Thank you for your comment. The policy has been revised to include the following statement as 4.C., “Long-term embedded programs functioning should consult with SLCC’s Office of Risk Management for specific guidance when following this policy. SLCC’s Office of Risk Management may consult with the Office of General Counsel to evaluate and create guidance for these programs.”

Thank you for your comment. Please reach out to the Office of Risk Management directly. We’ll connect with you and the Office of General Counsel to review your existing documentation for approval.

Thank you for your comment. We do request that long-term programs submit the program registration form annually. Please reach out to the Office of Risk Management, and we can engage in further conversations about this requirement for PACE.

Thank you for your comment. The completed forms should not be submitted to SLCC’s Office of Risk Management. These are records created as part of program operations and must be maintained as determined by Utah Law and state record retention schedules. The college’s Records Management Policy also applies and provides further guidance. It is the Program Director’s responsibility to ensure that records are maintained and disposed of in accordance with these requirements.

Definitions for Abuse and Neglect have been included. They are “as defined in the Utah Code § 80-1-102.” A definition for Volunteer, “a person who has successfully completed the volunteer approval process as determined by People and Workplace Culture,” has been included as well.

Program Directors determine which SLCC employees or non-SLCC employee volunteers who are at least 18 years of age are approved to supervise, interact with, or have access to minors within in their program. Program Directors are responsible for ensuring that these individuals comply with this policy and the Code of Conduct for Authorized Adults (which will be publicly posted online and linked to in this policy once the policy has been approved). Additionally, a checklist for Program Directors will be provided online to assist them with each step of the process outlined in this policy.

Thank you for your comment. The policy now contains language addressing contract workers in sections 4.B.7 and 4.D.4.

Thank you for your comment. No changes. This policy defines a minor as a person under the age of 18. This is used consistently throughout this policy.

Thank you for your comment. This section (now 4.B.) has been revised. We specifically have the Policy Scope section at the beginning so that program directors can know immediately, when reading the procedures, whether it applies to their program.

Thank you for your comment. This section has been revised and now contains language addressing contract workers.

Thank you for your comment. No changes.

Thank you for your comment. Risk Management will consult with the Office of General Counsel regarding this question.

Revision accepted. The statement, “There are no exceptions to these reporting obligations,” was also added to this section.

Thank you for your comment. 4.B. has been renumbered to 4.A. for improved clarity.

Thank you for your comment. Revision accepted.

Thank you for your comment. This form is managed by PWC. We will pass along your comments.

Thank you for your comment. This form is managed by PWC. We will pass along your comment and discuss with them changing the age from 21 to 18. Additionally, it appears that if you answer “no” to the question about whether you have had an S number as a volunteer in the past, then the Social Security Number field does appear on the form.

Thank you for your comment. This will be discussed with the Office of General Counsel.

Thank you for your comment. “All related records” refers to the records created as part of program operations that must be maintained as required by Utah Law and state record retention schedules. The college’s Records Management Policy also applies and provides further guidance.

Thank you for your comment. The Program Director should monitor the training completion dates. This could be done using a simple spreadsheet or other method. PWC would be responsible for the records management of the training records within NeoEd (where the training will be housed). Any records related to the program should follow the college’s Records Management Policy and applicable state record retention schedules.

Thank you for your comment. This was discussed with the legal department, and the guidance provided was 3 years.

Thank you for your comment. This was discussed with the legal department, and the guidance provided was 3 years.

Thank you for your comment. If the SLCC employee is working with minors in a capacity that is covered by this policy, background checks must be completed successfully every 3 years.

Thank you for your comment. This was discussed with the legal department, and the guidance provided was at least every 3 years.

Thank you for your comment. The college will need to determine this.

Thank you for your comment. PWC is responsible for records management regarding the actual background check. The Program Director should track successful completion dates for background checks. The college’s Records Management Policy and applicable state record retention schedules will apply. A publicly posted checklist for Program Directors will be available once this policy is approved to help them with this process.

Thank you for your comment. If the SLCC employee is working with minors in a capacity that is covered by this policy, background checks must be completed successfully every 3 years.

Thank you for your comment. Revision accepted.

Thank you for your comment. This will be done before the policy is approved and published online.

Thank you for your comment. If it is a third-party entity that is renting or using space on an SLCC property, not a program that is being overseen or “run” by SLCC, then an SLCC employee will not serve as program director. It is expected that the third-party entity will comply by ensuring that program workers have a) successfully passed a background check in the last 3 years, b) been provided training on working with minors, and c) follow the code of conduct for authorized adults that will be publicly posted online. This language has been incorporated into this section of the policy.

Thank you for your comment. This is outlined in the code of conduct for authorized adults, which will be hyperlinked in the policy and publicly posted online.

Thank you for your comment. This statement has been discussed with the Office of General Counsel. No changes.

Thank you for your comment. The phrase “conduct for authorized adults” in this section refers to a formal “code of conduct for authorized adults” that will be hyperlinked in the policy and publicly posted online.

Thank you for your comment. This statement has been discussed with the Office of General Counsel. Slight revisions were made to clarify “the code of conduct for authorized adults.”

Thank you for your comment. Risk Management maintains the uncompleted form templates. The program director maintains the completed forms (records) received. This policy section has been revised to reflect this.

Section 4, A, #7. The Grand Theatre occasionally hires minors as independent contractors (1099) to perform in our shows. Would this mean that a minor hired under a 1099 contract to perform at The Grand would be considered as an “SLCC programs not specifically designed for youth, where a minor’s involvement is limited to serving as a college employee.”?

1. Clarify Applicability to Year-Round Embedded Programs: Please clarify whether this policy applies to SLCC-sponsored programs like PACE, where full-time and part-time SLCC employees are embedded year-round in partner high schools under formal MOUs. These programs differ significantly from short-term camps or one-day events and may require distinct compliance timelines and expectations.
2. Clarify Participation Agreement Requirements: The PACE Scholarship Program requires students to submit an application and a parent/guardian permission form to participate. Does this satisfy the participation agreement requirement outlined in the policy? If not, please specify what additional documentation is needed and whether it must be submitted to Risk Management or retained by the program director.
3. Clarify Form Requirements for Campus Tours and One-Day Events: For one-day events such as campus tours, PACE collects parent/guardian permission forms. Please clarify whether these forms must be submitted to SLCC’s Office of Risk Management or if they can be retained internally. It would be helpful to distinguish between documentation requirements for short-term events versus year-round programs.
4. Clarify Which Programs Must Submit the Program Registration Form and When: Please specify whether long-term programs like PACE must submit the program registration form annually, per semester, or only once. Clear guidance on frequency and timing would help ensure compliance and reduce administrative confusion.
5. Add a Section for Year-Round Embedded Programs: Consider adding a subsection or appendix that outlines compliance expectations for year-round embedded programs like PACE, Trio, etc. including timelines for form submission, training, and background checks. This would help differentiate them from short-term or seasonal youth programs.

3- Definitions should include “Volunteer” and “Academic Program”. Also, does 3-B “Employee” include 1099 contracted workers? If not, are they treated as volunteers?

4-A-3 I suggest editing this to “…where the visiting school’s representative adults are required to retain supervision and custody of the visiting minors.” to provide clarity of expectations to the adult chaperones.

4-B Should be switched to be 4-A to make clear that reporting of child abuse is legally required, regardless of exceptions to the scope of this policy.

4-C-2 What is the timeline for submission of the SLCC Volunteer Agreement Form? What are the storage, retention, and destruction requirements of this form, since it has sensitive information including Social Security Number. The form has a COVID-19 section that may no longer be relevant, including a testing requirement. The form outlines the process for minors to complete the form, but the policy does not address minor volunteers and requirements for them.

4-C-3 The etrieve form only asks for Social Security Number if the volunteer is not working with participants under 21. It seems like it should be the opposite. Also, should that age be 21 or 18?

4-C-5 Related to the Participation Agreement: 1. The form does not have a location for printed Parent/Guardian information, only Emergency Contact, which may be different. 2. What are the storage and retention requirements for these Agreements? I suggest, “Participation Agreements must be kept on file and accessible for the duration of the program,” to ensure constant access to emergency contact information.

4-C-6 It would be helpful to outline what “all related records” includes.

4-D-3 Licensed childcare programs require training annually, which is considered a best practice in youth programming.

4-E-2. As above, background checks for people working with youth are generally required annually if they are a one-time search.

4-F Is very similar to 4-C-5. If it is directed at Parent/Guardians, I suggest editing to: “A parent or legal guardian must complete, sign, and submit a participation agreement for each minor participant. The Participation Agreement must be accepted and acknowledged by the Program Director before participation in a program.”

4-H Does the rest of this policy apply to Non-College Programs and Events or just this section? These programs are not included in 4-A, so it seems that the whole policy applies, but it is unclear who the Program Director would be; the SLCC representative or the non-college representative. Also, the definition of “Authorized Adult” is specific to SLCC employees and volunteers. If the other sections of this policy do not apply to these programs and events, I think it opens the door to liability for the college, as well as not providing positive direction to organizations to help them ensure youth safety on SLCC campuses.

4-I-1 Would failure to report abuse be considered a violation of this policy? 4-B outlines Utah law but does not state that this policy requires Authorized Adults to follow the law and report or face corrective action.

4-I-2 Clarifies my question on 4-H by stating that non-college entities must comply with this policy, but the use of “authorized adult” in this section does not align with the current definition that only includes SLCC employees or volunteers.

1. Policy
   1. No Comments on Purpose.
2. References
   1. No Comments on References.
3. Definitions
   1. 3.A: The definition should specify the approval process for becoming an authorized adult, including that approval is granted by SLCC’s Office of Risk Management.
   2. 3.C: Consider clarifying the definition of “minor” to avoid confusion with other definitions used by USHE, especially since this policy applies to individuals under both 18 and 21 in different contexts.
   3. Consider adding definitions for “abuse” and neglect”.
4. Procedures
   1. 4.A: Consider moving this section closer to the end of the policy.
   2. 4.A: The scope exceptions listed in Section 4 are confusing and may unintentionally exclude many minors from the protections of the policy. For example, it is unclear whether high school students are included in the exceptions, and the current structure makes it difficult to determine when the policy actually applies. To improve clarity, the policy should first define the specific circumstances under which it is triggered, such as the nature of the program, the role of the minor, and the type of adult supervision, before listing any exceptions. This would help readers understand the policy’s applicability and avoid misinterpretation.
   3. 4.A. Define the scope of when the policy applies. For example, Skills USA is a program where 2,000 kids come from all over the state with their schools, however, the judges are often community partners that work one-on-one with minors. It would be incredibly challenging to go through authorization of all of those adults that aren’t employees of the high schools but still participate in other capacities.
   4. 4.B: Utah law states that any person who has reason to believe that a minor has ben subjected to abuse or neglect to immediately notify Child and Family Services, peace officer, or law enforcement agency. Dependency is not a mandatory reporter trigger.
   5. 4.B: The previous section lists exceptions to the policy, but this section states that the reporting obligations apply to all situations, including the exceptions.
   6. 4.B: Consider incorporating this section into the policy statement; or create a new section that defines exactly the scope of the policy and what it applies to.
   7. 4.C: While Section 4C outlines that SLCC’s Office of Risk Management will identify the training content and platform for authorized adults, it does not specify who is responsible for monitoring training completion or maintaining training records. This lack of clarity may lead to inconsistent implementation across programs. Consider assigning recordkeeping responsibilities to People and Workplace Culture (PWC), similar to existing practices under Safe Hire, as program directors may not have the capacity or infrastructure to manage these records effectively.
   8. 4.E: The three-year validity period appears inconsistent with other SLCC policies. If the existing background check authorizes an individual for five years, it should be clarified whether that suffices for designation as an authorized adult under this policy.
   9. 4.E: Requiring background checks for all volunteers may be impractical. The policy should consider the logistical burden on SLCC, which may not have the infrastructure to process background checks at scale. This could deter participation and increase risk if checks are required but not feasible.
   10. 4.E: Who is responsible for paying for the background checks?
   11. 4.E: Who is responsible for maintaining background checks?
   12. 4.E: Do existing employees need to have another background check? The background check policy states that it needs to be reviewed every five years.
   13. 4.G: The policy references that “authorized adults must follow conduct guidelines located on the SLCC Office of Risk Management website”, but does not include a hyperlink or define what this entails.
   14. 4.I.1: The policy states that “an authorized adult who violates this policy may face corrective action”. To reduce ambiguity and prevent over-reporting or misinterpretation, consider clarifying the conditions under which corrective action is triggered. Articulating the use of the word may—for example, by referencing the college’s corrective action policy or specifying thresholds for violations—would help set clearer expectations and reduce unnecessary escalation.
   15. 4.I.2. Consider rephrasing to read: “If a non-college entity fails to comply with this policy or terms of a related contract, SLCC may take corrective action, including prohibiting the entity from conducting future programs, restricting current or future access to SLCC facilities, even prior to the contract’s expiration, or excluding specific individuals from participating in the program.
   16. 4.J: This states that Risk Management is required to maintain the forms. Does this mean the completed records? Because 4.C. states that it is the responsibility of the program director.

Aggregate Comments for Public Posting:

Protection of Minors from Abuse:

1. References:
   1. No Comments
2. Definitions:
   1. Authorized Adult: Is there a process for becoming an authorized adult
      1. Definition should say who they were approved by Risk Management
   2. Did USHE define minor in a different way, is it confusing that we are using Minor to apply to under 21 and under 18
      1. We aren’t concerned with people who are
      2. Clarify to background check policy as written
3. Procedures
   1. Policy Scope Exceptions
      1. Confused by the exceptions – it is a lot of minors who are in the exceptions
         1. Does this include high school students?
         2. This doesn’t seem to apply to anything based off the initial
      2. There needs to be a definition of when this program applies before the exception list because there doesn’t provide insight to when the policy actually is triggered.
      3. When does the policy apply
   2. Who is responsible for paying for the background checks
      1. SkillsUSA, 2000 kids, does that apply? The contests are judged by industry partners who are not part of the school, and they are in spaces with these youth
         1. Is this a school group visit?
   3. We don’t have any definitions of abuse, neglect – we need to add those
      1. Maybe also include language about dependency, but dependency is not mandatory reporting
      2. Utah Law requires us to report
         1. We just noticed a lot of exceptions, and then list the reporting obligations, but the reporting obligations apply to everything, including the exceptions.
      3. It might make sense to move B, incorporate it into the policy statement and pop it to the top – everyone on campus is a mandatory every time
      4. Create a new section that defines exactly the scope of the policy and what it applies to
   4. Move the entire section A exceptions to the very end of the policy
4. Program Director Responsibilities
   1. Still don’t know anything about the training and who does it.
      1. It says Risk identifies the training content and platform, but that doesn’t say who is responsible for monitoring, tracking completion
      2. Who is responsible for maintaining records of completion? Shouldn’t that be PWC/Anjali? Like Safe Hire? The program director might not be able to
5. Background Checks
   1. Do I have to do another background check?
   2. How long are volunteer background checks valid for?
   3. Who is responsible for maintaining background checks?
   4. Should this be consistent with the current background check policy?
      1. If the one that authorizes me for 5 years, doesn’t that cover me to be an authorized adult?
         1. The three years is inconsistent with the background policy
   5. No one is monitoring background checks at the college
   6. Volunteer frequency
      1. Is it practical, paying for volunteers? There’s a lot of logistic questions on the influence of the timeframe
      2. There will be people a lot of people who won’t come to campus if they have the onus of a background check
         1. Now they all have to do a background check?
         2. Who tells them?
         3. SLCC doesn’t have the infrastructure to do this many background checks for all of these events
            1. This is high-level risk if we require background checks, and then a small event happens if we don’t have background checks
      3. Waiver for volunteers that has the guidelines for participation with minors?
   7. Link the website in G and define what it means, and maybe implement the code of conduct for minors in a volunteer agreement/waiver that is volunteer facing
6. Violations
   1. An authorized adult, SLCC employee who violates this policy…
      1. Articulate the word may, so the tattletales calm down, put parameters around when corrective action policy is pinged.
   2. Could they have written this any longer and/or convoluted
      1. A non-college policy…
         1. Simply
         2. Maybe make it an enumerated list….
         3. This is really complicated
   3. It says that Risk is required to maintain the forms, does that mean the completed records? Because it says that it’s the program director above—but I think it should be in PWC.
7. Mandatory Reporter:
   1. Dependency is not a mandatory reporter trigger, it’s only abuse and neglect – misstatement of Utah Law