I. Purpose:
Hillcrest is committed to providing safe and effective services to our students. Safety and effectiveness go hand in hand. In order for students to be able to concentrate on their treatment and education, they must feel safe and protected. In order for staff to be able to focus on the care, treatment and education of students, they must feel safe and protected. HEC is committed to satisfying the expectations of its licensing agencies, and will consult agency liaisons as necessary to assure regulatory compliance and clear communication.

II. Objectives:
Allegations of abuse and neglect, injuries, emergencies, and incidents resulting in the potential for harm are taken very seriously. These types of events warrant a timely, thorough, and objective internal investigation, if indicated by the initial inquiry or by the nature of the incident itself. All events/incidents requiring an Internal Investigation require the immediate notification of the Executive Director and/or Senior Vice President or designee. The Executive Director and/or Senior Vice President will determine if the investigation will be conducted by the campus administration, the Director of Quality Assurance, or any other neutral party designee. If at any time during the Internal Investigation it appears that any illegal or criminal behavior was performed, the investigation will either cease or proceed under the direction of the local law enforcement.

III. Procedure:

 
1. A formal Internal Investigation must be conducted should any of the following occur:

 
• Allegation or complaint of abuse or neglect as defined by MA DCF and/or student’s referring state
• Major injury to student resulting in EMT response, emergency treatment, and/or physician intervention
• Allegation or complaint of sexual contact between students
• Missing child
• Vehicular accident
• Significant property destruction
• Stolen property
• Fire
• Discovery of illegal contraband (i.e. illegal substance, weapon, etc.)
• Significant program disruption (i.e. group violence, students left unattended, etc.)
• Sentinel events as defined by the JOINT COMMISSION
• A request for internal investigation by any state licensing and / or external reporting agencies
• Any other occasion when the Program Director determines the need for a formal investigation

2. Upon discovery of any of the above scenarios, a campus administrator, supervisor, or designee will contact the Program Director or Administrator on-call to determine the need for an Internal Investigation.

3. If it is determined that criteria is met for Internal Investigation, the Executive Director and/or Senior Vice President or designee will be notified immediately. The Executive Director and/or Senior Vice President, in conjunction with the Program Director and Quality Assurance Director, will determine if the event meets criteria for a reportable incident. This determination may be made initially, or at any time during the investigation as more information is gathered.

 
4. An official Internal Investigation File will be established by the Program Director, Quality Assurance Director, or designee, which minimally MUST include an official Internal Investigation Form, an Internal Investigation/Notification Checklist, and copies of any initial statements/reports related to the matter. The file will be given an Investigation ID code number using the campus initials first, the date of the incident/complaint second, and lastly, the primary student’s first and last initials. In the unlikely event that more than one investigation begins on the same day involving the same student, the code numbers will end with “a”, “b”, respectively. The Program Director (if investigation is conducted by campus administration) or Executive Director, Senior Vice President, and/or Quality Assurance Director (if investigation is conducted by a neutral party) will oversee all activities related to the investigation according to the timelines outlined in the Internal Investigation/Notification Checklist. The Executive Director, Senior Vice President, and/or the Director of Quality Assurance will provide support and supervision throughout the investigation as needed.

 
5. Immediate Response to Complaint / Incident

A. Campus administration and / or supervisory staff must collect initial written statements from all staff involved or may be witness to any reported incident or allegation. An HEC Formal Witness Statement form must be utilized when obtaining statements from staff related to an Internal Investigation. Depending on the nature of the event / incident and the initial information gathered, staff alleged to have been involved may be immediately suspended with or without pay pending the outcome of the investigation.
B. The Program Director, On-Call Administrator, or designee with consideration for causing as little disruption as possible to the daily routines of the students in the program, evaluate the situation and immediately take appropriate action to assure the health and safety of the students involved in the reportable incident / allegation and any other students similarly situated in the program. If determined to be necessary, the Program Director, On-Call Administrator, or designee will take additional action to prevent future acts of abuse and neglect including temporary removal of the student(s) from the program and/or reassignment of the student(s) within the facility. This would be conducted as an emergency measure if it is determined that there is a risk to the health or safety of such student(s) remaining at the program. If such immediate action is taken, HEC immediately make notifications to any Massachusetts licensing agencies and any out of state agencies appropriate to the student referring state, including agencies such as the New York State Justice Center for the Protection of People with Special Needs and the commissioner.
C. In all instances of alleged physical or sexual abuse, the campus Head Nurse or designee must be contacted immediately for medical consultation. The campus Head Nurse, agency Director of Nursing, and/or designee will determine if further medical treatment and / or evaluation is to be conducted by an off campus medical facility. The nursing department will document any evidence regarding a student’s body check and/or treatment provided to the student. The campus Program Director and / or Head Nurse will collect any and all documentation received by an outside medical facility for evidence of a reportable incident.
D. The Program Director, Director of Quality Assurance, or designee will begin to preserve any potential evidence to include, but not limited to:
• Securing the area wherein the suspected reportable incident occurred, if appropriate, and preserve relevant video surveillance material.
• Obtain sufficient documentation of the allegation / incident such as written initial statements, incident reports, medical information, etc.
• Conduct interviews and provide written summaries from all staff and students involved and / or witness to the reportable incident, when appropriate.
E. The program will provide counseling to the student(s) involved in any reportable incident or allegation, if appropriate. This will be conducted by the students primary clinician or designee, if possible.
F. Throughout the process of the internal investigation, HEC will cooperate with any external investigation conducted by DCF, DEEC, DESE, and law enforcement. In addition, HEC will cooperate with any out of state external investigation appropriate to the student(s) referring state. This includes cooperation with the New York Justice Center by complying with the procedures for the protection of New York state referred students in subdivision 5 of section 490 of the New York Social Services Law.

 
6. Notifications

 
A. The Program Director, the Director of Quality Assurance or designee will assure that all external communication / notification occurs in accordance with Hillcrest policy, state and licensing regulations, and the requirements of the students referring state agencies. These notifications are to include:
• Immediate report to the DCF local screening unit or state hotline if evenings or weekend.
• Notification to DEEC and DESE licensures via agency portals.
• Immediate reports to any out of state agencies appropriate to the student(s) referring state. These out of state agencies may include agencies such as the New York State Justice Center for the Protection of People with Special Needs, New York State Education Department and any local New York social services district, school district, and/or state agency funding the placement of any student involved in a reportable incident.
• Notification to student(s) legal guardian.
• Submit all required and requested initial documentation to all Massachusetts and out of state agencies.
B. The Program Director, Director of Quality Assurance, or designee will promptly make notifications to DCF, DEEC, DESE and any out of state agencies appropriate to the student(s) referring state including agencies such as the New York State Justice Center for the Protection of People with Special Needs regarding the resignation or termination of a subject of a report of alleged abuse or neglect from his or her position while an investigation is pending.

 
7. Internal Investigation Completion

 
A. The Program Director, Director of Quality Assurance, or designee will complete the HEC Internal Investigation Report Form upon the conclusion of the internal investigation. Every applicable item on both the Investigation/Notification Procedure Checklist and the Internal Investigation Report Form is critical and must be thoroughly completed in order to properly conduct, document and conclude any Internal Investigation. The Executive Director, Senior Vice President, and/ or the Director of Quality Assurance (if investigation is conducted by program administration) will assure the timely completion of every applicable item of the official Internal Investigation Report Form. The official Internal Investigation Report Form is required to be completed for all HEC Internal Investigations. The Executive Director, Senior Vice President, and/ or the Director of Quality Assurance (if investigation is conducted by program administration) will also assure the completion of every applicable item in sections I, II, and III of the Investigation / Notification Procedure Checklist according to the time lines required by all reporting and licensing agencies.
B. Upon completion of the internal investigation, the internal investigation report form and investigation / notification procedure checklist, the entire original file will be forwarded to the Executive Director and/or Senior Vice President for review and signature. Per DEEC, only reports signed by the Executive Director and/or Senior Vice President will be considered to be the “official” version of the investigation report.

C. If appropriate, The Program Director or designee will implement a program corrective / preventative action plan if the internal investigation determines that such abuse or neglect may have attributed in whole or in part to noncompliance by the program. In addition, the Program Director or designee will take such action as is necessary to prevent future acts of abuse and neglect including such actions as provision of increased training and/or supervision to staff pertinent to the prevention and remediation of abuse and neglect.
D. The Program Director, Director of Quality Assurance, or designee will submit a copy of the internal investigation report form and appropriate attachments to DCF, DEEC, DESE, and any out of state agencies appropriate to the student(s) referring state including agencies such as the New York State Justice Center for the Protection of People with Special Needs and the New York State Education Department.
E. The Program Director, Director of Quality Assurance, or designee will take appropriate action to support a request for additional information from DCF, DEEC, DESE and any out of state agencies appropriate to the student(s) referring state including agencies such as the New York State Justice Center for the Protection of People with Special Needs and the New York State Education Department.

 
8. Incident Closure

 
A. Obtain documentation of recommended and/or required corrective action from DCF, DEEC, DESE, and any out of state agencies appropriate to the student(s) referring state including agencies such as the New York State Justice Center for the Protection of People with Special Needs and the New York State Education Department. If corrective action is required due to noncompliance by the program that may in whole or in part contributed to the reported event of abuse or neglect, the program will implement a plan of prevention and remediation. This shall address at minimum the areas in which the program has been found to be out of compliance and shall indicate the manner in which the program will come into compliance. The corrective action plan shall be developed and all documentation will be submitted for approval to the appropriate agency within the timeframe specified on the report.
B. Obtain documentation of external investigation closure from DCF, DEEC, DESE, and any out of state agencies appropriate to the student(s) referring state including agencies such as the New York State Justice Center for the Protection of People with Special Needs. Any Massachusetts agency external investigation reports will be forwarded to out of state agencies appropriate to the student(s) referring state no later than 90 days, if made available to HEC.
C. The Executive Director, Senior Vice President, Director of Quality Assurance or designee will assure the timely completion of every item in incident closure section of the Investigation/Notification Procedure Checklist, and will maintain the entire original file at the Administrative Offices throughout the remainder of the process.

Child Abuse Policy
Following Massachusetts’s law, HEC prohibits any form of physical, sexual, or emotional abuse of its students, and mandates all staff to report incidents of suspected child abuse.
Abuse: the non-accidental commission of any act by a caretaker, which causes or creates a substantial risk of harm or threat of harm to a child’s well-being.

 
Neglect:
1. Failure by a caretaker, either deliberately or through negligence, to take actions necessary to
provide a child with minimally adequate food, clothing, shelter, medical care, supervision, or other essential care.

 
2. Serious physical injury (any non-trivial injury); death; malnutrition; and failure to thrive.

 
3. Serious emotional injury: an extreme emotional condition such as a severe state of anxiety, depression or withdrawal.

 
Child Abuse Reporting
1. Each and every one of the employees of HEC is required by law to report to their supervisor the awareness of any student who may be abused or neglected. Under M.G.L. Chapter 119, staff are categorized as mandated reporters, liable to civil or criminal action for failure to report a potentially abusive or neglectful situation or incident.

 
2. The term, mandated reporter, specifically addresses the fact that any person who works in a residential treatment center is required to report to DCF (Department of Children & Families). At HEC, once the staff member reports an incident or allegation to the person in charge, the employee is then relieved of any liability and the liability for not reporting belongs to the person in charge, i.e. the Program Director. All HEC staff are permitted to call in a report to any external reporting agencies if necessary, including out of state reporting agencies such as the New York State Justice Center.

3. All new HEC employees are provided with initial training regarding the HEC policy and procedure for staff responsibilities regarding abuse and neglect incidents and / or allegations. Before the commencement of duties, all new employees receive mandatory training during orientation titled “Preventing Abuse and Neglect / Mandated Reporting Responsibilities.”

 
4. Staff must immediately report to his/her supervisor any abusive behavior toward a student and complete a written report on the matter within 24 hours. The supervisor will ordinarily immediately notify his/her Program Director who, in turn, will notify without delay to the Senior Vice President and/or Executive Director. On the next business day, the Program Director will ordinarily submit a brief written statement of concern to the Senior Vice President and/or Executive Director.

 
5. HEC requires the Director of Quality Assurance, Program Director or, if absent, his/her administrative designee to immediately report to the Department of Children & Families (DCF), Early Education and Care (EEC), and Department of Elementary and Secondary Education (DESE). In addition, reports will immediately be made to any out of state agencies appropriate to the student referring state, including agencies such as the New York State Justice Center for the Protection of People with Special Needs, New York State Education Department and any local New York social services district, school district, and/or state agency funding the placement of any student involved in a reportable incident.

 
6. At the time of the allegation, the staff person alleged to have abused a student would ordinarily be suspended without pay pending a full investigation.

 
7. If the charge of abuse / neglect is not supported by the DCF, the staff member may be considered exonerated and reinstated with back pay. Depending upon the circumstances, the employee may be subject to disciplinary action, including suspension without pay and re-training.

 
8. If the charge of abuse / neglect is supported, the staff person may be terminated from employment and may face legal sanctions.

9. Employees not reporting suspected abuse or neglect are subject to discipline up to and including dismissal.

 
10. DCF regulations provide the following pertinent definitions as guidelines for reporting:

 
A. Abuse – the non-accidental commission of any act by a caretaker, which causes or creates a substantial risk of harm or threat of harm to a child’s well-being
B. Neglect – Failure by a caretaker, either deliberately or through negligence, to take actions necessary to provide a child with minimally adequate food, clothing, shelter, medical care, supervision, or other essential care.
C. Serious physical injury (any non-trivial injury); death, malnutrition; and failure to thrive.
D. Serious emotional injury: an extreme emotional condition such as a severe state of anxiety, depression or withdrawal.

On-Campus Swimming Activities

• A Designated Staff must be assigned to each swimming activity.
• The Designated Staff must not be included in the staffing ratios for that group.
• Approved student-to-staff ratios for the group swimming must be maintained for the entire duration of all swimming activities.
• Each Designated Staff must have current First Aid and CPR certifications.

The following rules apply at all times:

• No students allowed in pool area without staff
• All swimmers must rinse prior to using pool
• Staff or students with cuts or bandages may not use the pool
• Staff or students with communicable diseases may not use the pool
• No items are to be placed in the pool except those approved for pool usage
• No jumping/diving/horseplay
• Ladder must be used to enter and exit the pool
• Only one student can enter or exit the pool at a time
• No food or drink in the pool area
• No swimming after sunset
• Students must follow the instructions of the Staff at all times

Failure to follow any of the above rules will result in restriction from pool use.

Off-Campus Swimming Activities

• Swimming events at locations that already have a lifeguard will not require a HEC lifeguard to accompany the students.
• CPR-trained staff must be assigned to accompany any off-campus swimming activity where we will be relying upon the lifeguard on duty at the swimming area.
• Students will follow all rules imposed by the lifeguard on duty.
• No Hillcrest staff or student shall attend an off-campus swimming event at a location not employing their own lifeguard unless an HEC lifeguard is accompanying the group.

Revised 7/2013 DH
Policy & Procedures
Emergency Manuals

(Also see HILLCREST policy on “Professional Boundaries”.)

INTRODUCTION
By its very nature, residential care and treatment with children and adolescents involves intense interpersonal dynamics and some intensely intimate aspects of the lives of students. The nature of our work can contribute to and result in complicated emotions and strong personal feelings and/or relationships between staff and students. The familiarity that develops between staff and students also contributes to a relationship that may be so comfortable at times that feelings and responses may be, in fact, personal instead of professional.

These feelings and relationships, if understood, acknowledged and managed well, can have positive, beneficial, therapeutic impacts on students without causing harm to any student or staff. However, if misunderstood, unacknowledged or poorly managed, they have the potential to cause serious harm to students and/or staff. Therefore, the challenge is:
1) to understand, acknowledge and manage feelings and behaviors appropriately and professionally;
2) to develop staff-student relationships that are professional, therapeutic, and in the best interests of HEC students.

The role modeling of professional boundaries by all staff, regardless of role or function, promotes mutual respect and a culture of respect. It helps to insure proper care and treatment for students, and protects staff employment status, liability vulnerability and reputation. (Also see HEC policy on “Boundaries”.)

The following policy statement is intended to define the expectations and obligations of Hillcrest staff, both current and former, with regard to personal versus professional contact and/or relationships with current and/or former Hillcrest students.

POLICY STATEMENT

Hillcrest Educational Centers, as a licensed and accredited behavioral health agency, has an obligation to ensure that professional boundaries between students and staff are respected and maintained. Both experience and best practices have clearly demonstrated over time that maintaining these professional boundaries is essential to insure proper and effective care and treatment for students, regardless of the personal feelings, either positive or negative, any staff may have toward any student. Hillcrest, therefore, must reserve the right to limit and/or disapprove what is, or may be, inappropriate or unauthorized contact between current and/or former HEC staff and current and/or former HEC students, and/or any relations and/or contacts that are contraindicated by virtue of student or staff characteristics.

Regardless of their role or position, almost all Hillcrest staff come to know and have contact with students as part of their professional function and because of their Hillcrest employment. During the course of employment, it is natural and normal for each of us to have a range of feelings and reactions to the students, both positive and negative. It is natural for us to “like” some students more than others, just as it is natural for students to “like” some staff more than others. As Hillcrest staff, however, good practice and professional standards of conduct require us to treat and deal with all students in an unbiased, equal and professional manner, regardless of our personal feelings about them or our reactions to them. Therefore, the agency has both the right and the responsibility to develop and to enforce these standards for staff conduct with students.

All contacts and relationships between staff and students, current and/or former, must be strictly professional in nature and function, regardless of the employment status of the staff (i.e., currently or formerly employed by HEC) or the placement status of the student (i.e., current or former student). This, in fact, is the only way to insure that staff – student contact and relationships are appropriate and therapeutic in nature.

There are four basic conditions to which this policy applies.
1) The staff is currently employed at HEC. The student is currently in HEC care.
2) The staff is currently employed at HEC. The student has been discharged or transferred from HEC care.
3) The staff is no longer employed at HEC. The student is still in HEC care.
4) The staff is no longer employed at HEC. The student has been discharged or transferred from HEC care.

The essence of this policy is a clear differentiation and boundary between personal and professional contacts and relationships between staff and students, whether current or former. This differentiation and this boundary are consistent with HEC expectations, and with ethical codes and standards for all helping professions.

1) The relationships and/or contacts (i.e., communication by mail, telephone, email, etc.; in person meetings; etc.) between current and/or former HEC staff, and current and/or former HEC students are exclusively professional. They are guided and bound by the HEC Code of Ethics, HEC Policy and Procedures, and by the staff member’s current or former role and job description.

2) It is neither appropriate nor acceptable for any current or former student to have a current or former staff member’s home telephone number, home mailing address, email or “instant messenger” address, or any other personal or demographic information that allows or encourages personal versus professional contact. If a staff member becomes aware that a current or former student has such personal information about any staff, including themselves, they are required to immediately report this fact to their immediate or former supervisor, or to an HEC administrator.

3) Former Hillcrest staff shall have no contact with current or former HEC students unless the contact has been authorized by HEC administration.

4) Any and all desired contacts and/or relationships between current and/or former HEC staff and current and/or former HEC students that are outside the parameters of the staff member’s role and/or job description, and which therefore might constitute personal relationship or contact, must be discussed in advance with the campus Program Director and/or the agency Executive Vice President or CEO and be determined by them to be in the best interest of the current or former student. Such desired relationships and/or contacts may only be conducted with the knowledge and approval of the campus Program Director and/or the agency Executive Vice President or CEO.

Any such relationship and/or contacts between current and/or former HEC staff and current and/or former HEC students that are not approved in advance will be considered to be in violation of HEC policies, procedures and professional ethics. Such an unapproved relationship and/or contact will be cause for disciplinary action for a current employee who engages in such action, up to and including termination from employment. Legal or administrative action or referral may be initiated against former employees who violate this policy or when there is reason to believe this policy has been violated.

Former employees who choose not to respect and follow these policies and procedures will receive negative references to future, prospective employers and/or helping agencies (e.g., foster care or adoption agencies) checking HEC references.

Similarly, during any form of contact with a student’s family, guardian, or advocate, or with any representative an outside agency, staff are expected to act in a professional manner. For example, at no time during a professional contact may staff violate professional boundaries, form personal relationship or share personal information.

Finally, if there is any evidence or reason to believe that inappropriate and/or illegal contact between a current or former staff and a current or former student may have occurred, relevant social service and/or law enforcement agencies shall be notified.

WHEN FORMER STUDENTS CALL A CAMPUS
It is not possible to detail all possible scenarios or conditions related to former students calling, writing to, or making an unplanned visit to a campus. It is essential, therefore, that Supervisors use their best professional judgment about how to manage such contacts. The following guidelines should be used to guide such management decisions.

Calls:
1) The person answering the telephone should transfer the call to the Supervisor.
Calls from former students should not be transferred to other students, direct care staff or to Teams.
2) Most students who call a campus do so with benign intentions. They are usually attempting to maintain connections with people with whom they had meaningful relationships. Students may also call because they are troubled, are in trouble or are seeking affirmation or reassurance in some way. Therefore, whoever converses with a former student should be cordial and professional. The call should not be treated as “social call”. The conversation should be channeled toward the caller with regard to our interest in their activities, progress, etc.
3) Anyone conversing with a former student should be sure to guard the privacy and confidentiality of both current students and staff by not disclosing any information. A summary of the telephone call shall be developed in writing and reviewed with an HEC administrator to determine if any follow-up is required. The documentation of the telephone call, and the follow-up activities, if any, shall be placed in the former student’s file.

Mail:
1) Incoming mail from former students should be forwarded directly and unopened to the Program Director or his/her designee, who will determine whether a reply is in order and who should make that reply.
2) The principles noted above apply to mail as well as calls. The mail interaction should be cordial and professional, with ongoing interest about the student and their life expressed. Rules of confidentiality and privacy apply.

Unplanned Visits:
1) Unplanned, unapproved visits by former students are neither appropriate nor acceptable. As with any unauthorized visitor, the Supervisor should be immediately notified about the student’s presence and the Supervisor should intervene.

2) The visiting student must not be encouraged or allowed to “go visiting” on the campus without supervision. While on campus, they must be with a staff member at all times.

3) While being treated in a cordial and professional manner, the visiting student should receive a clear message that unplanned visits are not acceptable, and that all visits must be planned and approved. Without undue haste, the student should be directed to leave the campus in a timely fashion, and the Supervisor or his/her designee should ensure that the student has left. As with any unauthorized visitor or intruder, if the student refuses to leave in a timely fashion, despite the staff’s best encouragement, the police should be called.

(Also see HILLCREST policy on “Staff Contact and Relationships With Students”.)

INTRODUCTION

By its very nature, residential care and treatment with children and adolescents sometimes involves intense interpersonal dynamics and some intensely intimate aspects of the lives of students. The nature of our work can result in complicated emotions and strong personal feelings and/or relationships among staff and students. The familiarity that develops between staff and residential students also contributes to a relationship that may be so comfortable at times that feelings and responses may be more personal than professional. However, nurturance, acceptance, encouragement, and support can and must be provided by staff while still maintaining professional boundaries.

A student will interpret the staff’s actions based on the student’s own developmental level, on their cognitive ability to understand the parameters of the relationship, and on their level of emotional need and psycho-emotional condition. Abused, neglected and emotionally disturbed students frequently have issues or problems in interpersonal relationships. They often have inadequate sense of boundaries, and they sometimes interpret the staff’s actions in relation to their unmet needs and their experience in unhealthy relationships. Additionally, as caring adults, we are naturally inclined to reach out protectively to students who are showing distress or emotional pain. Without self-reflection, understanding and objective guidance (e.g., good supervision), the needs of a particular student and the needs of a particular staff can interact in such a way that the relationship moves in an unhealthy or inappropriate direction.

The work we do requires an ability to be meaningfully related to a student yet separate enough to distinguish one’s own feelings and needs. We owe it to our students to be introspective about ourselves and our own needs so that we do not blur or confuse relationships and send mixed messages.

These feelings and relationships, if understood, acknowledged and managed well, can have positive, beneficial, therapeutic impacts on students without causing harm to any student or staff. However, if misunderstood, unacknowledged or poorly managed, they have the potential to cause serious harm to students and/or staff. The challenge is to:
• understand, acknowledge and manage feelings and behaviors appropriately and professionally.
• develop staff – student relationships that are professional, therapeutic and in the best interests of Hillcrest students.

BOUNDARIES – DEFINITION AND FUNCTION
The term “boundaries” is a metaphor for the protective limits between the staff and the student. It refers to the psychological, emotional, interpersonal and even physical space that allows for a safe connection and relationship based on the student’s needs, not those of the staff. Boundaries, including such constructs as codes of ethics, professional standards and licensure, perform a number of important functions. For example, they:
• help to structure the staff – student relationship to be professional and therapeutic, not personal or social relationship.
• define appropriate behavior, and provide security and order.
• help to define roles and responsibilities, and set the parameters within which care, treatment and other services are delivered.
• allow students to get safely close to others, yet remain separate.

A professional/therapeutic relationship is a planned and goal directed series of interaction between agency staff and a student for the purpose of providing care and treatment to the student. In a professional/therapeutic relationship:
• the needs of the student, rather than of the staff, are the highest priority.
• the roles are clearly defined, structured and they do not change or reverse; the focus of the relationship is on the student.
• the interactions, interventions and outcomes are periodically evaluated.

In a friendship or social relationship, on the other hand:
• mutual needs are met, rather than the needs of the student, and it is appropriate at times to put one’s needs first.
• roles may shift periodically and even dramatically.
• there is little emphasis on evaluation of the interaction or the outcome.

The primary concern and focus in therapeutic relationships, and when establishing and managing boundaries with current and former students, must be the best interests of the student, as well as associated Hillcrest policies and procedures.

The development of a trusting “connection” between staff and the student is essential because it allows the student to take the necessary risks involved in making change. It is the responsibility of the staff to simultaneously maintain the boundaries of this professional relationship while establishing and maintaining a therapeutic “connection” with the student. It is essential, though not necessarily easy, to balance a caring and supportive relationship with students with appropriate professional distance and boundaries. This task is particularly complicated, difficult and critical with children and adolescents whose needs, urges, impulses and boundaries are often confused and distorted.

Some staff rationalize and justify their friendship or boundary violations with a student as being “the kind of help the student really needs” and as “really caring”. However, students come to Hillcrest for care and treatment; the long-term goals and plans for the students are the primary consideration. Inappropriate relationships are a shift away from the needs of the student needs to the needs of the staff. Students have the right to professional and therapeutic care, and Hillcrest has a responsibility to insure that staff have caring, but professional relationships with students.

Regardless of their role or position, almost all Hillcrest staff come to know and have contact with students as part of their professional function and because of their Hillcrest employment. As Hillcrest staff, good practice and professional standards of conduct require us to treat and deal with all students in an unbiased, equal and professional manner, regardless of our personal feelings about them or our reactions to them. The role modeling of professional boundaries by all staff, regardless of role or function, promotes mutual respect and a culture of respect. It helps to insure proper care and treatment for students, and it protects the staff as well as the students.

There are potentially serious consequences to the blurring of boundaries and to unprofessional relationships. When this happens, neither the student nor the staff are able to respond objectively due to the “friendship”. When objectivity is lost, staff respond out of emotion, rather than out of therapeutic objectivity and professional judgment about a student’s best interests. There is a conflict of interest that interferes with student treatment, and with the group and Team process and relationships.

Additionally, staff put themselves at risk for liability because of inappropriate or unapproved contact. If a student or student’s family were to pursue litigation or other legal action against a staff member, the staff may not have legal support from Hillcrest because they were not acting according to Hillcrest policy or appropriately in the capacity of an employee.

IMBALANCE OF POWER
In any professional relationship there is an inherent power imbalance, and the staff – student relationship is one of unequal power. Staff have knowledge, access to privileged information, authority and influence. Staff provide daily care and assistance to students, and students often grow to trust staff and value their help and care, which adds to the imbalance in the power structure within the relationship. Staff provide information about student behavior and progress, and they have input into important decisions made about students’ lives. Whether they realize it or not staff have tremendous influence over students. Therefore, staff have a responsibility to act in the best interests of the student. We, and not the students, are ultimately responsible for managing boundary issues, and we are accountable should violations occur.

Given the power imbalance that exists in the staff – student relationship, students may find it difficult to negotiate boundaries or to recognize or defend themselves against boundary violations. For that matter, students are usually unaware of the need for professional boundaries, and they may frequently initiate behavior or make requests that could constitute boundary violations. When a relationship is strictly professional, it has checks and balances that help to insure that staff – student interactions are appropriate and in the student’s best interests. As soon as the relationship becomes emotional and personal, however, the professional relationship is lost. The checks and balances designed to protect the student and the staff break down, and the staff responds more personally rather than professionally to the student.

It is possible to maintain a compassionate, warm and caring professional relationship with students that helps them feel cared for and motivated to work in treatment without violating professional boundaries.

BOUNDARY VIOLATION
“Boundary violation” means “outside the limits of the therapeutic and professional relationship”. Most boundary violations are unwitting, subtle, and largely unconscious. The history and plight of some students may persuade some staff to respond in a therapeutically inappropriate way. The seductive pull of helping can sometimes make the distinction between appropriate and inappropriate unclear. Boundary violations may occur with either current or former students, and they may occur even after staff have left employment with Hillcrest Educational Centers.

The following are examples of the types of professional boundaries violations that may occur between staff and students.:
Role boundaries:
o Doing things for the student that are not a part of job responsibilities (e.g., buying clothes for a student with your own money).
o Treating a student as a “friend” or confidant.
o Interacting with coworkers in a “social” manner with students present (e.g., discussing a date or a night out” in front of students).
o Having “rescue fantasies” about or “over-identifying” with a student or students.
Time, Place and Space boundaries:
o Spending more time or unusual time (e.g., during staff’s time off) with a student.
o Spending free time or private time with a student to the exclusion of other students.
o Having unapproved contacts with students in settings other than approved settings (e.g., during a community outing, bringing students to one’s own home).
o Violating the ‘rule of three”.
Money, Business and Service boundaries:
o Having any type of business, financial or service transaction with a student (e.g., borrowing or lending money; giving or taking personal money, buying or selling items).
Gifts and favors boundaries:
o Accepting or giving personal gifts, including personal photos (as opposed to giving or receiving gifts between staff and the Team).
o Allowing/encouraging the student to do favors for the staff (e.g., wash a staff’s car), or the staff for the student (e.g., make an unauthorized purchase for the student).
Fair and Equal Treatment boundaries:
o Treating students on the basis of your “like” or “dislike”.
o Favoring one student over others.
o Treating a student unfairly or differently from others; giving special attention/treatment to a student that differs from that given to other students, or refusing to provide normal or prescribed care and treatment to a student for personal reasons (e.g., dislike).

Clothing boundaries:
o Dressing in a way that is unsuitable for work or in a seductive manner or in any way that blurs, confuses or distorts the relationship with the student.
Language boundaries:
o Using too familiar or inappropriate names or nicknames in addressing each other, use of inappropriate or suggestive humor or language (e.g. profanity).
Self-disclosure boundaries:
o Sharing with a student personal or intimate information, work concerns or private information about other staff or students;
o sharing any sort of secrets with a student.
Physical Contact boundaries:
o Having a type of physical contact, or more physical contact than is appropriate or necessary, or than is allowed by campus policies, or than is reasonably required for a situation.
Abuse boundaries:
o Physical, verbal, emotional abuse; inappropriate or unnecessary use of restraints.
o Having any sort of sexual contact with a student.

The list above is not all-inclusive. It is intended for use as a guideline and to provide examples of unprofessional behavior and boundary violation.
Staff are expected to observe appropriate and professional conduct, including boundary maintenance, at all times. Failure to maintain professional conduct and to observe appropriate and professional boundaries will result in disciplinary action up to and including termination from employment.

Similarly, during any form of contact with a student’s family, guardian, or advocate, or with any representative an outside agency, staff are expected to act in a professional manner. For example, at no time during a professional contact may staff violate professional boundaries, form personal relationship or share personal information.
 
QUESTIONS TO CONSIDER IN EXAMINING POTENTIAL BOUNDARY ISSUES
In some cases, boundary issues may pose dilemmas for a staff, and there may not seem to be any clear or obvious answers. In determining how to proceed, in addition to discussion with one’s immediate supervisor, consideration of the following questions may be helpful.
o Is this in the student’s best interest?
o Whose needs are being served? Does this action benefit me rather than the student?
o Am I dealing with this student (or student’s family) differently than I would another student (or family) under similar circumstances? Am I treating this student differently (better or not as well) than I treat other students?
o Does my behavior with this client differ from my usual professional behavior (e.g., dressing differently, being more concerned about appearance)?
o How would this be viewed by the student’s family, guardian or custodial agency?
o Would I say or do this particular thing if a coworker were present? How would I feel telling a coworker or supervisor about this?
o Will this have an impact on the student’s care, treatment or emotional condition?
o Should I discuss my feelings, concerns or questions with my supervisor?
o Does this student mean something ‘special’ to me?
o Am I taking advantage of the student or allowing the student to take advantage of me?
o Would I be comfortable documenting this decision or this behavior in the Team Log or student’s file?
o Would this (or does this) decision or behavior violate state regulations, the Hillcrest Code of Ethics, Hillcrest Policies and Procedures, or any other common or reasonable standard for appropriate behavior?
The answers to these questions may provide some indication that professional boundaries may be at risk.
In order to prevent compromising the best interests of a Hillcrest student or staff job security, it is best to discuss potential boundary violations with one’s immediate supervisor before performing any questionable behavior. Remember, when in doubt, ask for help. Sometimes a staff will have a vague sense that something is not quite right with a particular student relationship but may be unable to put into words exactly what the problem or difficulty is. By talking with a supervisor the staff may gain a new perspective on the issue and perhaps develop some options and alternatives to deal with the issue or concern.

WARNING SIGNS
There may be times in residential care work when staff in any job or role could feel drawn toward a student, or experience feelings of attraction to a student. Similarly, staff could feel unjustified negative feelings toward or “bad chemistry” with a student. It is important that staff recognize these feelings as early as possible and take action to prevent the relationship from developing into something other than a professional one. The obligation is always on the staff, rather than on the student, not to cross the line.

Before actual physical or sexual contact or abuse occurs there may be a number of warning signs, or changes in the staff’s behavior. Additionally, this type of misconduct often follows a pattern wherein minor boundary violations (e.g., subtle favoritism or negative bias) gradually shift into major boundary violations (e.g., sexual contact or physical abuse). Staff should be alert to such signs that suggest he/she or a coworker may be starting to treat a particular student differently.
The following indicators should be considered as possible warning signs:
• frequently thinking (positively or negatively) of the student while away from work.
• Having rescue fantasies about or over identification with a student.
• spending time with the student away from other students or staff.
• planning or arranging the care of other students around the student.
• self-disclosure of personal information, or confidential or personal information about other students or staff to a student.
• undue concern about meeting the expectations or demands of the student, or disregarding the student’s legitimate needs or requests.
• inability to accept alternate opinions from colleagues about the student’s condition, progress or treatment goals.
• believing that only you truly understand or care about the student.
• feelings of personal responsibility for student’s progress, or a lack of caring about the student’s condition or progress.
• awareness of, or desire for more (or for less) physical contact and touch than with other students.
• flirtatious or overt sexual content in interactions with the student, regardless of who initiates that behavior.

WHAT STAFF CAN DO
When a staff recognizes any of these indicators or warning signs in their own behavior, or finds himself or herself having a problem with how he or she is treating or feeling about a student or how students are feeling about them, they should:
• get assistance as soon as possible.
• reflect and review their feelings and motivations.
• consider talking about the indicators, feelings or behaviors with their supervisor.
• adjust their behavior accordingly.

When staff recognize any of these warning signs in the behavior of a coworker, staff should:
• make the coworker and/or supervisor aware of the behavior,
• encourage and support reflection and review of behavior.

SUMMARY OF KEY POINTS
• The best interests of the student, and associated Hillcrest policies and procedures, are the highest priorities, and the deciding factors in relationships between current/former staff and current/former students, and in possible boundary violations.
• It is our responsibility, not the student’s, to maintain appropriate boundaries in our professional relationships with students.
• Initiation and or consent by the student for behavior that constitutes a boundary violation between staff and student is not an excuse or justification.
• It is important that staff maintain a professional and personal support structure that provides for feedback and advice on the management of boundary issues as it impacts on their work with students and coworkers.
• A staff’s termination of employment with Hillcrest, and/or the transfer or discharge of a student from Hillcrest Educational Centers’ care and treatment does not absolve staff’s responsibility to observe and respect professional boundaries and ethics.

General Guidelines
The pattern of staff supervision of students is determined by the program.  HEC utilizes both individual student and a team approach to supervision.  Staff members are assigned to a Student or a Team of students who are under their supervision.  All activities require consistency and routine.  When students are not involved in one-on-one instruction, Team participation and membership are stressed. Clinical strategies are outlined for each student in his/her individual CTP/IEP.
Students are not permitted to be alone and out of staff eyesight except when the need for privacy dictates.  Every attempt is made to engage each student in a positive way through a variety of educational, social and recreational experiences.
Students may be allowed a reasonable degree of privacy, for example, in bathrooms or in their bedrooms.  However, privacy can only be allowed if rooms have been checked to assure that no potentially harmful/dangerous objects or materials are present, if the student’s behavior and level are appropriate to the granting of privacy, and when no other students are in the room.   Even so, staff must be present outside the door of such areas and make checks at intervals to be determined by the Treatment Team and good child care practices.  If there are 2 or more students in the same room/area, then staff must be in a position to ensure all students in that area are in eyesight and ear shot.
Whenever students leave their campus, they must be accompanied by staff unless the student is being taken off-campus by an authorized visitor for an approved visit.
When supervisory responsibilities of a student are passed to another staff, it is mandatory that the staff turning over supervision and the staff taking on supervision * clearly acknowledge this transfer to one another so that misunderstandings can be avoided and student safety be maintained.
Teamwork and communication are necessary to provide close, effective supervision.  Any problems encountered in the supervision of students should be reported to the Child Care Supervisor.

Special Circumstance Guidelines

The Treatment Team, with the expressed documented permission of the Program Director, may develop a supervision structure which permits the student to engage in “non-direct supervised” On- or Off-campus academic, life-skill, and/or vocational experiences which are consistent with the student’s IEP and which are provided with the informed consent of the Parent/Guardian, School District and other funding agencies. This “supervision structure” should be time-limited, consistent with the student’s Treatment Level, subject to frequent routine reviews, and contain safeguards and conditions for the ultimate protection of the student.

These guidelines are designed to maintain the safety of the students. Full cooperation is expected from staff. Failure to supervise students properly may result in suspension and even termination from employment.

1. Students: HEC students, regardless of their age, are not permitted to smoke or use tobacco products (e.g., chewing tobacco), and students are not allowed to possess smoking or tobacco related materials or items, including fire related items such as lighters or matches.
2. Staff: All HEC sites are tobacco free. For more information, please see Chapter 16, Human Resources.

Hillcrest Educational Centers has clear and strict policies prohibiting sexual harassment of any kind between staff, between students and staff, and between students. Regardless of the intent, the creation of a hostile work environment for staff or living environment for students will not be tolerated.
For more information, please refer to the Personnel Policies in Section 8, Human Resources.

A. Definitions:
Age-appropriate sexual behavior: Behavior considered appropriate to a person’s chronological age and developmental stage and level.
Private place: Those areas identified by the Treatment Team at each campus providing a reasonable degree of privacy including, but not limited to, bathroom areas.

B. Health Education and Human Sexuality:
Depending on the age and developmental level of the students, classes offered at HEC help students understand the scope of sexuality and its place in human relationships. The classes provide opportunities for open discussion and are intended to help students make appropriate and informed decisions.
The structure of the Health Education classes, usually small groups, is flexible in order to meet the needs of individuals according to their ability to comprehend information and concepts. Students are assessed as to knowledge and understanding of health/sexuality issues before class structure is finally determined.
The Health Education classes are facilitated by teachers and staff trained to provide sex education. Staff who work with the class participants in other settings are encouraged to attend and participate in the classes. Depending upon the ages and developmental levels of the students to be involved, the content of the education program may include: defining appropriate expressions of affection; public vs. private places; sexually transmitted diseases; communication and human relationships; anatomy and physiology; contraception and reproduction; personal hygiene; health concerns; human sexual response; acceptable and non-acceptable sexual expression; understanding, preventing and coping with victimization.

1) Student Responsibilities
Students are expected and encouraged to:
a) Receive education regarding various components of health care and sexuality through the Health and Human Sexuality program, appropriate to the student’s age and developmental level.
b) Attend and cooperate with all routine medical appointments such as eye, gynecological and routine physicals with staff assistance, as needed.
c) Discuss any health concerns, routine and otherwise, including matters pertaining to sex and sexuality, with staff, their Clinician and/or the appropriate nurse or doctor.

2). Staff Responsibilities
Staff are expected and encouraged to:
a) Assist students in receiving and accepting all necessary medical care provided by both HEC and community health care providers, i.e., making appointments and accompanying them, if necessary.
b) Act appropriately as an advocate to help ensure quality health care.
c) Assist medical professionals in discussing health concerns with the student.
d) Be informed about the content of classes in which their students participate in the area of health/sexual education.

C. Questioning and curiosity
a) Definitions:
Questioning and curiosity are when individuals, through gesture or word, ask questions about various aspects of sexuality.
b). Student Responsibilities:
Student are expected to ask questions or discuss health/sexuality appropriately and discreetly, in appropriate places, at appropriate times.
c) Staff Responsibilities:
It is understood that discussing issues related to sex and sexuality with students is a sensitive and delicate task. Not all staff will feel comfortable in doing so, and staff must be aware of the scope and limitations of their own personal knowledge, experience and values.
Even while attempting to help a student with valid and genuine questions and concerns about this very human matter, staff must also remain consistently aware of professional boundaries and their role. Similarly, many HEC students have serious sexual issues; many have been victims of sexual abuse; and many are highly sexualized. Therefore, staff should be sensitive to indicators, both objective and intuitive, of the student’s motivations in raising issues of sex and sexuality. With many HEC students, questions regarding sex and sexuality may best be referred to the student’s Clinician.
1) Staff should respond to questions to the best of their ability, and in an objective and non-judgmental manner, being careful not to interject personal values or personal information. Staff should respond specifically to the question asked or the issue raised by the student, and should not expand the discussion or respond too widely.
2). If staff are not comfortable with subject matter, issue raised, or question asked staff should assist the student in finding the answer or information from someone else (e.g., clinician, nurse).
3) If staff do not know the answer, staff should offer to help the student look up the answer, i.e., Family Planning agencies, library, Human Sexuality program or assist the student in discussing the issue with someone else (e.g., clinician, nurse).

In all above instances, staff should follow-up to make sure students’ questions are answered and understood by the student.

D. Body Exploration, Masturbation
1) Definitions:
Body exploration occurs when a person, out of curiosity, observes or touches his or her own body.
Masturbation involves fondling/stimulating one’s own sexual areas for the purpose of sexual arousal.

2). Student Responsibilities
If a student chooses to engage in self exploration or masturbatory behavior he/she is expected to:
a) Stay in a private place so that the privacy rights of others are not violated.
b) Not let the behavior interfere with living, work or treatment responsibilities.
c) Not engage in the behavior to the extent or in a way that causes self injury.
d) Exercise good personal hygiene and appropriate care for his/her surroundings).

3) Staff Responsibilities
Staff are expected to:
a) Help the student understand that body exploration and masturbation are normal means of human sexual expression, and that it is important to consider time and place before one engages in these behaviors.
b) Assist in defining public vs. private places, and appropriate times for body exploration and masturbation.
c) If student engages in these behaviors in a way that is inconsistent with stated expectations and responsibilities, it is suggested that staff intervene as follows:
1] Discreetly interrupt the behavior by addressing the inappropriateness (e.g., time or place).
2] If the student continues to engage in the behavior, staff should explain that it appears the student is engaging in masturbatory behavior and ask the student to stop, and then engage in collaborative problem solving as appropriate.
3] During this intervention, staff should protect the individual from embarrassment, humiliation or feeling punished, i.e., shield them or cover them with a coat and/or redirect them to an appropriate time and place for this activity.
Excessive or inappropriate body exploration or masturbation should be referred to the Treatment Team for the development of a management plan.

E. Dating
Given the ages of our students, it is natural and normal that they should be interested in other students. However, dating and/or “going out” between students is prohibited at all HEC programs.

Hillcrest Educational Centers recognizes that our students and their parents / guardians and / or families have a wide range of spiritual and / or religious beliefs, values and practices. HEC understands that spiritual and / or religious beliefs, values and practices may be a significant and valuable source of comfort, support, strength, hope and guidance for our students and their families. Furthermore, the agency recognizes the importance of trying to understand, respect and support the student’s spiritual and / or religious beliefs, values and practices do not undermine essential care and treatment.

The agency recognizes that, as part of attempting to understand and support our students as completely as possible, it is important to assess the spiritual and / or religious beliefs, values and preferred practices, if any, of our students and the preferred practices of the student’s parent / guardian.