Advisory Group Member Tells BOE to Reject Policy as Written. Tells BOE to Reflect Upon the Words of Augustine of Hippo, "Right is right even if no one is doing it; wrong is wrong even if everyone is doing it.”

Comments on proposed policy and protocols regarding child abuse and neglect.

6/7/15 Submitted to Montgomery County Board of Education

By: Jennifer Alvaro

Thank you in advance for your time and consideration in this matter. For 3 years I have been engaged with Montgomery County schools and officials to improve their prevention and response to child sexual abuse of its students. As a member of the original MCPS Child Abuse Work group (formed due to my advocacy in April of 2014); and as a member of the current Child Abuse Advisory group I would urge you NOT to implement the current policy as submitted to you by the schools.

The current version of the draft policy appears superficially to be a comprehensive response to the astounding trail of abuse committed over years by dozens of school system employees and contractors against our children. In reality the policy and regulations are so riddled by errors, loopholes and conflicting information they would be a step backwards instead of forward.

I will not waste time here enumerating the legal flaws in the policy or regulations, I would instead refer you to the excellent submission by Ellen Mugmon for that information.

Now is not the time to mince words or spare feelings. Mincing words, sparing feelings and ignoring reality have landed MCPS in the national spotlight for failing in every sense of the word to do what is right to protect our children from those who have roamed freely in our schools and have been allowed to harm them, their friends, their families, other staff and their communities.

This policy and these procedures, even if corrected regarding the legal aspects, will still only be words on paper unless you demand other action be taken as well. This plan is doomed to failure unless there is an infrastructure to implement, maintain and continue its mission. Parceling aspects of the work out among various departments and people (who have no expertise in this field) is planning for failure. This plan is doomed to failure as long as the system continues to operate in secrecy, not only from the public but from its own advisory group members as well. This plan in doomed unless other correlating documents / policies / departments / regulations are brought into line and into compliance with these policies. For example, how long will the board continue to allow MCPS to tell staff and students (regarding sexual harassment):

"Prohibited conduct may include, but is not limited to, unwelcome behavior of a sexual nature. For example: Grabbing, touching, or patting / Sexual propositions / Sexually offensive pictures, magazines, notes, calendars, cartoons, or jokes / Unwanted flirtations or advances / Verbal abuse / Repeated pressure or requests for sexual activities / Rewards for granting sexual favors or the withholding of rewards for refusing to grant sexual favors /Graphic comments about an individual’s body or dress / Sexually degrading names / Such conduct may also constitute sexual harassment. In determining whether prohibited conduct constitutes sexual harassment, consideration will be given to the totality of the circumstances, including the context in which the conduct occurred. Dating or sexual relationships between employees/adult volunteers and students is prohibited.”
http://www.montgomeryschoolsmd.org/info/sexualharassment/

Shockingly, students and staff are advised to report the aforementioned behaviors NOT to police or Child Protective Services but rather to school staff and parents. This breach of duty has been brought repeatedly to the attention of your staff over the past year and yet, to this day, remains unedited on your website. When will an employee code of conduct be published? Codes of conduct for staff and volunteers are a critical piece of any response to addressing child abuse & neglect. Why is participation in the drafting of the code being hidden from Advisory group members and limited to
“internal stakeholders” / “superintendent’s cabinet”?

These are some of many examples which could be provided to highlight the egregious nature of what is acceptable, condoned and allowed to continue under the guise of protecting our children.

I ask you to demand a full, impartial investigation be conducted (with a public report and accounting) regarding the systemic failure of the schools to protect our children and staff from these abuses over the past decades.

I ask you to reject this policy as currently written and if and when corrected, continue to reject it without reviewing and approving the procedures, regulations, MOUs and other corresponding components (specifically the secret database of suspicious and inappropriate employees and those on restricted plans / instructions) related to this critical work. I ask you to commit to the protection of our children and staff. I ask you to reflect upon the words of Augustine of Hippo, "Right is right even if no one is doing it; wrong is wrong even if everyone is doing it.”

Sincerely,

Jennifer Alvaro
MCPS Child Abuse Advisory Group Member 
Parent of 2 MCPS Students 
Alumni of MCPS Schools 
Licensed Clinical Social worker (MD &VA) 
Certified Sex Offender Treatment Provider

Comments on Proposed Policy and Protocols Regarding Child Abuse and Neglect by Parents' Coalition of Montgomery County, Maryland