Form M-17C Form M-17C Interview Guide: Random Sample of Staff Interview

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

OFFICE OF REFUGEE RESETTLEMENT
PREVENTION OF SEXUAL ABUSE
COMPLIANCE AUDIT TOOL
ICF INTERVIEW GUIDE
FOR
A RANDOM SAMPLE OF STAFF

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 staff 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 UCPolicy@acf.hhs.gov.

Interview Details

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

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GUIDELINES FOR AUDITORS: INTERVIEWS WITH RANDOM SAMPLE OF STAFF
Selecting staff for interviews:
During the onsite visit, the auditor must interview a minimum of five care provider staff who have
contact with unaccompanied children (UC). As part of the pre-audit questionnaire, the auditor
must request a list of staff sorted by assignment (e.g., youth case worker) and by shift. The
auditor must select at random one line staff from different assignments or work locations, and
request that those selected be brought for an interview during the onsite visit. The goal is to
conduct interviews with representative staff working across a range of disciplines (e.g., youth
care worker, program administration, clinical services, etc.).
Interviews must be conducted in a setting where staff will feel free to talk without being overheard
by other staff.
At large care provider facilities or those with many different housing units, the auditor may choose
to interview more than five staff members to develop a more comprehensive assessment. The
decision regarding the total number of staff members to interview should take into consideration
the time available for interviews of both unaccompanied children and staff during the visit.
Informing staff of the compliance audit’s purpose and the reason for their requested
participation:
Prior to interviewing each member of staff, the auditor should communicate the following:
“Thank you for meeting with me. My name is [NAME]. I work with ICF, which has a contract with
the Office of Refugee Resettlement (ORR) to assess whether 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 certified by ORR to conduct this assessment. I selected
your name at random from a list of all staff and would like to ask you some questions about the
care provider’s policies and practices. I am interviewing other staff members at this facility. Your
participation is voluntary, and you may choose not to answer any or all of the questions.”
“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
provide this information to ORR.”
“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.
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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.
1. What topics have you been trained on and what was discussed in those trainings?
(Per Interim Final Rules, or IFR, and policy they should have received training on the topics
noted below. Probe about when training/refresher was last received.) (§411.31(a))?
a. ORR and the care provider facility’s zero tolerance policies for all forms of sexual abuse,
sexual harassment, and inappropriate sexual behavior.
b. The right of unaccompanied children and staff to be free from sexual abuse, sexual
harassment, and inappropriate sexual behavior.
c. Definitions and examples of sexual abuse and sexual harassment.
d. Situations where sexual abuse, sexual harassment, and inappropriate sexual behavior
may occur.
e. Physical, behavioral, and emotional signs of sexual abuse, and methods of preventing
and responding to sexual abuse.
f. How to avoid inappropriate relationships with unaccompanied children.
g. How to communicate effectively and professionally with unaccompanied children,
including unaccompanied children who are LGBTIQ+.
h. How to report sexual abuse, sexual harassment, or inappropriate behavior as well as how
to comply with relevant laws related to mandatory reporting.
i. How to keep information related to reports of sexual abuse, sexual harassment, and
inappropriate sexual behavior confidential.
j. How to understand and discuss sexual behavior with children and youth from different
cultures.
k. Trauma that unaccompanied children may have experienced.
l. Existing resources outside and inside the facility for children and youth that can help a
victim of sexual abuse or sexual harassment.
m. How to understand the culture and age of unaccompanied children.

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2. What are the procedures for conducting pat-­‐down searches, including cross-gender pat-down
searches? (§411.14(f)) Are you permitted to conduct cross-gender pat-down searches or patdown searches alone? (§411.14)

a. Can you provide an example of a circumstance that would warrant such a search?
i. (If they answer correctly, then interviewer can follow up with question 3.)

3. What are the procedures for pat-down searches of transgender and intersex minors?
(§411.14(f))

4. What are staff required to do if they have any knowledge, suspicion of, or information regarding
an incident of sexual abuse or harassment? (§411.61(a))

5. What are staff supposed to do if they know that a UC or another staff member is being
retaliated against for reporting an incident? (§411.61(a))

6. 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))

7. 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))

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8. 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?

9. When a minor alleges sexual abuse or sexual harassment, what are their options for
reporting? (§411.51(c))
a. (Auditor should be listening for verbally, in writing, anonymously and through third
parties.) (§411.51(c))

b. Do you document verbal reports? (§411.51(c))
i. If YES, how long, ordinarily, after a UC makes a verbal report do you
document it? (§411.51)

10. Do you know if there is a process for UC to report a grievance if they have one, and what is the

process? (§411.52)

11. Can a minor obtain assistance in preparing a grievance? Who can provide assistance? (§411.52(d))

12. If you are the first person alerted that a child has allegedly been the victim of sexual abuse or
harassment, what is your responsibility in that situation?

a. Can you describe how you report this information? (Probe: To whom would you report the
alleged sexual abuse or sexual harassment? Is there anyone with whom you would not share
the information?) (§411.61)

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b. (Probe: See if any of these actions are included.) (§411.64)
i. Separating the alleged victim, abuser, and any witnesses
ii. Preserving and protecting any crime scene until the appropriate authorities
can take steps to collect any evidence
iii. 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

13. What staffing ratio is required during waking and sleeping hours?
(Note to auditor: This question is not conclusive of non-compliance if the staff member
does not provide direct supervision to unaccompanied children.) (§411.13)

14. How does the program take steps to ensure that children and youth with disabilities or who are limited
English/Spanish proficient have an equal opportunity to participate in efforts to prevent sexual abuse
(e.g., providing accessible documents and orientation)? (§411.15)

15. Does the care provider provide access to in-person, telephonic, or video interpretative services to

assist UC with disabilities or youth who are limited English proficient when making an allegation of
sexual abuse or sexual harassment? (§411.15)

16. If you learn a child is at risk of imminent sexual abuse or sexual harassment, what actions do you
take to protect the child?

(Note to auditor: The standard requires immediate action but does not describe precise actions that
must be taken. The purpose of this question is to understand the care provider’s process and is not
conclusive of compliance.) (§411.62)

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17. Are staff permitted to view minors when showering, performing bodily functions, and changing clothes?
(§411.14(d))

a. Are there any exceptions this rule? (§411.14(d))

18. Are you aware of the policy prohibiting staff from searching or physically examining a minor in care
for the sole purpose of determining that minor’s sex? (§411.14(e))

19. What is the reporting requirement if you’re involved in off-duty misconduct? (§411.16(b))

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