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Office of Counsel

Programs for Minors

Do you have questions about the new policy on Programs for Minors?

A Central Registry for Programs for Minors has been established within the Office of Counsel/Risk Management (“Central Registry/Risk Management”). This Central Registry is where Programs for Minors should be registered, and it will also serve as a resource for information and forms related to these programs. If you have a question concerning the new Programs for Minors Policy, please first consult the policy and then check to see if the answer is provided in the answers to Frequently Asked Questions, below. If you still have a question related to a Program for Minors, please next direct the question to the designated Program Administrator or Program Sponsor within your school, division or department. If you have a question that can’t be answered by either of these methods, please contact the Central Registry/Risk Management at 758-7600, or email Mary Goldenberg ( or Spence Studwell ( with your question.

Frequently Asked Questions

Why was it necessary to create the Policy on Minimum Standards for Programs for Minors and Children?

Many schools and divisions of the University offer programs for minors and children, and the approaches to managing the related risks have been similarly diverse. The Policy balances the need for a uniform set of program requirements to protect minors under our care with the flexibility for schools and divisions to implement these requirements in a way that suits the particular needs of each program.

Does the Policy apply to every encounter with a child or minor on campus?

No. For example, the Policy does not apply to University events events that are open to people of all age groups in which children may be present such as fairs or festivals, or University events at which children will be accompanied at all times by a parent or legal guardian. Generally, the Policy applies to organized programs where the University is taking custody and control of minors as part of the program.

If I am a Dean or a Division Head, what do I need to do to be in compliance with this Policy?

By July 15, 2013, you must designate one or more program administrators who will be responsible for any Programs for Minors that currently exist within your school or division, and/or any Program that is expected to be offered during the 2013-14 academic year. If your school or division does not currently have any Programs for Minors and you do not anticipate offering such a program during the academic year, identifying one or more responsible program administrators at this time is optional. However, if you elect to defer naming an administrator, you as the Dean or Division Head are responsible for remembering to designate and identify an administrator later, in the event your school or division adds a Program for Minors. You may provide the name(s) of designated administrators by email to Mary Goldenberg ( or Spence Studwell (

If I have been designated as a responsible program administrator, what do I need to do to be in compliance with this Policy?

Program administrators should be prepared to meet the requirements of the policy beginning no later than September 1. The first step should be to determine whether your school or division is currently running any Programs for Minors and children covered by this Policy. If not, report to the Central Registry/ Risk Management that there are currently no covered programs within your school or division. If there are covered programs, proceed to the next steps.
For each covered program currently operating within your school or division, and any expected to be offered during the 2013-14 academic year, you must by September 1:

  • Register the program with the Central Registry/Risk Management;
  • Make arrangements to have background checks conducted on the employees who will work with minors as part of the program, as described in the Policy;
  • Develop a plan for supervision of minors consistent with the Policy; and
  • Train employees on the Policy and the plan.

How do I centrally register the program(s) I am responsible for?

Register all covered programs with the Central Registry/Risk Management. The information can be sent by email to: or A form for registering programs is currently in development and will be added to the website as soon as it is available; in the interim the information can be sent to Risk Management by email. The information must include at a minimum a description of the program; the signature of the Program Administrator; the name and contact information for the Program Sponsor; a statement confirming that required background checks have been completed or will be completed prior to the start of the program; a description of the plan for supervision of minors and for training employees; and a statement confirming that the employees have been trained or will be trained prior to the start of the program. Note that these requirements pertain to both currently existing programs and programs that will be offered during the 2013-2014 academic year.

Which employees need to have a background check conducted, how often does the background check need to be repeated, and how do I arrange the background check?

All adult employees who will have direct, regular and frequent contact with minors as a part of performing their University jobs or assigned roles in connection with a Program for Minors are required to have a background check that has been done within the last three years on record with the University at the time of hire and/or prior to beginning work with minors. (See Policy § 5). An approved vendor should be used to conduct the background check. For a list of approved vendors contact your HR business representative.

Who will provide the training, and what needs to be included in the training that employees working in these programs receive?

Each school or division offering a Program for Minors is responsible for training its employees covered by the Policy, and is permitted the flexibility to design a method for training best suiting its needs. Employees working with minors as part of a Program for Minors must be made familiar with the requirements outlined in the Policy. For example, covered employees should be familiar with the requirements for appropriate supervision of minors, and the appropriate behavioral boundaries that must be observed, as outlined in the Policy.

Will any additional training materials be provided?

Pilot testing of the Policy and its new requirements is currently underway and will continue over the summer. If any helpful materials are developed during the pilot program testing will be disseminated to program administrators. However, schools and divisions wishing to offer these programs should get started on developing their own training programs based on the content of the Policy.