AD93 Interactions With Prospective Students Who Are Minors and/or Minors Enrolled In University Classes

CONTENTS

• Purpose

• Scope

• Definitions

• Policy

  • Policy Violations

• Further Information

• Cross References

PURPOSE

The protection and safety of minors participating in university-sponsored programs, activities or services is among the highest priorities of the University.  The purpose of this policy is to provide direction and guidance to faculty, staff and independent contractors who interact with prospective students who are minors, dual-enrolled high school students who are minors and/or matriculated students who are minors.

SCOPE

This policy is applicable to all University employees, volunteers or independent contractors who have direct contact with minors who are prospective students and/or enrolled students.  This policy does not apply to organized youth programs that are specifically designed for and delivered to minors (please refer to policy AD39, Minors Involved in University-Sponsored Programs or Programs Held at the University and/or Housed in University Facilities).

DEFINITIONS

Adult – An individual 18 years of age or older. 

Authorized Adult - University employees, volunteers, and independent contractors, age 18 and older who, in the course of their University business or volunteer activity, have direct contact with non-matriculated minors. 

Child – An individual under 18 years of age.  Also referred to as a minor in University policies or documents.  

Direct Contact - Care, supervision, guidance, or control of, or routine interaction with minors.

Dual-Enrolled Student - An individual who is enrolled in a secondary school or homeschooled (grades 7 through 12) and is also enrolled in University classes.   

Enrolled Student - An individual who has graduated from secondary school and is enrolled in University classes.

Observable and Interruptible - An area in which an adult is present and can see, hear, direct, and assess the activities of the minor.

Matriculated Student –A student who is enrolled in an institution of higher education and pursuing a program of study that results in a postsecondary credential, such as a certificate, diploma, or degree. 

Minor – An individual under 18 years of age. Sometimes referred to as a child in University policies and documents.

One-On-One Contact - Any interaction, including in person, direct phone, or electronic contact, between one adult and one minor.

Pre-College Activities – Short-term, time limited activities designed for individuals who are engaging with institutions of higher education to explore options and gather information for the purpose of application/finalization of enrollment in an institution of higher education.  This includes, but is not limited to, admissions tours, recruiting visits, pre-admission meetings, interviews, and/or auditions, and class observation.

Prospective Student – An individual who is considering applying/has applied to an institution of higher education. 

Routine interaction - Regular and repeated contact, including direct phone or electronic contact, that is integral to a person's employment, volunteer work, or independent contractors’ responsibilities.

Sponsoring Unit - The academic, athletic, or administrative unit of the University that offers pre-college activities and/or enrollment opportunities that includes minor.

Student Host – An individual who is currently enrolled at Penn State, is 18 years of age or older, and assigned to host a prospective student who is visiting campus. 

POLICY

This policy is designed to provide University direction and guidance for appropriate conditions for the promotion of a safe environment for prospective students who are minors and/or minors enrolled in University classes. 

1. GENERAL REQUIREMENTS

1. Background Clearances

   1. All employees, volunteers and independent contractors who have direct contact with prospective students or enrolled students who are minors must have valid background clearances on record with the University at the time of hire and/or before interacting with minors. This includes employees, volunteers and independent contractors who have direct contact with minors who are dual-enrolled students. Clearance requirements shall not apply to employees, volunteers, and independent contractors whose direct contact with minors, in the course of employment, is limited to matriculated students.

   2. Please refer to HR99 - Background Check Process for further information.

2. Training & Education
   1. All University employees, volunteers, or independent contractors who have direct contact with prospective students or enrolled students who are minors are required to take the Reporting Suspected Child Abuse training as outlined in University Policy AD72 - Reporting Suspected Child Abuse. 
3. One-on-One Contact
   1. One-on-one in-person contact or one-on-one electronic communications between University employees, volunteers, or independent contractors and minors may occur from time to time.
      1. In- Person Contact
         1. If an in-person one-on-one contact occurs, such contact should be in a public area, or in a room with the door open, where the contact is observable and interruptible by another adult.
         2. A supervisor or another staff member should be notified of the contact in advance of the contact or as soon as it is reasonably practicable thereafter and the contact should be documented to a designated program file or approved university system/device.
         3. Additional external rules, if applicable, shall also apply.
      2. Electronic Communications
         1. Electronic communication includes, but is not limited to, phone calls, video chats, social media, emails, and direct messaging.
         2. If a one-on-one electronic communication occurs, such electronic communication should be documented to a designated program file or approved university system/device.
      3. Additional external rules, if applicable, shall also apply.  
      4. This guidance shall not apply to employees, volunteers, and independent contractors whose one-on-one contact is limited to matriculated students.

2. PROSPECTIVE STUDENTS AND PRE-COLLEGE ACTIVITIES

Pre-college activities include, but are not limited to, admissions tours, recruiting visits, pre-admission meetings, interviews, auditions, and/or class observation.

1. Campus Tours
   1. Tours are time-limited and do not lend themselves to one-on-one interaction. In addition, it is unusual for a prospective student who is a minor to participate without a parent/guardian present.  It is advisable for tours to follow their approved public routes and stay together in groups.
2. Meetings, Interviews and/or Auditions
   1. Refer to one-on-one contact guidelines outlined above in General Requirements (c).
3. Overnight Visitation
   1. There are times when prospective students who are minors are invited to campus for a pre-college activity that involves an overnight stay in a residence hall with a current Penn State Student Host. In addition to obtaining clearances and completing the training requirement, individuals hosting minors overnight must be provided with the Guidelines for Student Hosts document, available here.
4. Intercollegiate Athletics/NCAA
   1. For campuses that belong to the NCAA, Intercollegiate Athletics must also follow the guidelines outlined in the University’s NCAA Policy on Official and Unofficial Visits.

3. DUAL-ENROLLED AND ENROLLED STUDENTS WHO ARE MINORS

1. Eligibility for Dual Enrollment
   1. Penn State offers dual enrollment to high school students, including students who are minors, for university courses as non-degree students. Participation in dual enrollment, including the selection of courses appropriate for dual-enrolled students is determined by the campus administration and the participating campuses.  Qualified students, as determined by Undergraduate Admissions, earn University credits and experience through this program.
   2. In addition, the University may restrict dual-enrolled minor high school students from participating in certain student-related activities. Additional guidance for dual enrollment can be provided at University Park by Penn State’s Division of Undergraduate Studies. Guidance for Commonwealth Campuses is provided by the Office of the Vice President for Commonwealth Campuses
2. Involvement in Recognized Student Organizations
   1. Dual-enrolled students who are minors may not be active members of recognized student organizations. However, if a dual enrolled student is 18 years of age or older, they may participate as associate members, if the organization accepts associate members.
3. Residential Housing Requirements
   1. Dual-enrolled students are not eligible to reside in University housing.
   2. To be eligible to reside in University housing, a student must be in matriculated status, scheduled for classes or enrolled as a degree-seeking student and at least 16 years of age during the period of occupancy.
4. Domestic and International Travel
   1. If eligible to enroll in a University class that requires travel, a dual-enrolled student who is a minor is not eligible to participate in any experiences involving travel regardless of the distance, destination, or who/what is sponsoring the travel (University, student organization, etc.). Faculty are expected to provide these students with an alternative assignment that meets class objectives.
   2. Enrolled students who are minors, if eligible to enroll in a course involving international travel, must be at least 18 years of age at the start of travel for any educational semester abroad program. Short term domestic and international travel, not including semester abroad programs, for matriculated minors will only be considered when appropriate safeguards have been established in collaboration with the Office of Risk Management and the Office of Ethics & Compliance (Youth Compliance).   
5. Student Recreation Facilities
   1. Dual-enrolled students who are minors are not permitted to use the student recreation facilities.

4. POLICY VIOLATIONS

Federal, state, and/or local governments have enacted various laws and regulations relating to child protective services to which the University is bound. Compliance with this Policy is designed, in part, to ensure that the University is complying with its various obligations. University employees, volunteers or independent contractors who violate this Policy and/or supplemental Guidelines and Standards may be subject to disciplinary action.

FURTHER INFORMATION

For questions, additional detail, or to request changes to this policy, please contact the Office of Ethics and Compliance, Youth Program Compliance.

CROSS REFERENCES

AD39 Minors Involved in University-Sponsored Programs or Programs Held at the University and/or Housed in University Facilities

AD72 Reporting Suspected Child Abuse

HR99 Background Check Process

TR01 International Travel Requirements

Most Recent Changes:

Revision History (and effective dates):

• January 24, 2024 - New Policy.