Policy on Programs for Minors

Many University schools, divisions, Medical Center, and Affiliates offer programs for minors, each with diverse approaches to risk management. This policy establishes a uniform set of requirements to protect minors under our care, while allowing flexibility for schools and divisions to implement these requirements in a way that best suits their specific programs.

No, it does not. For instance, the policy does not cover University events open to all age groups where children might be present (e.g., fairs or festivals), or events where children are always accompanied by a parent or legal guardian. Generally, the policy applies to organized programs where the University, Medical Center, or Affiliates assume custody or supervisory control of minors as part of the program.

You must designate one or more Program Administrators responsible for any existing or anticipated Programs for Minors within your school or division.

• If your area currently has no Programs for Minors and doesn’t anticipate any this year, designating a Program Administrator now is optional.
• However, if you defer this designation, you remain responsible for ensuring a Program Administrator is named if a Program for Minors is added later.
• You can submit the name(s) of designated Program Administrators via email to the Programs for Minors Help mailbox.

Program Administrators are responsible for meeting the policy requirements. Your first step is to identify any Programs for Minors currently operating or expected to be offered within your school or division that are covered by this policy.

For each covered program, you must:

• Register the program with the Central Registry.
• Arrange for background checks for employees working with minors in the program, as outlined in the Policy.
• Develop a supervision plan for minors consistent with the Policy.
• Obtain appropriate parental consent forms and waivers, if applicable.
• Ensure employees are trained on the Policy and program plan by assigning and verifying completion of the mandatory MyPath module, “Minimum Standards for Programs for Minors and Children.”

You must register all covered programs with the Central Registry. Completing the Central Registry form verifies that all policy requirements are met for both existing programs and those planned for the year.

Yes, all new and existing programs must be registered annually. This ensures that proper consent/waiver forms, background checks, and training are verified, especially as participants or supervising individuals may change.

• Who: All employees who will have direct, regular, and frequent contact with minors as part of their job or assigned role in a Program for Minors.
• Frequency: Background checks must be on record with the University within the last three years at the time of hire and/or before starting work with minors.
• Arrangement: An approved vendor must be used. For a list of approved vendors, contact your HR business representative or email employment@hr.rochester.edu.

Each school or division offering a Covered Program is responsible for training its employees.

• Mandatory Module: We’ve created a MyPath training module, “Minimum Standards for Programs for Minors and Children,” which meets the policy’s training requirements. This module can be assigned to responsible individuals for completion.
• Annual Awareness: Additionally, all employees must complete an annual awareness training module as part of their general annual training. This module is automatically assigned by the Training and Education team.

This policy applies to all University departments that meet the definition of a Covered Program. There are limited exceptions that have been reviewed and approved by senior leadership. If you have questions about this policy or whether your program is considered a Covered Program, please email the Program for Minors Help mailbox.

The Parental/Guardian Release, Consent, and Permission Form  (“Form”) is a template provided to help you obtain parental permissions and liability waivers. This template can be customized to fit your specific Covered Program. If you have questions or wish to modify the Form or your existing documentation, please contact the Office of Counsel or the Program for Minors Help mailbox for assistance.

You will receive an email confirming your successful registration of a Covered Program. However, this confirmation does not signify approval that your program meets all policy requirements. It is the responsibility of the Program Administrator and Program Sponsor to ensure full policy compliance. The Office of Integrity and Compliance or the Office of Internal Audit may audit any registered Covered Program for compliance at any time.