With an Overview of the Memorandum of Understanding Between the Department of Education (DOE) and the Department of Services for Children, Youth and Their.
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With an Overview of the Memorandum of Understanding Between the Department of Education (DOE) and the Department of Services for Children, Youth and Their Families (DSCYF) DEVELOPED BY THE CHILD PROTECTION ACCOUNTABILITY COMMISSION (CPAC) School Training - August 2012 HOW TO IDENTIFY AND REPORT CHILD ABUSE AND NEGLECT IN DELAWARE Slide 2 HOW MANY CHILDREN ARE UNSAFE BECAUSE THEY ARE ABUSED OR NEGLECTED? National Statistics In FFY 2009, 3.3 million allegations of child abuse and neglect were reported. 25% of the investigations determined at least one child was abused or neglected. In FFY 2009, 1,770 children died as a result of abuse or neglect. Delaware Statistics The Division of Family Services received 14,010 reports in FY 2011. Of those, 7,358 (53%) met the criteria for investigation. 1,651 reports were substantiated. Source: DHHS, ACF Child Maltreatment 2009;DHHS, ACF Child Maltreatment 2009 Family Services Intake and Investigation Statistics 2 Slide 3 DIVISION OF FAMILY SERVICES CHILD ABUSE & NEGLECT REPORT LINE 24/7 1-800-292-9582 HOW DO I RECOGNIZE CHILD ABUSE AND NEGLECT? 3 Slide 4 CHILD ABUSE As defined in 10 Del.C.§901(1), Abuse or abused child means that the person: - Causes or inflicts sexual abuse on a child; or - Has care, custody, or control of a child, and causes or inflicts: Physical injury through unjustified force as defined in §468of Title 11; Emotional abuse; Torture; Exploitation; or Maltreatment or mistreatment 44 Slide 5 55 UNJUSTIFIED FORCE INCLUDES BUT IS NOT LIMITED TO: Throwing the child, kicking, burning, cutting, strikingwith a closed fist; Interfering with breathing; Use of or threatened use of a deadly weapon; Prolonged deprivation of sustenance or medication, ordoing any other act that is likely to cause or does causephysical injury, disfigurement, mental distress,unnecessary degradation or substantial risk of seriousphysical injury or death. Slide 6 CHILD ABUSE AS A CRIMINAL OFFENSE 11 DEL. C. § 1103 Misdemeanor - causes physical injury to a child; or - causes physical injury to a child when the person has engaged in aprevious pattern of abuse and/or neglect of such child. Felony - causes serious physical injury to a child; or - causes physical injury to a child 3 years of age or younger; or - causes physical injury to a child who has significant intellectual ordevelopmental disabilities. The misdemeanor and felony offenses both require that the person recklessly or intentionally causes the physical injury. 11 DEL. C. § 1103 defines physical injury and serious physical injury. 6 Slide 7 NEGLECT As defined in 10 Del. C. §901 (18) "Neglect" or "neglected child" means that a person:a. Is responsible for the care, custody, and/or control of thechild; andb. Has the ability and financial means to provide for the careof the child; and…. 77 Slide 8 NEGLECT (CONT.) 1. Fails to provide necessary care with regard to: food, clothing, shelter, education, health, medical or other care necessary for thechild's emotional, physical, or mental health, or safety and generalwell-being; or 2. Chronically and severely abuses alcohol or a controlled substance, is not active in treatment for such abuse, and the abuse threatens the child's ability to receive care necessary forthat child's safety and general well-being, or 3. Fails to provide necessary supervision appropriate for a child when the child is unable to care for that child's own basic needsor safety, after considering such factors as the child's age, mentalability, physical condition, the length of the caretaker's absence,and the context of the child's environment. 8 Slide 9 SEXUAL ABUSE As defined in 10 Del.C.§901(21), "Sexual abuse" means any act against a child that is described as a sex offense in § 761(h) of Title 11 including: Sexual Harassment Indecent Exposure Incest Unlawful Sexual Contact Rape Sexual Abuse of a Child by a Person in a Position of Trust, Authority or Supervision. Sexual Exploitation of a Child Dealing in Child Pornography 9 Slide 10 DETERMINING AGE OF CONSENT FOR SEXUAL CONTACT Consensual sexual contact between two minors does not require a mandatory report, even if that sexual contact results in a pregnancy. Suspected sexual behavior by force or coercion against a minor (even by another minor) must be reported. 10 Slide 11 DETERMINING AGE OF CONSENT FOR SEXUAL CONTACT (CONT) 18 years and older: Can consent to sexual contact with other adults. Except: When the victim suffers from a cognitive disability, mental illness or mental limitation which renders the victim incapable of appraising the nature of the sexual conduct or incapable of consenting; If force or coercion occurred on school grounds or at a school function; or If sexual contact occurred between a student and a school employee, then a school employee must report to the school administrator or designee. Additionally, all of these incidents require a report to the police. 11 Slide 12 DETERMINING AGE OF CONSENT FOR SEXUAL CONTACT (CONT) 16 and 17 year-olds: Can consent to sexual contact with someone who is under 30 years of age. 12-15 year-olds: Can ONLY consent to sex with someone who is no more than 4 years older than the child. Under 12 years-old: Children under 12 years old CANNOT legally consent to sexual contact. All of these cases MUST be reported. Children CANNOT legally consent to sexual contact with anyone who is in a position of authority (e.g. family member, babysitter, coach, teacher, doctor, clergy, etc.). 12 Slide 13 ENHANCED PENALTIES FOR CRIMES ASSOCIATED WITH SEXUAL ABUSE OF CHILDREN Title 11 of the Delaware Code Relating to Crimes Against Children and Specific Offenses was amended on June 30, 2010 to clarify who is in a position of trust, authority or supervision over a child and to enhance the penalties for committing such offenses. The provisions of the present criminal code concerning rape and unlawful sexual conduct that contain position of trust were also consolidated as a single crime known as "sexual abuse of a child by a person in a position of trust, authority or supervision." 13 Slide 14 EMOTIONAL MALTREATMENT Emotional abuse - defined as threats to inflict unduephysical or emotional harm, and it may also includechronic or recurring incidents of ridiculing, demeaning,and making derogatory remarks. Emotional neglect - defined as incidents ofisolating/shunning, rejecting or ignoring the child. 14 Slide 15 DEPENDENCY 10 Del. C. § 908 (8) "Dependency" or "dependent child" means that a person:a. Is responsible for the care, custody, and/or control of the child;andb. Does not have the ability and/or financial means to provide forthe care of the child; and… 15 Slide 16 DEPENDENCY (CONT.) 1. Fails to provide necessary care with regard to: food, clothing, shelter, education, health care, medical care or other carenecessary for the child's emotional, physical or mental health, orsafety and general well-being; or2. The child is living in a nonrelated home on an extended basis without the consent and approval of the DSCYF or anyagency or court licensed or authorized to place children in anonrelated home; or3. The child has been placed with a licensed agency whichcertifies it cannot complete a suitable adoption plan. 16 Slide 17 DEPENDENCY INCLUDES Child Living in a Non-Related Home Inability to Complete Adoption Plan Out-of-State Runaway Abandoned Infant (Safe Arms) 17 Slide 18 SAFE ARMS FOR BABIES 1-800-262-9800 Safe Arms for Babies allows a parent to go to any Delawarehospital emergency department and leave their newborn ( 14 days old or younger ) with any emergency department staff or volunteer. Provides immunity from criminal prosecution forabandonment provided the baby is alive, unharmed andbrought into a hospital emergency department. Detailed information can be found at the Division of PublicHealths website: http://www.dhss.delaware.gov/dhss/dph/chca/dphahsab01.html 18 Slide 19 SUBSTANCE ABUSE & DOMESTIC VIOLENCE RISK FACTORS ASSOCIATED WITH ABUSE AND NEGLECT 19 Slide 20 SUBSTANCE ABUSE Parental addiction is a significant factor in child abuse and neglectcases, with studies suggesting 40% to 80% of families in the child welfare system are affected by addiction. Data indicates that abused and neglected children from substanceabusing families are more likely to be placed in foster care and to remain there longer than maltreated children from non-substance families. SOURCE: CWLA NATIONAL FACT SHEET 2008 20 Slide 21 SUBSTANCE ABUSE (CONT.) ENDANGERING THE WELFARE OF A CHILD 11 DEL. C. § 1102(A)(5) (5) The person commits the offense of Driving Under the Influence as set forth in § 4177 of Title 21, or the offense of Operating a Vessel or Boat Under the Influence as set forth in § 2302 of Title 23, and during the commission of the offense knowingly permits a child less than 18 years of age to be a passenger in or on such vehicle, vessel or boat. 21 Slide 22 DOMESTIC VIOLENCE Delaware law does not mandate reports of DV to lawenforcement for adult victims. DV cases involving children are mandated reports to DFSwhen the DV is chronic or severe/escalating and impairsthe caregivers ability to keep the child safe. In Delaware, there are a variety of services to help victimsof DV including 24 hour hotlines that can provide crisisintervention, resources, legal remedies and safetyplanning. 22 Slide 23 WHEN CHILDREN ARE INVOLVED IN DOMESTIC VIOLENCE Report cases to DFS of child abuse when a: Child is injured during an incident of domestic violence. Child is not injured but is at risk of injury, such as witnessingdomestic violence where a weapon or a potentially dangerousobject has been used or where a child has attempted tophysically intervene in a manner that puts the child in dangerof being injured. 23 Slide 24 WHEN CHILDREN ARE INVOLVED IN DOMESTIC VIOLENCE (CONT) Report cases to DFS of emotional harm to a child due to domestic violence when a: Child is aware of DV (either chronic or single incident)perpetrated against his/her caregiver by a domestic partner andthat involves a significant injury to the victim or use ofweapon; AND Child has a diagnosed mental health condition or behaviorsthat signify severe psychological harm. 24 Slide 25 DOMESTIC VIOLENCE SERVICES Child Inc.'s Domestic Violence ProgramNew Castle County (Bilingual): 302-762-6110 SAFE Program at People's PlaceKent and Sussex Counties: 302-422-8058Northern Kent County: 302-678-3886 Abriendo Puertas Bilingual HotlineSussex County: 302-745-9874 25 Slide 26 HOW DO I REPORT CHILD ABUSE & NEGLECT? DIVISION OF FAMILY SERVICES CHILD ABUSE & NEGLECT REPORT LINE 24/7 1-800-292-9582 26 Slide 27 TITLE 16, SUBSECTION 903 OF THE DELAWARE CODE STATES: Any person, agency, organization or entity who knows or in good faith suspects child abuse or neglectshall make a report in accordance with § 904 of thistitle.… 27 Slide 28 16 Del.C. §908 (a) states that Anyone participating in good faith in the making of a report or notifying police officers pursuant to this chapter, performing a medical examination without the consent of those responsible for the care, custody and control of a child pursuant to § 906(b)(5) of this title, or exercising emergency protective custody in compliance with § 907 of this title, shall have immunity from any liability, civil or criminal, that might otherwise exist,… CAN I BE HELD LIABLE FOR MAKING A REPORT ABOUT CHILD ABUSE AND NEGLECT? 28 Slide 29 There is a penalty for not reporting. 16 Del. C. § 914. Penalty for violation. a) Whoever violates §903 of this title shall be liable for a civil penalty not to exceed $10,000 for the first violation, and not to exceed $50,000 for any subsequent violation. b) In any action brought under this section, if the court finds a violation, the court may award costs and attorneys' fees. CAN ANYTHING HAPPEN TO ME IF I DO NOT REPORT CHILD ABUSE AND NEGLECT? 29 Slide 30 If you observe physical or behavioral indicators, ask Minimal Fact Questions, such as : – What happened? – When did that happen? – Where did that happen? – Did you tell anyone what happened? Write down childs exact words if you must speak to child. If the child is unable to communicate, then make the report based on your observations of the physical and/or behavioral indicators. WHAT SHOULD YOU DO IF YOU SUSPECT CHILD ABUSE OR NEGLECT? 30 Slide 31 Avoid Expressing disbelief, shock or anger, etc. Value judgments and accusatory statements Thank the child for telling you and tell the child it is not his/her fault. Tell the child you have to report the abuse to a professional. WHAT SHOULD YOU DO IF YOU SUSPECT CHILD ABUSE OR NEGLECT? (CONT.) 31 Slide 32 1. Do not interview the child multiple times. 2. Do not take pictures of the injuries or ask the child to undress. (Exception – medical providers) 3. Do not notify the parent/caretaker you are making a report. WHAT SHOULD YOU DO IF YOU KNOW/SUSPECT CHILD ABUSE OR NEGLECT? (CONT.) 32 Slide 33 WHAT INFORMATION IS NEEDED TO MAKE A REPORT? Demographics; Known information about the parents or siblings; Known information about the alleged child victims physical health, mental health, educational status; Information regarding medical attention that may be needed for injuries; Any information you have about the way the caregivers behavior is impacting the care of the child; and Known information that could put the childs or DFS workers safety in peril such as the presence of alcohol, drugs, weapons, dangerous animals or criminal behavior. 33 Slide 34 CHILD ABUSE REPORT LINE To report suspected child abuse or neglect in Delaware callthe 24 Hour Division of Family Services (DFS) Report Lineat 1-800-292-9582. Delawares 800# is a national and statewide number.Reports should not be made to local DFS offices. Spanish translation is available 24/7. DFS also accepts written reports and walk-in reports. Calls are digitally recorded for random quality assurancereviews. 34 Slide 35 Magic words are I want to make a report. If unsure, DFS needs to be the decider. Its okay to call theReport Line and discuss what you know. The person who spoke to or observed the child should make the report because it is required by statute and the Report Line mayhave questions about the childs disclosure or condition. DFS may have information about the family you dont knowabout. You will be informed at the time of your call whether the reporthas been accepted or not for investigation or you should receive acall back within 24 hours, if you provide your name. 35 CHILD ABUSE REPORT LINE (CONT) Slide 36 THREE QUESTIONS THAT WILL BE ASKED OF THE REPORTER 36 What are you worried about? What is working well? What needs to happen next? Slide 37 WHAT ARE YOU WORRIED ABOUT? CaregiverBehavior Impact on Child 37 Slide 38 GENERALIZATIONS VS. BEHAVIOR AND IMPACT How do you know? What are the caregiver behaviors a ssociated with it? When do those behaviors show themselves? How do those behaviors impact the child? How did you find out? What does the child know? What has the child seen? What are you worried is happening or will happen? She is mentally ill. 38 Slide 39 WHAT IS WORKING WELL? If DFS does not know what is working well they cannot know how worried to be. Questions will be asked that rigorously surface the history of protectionand how this can be applied to the safety of the children going forward. 39 Slide 40 To Keep the Child Safe, AND To Help the Family. WHAT NEEDS TO HAPPEN NEXT? 40 Slide 41 THE DIVISION OF FAMILY SERVICES Receives reports for all children in the State of Delaware that have been abused or neglected. Then DFS will do one of three things: 1. Accept the report and investigate the allegations or conduct a family assessment; or 2. Refer the report to law enforcement for investigation; or 3. Document the report, but not investigate the allegations. 41 Slide 42 NEW DFS RESPONSE TIMES Investigation Response Times Priority One – Within 24 hours Priority Two – Within 72 hours Priority Three – Within 10 days 42 Slide 43 MEMORANDUM OF UNDERSTANDING (MOU) BETWEEN DOE AND DSCYF The entire MOU can be found at: http://www.doe.k12.de.us/DDOEDSCYFMOU.pdf 43 Slide 44 OVERVIEW OF THE MOU Ensures Compliance with 14 DE Code § 4123, which requires full-time teachers to receive 1 hour of training every year in the detection and reporting of child abuse; Establishes Each Disciplines Roles and Responsibilities in the Reporting and Investigation of Child Abuse; Enhances Case Collaboration and Information Sharing; Delineates McKinney- Vento Protections; Establishes a Protocol for Transition to/from DSCYF to Local Education Agencies (LEAs) and Charter Schools; and Addresses Confidentiality and Dispute Resolution. 44 Slide 45 ROLES AND RESPONSIBILITIES: CHILD ABUSE REPORTING Local Education Agencies/Charter Schools shall: Report suspicion of abuse or neglect; Make a new report each time abuse or neglect is suspected; School employee who spoke to or observed the child shall make the call to the report line. Fax or mail the Mandatory Reporting Form to DFS within 72 hours for documentation. 45 Slide 46 ROLES AND RESPONSIBILITIES: CHILD ABUSE INVESTIGATION Division of Family Services will respond as follows for reports initiated by the school: Never release the source of the report; Decide whether or not to initiate the investigation on-site at the school; Contact the school about the expected response time; Report to the schools main office and provide ID, if a school response is warranted; Contact law enforcement for reports that would constitute a criminal violence against a child and may request a police response at the school or for the police to transport the child to the hospital; 46 Slide 47 ROLES AND RESPONSIBILITIES: CHILD ABUSE INVESTIGATION(CONT) Division of Family Services will respond as follows for reports initiated by the school: Discuss the interview process with the reporter and conditions under which school personnel could be present; Interview the child; Observe and photograph a childs physical injuries in the school environment; Never conduct a physical assessment of a child alleging sexual abuse; Never transport a child without legal custody, temporary emergency protective custody or a signed parental/legal guardians consent; 47 Slide 48 ROLES AND RESPONSIBILITIES: CHILD ABUSE INVESTIGATION(CONT) Division of Family Services will respond as follows for reports initiated by the school: Authorized to take Temporary Emergency Protective Custody of a child from a school, day care facility, or child care facility; and Permitted to inform the reporter about the following: -DFS responded, the child is safe or the child was placed; -Who is allowed to have contact with child; -Explain if there is something school should be doing; -Who school should call if something else happens; and -When the childs placement changes if the child was placed out of home. 48 Slide 49 ROLES AND RESPONSIBILITIES: CHILD ABUSE INVESTIGATION(CONT) Division of Family Services will respond as follows for reports initiated by other sources: Decide whether or not to initiate the investigation at the school; Attempt to contact the school about the expected response time; Report to the main office and provide ID if a school response is warranted; May request that the school nurse assist with the physical assessment of the child, but will not request the nurse to complete the physical assessment prior to the DFS response; and Wellness Center reports will be handled as external reports, but the school may be contacted to obtain information. 49 Slide 50 50 MULTIDISCIPLINARY RESPONSE TO REPORTS DFS and/or law enforcement will conduct an investigation for any report that involves an offense against a child. The Department of Justice (DOJ) will decide if there is enough evidence to prosecute criminally or civilly. Whenever appropriate, cases will also be referred to the Childrens Advocacy Center (CAC) for a forensic interview, medical exam and/or mental health screening. Slide 51 51 HOW CAN INFORMATION BE SHARED? In general, DFS will share information only when there is a signed release of information (informed, time limited consent). DFS, law enforcement, the CAC, and the DOJ exchange information on families and children when this information is needed to assist an investigation involving a shared client. Slide 52 CASE COLLABORATION AND INFORMATION SHARING For Active DFS Investigations: Verbal or written consent of a parent/legal guardian or relative caregiver is not required for DFS to investigate allegations of abuse, neglect or dependency or to interview a child. Information sharing is encouraged once the investigation has begun. No identified DFS caseworker Contact the Report Line and leave name and number Identified DFS caseworker Contact the caseworker directly 52 Slide 53 CASE COLLABORATION AND INFORMATION SHARING (CONT) For Active DFS Treatment Cases: Information can be exchanged with a consent. No identified DFS caseworker Contact the Report Line and leave name and number Identified DFS caseworker Contact the caseworker directly DFS caseworker will contact the school periodically to assess the childs educational status * For more information about the DFS Investigation and Treatment process, please review the DFS Primer: http://kids.delaware.gov/pdfs/DFSPrimer.pdf http://kids.delaware.gov/pdfs/DFSPrimer.pdf 53 Slide 54 CONFIDENTIALITY 54 DSCYF and each LEA/Charter School will comply with the relevant laws and regulations that govern confidentiality. DSCYF and each LEA/Charter School will provide information to each other which is not specifically protected in order to ensure the successful support of children and families. DSCYF and each LEA/Charter School will make concerted efforts to ensure that parents/guardians understand the importance of sharing information for the success of their child. Laws related to Confidentiality: Child Abuse Prevention and Treatment ACT (CAPTA) Family Educational Rights and Privacy Act (FERPA). Health Insurance Portability and Accountability Act (HIPAA) Slide 55 WHAT HAPPENS WHEN A STUDENT ENTERS FOSTER CARE? 55 In Delaware, all children in foster care are eligible for the protections and provisions under the McKinney- Vento Homeless Assistance Act. Slide 56 MCKINNEY-VENTO PROTECTIONS Local Education Agencies/Charter Schools shall: Ensure that children in foster care placement are provided the benefits of the McKinney-Vento Act for homeless children. Provide transportation to the foster childs school of origin when in the childs best interest. Use the Determining Feasibility of School Placement Form 56 Slide 57 MCKINNEY-VENTO PROTECTIONS(CONT) Department of Services for Children, Youth, and Their Families (DSCYF) shall: Enroll a child in foster care in school immediately after a decision in a Best Interest Meeting. Request a meeting with the school when there is a change in foster care placement. Provide/arrange transportation until LEA transportation to school of origin is established. Provide necessary information and documents. Request an Educational Surrogate Parent if appropriate. Attend an end of year Best Interest Meeting in May/June. 57 Slide 58 MCKINNEY-VENTO PROTECTIONS (CONT) Local Education Agencies/Charter Schools shall: Enroll a child in foster care in the new school within 2 school days of referral (after a Best Interest Meeting) even if DSCYF is unable to produce records. Transfer of records promptly. Ensure that sending school fully transfers credits, including partial credits. 58 Slide 59 MCKINNEY-VENTO PROTECTIONS (CONT) Local Education Agencies/Charter Schools shall: Accept DSCYF letterhead as proof of residency. Accept registration materials from DSCYF case workers via fax or electronically and schedule a meeting or teleconference with DSCYF. Host meetings with necessary parties as needed. Host the Best Interest Meeting in May/June. 59 Slide 60 WHAT IF A STUDENT TRANSITIONS TO A DSCYF SCHOOL PROGRAM? 60 DOE and DSCYF have developed a protocol to ensure that children successfully transition to/from DSCYF school programs including licensed or contracted providers.. Slide 61 TRANSITION TO/FROM DSCYF TO LEAS AND CHARTER SCHOOLS 61 The protocol establishes the following: - Specific timeframes for meetings - Purposes of each meeting - Necessary participants - Actions to be taken - Information to be shared Protocol for Transition to/from DSCYF Programs to LEA or Charter Schools Slide 62 TRANSITION TO/FROM DSCYF TO LEAS AND CHARTER SCHOOLS (CONT) 62 Four timeframes for Transition Meetings are identified: - Before Admission to DSCYF School Programs Consents signed School information shared ASAP, but no later than 3 school days Notify District of Admission Date into program and date of initial meeting - Initial Educational Planning Meeting No later than 30 days after admission Submit Completed Educational Intake/Update (EIU) Form and educational records Schedule future Educational Planning Review Meetings Slide 63 TRANSITION TO/FROM DSCYF TO LEAS AND CHARTER SCHOOLS (CONT) 63 - Educational Planning Reviews DSCYF notifies school representative of dates Update EIU for each review Include face to face contacts with school representative Approximate discharge projections conveyed to school personnel - Discharge Planning from DSCYF School Programs No less than 2 weeks before discharge Identify services that need to be provided by receiving school as soon as possible Evaluate for special education services, or IEP needs to be changed Slide 64 WHAT HAPPENS IF REPRESENTATIVES FROM THE TWO DEPARTMENTS CANNOT AGREE? All attempts should be made to resolve disputes at the LEA/Charter School level with the District Liaison and appropriate DSCYF liaison. When disputes cannot be resolved, they shall be referred, in writing, to the Secretary of Education who may appoint a designee and the appropriate DSCYF Administrator as follows: - DPBHS – Director of Clinical Services - DFS – Administrator of the Office of Childrens Services - DYRS – DMSS Supervisor of Educational Services 64 Slide 65 CHILD WELFARE TRAININGS AND RESOURCES Guidelines for Responding to Teen Dating and Sexual Violence in Delaware Schools To obtain a copy of the guidelines: courts.delaware.gov/childadvocate/cpac_teenreporting.stm courts.delaware.gov/childadvocate/cpac_teenreporting.stm For more information, please contact the Domestic Violence Coordinating Council (DVCC) at 302-255-0405. Darkness to Lights Stewards of Children For more information: www.stewardsofchildrendelaware.orgwww.stewardsofchildrendelaware.org Onsite Training: Please contact Nikki Mowbray by email at email@example.com or call 302- 472-YMCA ext. 25. Online Training: Available at darkness2light.org.darkness2light.org School-Based Personal Safety Programs for Children For more information: www.pcadelaware.org/programs/www.pcadelaware.org/programs/ Onsite Training: Please contact Prevent Child Abuse Delaware at 302-425-7490. 65 Slide 66 66 66 Slide 67 67 Questions? Who?What ?When? Where ? How?Why?