I. Introduction 

A. Camp Bruce McCoy is a recreation and respite program of the Brain Injury Association of Virginia (BIAV).  It originated in 1983 as a response to a request from a mom who needed a break after becoming a full-time caregiver for her adult son with a significant traumatic brain injury.  What began as a weekend long event for about seven campers has become the nation’s preeminent camp for persons with brain injury. 

1. BIAV internal processes:  The BIAV conducts a very thorough pre-camp application process and requires a substantial amount of documentation from and conversation with each applicant and/or caregiver regarding the applicant’s medical status, self-care skills, cognitive abilities, mobility, and appropriateness for the program.  Camper applications are discussed with the program’s Medical Consultant, a physician with more than 30 years providing care to persons with brain injury. 
2. Camper profile:  The program is open to persons with brain injury, 18 and up, who can safely be managed in the setting and who can tolerate the activity level of the program.  Some campers require total care, others need varying levels of cognitive or physical assistance, and some live independently, work and drive themselves to camp.  Campers with tubes (e.g., tracheostomy, feeding tubes) are not eligible to participate; nor are campers with felony offenses. 
3. Camp staffing: 
   1. The program is led by a team of experienced rehabilitation professionals (occupational and physical therapists, nurses, and physicians) who, among them, have more than 75 years of experience with and participation in the program.  Their onsite supervision requirements include hiring and directing staff, organizing activities, managing medications, ensuring camper safety, responding to emergencies, coordinating supplies, and creating fun. 
   2. Hired staff members (i.e., employees) include counselors and attendants to provide assistance and care to the campers.  These are usually college students who are seeking acceptance into professional programs, like Occupational or Physical Therapy, or medical or nursing school. 
   3. Volunteers largely fall into one of two categories:  those who are seeking employment with and/or experience in the field of brain injury, and students participating in instructor led hands-on learning experiences. 
   4. To provide a safe environment for the summer camp program, BIAV conducts criminal background checks on all prospective staff and volunteers and will not hire or engage the services of anyone who has been convicted of sexual abuse, as defined in the Virginia Code.  See Camp Operations Manual:  Section II:  4, A-C. 
4. Program activities:  Campers are provided with choices of activities including, but not limited to, therapeutic horseback riding, fishing, canoeing, arts and crafts, games, campfires, and a dance.  Activities are conducted both as small group and camp-wide events, are facilitated by counselors, and are supervised by program directors and managers. 

B. The following documents policies and procedures of the BIAV that set the standard of acceptable behavior for BIAV and Camp Bruce McCoy staff and volunteers regarding sexual abuse, harassment, and molestation prevention. It includes:  

1. The BIAV Sexual Abuse and Molestation Prevention Policy 
2. Relevant sections of the BIAV Policy and Procedure Manual and the Camp Operations Manual are cross-referenced herein. 
3. Procedures specific to the Camp setting that are practiced to minimize the risk of sexual abuse, harassment and molestation of campers and staff.  
4. Appendices of forms, definitions, and procedures  

 II. Sexual Abuse and Molestation Prevention Policy 

A. Sexual abuse is any contact of a sexual nature between a camper and an adult or between two campers, including, but not limited to, any activity which is meant to arouse or gratify the sexual desires of the adult or the other camper. Sexual abuse of an individual is strictly prohibited in the BIAV workplace or during any BIAV-related program, service, or activity. Sexual abuse includes, but is not limited to, rape, sexual molestation, inappropriate touching, exposing oneself, sexually oriented conversations, sexual exploitation, sexual contact between a staff member or volunteer and a camper, or any attempts to commit such acts. Any behavior toward a camper that is unwelcome conduct of a sexual nature and would reasonably cause the camper to feel uncomfortable is prohibited.  These behaviors include unwelcome sexual advances, requests for sexual favors, and other verbal, nonverbal, or physical conduct of a sexual nature. BIAV will view any sexual activity between any staff member, volunteer, or other person of authority and any camper as unwelcome and nonconsensual. 

B. BIAV recognizes the importance of educating its staff members and volunteers regarding the prevention of sexual abuse between and among staff, volunteers, and campers.  BIAV staff members and volunteers will receive training on BIAV’s sexual abuse policy, sexual abuse, and sexual molestation upon hiring/volunteering and annually thereafter. All staff members and volunteers will be required to sign a form indicating receipt and understanding of the policy, Appendix 5 of the Camp Operations Manual. . 

C. BIAV takes seriously all allegations of sexual abuse.  When BIAV knows or reasonably should know that such an act has occurred, BIAV will take immediate action and follow the procedures outlined in this policy. This action will be taken either through an individual’s initiation of the Complaint process (See Camp Operations Manual Section IV. D- Complaints) or through reporting requirements outlined in this policy, including use of a Critical Incident Report Form (See Camp Operations Manual Section IV. Critical Incidents.)I Immediate reporting and the safety of the person potentially being harmed is of utmost importance.

D. Staff members and volunteers must immediately report actual or suspected sexual abuse to their supervisor and/or Executive Director.  If the matter involves a supervisor, a report must be made to the Executive Director. If the matter involves the Executive Director, a report must be made to the President of the Board of Directors or to another Board member if the President is not available.  

E. It is helpful, though not required, to provide a written record of the date, time, and nature of the incident(s) and the names of any witnesses.  If possible, BIAV’s Critical Incident Form should be used for documentation.

F. BIAV prohibits retaliation made against any staff member, volunteer, camper, or other person who in good faith puts forth a complaint of sexual abuse or who participates in any related See BIAV Policy and Procedures Manual Personnel Section XXI - Whistleblower.

G. BIAV prohibits staff members and volunteers from making knowingly false or malicious accusations. Anyone who violates this policy is subject to disciplinary action up to and including termination of employment.

H. BIAV is committed to following state and federal law for reporting allegations or incidents of sexual abuse to appropriate law enforcement and adult protective services. 

I. BIAV will take all allegations of sexual abuse or molestation seriously and will promptly, thoroughly, and equitably investigate whether sexual abuse or molestation has taken place in conjunction with any necessary reports to law enforcement or adult protective services organizations. The organization may utilize an outside third-party to investigate the alleged BIAV will cooperate fully with any investigation conducted by law enforcement or other regulatory/protective services agencies.

J. Those reasonably suspected or believed to have committed sexual abuse or molestation will be immediately suspended and have no further contact with campers or other staff members until the investigation is completed.  Depending on the outcome of the investigation, (i) the staff member or volunteer will be appropriately disciplined, up to and including the termination of his or her employment by, or association with, BIAV, or (ii) BIAV will document that the allegation was unfounded.

K. The person(s) making the allegation or filing the complaint will be notified of any corrective actions to be taken by BIAV, if applicable, and in line with confidentiality requirements.

L. BIAV will make every reasonable effort to keep the matters involved in the allegation as confidential as possible while still allowing for a prompt and thorough investigation.

III. Interactions between Staff/Volunteers and Campers 

A. When interacting with a camper one-on-one, staff members and volunteers shall follow the following guidelines: 

1. To the maximum extent possible, meet in a public place where both the staff member/volunteer and the camper are in full view of others. 
2. Avoid physical contact that can be misinterpreted. If meeting in a room, leave the door open or move to an area that can be clearly observed by others if passing by.  If the door must be closed due to a confidential setting (e.g., a counseling session), then ensure that any window is not blocked so that anyone walking by can view into the room. 

B. Physical Contact 

1. BIAV’s guidelines for appropriate physical interactions include side hugs, group hugs, shoulder-to-shoulder hugs, pats on the shoulder or back, handshakes, high-fives, pats on the head when culturally appropriate, touching hands/shoulders/arms, and holding hands in escorting situations. 
2. BIAV’s guidelines for inappropriate physical interactions include kisses, showing affection in isolated areas, lap sitting, wrestling, piggyback rides, tickling, any type of massage given by or to a camper in private, any form of unwanted affection, compliments relating to physique or body development, touching bottom/chest/genital areas. 

C. Verbal Interaction

1. BIAV’s guidelines for appropriate verbal interactions include positive reinforcement, appropriate jokes, encouragement, and praise. 
2. BIAV’s guidelines for inappropriate verbal interactions include name-calling, sharing secrets, discussing sexual encounters, involving campers in the personal problems or issues of staff and volunteers, off-color or sexual jokes, shaming, belittling, derogatory remarks, harsh language that may frighten, threaten, or humiliate campers. 

D. One-on-One Interactions

1. BIAV’s guidelines for appropriate one-on-one interactions include providing physical toileting or shower assistance when required, limiting physical contact to pats on the shoulder/high-fives/handshakes, meeting in a public place where in full view of others, and asking other staff and volunteers to randomly drop in. 
2. BIAV’s guidelines for inappropriate one-on-one interactions include physical affection that can be misinterpreted. 
3. If meeting in a room, staff are to leave the door open or move to an area that can be clearly observed by others if passing by. If the door must be closed due to a confidential need (e.g. a counseling session), then staff are to ensure any window is not blocked so anyone walking by can view into the room.  
4. If alone with a camper, staff are to document and immediately report any unusual incidents, including disclosures of alleged abuse and mistreatment, behavior problems and how they were handled, injuries, or any interactions that might be misinterpreted to the Camp Director. 

E. Off-site Contact

1. Appropriate offsite activities during the camp program include group outings and/or medical interventions that cannot be treated onsite by the medical manager. 
2. Outside of camp programming, appropriate offsite activities may include, but are not limited to, group outings and attending functions at a camper’s home with caregivers/guardians’ consent and presence. 
3. Inappropriate offsite contact, during or outside of the camp program, include taking one camper on a non-medically related outing without the caregivers/guardian’s written permission, visiting a camper in the camper’s home without a caregiver/guardian present, entertaining a camper in the home of a staff member or volunteer, and a camper spending the night with a staff member or volunteer. 

F. Electronic Communication 

1. Use of cameras in private areas including bathrooms and showers is prohibited.   
2. Sexually oriented conversations using social media and other forms of electronic communication are prohibited. 

G. Monitoring and Supervision

1. General Supervision 
   1. BIAV plans to provide a camper-to-staff ratio of 2:1. This ratio may be adjusted based on camper needs during an activity.  Additionally, nursing students, ranch staff, BIAV staff, and the Camp Bruce McCoy medical and administrative staff provide additional support.  Certain activities may require a 1:1 ratio, including canoeing, horseback riding, high ropes course, and swimming at the pool. 
   2. Camp offers structured, scheduled activities like horseback riding, fishing, arts and crafts, and yard games.  These activities are staffed to provide direct supervision with a minimum 2:1 camper to staff ratio.  This ratio will be adjusted if the physical or cognitive needs of participating campers are such that additional staff is required to maintain safety and supervision. 
   3. Easily visible and routinely checked areas of the campground are designated as authorized areas, are strictly supervised at all times, and are clearly conveyed to campers, staff, volunteers, and visitors. 
   4. Activities are to have at least one counselor of the same gender present if a camper of that gender is attending. 
   5. BIAV staff and volunteers will direct campers to structured activities and redirect campers who are not participating in a structured activity. 
2. Bathroom Activities 
   1. Camp Bruce McCoy Staff are trained to provide necessary and levels of toileting assistance to campers for those tasks and maintain appropriate levels of supervision at all times. 
   2. At any given time, there should only be as many campers in a restroom as there are individual stalls for use; others waiting to use the facility will wait outside with staff or volunteers. 
   3. Staff and volunteers will scan the bathroom before allowing campers to enter, and as appropriate, provide supervision from outside the bathroom door and within earshot. 
   4. Staff and volunteers will only be in the same stall with a camper if they are providing toileting assistance to that camper.  In these situations, the stall door should not be latched. 
   5. During group activity times, one male and one female staff or volunteer will be assigned to monitor bathrooms at the activity. 
3. Shower Activities 
   1. Staff and volunteers will shower at different times than campers. 
   2. During camper shower times, staff and volunteers will provide continuous supervision and monitor the bathroom to ensure only one camper is in each shower. 
   3. Staff and volunteers will provide direct physical assistance to campers who require this level of help and remain in earshot of campers who do not require direct physical assistance. 
   4. The head male and head female counselors will check in with each cabin during shower times and make sure that all the showers are clear at the end of the activity. 
4. Transitions 
   1. BIAV camp staff and volunteers are prohibited from leaving an activity until all campers are accounted for with either a walking escort or a ride in a golf cart to their next destination. 
   2. Campers are not to be left alone during activity transitions. 
   3. Staff will conduct head counts after every transition. 
   4. Campers at risk of getting lost or wandering are assigned a staff member or volunteer to supervise their transition from one activity to another and are “handed off” to another staff or volunteer at the receiving activity. 
5. Free Time 
   1. There is no unsupervised time at Camp Bruce McCoy. 
   2. During the day, “free time” occurs when campers and staff are at designated locations and awaiting initiation or completion of structured activities.  Staff are always present at these locations.  
   3. One afternoon activity called “Camp Bruce McCoy Time” allows the campers to self-select leisure activities of their choice from a predetermined list.  These activities occur in designated areas that are specific and supervised at all times. 
   4. The Camp Program Director(s) and Camp Program Manager conduct periodic check-ins of all program areas during Camp Bruce McCoy time. 
6. Transportation 
   1. All camp staff and volunteers transporting campers must pass a motor vehicle background check.  See Camp Operations Manual Section 2 A: Staffing. 
   2. Staff and volunteers should sit in seats that permit line of sight supervision. 
   3. Drivers are prohibited from making unauthorized stops. 
   4. Staff and volunteers are to report any unusual occurrences during the outing to management staff, who will determine if a Critical Incident Report should be made. 
   5. Staff and volunteers must avoid unnecessary physical contact with campers while in vehicles. 
7. Off-Site Activities 
   1. All sexual abuse and molestation policies apply to off-site and weekend activities. 
   2. Supervision levels are adapted to the community environments.  
   3. Additional off-site procedures are in the Camp Operations Manual Section IV: K. 
8. Overnight Activities 
   1. Counselors are assigned to cabins and are responsible for overnight supervision of campers in that cabin. 
   2. Male and female campers stay in separate cabins and are supervised by same sex staff. 
   3. Staff, volunteers, and campers will sleep alone in their own assigned beds. 
   4. If a camper gets up in during the night and only one counselor is awake, that counselor must wake up another counselor in that cabin.
   5. Door alarms are placed on cabin doors.  If an alarm goes off, two counselors in that cabin must get up to assist the camper. 
   6. One male and one female counselor will remain at the cabins during the nightly staff meeting to provide camper supervision and will obtain additional assistance if necessary. 

H. Reporting and Investigating Reports of Suspicious or Inappropriate Behaviors or Policy Violations

1. Staff and Volunteer Response 
   1. Interrupt the behavior. 
   2. Report the behavior to the Camp Program Director(s) either verbally or in writing using the Critical Incident Report form. 
   3. If the report is about the Camp Program Director(s), the report must be made to the Program Manager.  
   4. Document the report but do not investigate. 
2. Administrative Response (Camp Program Directors reporting to BIAV Executive Director) 
   1. Camp Program Directors will: 
      1. Remove any person reasonably suspected of inappropriate sexual behavior from program activities. 
      2. Interview and/or survey involved parties and other staff and volunteers who may have witnessed the event. 
      3. Document the report on the BIAV Critical Incident Form.  See Camp Operations Manual Appendix 4. 
      4. Report the incident to the BIAV Executive Director. 
   2. BIAV Executive Director will: 
      1. Advise the person who reported the behavior that the report is being taken seriously. 
      2. File a report and contact the state authorities if a concern arises about possible abuse at any point during the investigation. 
      3. Notify caregivers/guardians as appropriate. 
      4. Initiate disciplinary action, up to and including termination of employment and pursuit of criminal prosecution if policy violations with campers are confirmed.  
      5. Follow any additional Policies and Procedures noted in the BIAV Policy and Procedural Manual. 
   3. Organizational Response (Camp Directors, BIAV Executive Director) 
      1. Any statement to the media or legal representatives will be the sole responsibility of the Executive Director.  See BIAV Policy and Procedure Manual, Employee Section IIIA.   
      2. Conduct a review of the report, process, and outcomes for future reference. 
      3. Review the need for increased supervision to further reduce associated risks. 
      4. Review the need for revised policies or procedures to further reduce associated risks. 
      5. Review the need for additional training of Sexual Abuse and Molestation Prevention Policies and Procedures to further reduce associated risks.