanied children from sexual abuse and sexual
harassment? If so, how?

b.

Is video monitoring part of this plan?

c.

Is the staffing plan documented, and if so, where?

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5.

Are you consulted regarding any assessments of, or adjustments to, the staffing
plan for this facility? How often do these assessments happen?

6.

When assessing adequate staffing levels and the need for video monitoring,
please explain if and how the facility staffing plan considers the following:
(§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

7.

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

8.

What staffing ratio is required by the state licensing agency? (§411.13)
a. If 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 if they do rounds during the
shifts. Through your question, you should be listening for the elements in 9 and 10.
9.

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

10.

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

11.

When designing or acquiring substantial modifications to the care provider facility,
how does the program consider the effects of such changes on its ability to
protect unaccompanied children from sexual abuse? (§411.17(a))

12.

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

13.

Do you provide each unaccompanied child with an orientation on topics related to
preventing, detecting, and responding to sexual abuse and harassment? (§411.33(a))

14.

How quickly after admission do you provide this orientation? How often do you
provide refresher sessions? (§411.33(a))

15.

How does the program provide equal opportunities for UC with disabilities and
UC who are limited English/Spanish proficient 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)

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16.

How can minors report sexual abuse or sexual harassment, retaliation by other
residents or staff for reporting sexual abuse and sexual harassment, or staff
neglect or violation of responsibilities that may have contributed to an incident of
sexual abuse or sexual harassment? (§411.51(a))

17.

Where are the pre-programmed phones located? (§411.51(a))
a.

Can you describe when a minor may use these phones and for what purpose?

18.

How can children and youth report sexual abuse and sexual harassment to an
entity or person who is not part of the care provider? (§411.51(b))

19.

When a minor alleges sexual abuse or sexual harassment, can they do so
verbally, in writing, anonymously, and through third parties? (§411.51(c))
a.

Do you document verbal reports? (§411.51(c))

b.

If YES, how long, ordinarily, after a UC makes a verbal report do you
document it? (§411.51)

Instead of asking these questions, you could ask the facility to describe their
grievance process. During their answer, listen for the required elements in 20-21.
20.

Does the care provider allow youth to use the grievance process to report sexual
abuse, sexual harassment, and inappropriate sexual behavior? (§411.52)

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21.

How does the care provider ensure that grievances that involve an immediate threat
to UC health, safety, or welfare are handled in a time-sensitive manner? (§411.52)

Instead of asking the following questions, you could ask them to describe the facility’s
reporting process. In their answer, listen for the required elements in 22-26. Probing
may be necessary.
22.

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))

23.

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)

24.

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))

25.

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

26.

What happens if a youth reports sexual abuse or sexual harassment that occurred
in DHS (Department of Homeland Security) custody? (§411.63(d))

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27.

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

28.

Upon learning that a child has allegedly been the victim of sexual abuse or sexual
harassment, what actions do you take? Walk me through that process. (Probe:
See if any of these actions are included.) (§411.64)
a.

Separating the alleged victim, abuser, and any witnesses

b.

Preserving and protecting any crime scene until the
appropriate authorities can take steps to collect any evidence

c.

Requesting that the alleged victim, alleged perpetrator, and
any witnesses not take any actions that could destroy physical
evidence (such as washing, brushing teeth, changing clothes,
urinating, defecating, drinking, or eating), if the abuse occurred
within a time frame that allows for the collection of physical
evidence

29.

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

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.

Do you use the Assessment for Risk within 72 hours of an unaccompanied child’s
arrival at the care provider facility? (§411.41(a))

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32.

Do you update the Assessment for Risk every 30 days? (§411.41(a))

33.

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

34.

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

35.

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))

36.

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, cooperating with investigations.)
(§411.65(b))

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Instead of asking the specific questions, you could say, “Please describe any
circumstances in the last 12 months when the program took measures to ensure the
safety and security of a UC victim of sexual abuse or harassment.” You should listen
for the required elements in 37-39. Additional probing may be needed.
37.

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))

38.

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))

39.

What is the policy regarding placement of UC victims in 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 40-41.
40.

Please describe any recent (within the last 12 months) circumstances in which
one-to-one supervision was used to protect an unaccompanied child who was
alleged to have suffered sexual abuse or sexual harassment. Why was one-toone supervision used for the victim? (§411.68(c))

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41.

How long, usually, are victims placed on one-to-one supervision? What is the
expectation for how quickly staff should complete a re-assessment before taking
a UC victim off one-to-one supervision? (§411.68(c))

Instead of asking these questions, you could ask the facility to describe their
notification process. In their answer, listen for the required elements in 42-43.
42.

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))

43.

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))

44.

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

45.

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

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46.

How does the care provider ensure that information related to a sexual abuse or
sexual harassment report is kept confidential within the facility except to the extent
necessary for medical or mental health treatment, investigations, notice to local law
enforcement, or other security and management decisions? (§411.61(c))

47.

How do you ensure that outside confidential support services (e.g., crisis
intervention, referrals, emotional support, and legal support) are available to victims
of sexual abuse or sexual harassment? (§411.53)

48.

Is there a process in place to allow the presence of a victim’s outside or internal
victim advocate, to the extent possible, for support during a forensic examination and
investigatory interviews? (§411.21(c))

49.

If there are not staff at the care provider to conduct forensic medical
examinations, what process is in place to schedule one if an allegation involves
oral, genital, or anal contact by or to another person or object? (§411.21(b))
a. Is there is a process to ensure that the forensic medical examination is

performed by a SAFE (Sexual Assault Forensic Examiner) or SANE
(Sexual Assault Nurse Examiner) when possible? (§411.21(b))

b. Who performs forensic medical examinations when a SAFE or SANE is

not available? (§411.21(b))

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50.

Do UC victims of sexual abuse receive timely and unimpeded access to
emergency medical treatment, crisis intervention services, emergency
contraception, and sexually transmitted infections prophylaxis? (§411.92(a))

51.

Are medical and mental health services consistent with community level of care?
(§411.93(c))

52.

Are UC victims given access to all medical treatment, mental health treatment, and
treatment services regardless of whether the victim names the abuser or cooperates
with any investigation? (§411.92(b) and §411.93(f))

53.

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)

54.

Do staff perform pat-down searches at this facility?
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))
a.

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55.

Typically, how quickly are staff, contractors, or volunteers suspended from duties that
allow access to UC if they are suspected of perpetrating sexual abuse or sexual
harassment? (§411.66)

56.

Does the care provider perform background checks for employees prior to being
hired and gaining access to children or youth? (Probe: Are there any types of
employees that the care provider does not perform background checks on?)
(§411.16(c))

57.

Do you do this for any volunteer or contractor who may have contact with children
and youth as well? (§411.16(d))

58.

For those who may have contact with UC, does the care provider consider prior
incidents of sexual abuse, sexual harassment, and inappropriate sexual behavior in
determining whether to hire or promote anyone, or to enlist the services of any
contractor? (§411.16(a))

59.

Does the care provider ask all applicants and employees who may have contact
with UC about previous misconduct * in written applications for hiring or
promotions, and in any interviews or written self-­‐evaluations conducted as part of
reviews of current employees? (§411.16(b))

60.

Does the care provider impose upon employees a continuing affirmative duty to
disclose any such previous misconduct? (§411.16(b))

* Previous misconduct: (1) Any civil or criminal convictions, charges, arrests, investigations, or adjudications; (2) Having engaged in or
attempted to engage in sexual abuse, sexual harassment, or inappropriate sexual behavior; (3) Having been civilly or administratively
adjudicated to have engaged in or attempted to engage in any of the activities listed above.

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61.

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)

62.

In the case of 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)

Instead of asking these specific questions, you could ask them to describe the facility’s
process of reviewing sexual abuse and sexual harassment incidents, including code of
conduct incidents. During their answer you should listen for the elements required in
62-64.
63.

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

64.

How often are these reviewed? (§411.101)

65.

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

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