Internal Audit, Ethics & Compliance

Internal Audit Division

Implementing Procedures

Board of Regents Policy 6.9 Programs Serving Minors, provides the general requirements for properly screening and training employees and volunteers who work in Programs Serving Non-Student Minors. In accordance with this policy, each institution must establish procedures to implement the policy requirements. The following threshold requirements, as documented in Business Procedures Manual 16.8.2 Implementing Procedures must be included in each institution’s procedures:

A. Institutional Programming:

  1. Code of Conduct: Each institution must maintain a Code of Conduct for program staff and volunteers that addresses appropriate behavior and prohibited conduct when interacting with minors. This code should include the general prohibition against being alone with minors.
  2. Program Registration: Each institution must maintain a registry of authorized programs.
  3. Program Requirements: Prior to being authorized, program sponsors must have properly considered the following:
    • Qualifications of personnel leading and supervising the program.
    • Screening and background checks of staff and volunteers.
    • Supervision ratios.
    • Safety and security planning.
    • Response protocols for injury, illness, participant misconduct, and staff misconduct.
    • Transportation needs, if any.
    • Housing needs, if any.
    • Participation requirement forms.
    • Licensing requirements of state and federal agencies.
  4. Training: Each institution should maintain a training program that addresses mandatory reporting requirements, responsibilities and expectations, relevant institutional policies, safety and security procedures, and Staff Code of Conduct.
  5. Screening & Background Investigations: Institutions should conduct background investigations and appropriate screening of all staff and volunteers working in programs for non-student minors in accordance with the USG Human Resources Administrative Practice Manual. Personnel in charge of screening volunteers should be aware of the inherent limitations of background checks and should seek to utilize other screening methods, when possible, to include in-person interviews and reference checks.

B. Third-Party Programming -Facility Use Agreements:

Institutions licensing, leasing, or allowing the use of institutional facilities by non-USG entities for programs serving non-student minors must include language in a binding written agreement requiring the non-USG entity to comply with institutional policies on youth safety, background checks, training and minimum insurance requirements. In accordance with Board of Regents Policy 6.14.2, the form used for such agreements must be USG-approved.

For questions regarding the implementing procedures, please contact Chris McGraw, Assistant Vice Chancellor for Legal Affairs, or Wesley Horne, Director of Ethics & Compliance,