Child Safe Standards Compliance Monitoring Framework (2018-2019) For organisations funded and/or regulated by the Department of Health and Human Services

To receive this publication in an accessible format, email Child Safe Orgs <childsafeorgs@dhhs.vic.gov.au>.

Authorised and published by the Victorian Government, 1 Treasury Place, Melbourne.© State of Victoria, Department of Health and Human Services, August 2018.

ISBN 978-1-76069-563-7 (online/pdf/MS word)

Available at <https://providers.dhhs.vic.gov.au/child-safe-standards>

1. Contents

1. Contents..........................................................................................................................................

2. Introduction.....................................................................................................................................Purpose......................................................................................................................................................

The Standards............................................................................................................................................

Objectives of the framework.......................................................................................................................

Principles of the framework.........................................................................................................................

Scope of framework....................................................................................................................................

3. Roles and responsibilities.............................................................................................................Department of Health and Human Services................................................................................................

Disability Services transition to NDIS..........................................................................................................

Department funded and/or regulated organisations....................................................................................

Commission for Children and Young People..............................................................................................

4. Monitoring compliance..................................................................................................................Identifying non-compliance.........................................................................................................................

Addressing non-compliance........................................................................................................................

Assessing compliance with the Child Safe Standards................................................................................

Compliance tools........................................................................................................................................

Appendix 1: Terminology.......................................................................................................................Acronyms..................................................................................................................................................

Legislative terms.......................................................................................................................................

Appendix 2: Child Safe Standards........................................................................................................Child Safe Standards................................................................................................................................

Reportable Conduct Scheme....................................................................................................................

Appendix 3: Obligations of organisations under the Standards........................................................Overview...................................................................................................................................................

Compliance expectations..........................................................................................................................

Indicators of compliance...........................................................................................................................

2. IntroductionPurposeThe Child Safe Standards Compliance Monitoring Framework (the framework) sets out the Department of Health and Human Services’ (the department) approach to monitoring the compliance of its funded and/or regulated organisations with Child Safe Standards (the Standards).

On 26 November 2015, the Child Wellbeing and Safety Act 2005 (the Act) was amended to introduce the Standards which apply to all organisations that provide services or facilities for children in Victoria.

The department as a relevant authority under Schedule 1 of the Act has responsibility for promoting and monitoring compliance with the Standards for organisations that it funds and/or regulates (referred to as ‘entities’ in the legislation) which provide services or facilities to children.

The framework will be reviewed annually or more frequently when required by a regulatory or department strategy change.

The StandardsThe Standards have been introduced to drive cultural change in organisations so that protecting children from abuse is embedded in everyday thinking and practice. The Standards are outcome focused and principle based to reflect the diversity and size of organisations which are required to adopt a child safe environment. The Standards are as follows:

Standard 1: Strategies to embed a culture of child safety through effective leadership arrangements

Standard 2: A child safe policy or statement of commitment to child safety

Standard 3: A code of conduct that establishes clear expectations for appropriate behaviour with children

Standard 4: Screening, supervision, training and other human resources that reduce the risk of child abuse by new and existing staff

Standard 5: Processes for responding to and reporting suspected child abuse

Standard 6: Strategies to identify and reduce or remove risks of child abuse

Standard 7: Strategies to promote the participation and empowerment of children

The Standards are underpinned by the following set of principles:

Promoting the cultural safety of Aboriginal children

Promoting the cultural safety of children from culturally and/or linguistically diverse backgrounds

Promoting the safety of children with a disability.

Objectives of the frameworkThe framework aims to:

clarify the department’s roles in promoting, monitoring, and enforcing compliance with the Standards.

provide example indicators for compliance with the Standards, for organisations that are funded and/or regulated by the department

achieve improved understanding of compliance requirements for the Standards by supporting organisations through guidance and advice.

Principles of the frameworkThe department uses an outcomes and risk based approach to regulating its funded and/or regulated organisations. This is in line with contemporary best-practice regulation and whole of Victorian Government regulatory policy.

The regulatory principles that underpin the department’s approach to monitoring compliance are informed by better regulatory principles including:

Principle Commitment

Risk-based The department’s regulatory approach will be proactive and responsive in identifying, assessing and responding to risk, prioritising and targeting resources toward specific groups or behaviours that pose the greatest risk to the department’s outcomes.

Intelligence-led

The department’s regulatory approach will involve analysing incoming intelligence and data in order to allow the regulator to be responsive and accurate when assessing risk and undertaking compliance activities.

Outcomes-focused

Regulatory practice and decision-making will be driven by outcomes. Progress against outcomes will be measured to ensure continuous improvement and thereby will help to build the capabilities and capacity of organisations in the delivery of their services.

Impartial The department will act within its powers, with integrity and without any real or perceived conflicts of interest.

Collaborative Where the various departmental regulatory regimes, and those of other agencies, intersect, the regulator will work together to maximise effectiveness and minimise regulatory burden.

Proportionate The department’s regulatory response should be proportionate to the problem that it intends to address and should be based on an assessment of risk.

Having regard for the regulatory principles, the framework will:

build an organisational culture of child safety that emphasises continuous improvement

establish a monitoring compliance approach that is consistent with the Act

act in a transparent and proportional manner to compliance enforcement

minimise the administrative burden for funded and/or regulated organisations where possible.

Scope of frameworkThis framework applies to organisations funded and/or regulated by the department that provide services or facilities for children.

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3. Roles and responsibilities

Department of Health and Human ServicesUnder the Act, it is the department’s role to promote and oversee the Standards with organisations that it funds and/or regulates as a ‘relevant authority’. This includes:

out of home care

disability services

community services targeted at the safety and wellbeing of children, young people and families

public, private and denominational hospitals and health services

ambulance services

community health services

publicly funded mental health services and drug or alcohol services

peak sporting organisations.

The department will undertake this function using existing levers available to it as a regulator and/or funding/contract manager. The department has a range of legislative and administrative tools to support its role in monitoring and enforcing compliance.

Depending on the type of relationship the department has with an organisation, for example as a regulator or contract manager, the department will apply its powers in a risk based and informed manner commensurate with the identified non-compliance. The department will only engage in regulatory action where power and authority to act is provided through funding agreements or regulatory mechanisms.

The department will consider enforcement action on a case by case basis and this could take the form of guidance and advice, issuing a compliance action plan to help an organisation achieve compliance or more serious interventions such as a notice to comply or referral to the Commission for Children and Young People (the Commission).

Disability Services transition to NDISThe department is transitioning disability services to the National Disability Insurance Scheme (NDIS). During the transition period, the department remains accountable for ensuring that NDIS funded organisations are addressing the quality and safety requirements which apply to department funded organisations. From 1 July 2019, the department will not be a relevant authority for these service providers unless they provide services in other areas that are in-scope.

This document applies to NDIS disability service providers throughout the transition, and will be updated once future NDIS arrangements are clarified.

Department funded and/or regulated organisationsDepartment funded and/or regulated organisations that provide services or facilities to children play a critical role in keeping children safe and must comply with the Standards.

The responsibilities of organisations include:

taking action to ensure that they comply with the Standards

taking action to address non-compliance with the Standards

responding to requests for information from the department or the Commission about their compliance with the Standards.

Commission for Children and Young PeopleThe Commission is an independent statutory body which was established to promote improvement and innovation in policies and practices to protect the safety and wellbeing of Victorian children and young people, with a specific focus on vulnerable children and young people.

The Commission and the department play important complementary roles in promoting and overseeing compliance with the Standards.

The Commission has primary oversight and regulatory responsibility for the Standards and powers to oversee and enforce organisations’ compliance with the Standards. In accordance with section 32(2) of the Act, the Commission may request that a relevant authority (such as the department) takes action under any applicable law, contract or agreement to promote or require compliance of an entity with the Standards.

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4. Monitoring complianceMonitoring compliance with the Standards is a core regulatory function of the department.

All organisations funded and/or regulated by the department that provide services or facilities to children must comply with the Standards.

The department recognises that providing effective assistance and advice to regulated entities reduces the risk of non-compliance with the Standards. Information, guidance and advice are important regulatory functions to promote voluntary compliance, improve understanding and build capacity of organisations to meet the Standards and improve outcomes for vulnerable children.

The department will promote compliance of the Standards to all organisations that it funds and/or regulates in order to support these organisations with their compliance. The department will respond to compliance concerns using existing oversight and reporting mechanisms. The department’s approach to monitoring compliance with the Standards includes:

a collaborative and risk-based approach to identifying systemic child safety risks at an organisational and sector level

monitoring through existing regulatory and performance management mechanisms of the department

a more integrated and consistent approach to service correction and improvement.

The department will socialise a targeted compliance assessment process to support better regulatory practice amongst funded and /or regulated organisations and promote service improvements once the current framework (2018-2019) has been implemented and tested with in-scope organisations.

Identifying non-complianceThe department may identify concerns about an organisation’s compliance with the Standards through existing regulatory and contractual mechanisms, including:

the agency’s annual performance review through the department’s Funded Organisations Performance Monitoring Framework

failure to comply with program requirements

an incident investigation or reportable conduct investigation

a complaint review

a performance audit, service review or independent reviews

failure to respond to allegations of abuse as identified through incident reporting, complaint systems or the reportable conduct scheme

failure to comply with the reportable conduct scheme

failure to comply with legislated or contractual requirements, such as safety screening.

The department may also become aware of concerns about an organisation’s compliance through a referral from the Commission. In determining the appropriate compliance intervention, the department make an assessment on a case by case basis, taking into account an organisation’s actions to mitigate or resolve risks and achieve compliance.

Addressing non-complianceThe department addresses non-compliance to meet service delivery expectations and drive continuous improvement of entities that must embed the Standards in their organisations.

The department’s compliance monitoring efforts will focus on services with the highest risk to children through identifying areas of non-compliance and mapping non-compliance against the requirements of the Standards. The department will take an escalated approach to enforce compliance with the Standards based on identified risk. A risk based decision making framework aims to ensure actions taken are commensurate with risk. This enables the department to undertake appropriate and proportionate actions when non-compliance is identified.

Where an organisation’s compliance with the Standards is identified to be non-compliant (or at risk), the department’s intervention will reflect the identified risk to child safety (Appendix 4), and the nature, probability and impact of issues associated with non-compliance with the Standards.

This means that where there are:

Low levels of risk: Interventions may include an assessment of compliance and remedial action plans to identify and address areas of non-compliance.

Moderate levels of risk: Interventions such as performance audits and service reviews may be initiated to assist assessment and enforcement of compliance with the Standards.

High levels of risk: An organisation which provides higher risk services will have a high inherent level of risk, but where it introduces appropriate controls to reduce risks, the residual risk posed by the organisation as a whole, will be lower.

When planning its compliance interventions, the department will be guided by the terms of an organisation’s contractual agreement with the department and the department’s Better Regulatory Practice Framework <https://dhhs.vic.gov.au/publications/better-regulatory-practice-framework>.The department will also consider the risk to child safety posed by an organisation.

Once a risk has been identified and categorised, the department will assess the risk against an organisation’s compliance maturity history to appropriately and proportionately address the issue.

Assessing compliance with the Child Safe StandardsThe department has developed a compliance model which identifies indicators of compliance and non- compliance to help assist organisations in understanding their obligations in implementing the Standards and to help focus on continuous improvement.

All organisations within scope are expected to comply with each of the Standards. Compliance can only be met against each standard with attention to the child safe principles:

promoting the cultural safety of Aboriginal children

promoting the cultural safety of children from culturally and/or linguistically diverse backgrounds

promoting the safety of children with a disability.

Guidance is available on the Child Safe Standards page <https://providers.dhhs.vic.gov.au/child-safe-standards> on the department’s Service Providers website and the Child Safety page <https://ccyp.vic.gov.au/child-safety/> on the Commission for Children and Young People’s website to support organisations to comply with the Standards.

Compliance toolsContemporary regulatory practice focuses effort on building the capacity of entities to better understand their obligations under the legislation and therefore deliver services that are in line with the Standards. The department’s Better Regulatory Practice Framework outlines a range of different regulatory compliance tools to help achieve compliance and build the understanding of funded and/or regulated organisations including:

guidance and support

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assisted compliance

proactive compliance

graduated and proportionate sanctions

full force of the law.

A range of compliance tools are outlined in the Better Regulatory Practice Framework, for example, lower level interventions such as guidance and support to more stringent and responsive interventions such as restrictions on registration and cessation of funding.

Program specific regulators or contract managers are unlikely to have the full range of tools within their individual program, and therefore must consider the:

extent and limitations of their compliance tools

complementary compliance tools of external agencies, such as co-regulators, that could be used as part of a co-ordinated response

other administrative tools that are available to deliver outcomes (for example, through funding various programs and services).

The department may seek legal advice when making a decision about ongoing, systemic and wilful non-compliance.

When deciding the most appropriate enforcement response, the department must determine:

the outcomes it seeks to achieve

any potential risks to vulnerable children and the department

options for achieving the desired outcome.

As part of this approach, where there is a high and immediate risk to the safety of children, the department will take immediate action to ensure child safety.

Further informationFurther information about the Child Safe Standards <https://providers.dhhs.vic.gov.au/ child-safe-standards> can be found on the department’s website. This includes additional resources that have been designed for organisations that are funded and/or regulated by the department. In particular, an overview of the Victoria Child Safe Standards <https://providers.dhhs.vic.gov.au/overview-victorian-child-safe-standards-word> has information to help organisations to understand the requirements of each of the Child Safe Standards.

All organisations may also refer to the information and resources available on the Child Safety page <https://ccyp.vic.gov.au/child-safety/> on the Commission for Children and Young People’s website.

Appendix 1: Terminology

AcronymsTerm Definition

CSRU The department’s Child Safeguarding Regulations Unit

DJR Department of Justice and Regulation

DWES Disability Workers Exclusion Scheme

EAP The department’s Employee Assistance Program

ESU The department’s Ethical Standards Unit

NDIS National Disability Insurance Scheme

OoHC Out of Home Care

Organisation A department funded and/or regulated organisation

WWCC Working with Children Check

WWCC Unit Working with Children Check Unit

Legislative terms

Child Safe Standards (Child Wellbeing and Safety Act 2005)Term Definition

Applicable entity "applicable entity" means—(a) an incorporated body or association; or(b) an unincorporated body or association (however structured); or(c) an individual who—

(i) carries on a business; and(ii) engages contractors, employees or volunteers to assist the business in providing services or facilities;

Child A person under the age of 18 years.

Child abuse “child abuse” includes:(a) any act committed against a child involving —

(i) a sexual offence; or(ii) an offence under section 49M(1) of the Crimes Act 1958; and

(b) the infliction, on a child, of —(i) physical violence; or(ii) serious emotional or psychological harm; and

(c) the serious neglect of a child.

Head of a relevant entity “head of a relevant entity” means — (a) an individual who is primarily responsible for—

(i) engaging and terminating the engagement of the relevant entity's employees; and(ii) managing the relevant entity's employees; or

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Term Definition

(b) a person nominated by the relevant entity; or

(c) a person or class of person prescribed to be a head of a relevant entity.

Relevant authority In relation to a “relevant entity”, means any of the following:(a) a Department that is responsible for regulating the relevant entity;(b) a Department that provides funding to the relevant entity;(c) the Victorian Registration and Qualifications Authority;(d) any other authority—

(i) that regulates or funds the relevant entity; and (ii) that is prescribed to be a relevant authority.

Relevant entity “relevant entity” means — (a) an applicable entity that is required under the Child Safety and Wellbeing Act 2005 to comply with the Standards;* or(b) an individual who is required under the Child Wellbeing and Safety Act 2005 to comply with the Standards.*Refer to Category 1 and Category 2 applicable entities, listed in Schedules 1 and 2 of the Child Wellbeing and Safety Act 2005.

Appendix 2: Child Safe Standards

This section outlines the Child Safe Standards (the Standards) in more detail and their link with the reportable conduct scheme (the scheme).

The Standards aim to improve the way organisations prevent and respond to child abuse through driving cultural change in organisations that provide services for children. This will be achieved by embedding child safe practices and policies in everyday thinking and operations.

The Standards impose legal obligations on prescribed organisations, with primary responsibility for compliance resting with the head of the organisation. The Standards outline requirements for organisations to prevent child abuse, and are mandatory for all Victorian organisations that provide services or facilities to children.

Child Safe Standards The Standards outline minimum standards for child safety that apply across a broad range of organisations and highlight the importance of everyone playing a role in keeping children safe from harm and abuse.

The principles

The Standards are informed by three key principles that provide overarching guidance for organisations implementing the Standards:

promoting the cultural safety of Aboriginal children

promoting the cultural safety of children from culturally and/or linguistically diverse backgrounds

promoting the safety of children with a disability.

The principles recognise that while all children are vulnerable, some groups of children are considered to be at increased vulnerability. These groups include Aboriginal children, children from culturally and linguistically diverse backgrounds, and children with disabilities. Organisations are required to consider the increased vulnerability of these groups, and to take action to promote the safety of these children.

The Standards

There are seven standards which focus on governance and leadership, documenting duty of care, development of a code of conduct, human resources practice, responding to and reporting when issues arise, defining and managing risk, and empowering children. The seven standards that organisations must implement are:

Standard 1: Strategies to embed an organisational culture of child safety, including through effective leadership arrangements.

Standard 2: A child safe policy or statement of commitment to child safety.

Standard 3: A code of conduct that establishes clear expectations for appropriate behaviour with children.

Standard 4: Screening, supervision, training and other human resources practices that reduce the risk of child abuse by new and existing personnel.

Standard 5: Processes for responding to and reporting suspected child abuse.

Standard 6: Strategies to identify and reduce or remove risks of child abuse.

Standard 7: Strategies to promote the participation and empowerment of children.

The Standards apply to all organisations and businesses in Victoria that:

provide any services specifically for children

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provide any facilities specifically for use by children who are under the entity’s supervision

engage a child as a contractor, employee or volunteer to assist the entity in providing services.1

Reportable Conduct Scheme The scheme aims to improve oversight of how organisations respond to allegations of child abuse and child-related misconduct by their workers and volunteers.2 The scheme commenced on 1 July 2017, as part of the Victorian Government’s response to the 2013 landmark Inquiry into the Handling of Child Abuse by Religious and Other Non-Government Organisations (Betrayal of Trust Inquiry), and the Royal Commission into Institutional Responses to Child Sexual Abuse.

The scheme imposes specific legal obligations on in-scope organisations to:

notify the Commission of reportable conduct allegations and the findings of investigations

have systems in place to manage and investigate allegations of reportable conduct by their workers and volunteers.

There are five types of ‘reportable conduct’:

sexual offences committed against, with or in the presence of a child

sexual misconduct committed against, with or in the presence of a child

physical violence against, with or in the presence of a child

any behaviour that causes significant emotional or psychological harm to a child

significant neglect of a child.

As required by section 16K of the Act, in-scope organisations must:

prevent reportable conduct by an employee in the course of their employment

enable a person to notify the head of the entity or Commission of a reportable allegation or

investigate such allegations.

If the department becomes aware that an in-scope organisation does not have relevant systems in place, the in-scope organisation will also be non-compliant with the Standards and may be subject to further compliance intervention by the department. This is because there is overlap between the systems that an in-scope organisation is required to have in place under the scheme and the Standards that the organisation is also required to comply with.

1 s.22 of the Child Wellbeing and Safety Act 2005

2 People who are not employed or engaged directly by an organisation may not be within the scope of the scheme, for example, some workers hired through agencies or labour-hire companies, some workers on secondment and some contractors may not be considered to be ‘employees’ under the scheme. This is because those individuals may be employed or directly engaged by a third party rather than the organisation with which they work. For more information, please refer to the Commission’s website < https://ccyp.vic.gov.au/reportable-conduct-scheme/>.

Appendix 3: Obligations of organisations under the Standards This section provides an overview of the legislative obligations of organisations with the Child Safe Standards (the Standards). It includes example indicators of compliance.

Overview The Standards require organisations to develop strategies, policies and practices that are relevant to the type of services or facilities they provide to children.

The Standards are made in accordance with Part 6 of the Child Wellbeing and Safety Act 2005 (the Act) and broadly comprise three principles which must be included in an organisation’s response to each of the seven standards. The table below sets out some example activities which provide an indication of the actions that organisations may undertake in order to comply with the Standards.

While compliance with the Standards is mandatory, the Standards are not prescriptive in setting out specific methods by which organisations should comply. This gives organisations flexibility to determine the most appropriate – or innovative – means by which to create a child safe organisation.

Compliance expectations In-scope organisations are ultimately responsible for their own compliance

While the department’s role as a ‘relevant authority’ under the Act is to promote and oversee compliance with the Standards, the legislative requirement to comply with the Standards rests with the organisation.

The Standards apply to the whole organisation

The Standards apply to the organisation as a whole and not solely to programs or activities which involve children or services which are delivered as part of a consortia arrangement.

Indicators of complianceThe Standards aim to create a culture of child safety and continuous improvement, and consequently compliance cannot be simplified into a checklist of prescriptive minimum requirements. To assist organisations to achieve compliance, the table below provides some example indicators of child safe practices in connection with each standard.

Organisations may reference this table when determining whether they are compliant with their obligations under the Standards.

These example indicators should be considered in the context of what is best for each organisation. Decisions about how best to comply with the Standards need to be considered in relation to the organisation’s profile, risks to child safety, the context of their operations and their specific circumstances.

Key points:

All organisations subject to the Standards must take action to meet their legislative obligations.

There is no ‘one size fits all’ approach to the development and implementation of systems to protect children from harm or abuse however, there are some key activities that support compliance, or provide an indication of an organisation’s compliance, with the Standards.

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Table 1: Example indicators of child safe practices in line with the Standards

Child Safe Standard Example indicators of child safe practices

The Standards

Standard 1: Strategies to embed an organisational culture of child safety, through effective leadership arrangements

A child safe review has been undertaken including involvement of organisational leaders, and the next child safe review is scheduled.A child safety officer has been appointed.Child safety is a regular item for discussion at governance meetings and staff meetings.Child safe training is regularly held for staff and volunteers.Child wellbeing and safety strategies are reflected in the organisation’s work plan and business strategy.The organisation has developed a monitoring and reporting framework to monitor its progress with the implementation of the Standards.

Standard 2: A Child Safe Policy or Statement of Commitment to Child Safety

A Child Safe Policy (or Statement of Commitment to Child Safety) and a Code of Conduct have been developed, and approved by organisational leaders.Child safe information (including the Child Safe Policy and Code of Conduct) are provided to, and understood by, staff, children and parents - for example, through promotion on the organisation’s website, prominent locations, forums and induction activities.

Standard 3: A Code of Conduct that establishes clear expectations for appropriate behaviour with children

Standard 4: Screening, supervision, training and other human resource practices that reduce the risk of child abuse by new and existing personnel

Child safety is reflected in job advertisements, duty statements and position descriptions.Interview questions specifically include questions about child safe conduct.Reference checks are undertaken and specifically include questions about child safe conduct.The organisation has reviewed the Working With Children Check (WWCC) requirements for all positions, and ensured WWCCs are held.The organisation has robust staff and volunteer supervision and performance management strategies, which include specific reference to child safety.

Standard 5: Processes for responding to and reporting suspected child abuse

The organisation has in place clear policies and procedures for responding to, and investigating, suspected child abuse.The committee of management or board reviews policy and operational requirements annually for responding and reporting suspected child abuse. Policies include requirements relating to Failure to Disclose and Failure to Protect legislative requirement.3

Policies and procedures for reporting and acting on child safety concerns include appropriate consideration of record keeping, confidentiality and privacy requirements.

Standard 6: Strategies to identify and reduce or remove risks of child abuse

A child safe risk assessment has been undertaken including involvement of organisational leaders and consideration of situational risks, strategies to reduce or remove risk and the next

3

Child Safe Standard Example indicators of child safe practices

child safe risk assessment is scheduled.The organisation reports on its incident management and complaints processes and outcomes to inform updates to policy and operational requirements to remove or reduce future risks.

Standard 7: Strategies to promote the participation and empowerment of children

Children have participated in shaping the organisation’s child safe environment, including through formal and informal feedback mechanisms.Evidence of new or updated operational processes or policies that detail how the organisation will promote the empowerment of children. All of the above activities should be informed by involvement and feedback from children and parents.The organisation should be able to give evidence of its efforts to proactively raise awareness to all of the above activities.

The Principles

Principle 1: Promote the cultural safety of Aboriginal ChildrenPrinciple 2: Promote the cultural safety of children from culturally and/or linguistically diverse backgroundsPrinciple 3: Promote the safety of children with a disability

All of the above activities should reflect consideration of the varying needs of children, including the additional risks faced by Aboriginal Children, children from culturally and/or linguistically diverse backgrounds, and children with a disability.The organisation should clearly demonstrate a zero tolerance for discrimination.Policies and procedures should specifically address cultural inclusion, sensitivity and competency. Policies and procedures should address specific boundaries about interaction with children with a disability, including personal care assistance.The organisation should provide training and development on cultural sensitivity and competency, as well as interactions with children with a disability.

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