CHILD WELFARE

Federal Agencies Can 

Better Support State 

Efforts to Prevent and 

Respond to Sexual 

Abuse by School 

Personnel

Report to the Ranking Member, 

Committee on Education and the 

Workforce, House of Representatives

January 2014

GAO-14-42

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-42, a report to the 

Ranking Member, Committee on Education 

and the Workforce, House of Representatives

January 2014

CHILD WELFARE

Federal Agencies Can Better Support State Efforts to 

Prevent and Respond to Sexual Abuse by School 

Personnel

Why GAO Did This Study

While all child abuse is troubling, 

sexual abuse by school personnel 

raises particular concerns because of 

the trust placed in schools. Federal 

laws prohibit sexual harassment, 

including sexual abuse, in federallyfunded education programs and set 

minimum standards for state laws on 

reporting suspected child abuse. 

GAO was asked to review efforts to 

address child sexual abuse by school 

personnel. GAO examined: (1) states’

and school districts’ steps to help 

prevent such abuse, (2) their reporting 

requirements and approaches for 

investigating allegations, and (3) 

federal agencies’ efforts to address 

such abuse. GAO reviewed relevant 

federal laws, regulations, and 

guidance; surveyed state educational 

agencies in 50 states and the District 

of Columbia; and visited four states 

and six of their districts. States were 

selected based on actions taken in 

response to past allegations of abuse. 

GAO interviewed state agencies, 

school districts, local law enforcement 

and child protective service agencies, 

and experts identified through a 

systematic literature review.

What GAO Recommends

GAO recommends that Education 

collaborate with HHS and Justice to 

compile and disseminate information to 

states; identify a way to track the 

prevalence of sexual abuse; and that 

Education also clarify and disseminate 

information on how Title IX applies to 

personnel-to-student sexual abuse in 

the K-12 setting. Education and HHS 

provided technical comments and 

Education concurred with our 

recommendations. Justice had no

comments.

What GAO Found

To help prevent the sexual abuse of students in public K-12 schools, 46 of the 50 

states and the District of Columbia surveyed by GAO required background 

checks of applicants—such as teachers or bus drivers—seeking public school 

employment; however, the methods and sources varied widely. Forty-two states 

established professional standards or codes of conduct for school personnel, and 

22 of those included information on appropriate boundaries between personnel 

and students. Although experts view awareness and prevention training on 

sexual abuse and misconduct as another key prevention tool, only 18 states 

reported in the survey that they require school districts to provide this training. 

However, two of six districts GAO visited provided training to school personnel, 

volunteers, and students in response to prior allegations of sexual misconduct by 

school personnel. These trainings covered a variety of topics, including 

recognizing the signs of abuse and misconduct.

According to GAO’s survey, 46 states have laws that require school personnel to 

report child sexual abuse and designate the agency that investigates reports 

(local law enforcement and/or child protective services (CPS)), and 43 establish 

penalties for not reporting. In addition, school districts may have their own 

policies, which can sometimes create challenges. For example, three of the six 

school districts GAO visited have policies requiring suspected sexual abuse or 

misconduct to be reported to school administrators. Local investigative officials 

reported that such policies can be confusing, as they imply reports should only 

be made to school officials. This can result in a failure to report to the proper law 

enforcement or CPS authorities and interfere with investigations. For example, in 

one case study GAO reviewed, administrators pled guilty to failure to report 

suspected sexual abuse of a student by a teacher, who was later convicted of ten 

counts of abuse. Further, state and local officials told GAO that because different 

agencies can be involved with investigating reports of alleged child sexual abuse 

or misconduct for different reasons, each of the agencies’ particular goals may 

lead to potential interference with another agency’s investigation. In three of the 

four states GAO visited, law enforcement and CPS had developed methods, 

such as memorandums of understanding, to minimize this potential conflict and 

share information and expertise to resolve cases. 

Relevant programs at the Departments of Education (Education), Health and 

Human Services (HHS) and Justice (Justice) have supported state and local 

efforts to address sexual abuse by school personnel through limited training, 

guidance on boundary setting, and funding for collaboration among entities 

responding to allegations. Federal internal controls state that agencies should 

ensure there are adequate means of communicating with and obtaining 

information from external stakeholders who have a significant impact on agency 

goals. Yet, more than 30 of the states that GAO surveyed were not aware of 

available federal resources. No single agency is leading this effort, and 

coordination among federal agencies to leverage their resources and 

disseminate information to assist state and local efforts is limited. Further, the 

prevalence of this type of abuse is not known. Although several federal agencies 

collect related data, none systematically identify the extent of sexual abuse by 

school personnel, and efforts to address this data gap are limited. Finally, 

Education’s regulations under Title IX of the Education Amendments of 1972

(Title IX) require schools to have procedures in place to protect students from 

sexual abuse by school personnel. However, local officials told GAO that 

Education’s guidance was limited and they are unsure about how to apply these 

requirements to cases of adult-to-student sexual abuse in K-12 settings.

View GAO-14-42. For more information, 

contact Kay Brown at (202) 512-7215 or 

brownke@gao.gov.
Page i GAO-14-42 Child Sexual Abuse

Letter 1 

Background 5

Most States Use Background Checks and Professional Codes of 

Conduct as Prevention Efforts 15

Reporting and Investigating Often Involves Multiple Agencies As 

Well As School Districts, Which Sometimes Presents 

Challenges 26

Multiple Federal Agencies Provide Resources to Address Abuse 

by School Personnel, but Coordination and Data Are Limited 36

Conclusions 46

Recommendations for Executive Action 47

Agency Comments and Our Evaluation 48

Appendix I Objectives, Scope and Methodology 51

Appendix II Case Studies 56

Appendix III Comments from the Department of Education 62

Appendix IV GAO Contact and Staff Acknowledgements 65

Related GAO Products 66

Table

Table 1: Number of State Educational Agencies Aware of Federal

Resources to Help Prevent and Respond to Sexual Abuse 

and Sexual Misconduct by School Personnel, by Topic 43

Figures

Figure 1: Continuum of Examples of Possible Behaviors by 

Perpetrators of Child Sexual Abuse 5

Contents
Page ii GAO-14-42 Child Sexual Abuse

Figure 2: Local, State, and Federal Entities That May Be Involved 

with Addressing Cases of Child Sexual Abuse and 

Misconduct by K-12 School Personnel 7

Figure 3: Number of States Requiring Criminal Background 

Checks for Public K-12 School Employment, By Source 17

Figure 4: Number of States Requiring Awareness and Prevention 

Training on Sexual Abuse of Students by School 

Personnel, by Topic 23

Figure 5: Types, Purpose, and Selected Disciplinary Outcomes of 

Investigations, by Agency Type 31
Page iii GAO-14-42 Child Sexual Abuse

Abbreviations

BJS Bureau of Justice Statistics

CAC Child Advocacy Center

CAPTA Child Abuse Prevention and Treatment Act

CDC Centers for Disease Control and Prevention

CJA Children’s Justice Act

CPS child protective services 

CRDC Civil Rights Data Collection

Education Department of Education 

ESEA Elementary and Secondary Education Act of 1965

FBI Federal Bureau of Investigation

HHS Department of Health and Human Services 

Justice Department of Justice 

NASDTEC National Association of State Directors of Teacher 

 Education and Certification 

NCANDS National Child Abuse and Neglect Data System

NCES National Center for Education Statistics

NCVS National Crime Victimization Survey

OCAN Office on Child Abuse and Neglect

OCR Office for Civil Rights

OJJDP Office of Juvenile Justice and Delinquency Prevention

OSHS Office of Safe and Healthy Students

SSOCS School Survey on Crime and Safety

Title IX Title IX of the Education Amendments of 1972

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-14-42 Child Sexual Abuse

441 G St. N.W.

Washington, DC 20548

January 27, 2014

The Honorable George Miller

Ranking Member

Committee on Education and the Workforce

House of Representatives

Dear Mr. Miller:

Over the last decade, a number of media reports were made across the 

country about sexual abuse1 of students by public K-12 school personnel. 

A report prepared for the U.S. Department of Education in 2004 stated 

that nearly 9.6 percent of students are victims of sexual abuse by school 

personnel2

—such as teachers, principals, coaches, and school bus 

drivers—sometime during their school career.3

 

1

Definitions of sexual abuse may vary from state to state. For example, sexual abuse may 

be defined in general terms or by specifying various acts as sexual abuse, such as rape, 

molestation, or sexual assault. For purposes of this report, we consider sexual abuse to 

include any sexual activity involving a child that is a crime under applicable state law. 

However, the prevalence 

of sexual abuse by school personnel remains unknown, in part, because 

some cases go unreported. Further, the term sexual abuse may not 

capture the full spectrum of the issue. While child sexual abuse typically 

refers to the criminal act of forcing a child to engage in sexual activity with 

the perpetrator, other inappropriate behaviors with children may 

eventually lead to sexual abuse. For example, while not generally 

criminal, behaviors often referred to as “grooming” may be carried out by 

the perpetrator with the aim of establishing trust to facilitate future sexual 

2

For the purposes of this review, school personnel includes a wide variety of positions 

including, but not limited to, school district administrators, principals, teachers, 

paraprofessionals, school nurses, coaches, guidance counselors, school psychologists, 

school cafeteria staff, janitors, and school bus drivers. 

3

Shakeshaft, C, Educator Sexual Misconduct: A Synthesis of the Literature, U.S. 

Department of Education, 2004. The estimate provided in the report is the most recent 

information available on the prevalence of such abuse and misconduct and is based on 

secondary analysis of data collected for the American Association of University Women in 

Fall 2000 from a sample of 8th through 11th grade students in 80,000 schools and focused 

on experiences that occurred in school.
 

Page 2 GAO-14-42 Child Sexual Abuse

activity with the child. These behaviors could lead to sexual misconduct,4

Sexual abuse of students by school personnel raises particular concerns 

because of the trust and responsibility placed with schools to ensure a 

safe and productive learning environment. As research has shown, child 

sexual abuse often has significant detrimental consequences on 

children’s physical, psychological, academic, and behavioral 

development.

including unwelcome or sexual advances, requests for sexual favors, and 

other verbal, nonverbal, or physical conduct of a sexual nature. Further, 

the growing use of technology and social media as a new and convenient 

way for adults and students to interact may pose questions about what 

interactions between school personnel and students are considered 

appropriate. Early signs of inappropriate behavior with a child can be the 

key to identifying and preventing the criminal act of sexual abuse.

5 States have the primary role in ensuring the safety of their 

citizens. While federal law establishes minimum standards for state 

mandatory reporting laws regarding known or suspected child abuse,6

 

4

Definitions of sexual misconduct may also vary by state and may include a variety of 

behaviors. For example, sexual misconduct could include any verbal or physical activity 

directed toward a child that is sexual in nature and designed to establish a romantic or 

sexual relationship with the child. Sexual misconduct may eventually lead to sexual abuse, 

but may not be considered a criminal act in and of itself, although it may be considered a 

violation of other laws, regulations, or professional codes of conduct. Although we 

primarily use the terms sexual abuse and misconduct in this report, we occasionally may 

use alternative terms that encompass related issues, such as child maltreatment or sexual 

violence.

states primarily define their own requirements for preventing, reporting, 

and investigating child abuse and neglect, including child sexual abuse. 

Variations across state laws may include who is considered a caretaker, 

who is mandated to report suspected abuse, what must be reported, and 

to which agency reports should be directed. Further, school districts 

within a state (sometimes hundreds per state) can establish policies and 

procedures that go beyond state requirements. In addition, efforts to 

prevent and respond to child sexual abuse by school personnel may 

involve various agencies, such as education, child welfare, and criminal 

5

Robert J. Shoop, Sexual Exploitation in Schools: How to Spot It and Stop It (2004). 

6

As a condition of receiving federal funding under the Child Abuse Prevention and 

Treatment Act (CAPTA), as amended, states must comply with certain requirements, 

including establishing a state mandatory reporting law. 42 U.S.C. § 5106a(b)(2).
 

Page 3 GAO-14-42 Child Sexual Abuse

justice,7

1. What steps have states and school districts taken to help prevent 

child sexual abuse by school personnel?

whose roles and missions differ. You asked us to review how 

states, school districts, and the federal government address child sexual

abuse by public K-12 school personnel. Our review addresses the 

following questions:

2. What are states’ and school districts’ reporting requirements and 

approaches to investigating allegations of child sexual abuse by 

school personnel?

3. To what extent have federal agencies made efforts to prevent and 

respond to child sexual abuse by school personnel?

To perform this work, we used a number of approaches to help identify 

the steps states, public school districts, and federal agencies have taken 

to prevent, identify, report, and respond to sexual abuse by public K-12 

school personnel against students. To understand the role different levels 

of government play in addressing these issues, we reviewed relevant 

federal laws, regulations, and policies; interviewed officials from a range 

of federal agencies and organizations including the Departments of 

Education (Education), Health and Human Services (HHS), and Justice 

(Justice); and reviewed relevant federal agency documents and existing 

data sources on child sexual abuse. We also interviewed subject matter 

experts whom we identified through a systematic review of available 

literature on the topic. Such experts included officials from a range of 

relevant organizations, including education and child advocacy groups.

To gather a national overview of states’ requirements for identifying, 

reporting, and investigating suspected cases of sexual abuse of students 

by school personnel, we fielded a survey of state educational agencies in 

all 50 states and the District of Columbia from May 7 through July 25, 

2013. All 50 states and the District of Columbia completed the survey. 

Survey responses reflect the status of states’ requirements at the time of 

survey completion. The survey included questions on state laws and 

 

7

For the purposes of this report, child welfare refers to all types of child welfare agencies 

and includes state and local child protective service agencies, which specifically address 

child abuse and neglect. Similarly, criminal justice refers to all types of criminal justice 

entities and includes law enforcement agencies, attorneys general offices, district 

attorneys’ offices, and the courts.
 

Page 4 GAO-14-42 Child Sexual Abuse

regulations, training, codes of conduct, monitoring, guidance, and federal 

assistance. We also sent one follow-up question to survey respondents 

regarding background checks of contract employees at public K-12 

schools, which received a response rate of 94 percent.

We also visited four states—Georgia, Massachusetts, Virginia, and 

Washington—to gather additional information from public school districts, 

as well as those who investigate cases of sexual abuse and misconduct 

by school personnel, such as officials from state and local educational 

and child protective service agencies, local police departments and 

prosecutor offices, and relevant child advocacy organizations. We 

selected states that had developed laws or regulations to address 

prevention, detection, reporting, and/or investigation of child sexual abuse 

specifically by school personnel. We selected a total of six school districts 

based on information about policies and training to address such issues, 

as well as expert recommendations and the proximity of the school district 

to other offices within each state we visited. We spoke with school 

superintendents, attorneys that represent schools, human resources 

personnel, school counselors, and school safety officials, when available. 

We reviewed policies, training materials, and other relevant 

documentation and observed one school district’s training session on the 

subject. The results of the site visits are not generalizable to all public 

school districts, state educational and child welfare agencies, local police 

departments and prosecutor offices, or relevant child advocacy 

organizations.

Finally, GAO’s investigative staff reviewed closed criminal cases, 

identified through media and legal database searches, to illustrate the 

complexities of these cases and how incidents of sexual abuse are 

identified, reported, and investigated. We selected cases to achieve 

variation among these criteria: gender of perpetrator and victim, age of 

child(ren), whether there were multiple victims of the same perpetrator, 

and the position of the perpetrator in the school (teacher, school 

administrators, bus driver, janitor, etc.). Our investigators reviewed five

cases that were determined to be closed, with no pending litigation. The 

case study reviews involved travel to several states and interviews with 

agencies and individuals involved in each case as well as case file 

reviews. Case studies were conducted from May through July 2013. See 

appendix II for summaries of the case studies.

We conducted this performance audit from October 2012 to January 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 
 

Page 5 GAO-14-42 Child Sexual Abuse

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on the audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Our investigative activities 

were conducted in accordance with standards prescribed by the Council 

of the Inspectors General for Integrity and Efficiency.

While child sexual abuse—the act of forcing a child to engage in sexual 

activity with a perpetrator—is generally criminal in nature, perpetrators of 

such abuse typically exhibit other inappropriate, and sometimes 

noncriminal, behaviors. These behaviors of perpetrators may be 

displayed on a continuum and may include grooming, sexual misconduct 

and child sexual abuse. See figure 1. 

Figure 1: Continuum of Examples of Possible Behaviors by Perpetrators of Child 

Sexual Abuse

Note: Definitions of sexual abuse and sexual misconduct may vary from state to state. For example, 

sexual abuse may be defined in general terms or by specifying various acts as sexual abuse. For 

purposes of this report, sexual abuse includes any sexual activity involving a child that is a crime 

under applicable state law. Definitions of sexual misconduct may also vary by state and include a 

variety of behaviors. For example, sexual misconduct could include any verbal or physical activity 

directed toward a child that is sexual in nature and designed to establish a romantic or sexual 

relationship with the child. Grooming behaviors are part of a pattern of behavior and are done with the 

intent to perpetrate future sexual abuse or misconduct, but the same behaviors may also be done 

without such intent.

Background

Behaviors of Perpetrators 

of Child Sexual Abuse
 

Page 6 GAO-14-42 Child Sexual Abuse

State and local agencies in the education, child welfare, and criminal 

justice systems lead the efforts to prevent, detect, and respond to cases 

of sexual abuse of and misconduct toward students by public K-12 school 

personnel. In accordance with their distinct missions and roles, each type 

of agency plays a part in ensuring the safety and protection of children. 

Three federal agencies with corresponding missions support state and 

local efforts: Education, HHS, and Justice (see figure 2).

Entities Involved in 

Addressing Cases of Child 

Sexual Abuse and 

Misconduct by School 

Personnel
 

Page 7 GAO-14-42 Child Sexual Abuse

Figure 2: Local, State, and Federal Entities That May Be Involved with Addressing Cases of Child Sexual Abuse and 

Misconduct by K-12 School Personnel

Notes:

The concentric circles in the figure are solely intended to illustrate the different levels of government, 

not the relationship between these levels.
 

Page 8 GAO-14-42 Child Sexual Abuse

For this review, while we generally found that state and federal criminal justice entities had limited 

involvement with cases of child sexual abuse and misconduct by school personnel, it is possible that 

state attorneys general offices, state and federal courts, and state and federal law enforcement 

entities may be involved with such cases.

a

State offices of professional licensure, which may be located within or separate from state 

educational agencies, are often involved with cases of child sexual abuse and misconduct by school 

personnel.

Education’s Office for Civil Rights (OCR) enforces Title IX of the 

Education Amendments of 1972 (Title IX), which prohibits sex 

discrimination, including sexual harassment, in federally-funded education 

programs and activities.8 According to Education’s guidance, sexual 

abuse of students and sexual misconduct by school personnel are 

included in the broad set of behaviors prohibited under Title IX.9

All public and private education institutions that receive federal funds 

must comply with Title IX. OCR’s regulations establish procedural 

requirements for the prevention or correction of sex discrimination, 

including sexual harassment. These requirements include issuance of a 

policy against sex discrimination and adoption and publication of 

grievance procedures providing for prompt and equitable resolution of 

complaints of sex discrimination. The regulations also require schools 

receiving federal funds for education programs or activities to designate 

at least one employee to coordinate Title IX compliance, commonly 

known as a Title IX coordinator, whose responsibilities include the 

Although 

Title IX is not a criminal statute, the behaviors prohibited by Title IX may 

be criminal or noncriminal in nature, depending on state or federal law. 

 

8

Pub. L. No. 92-318, tit. IX, 86 Stat. 235, 373-75 (codified as amended at 20 U.S.C. §§ 

1681-88). See also 34 C.F.R. pt. 106. Title IX generally provides that “[n]o person ... shall, 

on the basis of sex, be excluded from participation in, be denied the benefits of, or be 

subjected to discrimination under any education program or activity receiving Federal 

financial assistance.” The Supreme Court has held that sex discrimination includes sexual 

harassment. See Franklin v. Gwinnett County Pub. Sch., 503 U.S. 60, 75 (1992) (citing 

Meritor Sav. Bank v. Vinson, 477 U.S. 57, 64 (1986)). Each federal agency that provides 

financial assistance is responsible for enforcing Title IX.

9

Education’s definition of sexual harassment prohibited under Title IX includes unwelcome

conduct of a sexual nature that is sufficiently serious as to deny or limit a student’s ability 

to participate in or benefit from a school’s education program or activity. It may be 

committed by other students, school employees or non-employee third parties. See OCR, 

Revised Sexual Harassment Guidance: Harassment of Students by School Employees, 

Other Students, or Third Parties (Washington D.C.: January 2001). For the purposes of 

this review, we focused on cases involving school personnel-to-student sexual abuse or 

misconduct in the K-12 setting. 

K-12 Education
 

Page 9 GAO-14-42 Child Sexual Abuse

coordination of investigations of complaints alleging noncompliance.

10

OCR is responsible for enforcing schools’ compliance with Title IX, and if 

it finds a school has violated Title IX as the result of sexual abuse or 

sexual misconduct by school personnel, it will require the school to take 

appropriate remedial steps.11

Education’s Office of Safe and Healthy Students (OSHS) administers, 

coordinates, and recommends policy for improving programs and 

activities that are designed to provide financial assistance for drug and 

violence prevention activities, among other things.12 Specifically, under 

the Safe and Drug-Free Schools and Communities Act—Title IV, Part A of 

the Elementary and Secondary Education Act of 1965, as amended—

OSHS administers several types of programs, including grants to public 

K-12 school districts for a broad range of violence prevention activities.13

Education’s National Center for Education Statistics (NCES) is tasked 

with collecting, acquiring, compiling and disseminating full and complete 

statistics on the condition and progress of education at the elementary 

While the statute does not specifically identify who may be considered 

perpetrators of violence for purposes of Title IV grant programs, 

according to OSHS officials, the funded projects have primarily focused 

on peer-to-peer violence.

 

1034 C.F.R. §§ 106.8 – 106.9.

1134 C.F.R. § 106.3(a). According to OCR guidance, in determining whether a school has 

violated Title IX, OCR will consider whether a school is in compliance with the regulations, 

whether it appropriately investigated and responded to allegations of sexual harassment, 

and whether it has taken corrective action to end the harassment, prevent its recurrence, 

and, as appropriate, remedy its effects. OCR is required to make schools aware of 

potential Title IX violations and to seek voluntary corrective action. If OCR is unable to 

negotiate a settlement with the school, OCR may initiate an enforcement action to 

suspend or terminate federal financial assistance, or refer the case to the Department of 

Justice. See 20 U.S.C. § 1682.

12In addition to drug and violence prevention activities, OSHS administers, coordinates, 

and recommends policy for improving programs and activities that are designed to provide 

financial assistance for activities that promote the health and well-being of students and 

school preparedness activities that contribute to improved conditions for learning. For the 

purposes of this review, we focus on those OSHS grants and projects related to violence 

prevention in schools.

13Pub. L. No. 107-110, §§ 4001-4155, 115 Stat. 1425, 1734-65 (2002) (codified at 20 

U.S.C. §§ 7101-65). Awards were last made under these grants in fiscal year 2012. 

Funding was only awarded to pre-existing programs and at reduced funding levels.
 

Page 10 GAO-14-42 Child Sexual Abuse

and secondary levels, among other activities.14 NCES is required to 

collect data on the incidence, frequency, seriousness, and nature of 

violence affecting students, including information regarding the 

relationship between victims and perpetrators.15

At the state level, state educational agencies are responsible for 

complying with federal requirements, such as Title IX, and overseeing 

local school districts’ implementation of state and federal requirements. 

Some of these state agencies also play a key role in ensuring that 

professionals, including teachers and other school personnel, are 

qualified to teach in a classroom or operate a school by issuing educator 

licenses.

The School Survey on 

Crime and Safety (SSOCS), administered by NCES, is the primary source 

of school-level data on crime and safety.

16

At the local level, school districts operate local public elementary and 

secondary schools. In school year 2011 to 2012, over 49.5 million 

students were enrolled in the nation’s 98,328 public elementary and 

secondary schools.

The authority to issue educator licenses typically resides within 

state licensure offices, which may be found within or outside of the state 

educational agencies. Licensure offices establish and enforce a set of 

behaviors commonly known as a professional code of conduct and 

oversee the discipline of educational practitioners who violate such 

professional codes of conduct.

17

 

14Education Sciences Reform Act of 2002, Pub. L. No. 107-279, §§ 151-58, 116 Stat. 

1940, 1957-62 (codified as amended at 20 U.S.C. §§ 9541-48).

School districts carry out state and federal 

requirements and may have the authority to go beyond any minimum 

requirements and create their own policies regarding how schools under 

their jurisdiction operate. When an allegation of sexual abuse or 

misconduct is reported, the school district and school may conduct their 

own investigations to determine any violations of employment conditions, 

which may result in actions taken against the employee, such as 

termination of employment.

1520 U.S.C. § 9543(a)(1)(H).

16The types of positions within schools that require a state educator license vary by state. 

17P. Keaton, Selected Statistics From the Common Core of Data: School Year 2011–12, 

NCES 2013-441, U.S. Department of Education, National Center for Education Statistics

(Washington, D.C.: 2013). 
 

Page 11 GAO-14-42 Child Sexual Abuse

HHS is the principal federal agency that provides oversight of state 

implementation of federal child welfare requirements. State and local child 

welfare programs are intended, in part, to protect children who have been 

maltreated and help prevent maltreatment. HHS uses the term child 

maltreatment to include neglect and abuse—not only physical and 

emotional abuse but also sexual abuse.18 Initially enacted in 1974, the 

Child Abuse Prevention and Treatment Act (CAPTA) strengthened federal 

support for states in preventing and responding to child abuse and 

neglect, which has historically involved cases of intra-familial abuse and 

neglect.19

• a state law for mandatory reporting by individuals required to report 

known or suspected child abuse or neglect;

CAPTA, as amended, authorizes federal funding for grants to 

states to support prevention, investigation, and handling of cases of child 

maltreatment. As a condition of receiving federal grant funds under 

CAPTA, states are required to, among other things, have:

20

• procedures in place for screening and promptly investigating reports 

of known or suspected child abuse or neglect, and for ensuring 

children’s safety;21

• a state law or statewide program that includes the cooperation of state 

law enforcement officials, courts with jurisdiction, and appropriate 

state agencies providing human services in the investigation, 

assessment, prosecution and treatment of child abuse and neglect;22

• provisions that grant immunity from prosecution (under state and local 

laws and regulations) for individuals who make good faith reports of 

known or suspected child abuse or neglect.

and

23

 

18Child welfare programs aim to protect children from both abuse and neglect; however, 

neglect is generally not applicable in situations of abuse or misconduct by school 

personnel. 

19Pub. L. No. 93-247, 88 Stat. 4 (1974) (codified as amended at 42 U.S.C. § 5101 et. 

seq.). See also 45 C.F.R. pt. 1340. 

2042 U.S.C. § 5106a(b)(2)(B)(i). CAPTA does not require states to provide a penalty for 

failure to report child abuse or neglect, nor does it address where such a report is to be 

made.

2142 U.S.C. § 5106a(b)(2)(B)(iv), (v), (vi). 

2242 U.S.C. § 5106a(b)(2)(B)(xi). 

2342 U.S.C. § 5106a(b)(2)(B)(vii).

Child Welfare
 

Page 12 GAO-14-42 Child Sexual Abuse

For those states that apply for and receive Children’s Justice Act (CJA) 

grants—authorized under section 107 of CAPTA—the state must 

establish a multidisciplinary (or CJA) taskforce to improve the 

investigation and prosecution of child abuse and neglect cases.24

According to HHS, most states have policies that require cross-system 

reporting of at least some child abuse and neglect reports, across child 

protective services, law enforcement agencies, and prosecutor’s offices, 

regardless of where the initial report is made.25

CAPTA defines child abuse and neglect as “at a minimum, any recent act 

or failure to act on the part of a parent or caretaker, which results in 

death, serious physical or emotional harm, sexual abuse or exploitation, 

or an act or failure to act which presents an imminent risk of serious 

harm.”26 CAPTA defines sexual abuse to include “the employment, use, 

persuasion, inducement, enticement, or coercion of any child to engage 

in, or assist any other person to engage in, any sexually explicit conduct 

or simulation of such conduct for the purpose of producing a visual 

depiction of such conduct;” or “the rape, and in cases of caretaker or 

inter-familial relationships, statutory rape, molestation, prostitution or 

other forms of sexual exploitation of children or incest with children.”27

In their mandatory reporting laws, states may establish different 

standards for reporting child abuse or neglect and may choose whom to 

For 

purposes of compliance with CAPTA’s requirements, states’ definitions of 

“child abuse and neglect” and “sexual abuse” must be consistent with the 

definitions provided by CAPTA; however, states may also expand on 

these definitions in their state laws. For example, state law may define 

who constitutes a “caretaker” and states generally include parents, 

guardians, and day care workers, though states’ definitions of caretaker 

may vary.

 

24These grants were originally authorized by the CJA, which amended CAPTA Pub. L. No. 

99-401, tit. I, 100 Stat. 903, 903-07 (1986) (codified as amended at 42 U.S.C. § 5106c). 

Only states that are eligible for the basic state grants under CAPTA can apply for CJA 

grants. 

25U.S. Department of Health and Human Services, Children’s Bureau, Child Welfare 

Information Gateway, Cross-Reporting Among Responders to Child Abuse and Neglect 

(Washington, D.C.: 2013). 

2642 U.S.C. § 5101 note. 

2742 U.S.C. § 5106g. 
 

Page 13 GAO-14-42 Child Sexual Abuse

include in their definitions of mandatory reporter.28

The 1988 amendments to the CAPTA required HHS to establish a 

national data collection and analysis program for data on child abuse and 

neglect.

Those designated as 

mandatory reporters typically have frequent contact with children and may 

include teachers, principals, social workers, and other school personnel 

such as volunteers; physicians, nurses, and other health-care workers; 

counselors, therapists, and other mental health professionals; child care 

providers; medical examiners or coroners; and law enforcement officers.

29 HHS responded to this requirement by establishing and 

maintaining the National Child Abuse and Neglect Data System 

(NCANDS), which is a voluntary data-reporting system. Since at least 

2000, state child protective service agencies have increasingly voluntarily 

provided data on children who were maltreated to HHS for NCANDS. 

From these data, HHS conducts analysis and publishes a yearly Child 

Maltreatment report. The most recent report, for fiscal year 2011, 

presents national data about child abuse and neglect known to child 

protective service agencies in the United States. In addition, in 

accordance with CAPTA’s requirements, HHS has established a national 

information clearinghouse—the Child Welfare Information Gateway—and 

conducts research, in consultation with other federal agencies and 

experts, to provide information needed to better protect children from 

child abuse or neglect and to improve the well-being of victims.30

The Office on Child Abuse and Neglect (OCAN), a division of the 

Children’s Bureau within HHS’ Administration for Children and Families, 

helps states meet federal CAPTA requirements and takes the federal lead 

in educating states and communities about how to prevent and respond 

to child abuse and neglect. HHS also provides training and technical 

assistance to child welfare systems at the state and local levels through 

 

28According to HHS, as of August 2012, New Jersey and Wyoming were the only two 

states that had not enumerated specific professional groups as mandatory reporters, but 

required all persons to report. Department of Health and Human Services, Children’s 

Bureau, Child Welfare Information Gateway, Mandatory Reporters of Child Abuse and 

Neglect, (Washington, D.C.: June 2012).

29Child Abuse Prevention, Adoption, and Family Services Act of 1988, Pub. L. No. 100-

294, sec. 101, § 6(b)(1), 102 Stat. 102, 107.

30See 42 U.S.C. §§ 5104, 5105(a).
 

Page 14 GAO-14-42 Child Sexual Abuse

the Children’s Bureau, its regional offices, and various National Resource 

Centers.31

Another office within HHS that focuses on the prevention of violence is 

the Centers for Disease Control and Prevention’s (CDC) Division of 

Violence Prevention. The CDC views child maltreatment as a serious 

public health problem with extensive short- and long-term health 

consequences, and seeks to stop the abuse before it occurs. The mission 

of CDC’s child maltreatment prevention program is to prevent 

maltreatment and its consequences through surveillance, research and 

development, capacity building, communication, and leadership. These 

priorities guide the agency’s approach to child maltreatment, which is 

through the promotion of safe, stable, and nurturing relationships and 

environments between children and their caregivers.

State child protective service agencies track allegations of child sexual 

abuse and provide support to their local offices, policy guidance and 

clarification, staff training, and case monitoring services. Local child 

protective service (CPS) agencies investigate reports of suspected child 

abuse, including child sexual abuse. Local CPS agencies also refer cases 

to law enforcement agencies or district attorneys for criminal investigation 

and prosecution.

Justice—the primary federal criminal investigation and enforcement 

agency—also administers grants and collects data on criminal activity.32

Its Office of Juvenile Justice and Delinquency Prevention (OJJDP) is 

responsible for providing national leadership, coordination, and resources 

to prevent and respond to juvenile delinquency and victimization.33

 

31HHS’ National Resource Centers provide technical assistance in specific focus areas 

with the goal of helping agencies, managers, family and juvenile courts, and other child 

welfare professionals better serve children and families.

OJJDP supports states and communities in their efforts to develop and 

implement effective and coordinated prevention and intervention 

32Justice plays a more involved role when activities involving a student could constitute a 

federal crime, such as when mail or the Internet is used to sexually abuse children. Such 

crimes were outside of the scope of this review.

33OJJDP administers grants and other activities under the Juvenile Justice and 

Delinquency Prevention Act of 1974, as amended, Pub. L. No. 93-415, 88 Stat. 1109 

(codified as amended at 42 U.S.C. § 5601 et seq.). 

Criminal Justice
 

Page 15 GAO-14-42 Child Sexual Abuse

programs and to improve the juvenile justice system so that it protects 

public safety, holds offenders accountable, and provides treatment and 

rehabilitative services tailored to the needs of juveniles and their families. 

OJJDP administers projects, programs, and initiatives related to crimes 

against children and children’s exposure to violence. It provides 

leadership and funding in the areas of prevention, intervention, treatment, 

and enforcement.

To better understand crime victimization, the Bureau of Justice Statistics 

(BJS) conducts the National Crime Victimization Survey (NCVS), the 

nation’s primary source of such information. Each year, data are obtained 

from a nationally representative sample of about 40,000 households to 

capture information about the frequency, characteristics, and 

consequences of criminal victimization in the United States. The survey 

consists of interviewing victims (including children ages 12 through 18) 

about exposure to crime, and enables BJS to estimate the likelihood of 

victimization by rape and sexual assault, among other crimes, for the 

population as a whole as well as for segments of the population. The 

NCVS provides the largest national forum for victims to describe the 

impact of crime and characteristics of violent offenders.

At the local level, law enforcement agencies and district attorneys are 

responsible for investigating and prosecuting cases of child sexual abuse 

by school personnel regardless of whether the case was referred to them 

by CPS or some other source. Law enforcement agencies and district 

attorneys generally decide if a case warrants action on their part, based 

on the facts and circumstances of each case.

Most States Use 

Background Checks 

and Professional 

Codes of Conduct as 

Prevention Efforts
 

Page 16 GAO-14-42 Child Sexual Abuse

Background checks were the primary tool states used to prevent sexual 

abuse and misconduct by school personnel, according to our survey. 

Experts on child sexual abuse we spoke with recommend that schools 

and districts incorporate background checks—typically used to screen for 

criminal or other relevant histories of applicants—into the hiring process

as part of their efforts to help protect the safety of children in school. 

Forty-six states reported in our survey that they required background 

checks for applicants seeking employment in a public K-12 school, 

regardless of whether the position was as a school principal, teacher, or 

secretary, for example. However, the methods and sources used to 

conduct background checks for school personnel varied widely, and 

included matching an applicant’s name and date of birth, Social Security 

number, or fingerprints to state or federal criminal databases, or child 

abuse and neglect registries. According to our survey, 36 states relied on 

both state and federal sources of criminal data—such as a state law 

enforcement database or the Federal Bureau of Investigation’s Interstate 

Identification Index34

 

34The Federal Bureau of Investigation’s Interstate Identification Index is an automated 

information system used to exchange criminal history records and related information 

between federal, state, and local criminal justice agencies, for this purpose. The index 

includes arrest and conviction information voluntarily reported by federal, state, and local 

agencies. Other federal sources include Justice’s national sex offender public registry, 

which is a publicly available web-based tool that can be used to search for sex offenders 

by name and/or location. See 

—to gather information on applicants (see Figure 3).

http://www.nsopw.gov/en-US/Home/About. The national sex 

offender public registry is a cooperative effort between state agencies that host public sex 

offender registries and the federal government. The website is operated by Justice.

Most States Rely on 

Background Checks to 

Screen Applicants for 

Positions in Public K-12 

Schools but Concerns 

over Completeness and 

Accuracy Exist
 

Page 17 GAO-14-42 Child Sexual Abuse

Figure 3: Number of States Requiring Criminal Background Checks for Public K-12 

School Employment, By Source

a

In addition, nearly half of all states (25) reported consulting the National 

Association of State Directors of Teacher Education and Certification 

(NASDTEC) clearinghouse—a database of information voluntarily 

reported by states on teachers who have lost teaching certificates due to 

abuse or misconduct, according to a NASDTEC official.

Of the 46 states requiring background checks for applicants seeking employment in public K-12 

schools, regardless of position, 45 identified the use of either state and/or federal law enforcement 

data sources when conducting background checks; one state did not indicate the sources used for 

obtaining background information on applicants.

35

In addition to screening public school job applicants, some states required 

background checks of other adults who may interact with students in 

public K-12 schools. For example, according to our survey, 17 states 

required background checks for school volunteers. In addition, 36 states 

required background checks for contract employees working in public K12 schools, often under certain conditions, such as those who may have 

direct or unsupervised contact with students, or for certain positions, such 

 

35According to NASDTEC, the clearinghouse contains information about teacher 

education and certified personnel in all 50 states, U.S. territories, and the Canadian 

provinces.
 

Page 18 GAO-14-42 Child Sexual Abuse

as cafeteria, transportation, janitorial, or maintenance workers. According 

to our survey, 12 states did not require background checks for contract 

employees working in public K-12 schools.

Some school districts we visited established their own policies for

background checks to help safeguard children in their schools. For 

example, in one district, volunteer applicants must complete a disclosure 

form that asks about prior convictions and abuses and undergo a 

background check before serving as a volunteer, even though the state,

according to our survey, does not require background checks for 

volunteers in its public K-12 schools.36

State and local education officials and industry experts, however, have 

identified limitations to background checks that raise questions about the 

sufficiency of the checks alone to help protect students. In our previous 

work, we noted that criminal history checks on school employees may not 

be adequate when they are not national, fingerprint-based, or recurring.

Another school district developed 

a system to conduct background checks for school volunteers and 

contractors based on their level of contact with students, according to 

officials. Because background checks are costly, only those volunteers 

who may have time alone with children, such as a chaperone on an 

overnight trip, undergo a full state and federal criminal history background 

check, which includes nationwide data on federal and state criminal 

arrests and convictions.

37

• Education officials in one state told us that whether a sex offender is 

included in the state’s public sex offender registry depends upon the 

local court system, and not all offenders will be identified through such 

a search.

Several education, criminal justice, and other officials also raised 

concerns over the completeness of the data available through 

background checks. For example,

• Officials in two states cited their inability to access relevant data 

across states, such as another state’s child abuse and neglect 

 

36According to policy in this district, active volunteers are required to have a background 

check at least every 2 years.

37GAO, K-12 Education: Selected Cases of Public and Private Schools That Hired or 

Retained Individuals with Histories of Sexual Misconduct, GAO-11-200 (Washington, D.C.: 

Dec. 8, 2010).
 

Page 19 GAO-14-42 Child Sexual Abuse

registry, which is problematic when applicants come from other 

locations.

• Aside from checks of criminal data, a NASDTEC official told us that 

states do not uniformly report information on educators who have 

been disciplined to the NASDTEC clearinghouse. State educational 

officials in each of the four states we visited also said they have 

identified missing, incomplete, or incorrect data in the database.

• An assistant district attorney expressed concern that federal law 

enforcement databases only capture information on predators who

have been caught and charged with crimes—a fraction of all sexual 

predators who perpetrate abuses against children.

• Representatives from a risk management company told us few 

offenders are caught the first time they abuse, and sex offenders often 

have many victims before they are caught.

Case Study: Background Checks Do Not Pick Up What Is Not Reported

A male second grade teacher was convicted of aggravated criminal sexual abuse and 

sentenced to 60 years in prison for sexually abusing 10 female students in two different 

school districts, despite undergoing a background check which included a criminal 

history check, reference check, and a review of his teaching experience. At the first 

school district at which he taught, the teacher had been disciplined for downloading 

pornography onto his work computer. He was also disciplined at the same school and 

not rehired after a parent filed a complaint alleging that the teacher told a student that 

she reminded him of a female movie star, gave the student pictures of that star, 

repeatedly stared at the student and touched her unnecessarily on several occasions, 

though not in any inappropriate areas. When he left the school, he received a positive 

recommendation, and neither of the alleged incidents was relayed to his new employer. 

The teacher’s suspicious behavior was brought to the attention of officials when a 

mother at the second school learned from her daughter about activities occurring during 

her after-school program that suggested the possibility of sexual abuse. The teacher 

was later convicted of aggravated criminal sexual abuse of eight girls at the second 

school and two girls at the first school. According to school district officials, the second 

school district that hired him has implemented additional steps to help protect student 

safety, such as additional reference checks, including sources independently identified.

In addition to concerns over completeness of the data, officials 

representing state education and employee groups have questioned the 

accuracy of data available for background checks. For example, officials 

from one state educational agency told us that because their state’s 

public sex offender registry is searchable by name and not Social 

Security number, confusion can arise when searching for common 

names. In addition, representatives of a teacher’s union expressed 
 

Page 20 GAO-14-42 Child Sexual Abuse

concern over possible mistaken identities or other errors associated with 

background checks.38

Professional standards or codes of conduct serve as another tool that 42 

states reported using as part of their efforts to try to prevent sexual abuse 

and misconduct by school personnel. According to experts, policies that 

identify acceptable and unacceptable behavior for school personnel—

such as being behind closed doors with a student—can help staff, 

students, and parents determine when violations of the rules have 

occurred. Such policies can help to identify questionable behavior that 

should be reported and communicate to school personnel the potential 

consequences of violating the rules, such as termination of employment, 

which may also deter potential abuse, according to experts. Thirty-four of 

the 42 states with professional standards or codes of conduct reported 

that they apply only to licensed professionals, such as teachers and 

school principals, rather than to all school personnel.39

 

38The National Employment Law Project, a non-profit advocacy organization in support of 

low-wage and unemployed workers, recently released a report which cites inaccuracies 

and missing critical information in background checks conducted by the FBI. According to 

the report, because states do not routinely update information following initial arrests to 

the FBI, such records often lack final disposition information, such as updated information 

on charges that have been dismissed. Consequently, applicants may be denied 

employment based on unsubstantiated and erroneous charges. Madeline Neighly and 

Maurice Emsellem, Wanted: Accurate FBI Background Checks for Employment (National 

Employment Law Project, July 2013). 

Twenty-two states 

reported that their standards or codes of conduct help define boundaries 

between school personnel and students through examples of appropriate 

and inappropriate behavior, including the use of technology such as cell 

phones and social media such as Facebook. During our site visits, we 

identified some states that developed educator codes of conduct, or 

similar policies, that identify examples of unethical or unprofessional 

conduct with students and that, if violated, are grounds for disciplinary 

action. For example, one state’s policy guidance requires contact 

between school personnel and students to always be nonsexual, 

appropriate to the circumstances, and unambiguous in meaning. 

According to this policy guidance, acts such as unnecessarily invading a 

student’s personal privacy and singling out a particular student or group 

39License requirements may vary from state to state. School personnel that generally do 

not hold professional licenses from the state educational agency or state licensing agency

include, for example, janitors, and school bus drivers.

A Majority of States Have 

Established Professional 

Codes of Conduct for 

Licensed School 

Personnel as a Tool to 

Hold Them Accountable 

for their Behavior
 

Page 21 GAO-14-42 Child Sexual Abuse

of students for personal attention and friendship beyond the bounds of an 

appropriate educator/mentor-student relationship constitute violations of 

these boundaries and may result in formal disciplinary action.

According to our survey, 15 states address behavior commonly referred 

to as grooming—behavior intended to establish trust with a student to 

facilitate future sexual activity—in their standards or codes of conduct. 

According to experts we spoke with, some perpetrators of child sexual 

abuse groom potential victims by devoting a significant amount of time 

and attention interacting with them one-on-one. Although such 

interactions taken individually may not be problematic, a pattern of such 

behavior—such as a teacher repeatedly driving a student home alone—

could indicate a possible problem. Officials in one school district we 

visited explained that perpetrators of child sexual abuse sometimes also 

groom other individuals—such as members of the child’s family—to gain 

their trust, in the hope that these individuals will not view certain behavior 

as inappropriate. For example, school district officials told us of a case 

where an alleged perpetrator bought a house for a family as a means to 

maintain contact with young children and foster a sense of dependency. 

While experts suggest that grooming behavior can be difficult to identify, 

identifying and addressing violations of boundaries or rules by school 

personnel as they occur may help prevent future abuse.

Case Study: “Grooming” the Victims

A male middle school teacher was arrested, charged with, and pled guilty to seven 

counts of indecent liberties with a child and indecent liberties with a student, and 

sentenced to 18-22 months in prison for each count, consecutively, for inappropriate acts 

with multiple female students. The school principal reported to law enforcement that the 

teacher was acting inappropriately with female students. A law enforcement investigation 

found that the male teacher had engaged in “grooming” behavior with multiple students, 

including taking them out to dinner in groups as well as in one-on-one situations and 

buying them gifts, such as a necklace, computer, cell phone, and camera. In addition, 

through the course of the investigation, instances of touching and kissing between the 

teacher and some of the students were revealed. A forensic examination of his computer 

also revealed pornographic images that appeared to be edited to depict the faces of 

some of his students on someone else’s body.

Officials in some school districts we visited spoke to us of challenges 

arising from applying seemingly black-and-white sexual abuse prevention 

policies to the real-life school environment. For example, while employees 

at one school district are generally prohibited from transporting students 
 

Page 22 GAO-14-42 Child Sexual Abuse

in their personal vehicles,40 school district officials expressed concern that 

a teacher may feel obliged to do so upon learning that a student does not 

have a ride home after a tutoring session. In an example from another 

school district, officials said that rules about social media—such as 

prohibiting teachers and students from being Facebook friends—are not 

feasible; some teachers use this forum as a way to share educational 

interests or to quickly share messages about school event cancellations. 

What is important, instead, is transparency in communication, according 

to officials. Similarly, officials in another district explained that it is the 

conduct and behavior of school personnel that should be closely 

evaluated, not the means of communication. In developing local policies, 

school district officials suggested that it is important for districts to be able 

to tailor policies to meet their individual needs. For example, officials from 

one school district we visited said that state guidance with overly 

prescriptive rules on the behavior of school personnel is impractical, and 

that certain factors, such as the age levels of the students and student 

demographics, among other things, should be considered.

We found that most states do not require awareness and prevention 

training, although according to experts, high quality training on the 

prevention of child sexual abuse by school personnel is critical to help 

school officials identify early warning signs of abuse and know how to 

respond when questionable behavior is suspected. Ideally, experts 

recommend that school personnel, parents, and students receive some 

type of training as part of school’s efforts to prevent child sexual abuse. 

According to our survey, 18 states required school districts to provide 

awareness and prevention training on sexual abuse or misconduct by 

school personnel against students. At least 15 of the 18 states required 

school district superintendents, school administrators, counselors, 

psychologists, and teachers to attend this training; however, fewer than 

half of the 18 states required Title IX coordinators, cafeteria and janitorial 

personnel, and bus drivers to take the training. Ten states required 

coaches to attend sexual abuse training while eleven states require 

training for sexual misconduct. Aside from school staff, three states 

required students to attend awareness and prevention training and one 

 

40The policy in this school district states that on a case-by-case basis, administrators may 

make exceptions to this requirement in the event of emergencies or unusual 

circumstances. 

While Most States Do Not 

Require It, Some School 

Districts We Visited 

Provide Sexual Abuse 

Prevention Training to 

School Personnel, 

Volunteers, and Students
 

Page 23 GAO-14-42 Child Sexual Abuse

state required it for school volunteers, such as tutors. No states reported 

requiring districts to offer training for parents.

Regarding training content, states most frequently required school district 

awareness and prevention training on sexual abuse to cover topics 

related to mandatory reporting requirements (see fig. 4).41

Figure 4: Number of States Requiring Awareness and Prevention Training on Sexual Abuse of Students by School Personnel, 

by Topic

An expert from 

a risk management firm we spoke with told us that training on mandatory 

reporting requirements, such as who is considered a mandatory reporter 

and to whom reports should be made, generally does not adequately 

focus on preventing child sexual abuse in the first place.

Experts told us that prevention training should include information on 

appropriate and inappropriate behavior by school personnel and on the 

grooming process, so that patterns of behavior may be more closely 

monitored and evaluated. Because of this, a number of experts also 

recommend training that is scenario-based, to give participants the 

opportunity to practice responses. In addition, some experts suggest that 

 

41Our survey did not directly assess whether or to what extent states provided training on 

mandatory reporting requirements to school personnel.
 

Page 24 GAO-14-42 Child Sexual Abuse

training be provided to all staff—such as bus drivers and cafeteria 

personnel—in addition to teachers and school administrators. According 

to one expert, for training to be effective, it should also be given to 

parents—who may be among the first to notice warning signs—as well as 

students, in an age-appropriate manner. For example, age-appropriate 

training for young students may include information on expectations of 

privacy, whereas older students may learn about unhealthy relationships 

and setting appropriate boundaries. Some experts suggest that 

combining prevention training with other safety measures, such as 

background checks and code of conduct policies, helps school districts 

reduce their vulnerability to potential perpetrators of child sexual abuse. 

Additionally, according to a risk management expert, the offer of lower 

insurance rates by insurance companies may provide an additional 

incentive for school districts to implement multiple risk management 

strategies to protect against sexual abuse by school personnel.

Some school districts we visited developed training aimed at preventing 

child sexual abuse by school personnel for a range of personnel, 

volunteers, and students, as recommended by experts, and delivered the 

training in-person and online. For example, in response to prior 

allegations of child sexual abuse by a teacher, according to officials, one 

district developed in-person training modules designed for executive-level 

managers such as school superintendents, staff, volunteers, and 

students.42 Officials in another district said the district recently developed 

an online, interactive training course on preventing adult sexual 

misconduct with students that will be required for all staff, including bus 

drivers and cafeteria workers, volunteers and student mentors.43

 

42According to officials, the district requires training for all staff who interact with students, 

including athletic coaches. In addition, the student training module is video-based and 

intended as a training component for 9th grade health courses. 

In 

addition to including examples of appropriate and inappropriate behavior 

in their training, these school districts also include scenarios depicting 

questionable interactions between school personnel and students. For 

example, officials said their district’s online training course includes 

scenarios of ‘gray area’ behaviors—such as a teacher being alone in a 

room with a student—where the level of appropriateness depends on the 

context of the situation and the age of the student. A few school districts 

43According to school district officials, in order to be licensed by that state, teachers 

currently must complete an online training module on their responsibilities as mandatory 

reporters of suspected child abuse and neglect and certify the course’s completion. 
 

Page 25 GAO-14-42 Child Sexual Abuse

also assessed training participants on their understanding of the material 

presented. For example, one district requires all employees to 

demonstrate a minimum competence of at least 80 percent on an 

assessment of a sexual harassment compliance video, which, according 

to officials, includes information on employee-student relationships.

Officials in several school districts cited time and cost constraints to 

providing training on the prevention of child sexual abuse by school 

personnel. Officials said it can be difficult for teachers to attend this 

training, as well as other required training, in the limited time allotted for 

their professional development. In addition, some officials said the cost of 

hiring substitute teachers to take the place of teachers in training, and 

training materials, if developed by another organization, can be cost 

prohibitive. To help increase the accessibility of training to wider 

audiences and lower costs, experts we spoke with have suggested online 

training and train-the-trainer approaches—in which school district 

administrators or other representatives receive the training and then pass 

the information on to school personnel in their local districts.

Case Study: Training is Not Always Enough

Behavior by school personnel that is not criminal may nevertheless be inappropriate. A 

female high school teacher and coach was found to have engaged in an ongoing sexual 

relationship with a female 16-year old student. The teacher’s conviction of sexual assault 

was later overturned because the student had reached the age of consent at the time of 

the sexual relationship. According to district officials, the teacher would have received 

annual training that identified standards of conduct for educators, including what 

constitutes inappropriate behavior between school personnel and students. Since this 

case, the state has changed its law to provide that consensual sex between a student and

teacher with supervisory or disciplinary authority over the student constitutes sexual 

assault, even if the student is at or past the age of consent.
 

Page 26 GAO-14-42 Child Sexual Abuse

State laws in almost all of the states we surveyed identified school 

personnel—who are often in a position to look for, identify and report 

suspicions of abuse—as mandatory reporters.44 Such positions typically 

included school administrators, teachers, school psychologists, and 

school nurses, among other positions, according to our survey. In light of 

recent cases of sexual abuse by school personnel involving multiple 

children and occurring over a number of years, some states have also 

expanded their definition of mandatory reporter, according to some 

experts we interviewed. For example, one state recently expanded its 

mandatory reporting law to include all public and private K-12 employees 

as mandatory reporters, whereas previously it had included only school 

teachers and officials.45

 

44Specifically, 46 states responded that their state laws identify school personnel as 

mandatory reporters for sexual abuse while 41 states do so for sexual misconduct.

According to our survey, mandatory reporters 

were most often required by state law to report to the state or local child 

protective service agency (41 states for sexual abuse and 36 states for 

sexual misconduct) and local law enforcement (35 states for sexual 

abuse and 31 states for sexual misconduct). In addition, some states’ 

laws also required reports to a school employee designee (18 states for 

both sexual abuse and misconduct) or a state educational agency (17 

states for both sexual abuse and misconduct).

45This state’s mandatory reporting law also includes other professions as mandatory 

reporters, such as physicians, nurses, and social workers, in addition to employees at the 

K-12 level. The recent amendments to the state’s mandatory reporting law also added 

employees of public and private institutions of postsecondary and higher education.

Reporting and 

Investigating Often 

Involves Multiple 

Agencies As Well As 

School Districts, 

Which Sometimes 

Presents Challenges

Most States Have 

Minimum Child Abuse 

Reporting Requirements 

and Some School Districts 

We Visited Have 

Additional Reporting 

Policies
 

Page 27 GAO-14-42 Child Sexual Abuse

Beyond the minimum reporting requirements outlined under state 

mandatory reporting laws, three state educational agencies and five of 

the school districts we visited have made additional efforts to ensure that

mandatory reporters in K-12 education understand their responsibility to 

report. For example, officials with one state educational agency we visited 

said the state provided training to school districts on developing policies 

and communicating with school personnel about their role in reporting 

suspected abuse, including who, what, when, and how to report such 

suspicions. At the local level, officials at one school district we met with 

said they included reporting requirements in school personnel handbooks 

and/or in staff meeting discussions. Other school districts we visited had 

developed additional means to ensure that personnel knew when to 

report suspected abuse. For example, one school district created ID sized 

“cheat sheets” for school personnel to carry or use as a reminder of the 

district’s policies on reporting suspected abuse by school personnel. 

While experts we spoke with noted that it is important for school districts 

to be able to establish their own policies with additional requirements or 

information appropriate for their school, we found that states do not 

always monitor such policies for compliance with state laws and state 

educational agency policies. For example, according to our survey, 32 

states reported that they did not monitor school districts to ensure that 

any relevant policies and procedures at the district level adhered to state 

requirements regarding sexual abuse and 10 reported not monitoring for 

adherence to policies and procedures regarding misconduct by school 

personnel.

Experts and officials in three of the four state educational agencies and 

three of the six school districts we visited reported challenges with 

ensuring that school personnel comply with the policies on reporting 

suspected sexual abuse by school personnel. In response to these 

challenges, these state and local level agencies told us they have taken 

certain steps to build awareness about such responsibilities. Challenges 

included:

Uncertainty about whether to report. Experts explained that mandatory 

reporters may have difficulty deciding whether to report those behaviors 

that are not criminal in nature, but otherwise may be questionable—the 

gray area. Officials in four of the school districts we visited noted that 

school personnel have asked if such gray area behaviors warrant 

reporting to CPS or law enforcement. To ensure that reports are made, 

three school districts we visited specified in policy the types of behaviors 

that warrant reporting. As one school official explained, after having a 

past incident of suspected sexual misconduct in one of its schools, the 

Challenges Arise with Ensuring 

Reports of Such Abuse and 

Misconduct are Made
 

Page 28 GAO-14-42 Child Sexual Abuse

school district expanded its code of conduct to further outline boundaries 

between school personnel and students in an effort to not only prevent its 

occurrence, but also to help mandatory reporters understand when such 

reports should be made.

Delayed and incomplete reports. During our site visits, CPS and local law 

enforcement officials told us that reports of suspected child sexual abuse 

or misconduct made only to school administrators have resulted in 

delayed reports to CPS and/or law enforcement. Some state mandatory 

reporting laws, including the law in at least two states we visited, permit 

school staff to report to the person in charge of the facility in which they 

work, who is then required to report to CPS or law enforcement. For 

example, in one state we visited, consistent with that state’s mandatory 

reporting law, one school district’s policy only requires school staff to 

report to designated school officials rather than directly to CPS or law 

enforcement. Further, one state CPS agency noted that when reports are 

filed second-hand by school district officials rather than the actual 

witness, critical details and context may be missing from the report. Some 

states recently amended their laws to prevent such second-hand 

reporting. One state, for example, amended its laws to specifically require 

mandatory reporters to report known or suspected child abuse or neglect 

directly to CPS, law enforcement, or another designated authority, instead 

of just reporting to a supervisor, as was permitted prior to the 

amendment.

Failure to report. CAPTA requires states’ laws to include provisions that 

grant individuals immunity from prosecution for reports of known or 

suspected child abuse or neglect made in good faith, which may 

encourage reporting. States have established procedures for mandatory 

reporters to report alleged abuse, and state law generally protects them 

from prosecution for reports made in good faith even if their suspicions 

turn out to be unfounded. However, experts we spoke with noted that 

failure to report—when school personnel witness or suspect, but do not 

report, sexual abuse—may occur. Experts told us that cognitive 

dissonance—the inability for someone to believe that something outside 

of their current view could be happening—often occurs when school 

personnel witness colleagues perpetrate sexual abuse or misconduct. For 

example, a mandatory reporter may dismiss suspicions about a colleague 

because such suspicions go against their pre-existing views. As a result 

of these uncertainties or disbeliefs, experts also told us that mandatory 

reporters may choose not to report suspicions of such behaviors. As 

previously discussed, training for school administrators, school personnel, 
 

Page 29 GAO-14-42 Child Sexual Abuse

students and parents may also help people identify behaviors that are 

questionable.

Failure to report occurs even though some states have established 

penalties for failure to report within a specified amount of time. According 

to our survey, 43 states have penalties for failure to report suspected 

sexual abuse by school personnel, and 37 have penalties for failure to 

report sexual misconduct by school personnel. Such penalties most often 

included criminal penalties, fines, and suspension or revocation of a 

license. For example, the law of one state we visited provides that 

mandatory reporters who fail to file a report within 24 hours after having 

reason to suspect a reportable offense of child abuse and neglect shall be 

fined no more than $500 for the first failure, and at least $1,000 for any 

subsequent failures. For some cases, such as those evidencing acts of 

rape, the law provides that a person who knowingly and intentionally fails 

to make the required report shall be found guilty of a misdemeanor.46 For 

half of the state educational agencies we visited, failure to report was 

grounds for license revocation. At the local level, half of the school 

districts we visited reported having a zero-tolerance policy for failing to 

report suspected sexual abuse or misconduct, in part because districts 

and school personnel could be held liable and face civil suits for not 

reporting—a lesson one of these school districts had learned firsthand. 

Officials at this school district said the district paid $3 million as a result of 

a lawsuit which alleged that a principal in the district had failed to take 

action in response to reports from teachers of inappropriate contact 

between an elementary school teacher and students.

 

46The law of another state we visited provides that violation of the state’s mandatory 

reporting requirements shall be punished by a fine of not more than $1,000. The law also 

provides for additional fines and possible imprisonment for certain types of violations, such 

as knowingly and willfully filing frivolous reports, or willfully failing to report known child 

abuse or neglect that resulted in serious bodily injury to or death of a child. 
 

Page 30 GAO-14-42 Child Sexual Abuse

Case Study: Failure to Report

Multiple school administrators, including the school district director of human resources 

and the superintendent, pled guilty to misdemeanor charges for failure to report in a case 

where a male teacher was found guilty of aggravated criminal sexual abuse of eight

female second graders. A parent reported to the school district superintendent, who 

reported to the school principal, that her child had told her about suspicious activities at 

school. Upon receiving the report, the school principal stated that she would investigate. 

She later reported back to the parents that the teacher used “poor judgment.” About 3 

months later, by word of mouth, the police learned of similar allegations and opened an 

investigation, through which other students were identified as possible victims. A search of 

the teacher’s classroom revealed, among other things, blindfolds and scarves that tested 

positive for the teacher’s semen. Although state law required educators to report 

suspected abuse to CPS or law enforcement, these school administrators failed to do so.

Responding to reports of sexual abuse of students by public K-12 school 

personnel often involves criminal justice, child welfare, and educational 

agencies, and could result in multiple investigations to determine the 

extent of violations of various laws or policies. According to our survey, 

state laws often dictate which agency or agencies have authority to 

investigate cases of alleged sexual abuse or misconduct. Each agency, 

operating under its own authority, may investigate a case of suspected 

child sexual abuse or misconduct by school personnel to determine 

whether certain violations have occurred, including violations of criminal 

laws, civil laws such as requirements related to child well-being, or 

conditions of employment. In addition, each agency may have to meet 

different standards of evidence and requirements when conducting its 

investigation. For example, the standard of evidence needed for a school 

to determine whether an employee violated a professional code of 

conduct may be different from the standard of evidence needed to 

prosecute someone for a crime. See figure 5.

Investigations Into 

Allegations of Sexual 

Abuse May Be Conducted 

By School Districts and 

Other State and Local 

Agencies
 

Page 31 GAO-14-42 Child Sexual Abuse

Figure 5: Types, Purpose, and Selected Disciplinary Outcomes of Investigations, by Agency Type

Note: This table identifies examples of disciplinary outcomes that may result from investigations. It 

does not include the services or support that investigative agencies may also provide, such as 

counseling services. It does not include federal agencies.

a

Determining which agency takes the lead in an investigation of alleged 

child sexual abuse by school personnel can be difficult. In addition, timing 

when additional investigations by other agencies should occur can vary 

by case and state. While CPS often takes the lead for investigations of 

parental abuse, in cases where school personnel are the suspected 

perpetrators of sexual abuse or misconduct, state laws determine 

whether CPS or law enforcement will take the lead on such 

investigations. As previously noted, our survey indicated that mandatory 

reporters are required by some state laws to notify CPS of potential 

Some child protective service (CPS) agencies we visited noted they use a lower standard of 

evidence than agencies responsible for enforcing criminal laws (such as a preponderance of the 

evidence instead of beyond a reasonable doubt) to determine if sexual abuse occurred. For example, 

one CPS agency we spoke with noted that its investigators are directed to consider “grooming” 

behavior to be abuse. Further, they can take a wide variety of actions and provide a variety of 

services, such as a transfer of schools or counseling services.
 

Page 32 GAO-14-42 Child Sexual Abuse

sexual abuse or misconduct, while several states required reports to local 

law enforcement. Some states’ laws allowed mandatory reporters to notify 

either of the agencies, as long as at least one is notified. According to 

officials in the states we visited, in those instances when a state requires 

mandatory reporters to notify CPS, CPS will receive the notification, but 

may or may not have authority under that state’s law to investigate cases 

involving school personnel and may refer the case to law enforcement. In 

the states we visited, CPS’s involvement in cases in which the alleged 

perpetrators were school personnel ranged from not participating in the 

investigation at all to leading the interview with the victim or, in some 

cases, conducting an independent review. When allegations of child 

sexual abuse or sexual misconduct by school personnel arise, state 

educational agencies may also have the authority to conduct their own 

investigations. According to our survey, 15 states provided authority to 

state professional practices or licensing boards to investigate reports of 

child sexual abuse by school personnel, while 17 states did so for reports 

of sexual misconduct. State offices that oversee educator licensing may 

be able to suspend or revoke an educator’s license for violations of state 

licensing requirements; for instance, in two states we visited, these offices 

were authorized to revoke licenses for reasons such as criminal 

conviction, conduct detrimental to the health or welfare of students, or 

other good cause, including gross misconduct or negligence. For 

example, in one state we visited, officials from the state educational 

agency told us they had revoked the license of a guidance counselor who 

started a relationship with a student after the student graduated based on 

evidence that the counselor had begun “grooming” the student while she 

was still enrolled in school. No criminal charges were filed due to the age 

of the individual, but the state educational agency took action based on 

violations of the school’s code of conduct for licensed educators.

Because different agencies can be involved with investigating reports of 

alleged child sexual abuse or misconduct by school personnel for 

different reasons, each of the agencies’ particular goals may lead to 

potential interference with another agency’s investigation, according to 

education, child welfare, and law enforcement officials, and experts we 

interviewed. Specifically, conflicting missions can lead to subjecting 

children to multiple interviews, not sharing reports, and prematurely 

alerting alleged perpetrators of investigations. For example:

• School or school district investigations can interfere with law 

enforcement and CPS investigations. Law enforcement, district 

attorneys, and CPS officials we spoke with said that school and 

school district administrators’ initial inquiries into reports of sexual 

Challenges May Arise When 

Multiple Parties Investigate
 

Page 33 GAO-14-42 Child Sexual Abuse

abuse or misconduct before a formal report is made to law 

enforcement or CPS can interfere with the criminal and child welfare 

investigations and unintentionally cause additional trauma for the 

victim. We learned from our site visits that school officials may initiate 

their own investigations before reporting the allegation to CPS or law 

enforcement for different reasons, which include gathering additional 

information to determine whether an incident should be reported, and 

typically are structured to serve interests such as taking quick action 

to address any personnel decisions, reducing the financial impact on 

the school of suspending teachers, and protecting the school’s 

reputation. One school district we visited organizes a team that 

determines whether to report an incident to CPS; however, officials 

told us that the district makes it clear to staff that they may file a report 

regardless of the team’s decision. In one state we visited, school 

district officials told us they prioritize law enforcement investigations 

above their own, but it is not always possible to wait to conduct their 

own investigation because criminal cases may take more time—

sometimes a year or longer. As they explained, this could interfere 

with their ability to take timely and appropriate personnel actions, such 

as suspension or termination of employment, if warranted.

To help prevent these long waits, one state educational agency official 

told us his agency encouraged school administrators to get as much 

information as possible about a reported case before law enforcement 

eventually stopped the district’s investigation. An attorney that worked 

for one district we visited noted the financial expense to the school 

and possible impact on a teacher’s reputation of keeping teachers on 

administrative suspension for long periods of time. School officials 

may also conduct investigations to protect their own reputation or that 

of the school district. Because of the school’s investigation, the 

alleged victim may be subjected to multiple interviews by different 

parties, which, law enforcement as well as CPS and Child Advocacy 

Center (CAC) officials told us, can place an undue burden on the 

victim and their family. Further, law enforcement officials told us of 

concerns they have with schools initiating their own investigation. For 

example, if school officials are not trained in proper interview 

techniques, they may inappropriately dismiss an allegation and fail to 

report it to those who are properly trained to investigate such cases.

• The goals of assessing child safety and determining criminal activity 

can sometimes conflict with one another. In determining potential 

harm to a child, CPS may be required to notify the alleged perpetrator 

of its investigation. Such requirements and actions can sometimes 

conflict with law enforcement investigations. For example, in one state 

we visited, CPS is authorized to initiate an investigation in some
 

Page 34 GAO-14-42 Child Sexual Abuse

circumstances when the alleged perpetrator is a teacher. In this state, 

CPS is required to conduct an initial review within 5 days of receipt of 

a report to determine if the report is valid, and if so, it determines 

whether to initiate an investigation, which often involves interviewing 

the alleged victim and the alleged perpetrator. Law enforcement 

officials we spoke with said that this practice can sometimes conflict 

with their preferred approach of using the element of surprise to 

capture critical information from the perpetrator. In one example, law 

enforcement officials stated that an alleged perpetrator who knew of 

their investigation fled the area, further complicating the case and 

putting others at risk of harm.

While the goals and requirements of each agency investigating reports of 

suspected child sexual abuse by school personnel can potentially 

compromise other investigations, agencies we visited have established 

ways to increase collaboration to address these challenges. All six school 

districts, five CPS agencies, three law enforcement agencies, and two

district attorneys we spoke with told us they either informally collaborate 

during these investigations or have formal agreements in place to 

collaborate with each other. In some instances, collaboration is mandated 

by state law.47 For example, the law in one state we visited required each 

county to develop and adopt a written protocol for handling criminal child 

sexual abuse investigations that addresses coordination between the 

prosecutor’s office, law enforcement, CPS, children’s advocacy centers, 

local advocacy groups, community sexual assault programs, and other 

relevant agencies.

 

47States that receive federal funding under CAPTA are required to have a state law or 

statewide program that includes the cooperation of state law enforcement officials, courts 

of competent jurisdiction, and appropriate state agencies providing human services in the 

investigation, assessment, prosecution and treatment of child abuse and neglect. 

Challenges are Sometimes 

Addressed through 

Collaboration between 

Agencies during Investigations
 

Page 35 GAO-14-42 Child Sexual Abuse

Case Study: Communication between Agencies

After a parent filed a report with local law enforcement alleging that a female school bus 

driver had engaged in an inappropriate relationship with a male student, investigators 

learned from the student that the relationship lasted 2 years and began when the student 

was 15 years old. When police interviewed the bus driver the next day, she was arrested 

and confessed to having a sexual encounter with the student when he was 15. The police 

formally notified the school district, per an agreement between law enforcement and the 

school district, and the bus driver was placed on suspension. She was later convicted of 

indecent liberties with a child, received a suspended prison sentence, and was required to 

register as a sex offender, among other penalties. Upon this conviction, the school district 

terminated the bus driver’s employment. Law enforcement officials who investigated the 

case reported that they had a good working relationship with the school district.

In three of the four states we visited, we found that law enforcement and 

CPS formed multi-disciplinary task teams and set protocols, through 

memoranda of understanding, for how to respond to allegations of child 

sexual abuse. One protocol specifically included procedures for how to 

settle disagreements between agencies about cases. However, these 

memoranda and/or multidisciplinary networks generally did not include 

school officials. We were told by two district attorneys that since the 

collaboration between law enforcement and CPS included a broader 

focus on child sexual abuse and misconduct by any type of perpetrator, 

the district attorneys would determine on a case-by-case basis whether to 

include school officials. During these interagency meetings, the facts of 

the case are reviewed and plans are made to properly interview the 

child(ren). For example, one state we visited developed a Sexual Assault 

Intervention Networks (SAINs) program, which is a collaborative effort 

involving CPS, local law enforcement, and the district attorney’s office. As 

soon as CPS receives a report of child sexual abuse, these agencies 

coordinate as a multidisciplinary team to reduce the number of times a 

child is interviewed by different professionals and provide needed 

services for the child and family. Many state and local agencies, including 

the four states we visited, also have CACs that serve as safe places for 

victims and provide specialists for investigative interviews. For example, 

in one state we visited, within 48 hours of notification that law 

enforcement is initiating an investigation, the prosecutor convenes a 

multidisciplinary meeting at the CAC that includes CPS, law enforcement, 

advocacy groups, and school districts, when applicable. Officials from law 

enforcement, district attorneys’ offices, CPS, and educational agencies 

we spoke with stated that these collaborative approaches are critical to 

helping them understand one another’s goals, increasing information 

sharing, and minimizing additional harm to the victim in the form of

multiple interviews.
 

Page 36 GAO-14-42 Child Sexual Abuse

Case Study: Supporting Another Agency’s Goals

When a male high school coach was charged with, and pled guilty to, sexual battery of a 

minor for sending inappropriate text messages to a female student containing 

pornographic photos, the police, the prosecutor, and the school district worked together 

closely. The prosecuting attorney understood the needs of the school district, which, in this 

case, included investigating and prosecuting the case before the start of a new school 

year. The detective reported that he was able to investigate the crime and obtain a guilty 

plea within 30 days—crediting the prosecuting attorney and cooperation from family and 

school personnel. The detective reported that the outcome of the investigation could not 

have worked out any better.

The issue of sexual abuse by school personnel crosses several federal 

agencies’ missions, with no single agency having a clear leading role to 

coordinate with other agencies to oversee the prevention of and response 

to such situations. Education, HHS, and Justice each have distinct 

missions and each can lend unique expertise to help states, school 

districts, and schools prevent and respond to sexual abuse by school 

personnel. The agencies have worked together on the issue of child 

abuse in the past. In response to a requirement in the 1988 amendments 

to CAPTA, HHS led 30 federal agencies in a Federal Inter-Agency Task 

Force on Child Abuse and Neglect to help coordinate federal activities 

related to the prevention and treatment of child abuse and neglect. 

Education and Justice were members of the task force. According to one 

HHS official, following the 1996 amendments to CAPTA, which eliminated 

the requirement for such a task force, federal agency members have 

continued to voluntarily coordinate as a work group to communicate and 

exchange ideas concerning child maltreatment-related programs and 

activities; collect information about federal child maltreatment prevention 

and treatment activities; and provide a basis for collective action through 

Multiple Federal 

Agencies Provide 

Resources to Address 

Abuse by School 

Personnel, but 

Coordination and 

Data Are Limited

Federal Agencies Provide 

Limited Training, 

Guidance, and Funding, 

and Collect Data Related 

to Child Sexual Abuse, but 

These Efforts Are Not Well 

Coordinated or 

Disseminated
 

Page 37 GAO-14-42 Child Sexual Abuse

which funding and resources can be maximized. However, in July 2013, 

the lead official responsible for coordinating these meetings told us that 

none of the meetings have focused on addressing sexual abuse when 

perpetrated by school personnel.

With respect to their individual agency efforts to support states and school 

districts to address this issue, Education, HHS, and Justice have provided 

limited support in the form of training, guidance and resources, federal 

funding, and data collection. This support either addresses school 

personnel-to-student sexual abuse and misconduct directly or through

more general ways to prevent violence or child sexual abuse. Agency 

officials provided examples, including: 

• In partnership with a school district we visited, Education’s Office of 

Safe and Healthy Students (OSHS) conducted training on the 

prevention of and response to educator sexual misconduct, covering 

such topics as establishing proper boundaries between school 

personnel and students, identifying and training staff to recognize the 

signs of adult sexual misconduct, and establishing policies and 

procedures on how to prevent and respond to sexual abuse by school 

personnel. The school district received grant funds through 

Education’s Readiness and Emergency Management for Schools 

program to develop this training after several incidents of abuse by 

school personnel occurred in the district, including a high profile case 

that culminated in the murder of a teacher accused of sexual 

misconduct with students. OSHS has provided the training to other 

school districts throughout the country on request. For example, in 

2012, OSHS arranged 11 training sessions across nine states for a 

variety of education entities, including school districts, which had a 

combined total of approximately 500 attendees. According to OSHS 

officials, the training targeted security officers, superintendents, 

assistant superintendents, and school counselors. In addition, one

training was conducted at a school district in May 2013 and three 

others are scheduled or planned for later in the year. Education also 

funded a video module geared towards students as a training 

component for 9th grade health courses at one school district. The 

video included vignettes designed to prompt student discussion about 

what to say when confronted by sexual abuse or misconduct by 

school personnel, who to talk to, and who can help, according to 

district officials.

• OCR officials said they conduct presentations on Title IX issues 

involving both student-to-student and school personnel-to-student 

harassment. OCR officials also told us they use assistance centers to 

Training
 

Page 38 GAO-14-42 Child Sexual Abuse

respond to requests from schools for information and provide 

technical assistance, such as training and guidance to help 

communicate a school’s responsibilities under Title IX, and to help 

schools implement the regulations. The centers have also received 

requests for assistance with sexual harassment training. OCR officials 

said this type of broad training on sexual harassment could also be 

applicable in cases of sexual abuse perpetrated by school personnel.

• Although not focused specifically on sexual abuse by public K-12 

school personnel, Justice’s OJJDP has funded Darkness to Light 

trainings, which focus on the rehabilitation and prevention of child 

sexual abuse in all settings, including public K-12 schools.

• OSHS developed and distributed a technical assistance guide on 

educator sexual misconduct explaining what educator sexual 

misconduct is and how to prevent and respond to it. According to 

OSHS officials, this guide was shared with an electronic list of 

grantees and others involved in measuring school climates, primarily 

school districts and some state officials. Because the guidance was 

well received, OSHS officials told us they provided additional training 

to school districts.

• In 2001, OCR issued Revised Sexual Harassment Guidance: 

Harassment of Students by School Employees, Other Students, or 

Third Parties. The guidance provided information about schools’ 

responsibility to take immediate and effective steps to end sexual 

harassment, including sexual abuse of students by school personnel. 

In 2006, OCR reissued the 2001 guidance with a letter reminding 

schools of their obligations. In 2008, OCR issued a pamphlet 

answering questions on sexual harassment and has since issued two 

dear colleague letters about peer harassment and sexual violence, 

respectively, both of which refer to OCR’s 2001 guidance on 

personnel-to-student harassment.

• In 2007, the CDC developed a resource on practices for preventing 

child sexual abuse in youth-serving organizations.48

 

48Saul J, Audage NC. Preventing Child Sexual Abuse Within Youth-serving Organizations: 

Getting Started on Policies and Procedures, Centers for Disease Control and Prevention, 

National Center for Injury Prevention and Control (2007). The recommendations contained 

in this resource are based upon comments from experts at a meeting sponsored by CDC 

in August 2004. 

According to 

CDC officials we spoke with, this resource was designed to include 

practices that can be applied to many different organizations, 

including schools. For example, the report includes information on 

protocols involving employment screening, interactions between 

Guidance and resources
 

Page 39 GAO-14-42 Child Sexual Abuse

individuals, monitoring employee behavior, ensuring a safe 

environment, responding to inappropriate behavior, and training. CDC 

officials also explained that organizations, including schools, need to 

provide continuous training and review so that all employees know 

that the school takes sexual abuse seriously and has a policy about 

appropriate behavior and responding to sexual abuse. Further, CDC 

officials told us that organizations need to review how the policy is 

working over time, and see if there are any lessons learned that could 

be incorporated into the school’s policy. In the event that the 

organization has any cases of sexual abuse, the policies also need to 

be applied and tested. CDC officials told us they use the practices 

resource to conduct presentations at conferences to help many 

different kinds of organizations address child sexual abuse. In 

addition, risk management organizations and insurance companies 

recommend the use and application of the information in the CDC 

resource. For example, one insurance company told us that after 

evaluating an organization, such as a school district, including its risk, 

mission, and operations, they have recommended using CDC’s 

resource as a guide to developing step-by-step policies and 

procedures.

• HHS’ Administration for Children and Families has a web/Internet 

portal of information addressing the prevention and treatment of child 

abuse and neglect called the Child Welfare Information Gateway. 

While many of the resources on the portal provide information that 

addresses child abuse and neglect broadly and in the context of the 

family environment, the portal also provides a few resources on 

identifying adults at risk of sexually abusing children and examples of 

sexual abuse by school staff are provided. For example, the portal 

includes a link to CDC’s resource and other materials on prevention, 

though not specific to schools. Experts and federal officials we spoke 

with told us that additional information that specifically addresses 

these types of cases could be helpful to include on the portal.

• CDC funded cooperative agreements in 2002 with three states that 

provided services related to child sexual abuse.49

 

49According to CDC officials, this program ended in 2008. 

All of the grantees 

looked at the prevention of sexual abuse at the societal level and two

states, Massachusetts and Georgia, specifically included schools. For 

example, Georgia used a CDC grant to conduct train-the-trainer 

programs in conjunction with the state’s educational agency to 

address child sexual abuse. Officials said CDC’s resource was useful 

Other grants
 

Page 40 GAO-14-42 Child Sexual Abuse

for developing the training curriculum because it includes all the 

important processes needed for preventing child sexual abuse in 

organizations that serve youth.

• HHS’ Administration for Children and Families and Justice’s Office for 

Victims of Crime, through the CJA program, provide grants to states 

to improve administrative and judicial proceedings regarding the 

investigation and prosecution of child abuse cases, particularly child 

sexual abuse cases.50 To be eligible, states are required to establish 

multidisciplinary or CJA task forces. These task forces are made up of 

representatives from local law enforcement departments, CPS 

agencies, and child advocates, among other professionals.51

Although several federal agencies collect related data, none collect 

comprehensive data that would quantify the prevalence of sexual abuse 

by school personnel. Some examples of the federal efforts to collect data 

include the following:

In some 

of states we visited, multi-disciplinary task forces have used CJA 

grant money and other federally-supported resources to conduct 

educational awareness and outreach to schools, as well as trainings 

to help improve the skills of those conducting forensic interviews of 

victims when allegations of sexual abuse are reported.

• Through its National Center for Education Statistics (NCES), 

Education collects information on school safety and crime. Although 

NCES’ school violence data are required by statute to include 

 

50Funding for CJA grants comes from the Crime Victims Fund (CVF), which is 

administered by Justice’s Office for Victims of Crime (OVC). The CVF, initially established 

by the Victims of Crime Act of 1984, is funded by fines and penalties paid by convicted 

federal offenders. Each year OVC transfers approximately $17 million from the CVF to 

HHS’ Administration on Children and Families to make grants under section 107 of 

CAPTA, as amended. HHS then distributes these funds to states through formula grants 

in the amount of $50,000 to each state, plus an additional amount based on the population 

of children under 18 years of age in the applicant’s jurisdiction. Additionally, OVC retains a 

portion of the CVF for a discretionary grant program that provides resources to tribal 

communities to improve the investigation and prosecution of child abuse. See 42 U.S.C. 

§§ 10601-08.

51Under the Victims of Child Abuse Act of 1990, as amended, OJJDP also provides grant 

funding to the National Children’s Alliance and the Regional Children’s Advocacy Centers 

program to establish and enhance local CACs and the multidisciplinary response to child 

abuse throughout the United States. Funding under the Victims of Child Abuse Act also 

supports the delivery of training and technical assistance to child abuse professionals and 

prosecutors to improve the investigation and prosecution of child abuse. See 42 U.S.C. §§ 

13001-004. 

Data collection and analysis
 

Page 41 GAO-14-42 Child Sexual Abuse

information on the relationship between victims and perpetrators, 

NCES does not capture information about whether the perpetrators of 

sexual abuse against students are school personnel.52

 

5220 U.S.C. § 9543(a)(1)(H). 

We examined 

the School Survey on Crime and Safety (SSOCS)—one of the primary 

sources of school-level data on crime and safety—and spoke with 

NCES officials who said the survey is not designed to collect 

information on whether school personnel are the perpetrators of child 

sexual abuse in schools. According to an official at NCES, the survey 

captures counts of crime, including “rape or attempted rape” and 

“sexual battery other than rape” that occurred at school from a 

nationally representative cross-section of schools; however, it does 

not capture information about who specifically committed those 

crimes, and only captures crimes committed on school grounds. 

Furthermore, the official explained that, due to uncertainties in future 

funding for these surveys, NCES does not plan to add variables that 

would capture the type of perpetrator. According to one NCES official, 

NCES does not view the SSOCS as the appropriate vehicle for

collecting incident-level data and determined that data on violence 

against all persons, including students, are already collected through 

the National Crime Victimization Survey (NCVS) carried out by 

Justice. NCES officials asked Justice’s Bureau of Justice Statistics 

(BJS) to make some changes to the NCVS to account for alleged 

perpetrators who are school personnel, but acknowledged that more 

could be done to obtain more accurate counts and robust analysis. In 

2007, BJS added the variable “teacher/school staff” to a question in 

the NCVS that asks about how the victim knew the offender; however, 

from 2007 to 2012, no cases of sexual violence against any students 

ages 12 to 18 by school personnel were reported in the NCVS. 

Further, as the survey is currently designed, data collected are limited 

to capturing information about victims age 12 and older. BJS officials 

offered several reasons why the NCVS may not be capturing cases of 

sexual violence by teacher/school staff. For example, the survey 

draws from a small sample of children ages 12 through18; uses broad 

language in the two questions asked; and captures crimes occurring 

within the last 6 months, when generally, victims of sexual abuse do 

not report such abuse until they are adults, according to official we 

spoke with. In addition, they explained, sexual violence is difficult to 

measure and children may not fully understand what is happening to 

them or be unwilling to report it.
 

Page 42 GAO-14-42 Child Sexual Abuse

• According to an Education official, the agency’s Civil Rights Data 

Collection (CRDC) is another data set which captures wide-ranging 

information on education and civil rights issues from public schools 

and is used by OCR for enforcement and monitoring of compliance 

with federal civil rights laws, including Title IX.53

• Education’s OCR also maintains an electronic database of complaints 

regarding Title IX issues; however, the system does not have a 

variable that identifies the alleged perpetrator of sexual violence.

However, while these 

data cover the universe of schools, data specifically on reports of 

school personnel as alleged perpetrators is not collected.

• HHS captures data in the National Child Abuse and Neglect Data 

System (NCANDS). These data are reported by state child protective 

services agencies; however, NCANDS does not specifically identify 

whether the alleged perpetrators of child sexual abuse are school 

personnel.54

While Education, HHS, and Justice all have data systems that capture 

information from state and local entities about child abuse, none capture 

the extent of sexual abuse and misconduct perpetrated by public K-12 

school personnel. In response to a requirement in the 2002 

reauthorization of the Elementary and Secondary Education Act of 1965 

(ESEA), Education had taken steps to understand this issue by 

contracting with an expert in the field, who conducted a study on educator 

sexual misconduct to identify the prevalence of sexual abuse by school 

personnel. Because of limited data, instead of original research, the 2004 

study resulted in a synthesis of existing literature on the prevalence of 

educator sexual misconduct, offender characteristics, targets of 

misconduct, and recommendations for prevention, such as written schooland school district-level policies prohibiting such behavior, hiring and 

screening practices to identify red flags in applicant backgrounds, and 

educating employees and students about unacceptable behaviors. Even if 

 

53The CRDC collects information about school characteristics and about programs, 

services, and outcomes for students. Among the topics included are students’ participation 

in algebra and other college-preparatory subjects, retention, teacher 

experience/absenteeism, school funding, harassment, restraint/seclusion, and additional 

information related to discipline. The 2009-2010 CRDC collection included the first of its 

kind school and district level reporting of harassment. However, many districts were 

unable to provide complete data on students reported to have been harassed, and 

incidents by type of harassment. As a result, these data may be underestimated. 

54Reports by state child welfare agencies to NCANDS are identified as 

“substantiated/founded” or “unsubstantiated/unfounded”. 
 

Page 43 GAO-14-42 Child Sexual Abuse

there were systems designed to capture data on school personnel as 

perpetrators of sexual abuse and misconduct, interested stakeholders 

would still need to check multiple systems for information about criminal 

activity, actions taken against licensure, and cases captured in child 

welfare databases. One expert we spoke with suggested that original 

research or a longitudinal study could help stakeholders and the general 

public understand the full scope of the problem.

According to our survey of state educational agencies, less than half of 

the states said they were aware of resources available to them from the 

federal agencies. See table 1.

Table 1: Number of State Educational Agencies Aware of Federal Resources to Help 

Prevent and Respond to Sexual Abuse and Sexual Misconduct by School 

Personnel, by Topic 

Number of States Aware of Information/Guidance

Resources from Federal 

Agencies Sexual abuse Sexual misconduct

Education 18 19

HHS 12 11

Justice 11 11

Source: GAO analysis of survey data from 50 states and the District of Columbia.

In addition to limited awareness of existing federal resources to address 

this issue, according to our survey, 29 states said additional guidance and 

technical assistance from the federal government could be useful to 

states or school districts to help address sexual abuse or misconduct by 

school personnel. Examples of such assistance included guidance on 

developing professional standards and codes of conduct, examples of 

training models and materials, federal sponsorship or provision of training 

that addresses prevention and response, and opportunities for federal 

grants to states for outreach and prevention programs. State officials we 

spoke with frequently mentioned their need for additional guidance and 

technical assistance to help with policies to prevent and respond to 

sexual abuse by school personnel. Furthermore, some school district 

officials we spoke with at our selected site visits were unaware of 

guidance from the federal agencies when developing their own policies to 

address sexual abuse and misconduct.

State and Local Agencies 

Have Limited Awareness of 

Federal Resources to Help 

Prevent and Respond to 

Sexual Abuse and Misconduct 

by School Personnel
 

Page 44 GAO-14-42 Child Sexual Abuse

The limited coordination among Education, HHS, and Justice to leverage 

combined resources, expertise, and capacities across agencies may 

hinder the agencies’ efforts to address this complex issue in a 

crosscutting and multidisciplinary way. The Government Performance and 

Results Act of 1993 (GPRA), as updated by the GPRA Modernization Act 

of 2010,55 establishes a framework for a crosscutting and integrated 

approach to focusing on results and improving government 

performance. This framework includes identifying how an agency is 

working with other agencies to achieve its performance goals. 

Furthermore, according to the Standards for Internal Control in the 

Federal Government, federal agencies should ensure there are adequate 

means of communicating with external stakeholders who have a 

significant impact on agency goals.56 No single federal agency is leading 

the effort, and weaknesses in coordination among these agencies to 

disseminate comprehensive information to state and local entities may 

leave states and local entities without important information that could 

help ensure a comprehensive and integrated approach to addressing this 

issue.

Education plays an important role in addressing the issue of sexual abuse 

by school personnel through its oversight of schools’ and districts’ 

compliance with Title IX, including requiring schools to designate an 

employee as a Title IX coordinator and adopt grievance procedures for 

the resolution of complaints of Title IX violations. However, we found 

limited awareness and, in some cases, confusion about the role of Title IX 

coordinators when allegations of sexual abuse or misconduct by public K12 school personnel against students arise. School officials at four of the 

six school districts we visited told us that Title IX coordinators are not 

involved when allegations of sexual abuse or sexual misconduct are 

made against school personnel. For example, one district official said the 

Title IX coordinator is generally the district athletic director who handles 

discrimination and gender equality issues, and it is human resource 

officers, principals, and superintendents that most often handle reports of 

suspected sexual abuse or misconduct by school personnel. Subject 

 

55Pub. L. No. 111-352, 124 Stat. 3866 (2011) (amending Pub. L. No. 103-62, 107 Stat. 

285). 

56GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

Education’s Regulations 

and Guidance for Title IX 

Include Requirements to 

Protect Students, but K-12 

Educators Are Unclear On 

How To Apply the 

Requirements
 

Page 45 GAO-14-42 Child Sexual Abuse

matter experts and association officials representing Title IX coordinators 

also said these cases are generally not handled through Title IX 

coordinators. Further, these experts and officials explained that K-12 

education professionals generally view Title IX requirements as more 

applicable in athletic programs or in cases of employee-to-employee 

harassment. Other experts who have worked with school administrators 

or school districts to provide training on preventing child sexual abuse told 

us some school administrators were not aware of the requirements of 

Title IX, who the Title IX coordinator was, or the coordinator’s 

responsibilities. 

Title IX prohibits sexual harassment in education programs or activities, 

and compliance with Title IX and Education’s regulations is required of all 

schools receiving federal assistance, including public K-12 school districts 

and schools; however, Education’s related guidance and other outreach 

to specify how the regulations apply to situations where K-12 school 

personnel perpetrate sexual abuse or misconduct against students is 

limited. As a result, schools may be left on their own to determine which 

cases are subject to Title IX compliance requirements. For example, in 

two school districts we visited, school officials said they interpreted Title 

IX violations to include adult-to-adult or student-to-student incidents, not 

adult-to-student incidents. In one school district official’s view, sexual 

harassment consists of an element of adult behavior toward another adult 

co-worker and is not relevant to cases of sexual abuse of students. 

Education’s 2001 guidance specifies that Title IX protects students from 

sexual harassment by a teacher or other school employee, among other 

types of harassment, and includes some examples of prohibited conduct. 

Although some of the examples are in K-12 settings, the guidance 

focuses more on a variety of situations in a college campus or university 

setting.57

 

57U.S. Department of Education, Office for Civil Rights, Revised Sexual Harassment 

Guidance: Harassment of Students by School Employees, Other Students, or Third 

Parties (Washington, D.C.: January 2001). 

OCR officials explained that, while sexual abuse was covered in 

its 2001 sexual harassment guidance, through compliance investigations 

and technical assistance with schools, officials concluded that schools 

needed additional guidance on Title IX’s applicability to sexual abuse 

allegations. OCR developed and issued a pamphlet in 2008 which 

condensed the material covered in the 2001 guidance into a more 

accessible format and included some examples of inappropriate sexual 
 

Page 46 GAO-14-42 Child Sexual Abuse

conduct between K-12 school personnel and students.58

An official we spoke with at one association representing Title IX 

coordinators told us that much of Education’s guidance never took hold at 

the K-12 education level. OCR officials explained that while they receive 

some complaints against school personnel, they receive many more 

about student-to-student harassment. In addition to OCR’s written 

guidance, OCR officials said they conduct presentations on Title IX issues 

involving both student-to-student and school personnel-to-student 

harassment and use assistance centers to provide technical assistance, 

as mentioned earlier. Despite these efforts, one association representing 

Title IX coordinators told us they receive calls from school 

superintendents—and to a lesser degree, athletic directors—to better 

understand the requirements under Title IX and inquire about available 

training, because there is limited information available about how Title IX 

applies to the specific types of situations that arise in K-12 education.

Education’s 

sexual harassment guidance since 2008 has focused on peer-perpetrated 

sexual harassment and violence against students and refers readers to its 

prior guidance for information about personnel-to-student sexual 

harassment, despite continued reports of cases involving sexual abuse 

and misconduct by public K-12 school personnel and the changing nature 

of interactions between students and school personnel through the use of 

social media, for example.

The sexual abuse of students and sexual misconduct by public K-12 

school personnel is a complex problem, and such behavior is particularly 

egregious because schools are entrusted with educating the nation’s 

children. There are no simple solutions to this problem and, although 

states and school districts are taking some positive steps, current efforts 

are clearly not enough. Background checks can help identify some 

previous offenders; however, they have limitations. Professional 

standards and codes of conduct can help clarify what is considered 

inappropriate behavior but often do not apply to all school staff, and 

training on recognizing and preventing child sexual abuse by school 

personnel is not widespread. School administrators can respond quickly 

to limit contact when abuse is suspected, but their action can also hinder 

 

58U.S. Department of Education, Office for Civil Rights, Sexual Harassment: It’s Not 

Academic (Washington D.C.: 2008). 

Conclusions
 

Page 47 GAO-14-42 Child Sexual Abuse

CPS and law enforcement investigations without close collaboration 

among all parties. Unless these individual components are both 

strengthened and integrated, states and school districts will continue to 

miss opportunities to prevent and respond quickly and effectively to child 

abuse by school personnel.

The federal government, through its existing resources and expertise, is 

well positioned to assist states and localities and to help strengthen their 

prevention and response efforts. Education, HHS, and Justice each bring 

specific expertise to the table. However, because federal efforts and 

collaboration to date have been limited, states, districts, and schools have 

worked to address this type of sexual abuse and misconduct with minimal 

federal guidance on model policies, programs, and practices. Further, 

most states are not aware of the federal resources that are currently 

available. In addition, some states have enacted laws and states and 

school districts have developed policies to prevent and respond to such 

abuse but have limited information on the magnitude of the problem, 

which the federal government is in a position to provide. Finally, limited 

understanding of how Title IX requirements apply to allegations of 

suspected sexual abuse or misconduct by school personnel against K-12 

students may hinder state and local efforts to properly address such 

cases, prevent such behaviors and actions in the future, and ultimately 

protect children from harm.

In order to help inform federal, state, and local initiatives to prevent and 

respond to child sexual abuse by school personnel, the Secretary of 

Education should lead an effort, in collaboration with the Secretary of 

HHS and the Attorney General, to leverage resources, expertise, and 

capacities across the departments to:

• Develop a comprehensive package of materials for states, districts, 

and schools that outlines steps that can be taken to prevent and 

respond to child sexual abuse by school personnel. For example, this 

could include compiling, assessing, and enhancing existing guidance, 

training materials, grant opportunities, and other resources;

• Determine the most cost-effective way to disseminate federal 

information so that relevant state and local educational agencies, child 

welfare agencies, and criminal justice entities are aware of and have 

access to it; and

• Identify mechanisms to better track and analyze the prevalence of 

child sexual abuse by school personnel through existing federal data 

collection systems, such as the School Survey on Crime and Safety, 

Recommendations for 

Executive Action
 

Page 48 GAO-14-42 Child Sexual Abuse

the National Child Abuse and Neglect Data System, and the National 

Crime Victimization Survey.

To help ensure that Title IX requirements to prevent and address sexual 

harassment, including sexual abuse and misconduct by school personnel 

against students, are carried out appropriately at public K-12 schools, the 

Secretary of Education should:

• Clarify and disseminate information on the roles and responsibilities of 

Title IX coordinators and more clearly emphasize that Title IX also 

applies to public K-12 schools and to cases involving school 

personnel-to-student sexual abuse and misconduct. For example, 

Education could update its existing Title IX guidance to specifically 

include information about adult-to-student sexual abuse and the 

applicability of Title IX to K-12 schools, examples of the types of 

behavior that may violate Title IX, and instructions on how to ensure 

school personnel can effectively carry out their responsibilities.

We provided a draft of this report to the Departments of Education, HHS, 

and Justice for review and comment. Education provided formal 

comments that are reproduced in appendix III. Education and HHS 

provided technical comments, which we incorporated as appropriate. 

Justice did not have any technical or formal comments. 

Education agreed that there is an important federal role in adequately 

informing and equipping state and local entities to address the prevention 

of and response to child sexual abuse by school personnel. Education 

also noted that while the federal government is well positioned to help 

states and localities, it is vital that all states also have a policy that 

requires background checks of all adults working with students.

Education concurred with our recommendation that the department, in 

collaboration with HHS and Justice, leverage resources, expertise, and 

capacities to compile and disseminate information to states and identify a 

way to track the prevalence of sexual abuse by school personnel. In 

response, Education said that it is taking action to revise its Adult Sexual 

Misconduct training module offered through the Office of Safe and 

Healthy Students to target a wider audience, including school volunteers. 

We believe this is an important step and suggest Education widely 

disseminate its revised training module and encourage state and local 

educational agencies to adopt the training for all who come into contact 

with students. Education said it will explore ways to collaborate with HHS 

and Justice to develop resources and provide more comprehensive 

Agency Comments 

and Our Evaluation
 

Page 49 GAO-14-42 Child Sexual Abuse

technical assistance in a cost-effective way. Further, Education said it will 

explore methods to better track and analyze the prevalence of child 

sexual abuse by school personnel. Without these data, the federal 

government will continue to lack key information to help target technical 

assistance and other resources and equip state and local entities with the 

information to better address this issue. 

In response to our recommendation to clarify and disseminate information 

about the applicability of Title IX in cases of adult-to-student sexual abuse 

and misconduct, Education said its Office for Civil Rights is currently 

developing guidance on peer sexual violence. This guidance will again 

mention that Title IX applies to sexual harassment at the K-12 and 

postsecondary levels and remind schools that Title IX also prohibits 

sexual harassment of students by employees. It will also provide 

information on the roles and responsibilities of the Title IX coordinators. In 

addition, Education said this office plans to develop policy guidance 

focusing on schools’ requirements to designate a Title IX coordinator and 

explaining the coordinators’ roles and responsibilities in the K-12 and 

postsecondary settings. We continue to encourage Education to consider 

ways to make all guidance on this issue as clear as possible, which may 

require issuing a set of guidance separate from the one focusing on peers 

that highlights the importance of this issue and the applicability of Title IX 

in situations of abuse by school personnel.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 4 days from the 

report date. At that time, we will send copies to the Secretary of 

Education, HHS, and the Attorney General and interested congressional 

committees. The report will also be available at no charge on the GAO 

Web site at www.gao.gov. 
 

Page 50 GAO-14-42 Child Sexual Abuse

If you or your staff members have any questions about this report, please 

contact me at (202) 512-7215 or Brownke@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix IV.

Sincerely yours,

Kay Brown, Director

Education, Workforce, and Income Security Issues
Appendix I: Objectives, Scope and 

Methodology

Page 51 GAO-14-42 Child Sexual Abuse

This appendix discusses in detail our methodology for addressing three 

research questions:

(1) What steps have states and school districts taken to help prevent child 

sexual abuse by school personnel? (2) What are states and school 

districts’ reporting requirements and approaches to investigating 

allegations of child sexual abuse by school personnel? and (3) To what 

extent have federal agencies made efforts to prevent and respond to child 

sexual abuse by school personnel? To address these questions, we 

reviewed relevant federal laws, regulations, and guidance; conducted 

interviews with Education, HHS, and Justice officials and with other 

representatives of the K-12 education, child welfare, and criminal justice 

communities; surveyed state educational agencies in 50 states and the 

District of Columbia; and conducted site visits to four states and six of 

their school districts, where we interviewed state agencies, school 

districts, local law enforcement and child protective service agencies and 

reviewed relevant information. We conducted this performance audit from 

October 2012 to January 2014 in accordance with generally accepted 

government auditing standards. Those standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on the audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives. Our 

investigative activities were conducted in accordance with standards 

prescribed by the Council of the Inspectors General for Integrity and 

Efficiency.

To identify federal efforts to prevent and respond to child sexual abuse by 

school personnel, we reviewed relevant federal laws as well as 

Education’s regulations and guidance on Title IX requirements for 

schools. We also reviewed Education’s School Survey on Crime and 

Safety, HHS’ National Child Abuse and Neglect Data System, and 

Justice’s National Crime Victimization Survey to identify information 

federal agencies collect on child sexual abuse and misconduct 

perpetrated by school personnel.

To examine the federal role in addressing child sexual abuse by K-12 

public school personnel, we interviewed officials from Education, HHS, 

and Justice, relevant education and child welfare groups, and risk 

management organizations. At Education, we spoke with officials in the 

Office for Civil Rights, Office of Safe and Healthy Students, and the 

Appendix I: Objectives, Scope and 

Methodology

Review of Federal Laws, 

Regulations, Guidance 

and Data

Interviews with Federal 

Officials and Other Experts
Appendix I: Objectives, Scope and 

Methodology

Page 52 GAO-14-42 Child Sexual Abuse

National Center for Education Statistics. At HHS, we spoke with officials 

at the Administration for Children and Families’ Children’s Bureau. At 

Justice, we interviewed officials from the Office for Victims of Crime, 

Office of Juvenile Justice and Delinquency Prevention, and the Bureau of 

Justice Statistics. We interviewed experts from a broad range of 

education and child welfare groups including the American Association of 

School Administrators, the Association of Title IX Administrators, 

Committee for Children, the National Association of State Directors of 

Teacher Education and Certification, the National School Board 

Association, the Crimes Against Children Research Center, Darkness to 

Light, Stop it Now, and Stop Educator Sexual Abuse, Misconduct and 

Exploitation. We also interviewed officials at risk management 

organizations such as First Nonprofit Insurance Company and 

Praesidium, Inc.

To obtain national-level information on states’ requirements and practices 

for preventing and addressing sexual abuse and sexual misconduct by 

school personnel in public K-12 schools, we designed and administered a 

Web-based survey to state commissioners and superintendents of 

education in the 50 states and the District of Columbia. The survey was 

conducted between May and July 2013, with 100 percent of states 

responding to the survey. The survey included questions about state laws 

and regulations regarding employment practices, training, mandatory 

reporting, and investigations of allegations of sexual abuse and sexual 

misconduct by school personnel; state codes of conduct, and monitoring 

and guidance provided to school districts; and assistance from the federal 

government. In July 2013, we sent a follow-up question by e-mail to all 

survey respondents about requirements for background checks for 

contract employees working in public K-12 schools. We received 

responses to the additional question from 48 states through August 

2013.1

Because this was not a sample survey, there are no sampling errors. 

However, the practical difficulties of conducting any survey may introduce 

nonsampling errors, such as variations in how respondents interpret 

questions and their willingness to offer accurate responses. We took 

 

1

As of August 2013, Connecticut, New Mexico, and West Virginia had not provided 

responses to our follow-up question.

Case Studies
Appendix I: Objectives, Scope and 

Methodology

Page 53 GAO-14-42 Child Sexual Abuse

steps to minimize nonsampling errors, including pretesting draft survey 

instruments and using a Web-based administration system. Specifically, 

during survey development, we pretested draft instruments with officials 

in Alabama, Oregon, Pennsylvania, and Washington state. We also 

received comments on our draft survey from Education’s Office for Civil 

Rights, Office of Elementary and Secondary Education, and Office of the 

General Counsel; and HHS’ Administration for Children and Families. In 

the pretests and expert reviews, we were generally interested in the 

clarity of the questions and the flow and layout of the survey. For 

example, we wanted to ensure that terms used in the survey were clear 

and known to the respondents, categories provided in closed-ended 

questions were complete and exclusive, and the ordering of survey 

sections and the questions within each section were appropriate. On the 

basis of the pretests and expert reviews, the Web instrument underwent 

some revisions. A second step we took to minimize nonsampling errors 

was using a web-based survey. By allowing respondents to enter their 

responses directly into an electronic instrument, this method automatically 

created a record for each respondent in a data file and eliminated the 

need for and the errors associated with a manual data entry process. 

When the survey data were analyzed, a second, independent analyst 

checked all computer programs to further minimize error. Responses to 

the additional question received by email were analyzed and the results 

were corroborated by additional team members.

While we did not independently validate all of the information that state 

officials reported through our survey, we reviewed the survey responses 

overall to determine that they were complete and did not contradict one 

another. Also, where necessary, we requested further clarification from 

states to their responses on the additional survey question. On the basis 

of our steps, we believe our survey data from both sources are sufficiently 

reliable for the purposes of our work.

To gather more in-depth information about state and local requirements 

and practices to prevent and respond to child sexual abuse and 

misconduct by school personnel, we conducted site visits to four states: 

Georgia, Massachusetts, Virginia, and Washington. We selected states 

that were identified during our initial expert interviews as having 

developed laws or regulations to address prevention, detection, reporting, 

and/or investigation of child sexual abuse specifically by school 

personnel. We selected a total of six public school districts based on 

information about their policies and training to address such issues, 

expert recommendations, and the geographic location of the school 

Site Visits
Appendix I: Objectives, Scope and 

Methodology

Page 54 GAO-14-42 Child Sexual Abuse

district within each state we visited. We also based selections on states or 

local districts that had previously dealt with a case of reported child 

sexual abuse or misconduct by public K-12 school personnel. In addition 

to public school districts, we visited and gathered information from others 

who are involved in responding to cases of sexual abuse and misconduct 

by school personnel, such as officials from state educational and child 

welfare agencies, local police departments and prosecutors’ offices, and 

relevant child advocacy organizations.

Across the states we visited, we interviewed officials at four state 

educational agencies, which supervise elementary and secondary 

education, four state child protective service agencies, six public school 

districts, four school boards or teachers’ associations, two local 

departments of child protection, five police departments, five district 

attorney’s offices, two Children’s Advocacy Centers (CAC), one service 

organization for victims (non-CAC), and three child advocacy groups. At 

the school districts we visited, we spoke with school superintendents, 

attorneys, human resources personnel, school counselors, and school 

safety officials, when available. During each of these interviews, we 

collected information on state and local policies and procedures for 

responding to and investigating reports of child sexual abuse or 

misconduct and challenges and strategies in addressing reports of child 

sexual abuse and misconduct by public K-12 school personnel. We also 

gathered and reviewed general information about how cases were 

managed and any lessons learned. For the CAC and service 

organizations, we learned about procedures for handling reports, how 

interviews are conducted, the roles of the different agencies working with 

these organizations, and toured two CAC facilities, including the rooms 

where interviews with children take place. We also observed one school 

district’s training session for school personnel on the subject. We 

reviewed policies, training materials, and other relevant documentation.

Information we gathered on our site visits represents the conditions 

present at the time of our visit. We cannot comment on any changes that 

may have occurred after our fieldwork was completed. Our site visit 

findings cannot be generalized to the larger state or local education, child 

welfare, or law enforcement population.

To illustrate the complexities of cases of sexual abuse and misconduct by 

K-12 school personnel and how incidents are identified, reported, and 

investigated, investigators from GAO’s Forensic Audits and Investigative 

Service team reviewed closed criminal cases identified through media 

Closed Case Reviews
Appendix I: Objectives, Scope and 

Methodology

Page 55 GAO-14-42 Child Sexual Abuse

and legal database searches. We selected cases for further review to 

achieve variation among these criteria: gender of perpetrator, age of 

child(ren), if there were multiple victims of the same perpetrator, and 

perpetrators who held different positions in the school (teacher, school 

official, bus driver, janitor, etc.). The investigators reviewed five cases that 

were determined to be closed, with no pending litigation. The case study 

reviews included travel to several states and interviews with agencies and 

individuals involved in each case (including, but not limited to, law 

enforcement personnel, school administrators, prosecutors, and child 

welfare agencies). In addition, we reviewed case files and other relevant 

documents. Case study reviews were conducted from May 2013 through 

July 2013. Our investigative activities were conducted in accordance with 

standards prescribed by the Council of the Inspectors General for 

Integrity and Efficiency.
Appendix II: Case Studies

Page 56 GAO-14-42 Child Sexual Abuse

The facts described in the following five cases come from our 

investigators’ interviews with agencies and individuals involved in each 

case and a review of case files and other relevant documents. These 

cases are meant to illustrate concepts and issues discussed in the report; 

we made no independent evaluations of the merits of the underlying 

cases. (See App. I for information on the case study methodology.)

As discussed in the report, one of the challenges with preventing and 

addressing child abuse by school personnel is the failure to report 

allegations to law enforcement or child protective services. According to

investigators interviewed and documents we reviewed, in November 

2006, a mother learned from her second-grade daughter about activities 

occurring during the after-school program the daughter attended that 

suggested the possibility of sexual abuse by a second-grade teacher. On 

the day she learned of these activities, the child’s mother reported the 

alleged suspicious activities to the district superintendent, who informed 

the school principal. The next day the child’s parents met with the 

principal, who agreed to conduct an investigation. The principal’s 

investigation concluded with a phone call to the child’s parents in which 

the school principal stated the incident was a matter of “poor judgment” 

by the teacher. Unsatisfied, the child’s parents again contacted the district 

superintendent who ordered an investigation at the district level. About a 

month later, the parents received a letter stating that the district’s 

investigation was complete, and the incident was referred to as a 

personnel matter. The letter also said the school district could not discuss 

the issue with the parents. The parents reported that they moved their 

daughter to another school because they felt that the school district failed 

to handle the matter appropriately.

In January 2007, a report was made to the police department by a police 

officer, who had heard from his wife, a teacher in the same school district, 

an allegation that the male second-grade teacher may have sexually 

molested a female student. The police department initiated an

investigation. Also in January 2007, following the filing of the police report 

by the officer, the parents allowed their child to be interviewed by a 

trained child welfare investigator. The investigator’s interview identified a 

likelihood of abuse, and two additional potential victims were named by 

the child. Those potential victims were also interviewed by child welfare 

investigators and provided the investigators with detailed allegations of 

abuse similar to those found in the interview of the first child. Police 

investigators also interviewed the district superintendent, who shared the 

results of the district’s investigation and expressed his satisfaction with 

Appendix II: Case Studies

Case A
Appendix II: Case Studies

Page 57 GAO-14-42 Child Sexual Abuse

the results of the inquiry. Police investigators obtained and executed 

search warrants, which resulted in the seizure of toys, food items, 

scarves, a blindfold and a notebook from the teacher’s classroom. A 

semen stain was identified on the scarves and a blindfold that the police 

later matched through DNA analysis to the teacher. Two days after the 

police report was filed, the teacher was arrested, and he was eventually 

convicted of aggravated criminal sexual abuse against eight victims in this 

case and sentenced to 48 years in prison.

No report of alleged sexual molestation had been made by school or 

district officials to police or the child welfare agency. According to the 

prosecutor, state law requires that educators report potential abuse to law 

enforcement or the child welfare agency; he further said that notifying 

district officials does not satisfy this requirement. Their failure to report 

potential child sex abuse resulted in misdemeanor pleas by the school 

principal, the school district’s director of human resources, and the district 

superintendent.

During the course of their investigation, police investigators also learned 

that the teacher had previously been a second grade teacher in a 

neighboring school district for 2 years and had been allegedly involved in 

two incidents that were not brought to the attention of his subsequent 

employer. In the first incident, the school found that the teacher had been 

subscribing to inappropriate Internet web sites in violation of Board of 

Education policy and the school district’s code of conduct by downloading 

pornography to a school computer and sending that material from the 

school computer to his home computer. For that incident, he received a 

letter of reprimand in his personnel file from the school district’s Office of 

the Superintendent, telling him to desist and obtain counseling. 

Additionally, he was suspended with pay for 5 days and advised that any 

further incident of this nature would lead to termination. The second 

incident involved a female student, whose parents filed a complaint with 

the school about 7 months after the first incident involving pornography, 

alleging that the teacher told the student that she reminded him of a 

female movie star, gave the student pictures of that star, repeatedly 

stared at the student and touched the student unnecessarily on several 

occasions, though not in any inappropriate areas. The school district 

placed the teacher on paid administrative leave for the remainder of the 

school year and did not rehire him. When he left the school, he received a 

positive recommendation, and neither of the alleged incidents was 

relayed to his new employer.
Appendix II: Case Studies

Page 58 GAO-14-42 Child Sexual Abuse

In addition, during the investigation, the police investigators also learned 

about similar allegations involving two female students and the teacher 

while he was employed previously at the other school. The teacher was 

convicted of aggravated criminal sexual abuse of two children in this 

school district, for which he received an additional sentence of 12 years, 

to be served consecutively with the 48-year sentence.

Another challenge discussed in the report is the limitations of background 

checks. At the time of the incident, the second school district that hired 

the teacher would have conducted a background check on the teacher as 

part of the hiring process that consisted of a criminal history check, 

reference check, and a review of his teaching experience. Today, 

according to district officials, the school district also checks sex offender 

registries and related websites, performs additional reference checks 

including sources independently identified, takes fingerprints and checks 

the fingerprints for criminal history and identity, and, since 2008, does a 

check with the child welfare agency to see whether there are reports of 

pending child abuse investigations or findings of child abuse. Since this 

incident, the school district has also implemented periodic mandatory 

training using the child welfare agency’s staff to teach classes on 

mandatory reporting requirements and recognizing signs of potential 

abuse.

As described in the report, school personnel who commit sexual abuse of 

students may engage in “grooming” behavior with potential victims: 

behavior carried out with the intent of establishing trust with a student to 

facilitate future sexual activity. In October 2009, a middle school principal 

reported an allegation that a teacher at the school had engaged in 

inappropriate touching of students to an attorney for the school district, 

who then reported it to police. A subsequent investigation by the police 

department, which included interviews with parents and students, 

identified behavior between the teacher and multiple students that 

included taking female students out to dinner in groups as well as in oneon-one situations. It also identified instances of the teacher buying gifts 

such as a necklace, computer, cell phone, and camera for students. 

Additionally, instances of touching and kissing were identified between 

the teacher and some of the students. A forensic examination of the 

teacher’s computer revealed child pornography. The examination also 

revealed several pornographic pictures depicting sexual acts which 

appeared to be edited to depict the faces of his students on someone 

else’s body. The teacher was arrested in October 2009 and subsequently 

convicted in November 2011 of seven counts of indecent liberties with a 

Case B
Appendix II: Case Studies

Page 59 GAO-14-42 Child Sexual Abuse

child and indecent liberties with a student, and sentenced to 18-22 

months in prison on each count, consecutively.

As discussed in the report, sexual abuse and misconduct by school 

personnel may include a range of behavior. In some cases, behavior by 

school personnel that is not criminal may still be inappropriate. In 

November 2006, the mother of a 16-year-old female student contacted 

the local police department with an allegation of an inappropriate 

relationship between her daughter and a female high school 

teacher/softball coach. The mother became concerned after she:

• found letters in her daughter’s purse that she suspected were from the 

teacher;

• became aware of her daughter skipping classes to stay in the 

teacher’s classroom;

• found out that her daughter had been seen on the athletic track with 

the teacher;

• learned that the teacher had driven her daughter home from school; 

and

• realized that her daughter had visited the teacher’s residence.

In response, the police initiated an investigation that found that the 

relationship between the teacher and the student had progressed to a 

sexual relationship. Although the teacher was prosecuted and convicted 

of sexual assault, the state supreme court later overturned the teacher’s 

criminal conviction because the student had reached the state’s age of 

consent at the time of the sexual relationship. Following this case, the 

state changed its law to provide that consensual sex between a student 

and teacher, who has supervisory or disciplinary authority over the 

student, constitutes sexual assault even if the student is at or past the 

age of consent. The student was not in the teacher’s class, but the court 

recognized that, on occasion, the student was subject to the teacher’s 

authority while she was assigned to cafeteria duty and, as a student in the 

school, is expected to obey teachers because they are faculty members.

In addition, as discussed in more detail in the body of this report, 

preventative measures such as training may not necessarily prevent 

sexual abuse or misconduct by school personnel. In this case, the 

teacher, according to the principal, would have received annual training 

that identified standards of conduct for educators, which included what 

constitutes inappropriate behaviors between school personnel and 

students.

Case C
Appendix II: Case Studies

Page 60 GAO-14-42 Child Sexual Abuse

As discussed in the report, addressing allegations of sexual abuse or 

misconduct by school personnel can be facilitated by communication 

between the various agencies involved. In 2011, a mother reported to the 

local police department an allegation of an inappropriate relationship 

between her son, who was 17 years old at the time, and his former middle 

school bus driver. The mother made the report after finding suspicious 

items, including three pairs of women’s panties and photos of the female 

bus driver, clothed, on her son’s USB flash drive. The police interviewed 

her son, who told the detective that he and the bus driver loved each 

other and planned to get married when he turned 18 years old. He further 

stated to police that in 2009, when he was 15 years old, the bus driver 

engaged in a sexual encounter with him. The police immediately arrested 

the bus driver, who confessed to the sexual encounter during their initial 

interviews. The police formally notified the school district, per an 

agreement between law enforcement and the school district, and the bus 

driver was placed on suspension. The investigation revealed that the 

incident was a singular sexual encounter and did not identify other victims 

or prior complaints of inappropriate contact or allegations involving 

students against the bus driver. The bus driver was convicted in 2012 of 

taking indecent liberties with a child, received a sentence of 5 years in 

prison (of which 4 were suspended and 1 was stayed for 10 years), and 

was ordered to register as a sex offender, have no contact with the victim, 

obtain treatment from a licensed therapist, and to make a one-time 

restitution payment to the victim to cover the cost of his counseling 

treatment. Upon the conviction, the school district terminated the bus 

driver’s employment. Law enforcement officials who investigated the case 

reported that they had a good working relationship with the school district.

In another example of inter-agency cooperation, in August 2011, a mother 

contacted the county sheriff’s office to report allegations of inappropriate 

text messages and pornographic images on her 16-year-old daughter’s 

cell phone from a male high school coach. Upon receiving the initial 

report, the sheriff’s office notified school officials about the allegation and 

worked collaboratively with the school district to ensure appropriate 

administrative action. The principal said that at the time the high school 

did not have a policy that prohibited educators from interacting with 

students by cell phone or Internet. During interviews with detectives, the 

coach admitted that he sent inappropriate messages and images to the 

victim. In September 2011, the coach pled guilty to a charge of sexual 

battery of a minor and was sentenced to a term of 10 years. The 

sentence was suspended and he was placed on probation for 10 years 

and required to register as a sex offender. While there were no formal 

Case D

Case E
Appendix II: Case Studies

Page 61 GAO-14-42 Child Sexual Abuse

policies or procedures for how the prosecutor or detective worked with 

school officials, such collaboration did occur in this case. The 

prosecutor’s office obtained a conviction of sexual battery of a minor 

within 30 days of the initial report. The detective said the outcome of the 

investigation could not have been any better. He said they were able to 

investigate the crime and obtain a guilty plea in a short period of time – 

crediting the prosecuting attorney and cooperation they received from 

family and school personnel.
Appendix III: Comments from the Department 

of Education

Page 62 GAO-14-42 Child Sexual Abuse

Appendix III: Comments from the 

Department of Education
Appendix III: Comments from the Department 

of Education

Page 63 GAO-14-42 Child Sexual Abuse
Appendix III: Comments from the Department 

of Education

Page 64 GAO-14-42 Child Sexual Abuse
Appendix IV: GAO Contact and Staff 

Acknowledgements

Page 65 GAO-14-42 Child Sexual Abuse

Kay Brown, (202) 512-7215 or brownke@gao.gov. 

In addition to the contact named above, individuals making key 

contributions to this report were Sara Schibanoff Kelly, Assistant Director; 

Melissa Jaynes; Avani Locke; and Claudine Pauselli. Also contributing to 

this report were James Bennett, Gary Bianchi, Sarah Cornetto, Paul 

Desaulniers, Holly Dye, Wayne McElrath, Joel Marus, Jean McSween, 

Ramon Rodriguez, Almeta Spencer, Julie Spetz, and Helina Wong.

Appendix IV: GAO Contact and Staff 

Acknowledgements

GAO Contact:

Staff 

Acknowledgements:
Related GAO Products

Page 66 GAO-14-42 Child Sexual Abuse

Child Care: Overview of Relevant Employment Laws and Cases of Sex 

Offenders at Child Care Facilities. GAO-11-757. Washington, D.C.: 

August 19, 2011.

Child Maltreatment: Strengthening National Data on Child Fatalities Could 

Aid in Prevention. GAO-11-599. Washington, D.C.: July 7, 2011.

K-12 Education: Selected Cases of Public and Private Schools That Hired 

or Retained Individuals with Histories of Sexual Misconduct. GAO-11-200. 

Washington, D.C.: December 8, 2010.

Seclusions and Restraints: Selected Cases of Death and Abuse at Public 

and Private Schools and Treatment Centers. GAO-09-719T. Washington, 

D.C.: May 19, 2009.

Residential Facilities: Improved Data and Enhanced Oversight Would 

Help Safeguard the Well-Being of Youth with Behavioral and Emotional 

Challenges. GAO-08-346. Washington, D.C.: May 13, 2008.

Residential Treatment Programs: Concerns Regarding Abuse and Death 

in Certain Programs for Troubled Youth. GAO-08-146T. Washington, 

D.C.: October 10, 2007.

Related GAO Products

131209
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.