Legacy Haven Academy Comprehensive Housing and Residential Staffing Policy

Introduction and Analysis

This revised policy, updated as of September 30, 2025, integrates Arizona state and Mohave County-specific requirements for the student housing plan and residential staffing at Legacy Haven Academy (LHA) in Mohave County, Arizona. It incorporates the clarification that awake student supervision during daytime class or on-campus activities is handled by instructors at a consistent 1:6 ratio (1 instructor per 6 students), with residential managers focusing on non-instructional hours (evening, night, and non-class periods). The housing plan remains segmented: dormitory-style for grades 5-8 (double occupancy with Jack-and-Jill bathrooms), apartment-style for grades 9-11 (eight students with double bedrooms and common area), and single-family home-style for grade 12 (four students with private bedrooms, Jack-and-Jill bathrooms, common area, and shared yard maintenance). Federal standards (e.g., ADA, NFPA) persist, but Arizona Revised Statutes (ARS), Arizona Administrative Code (AAC), and local ordinances govern implementation. Thirty-two residential managers oversee housing during non-instructional hours, with emphasis on swing (e.g., 3:00 PM–11:00 PM) and night (11:00 PM–7:00 AM) shifts to meet DCS supervision ratios, standardized as 1:10 awake and 1:15 sleep for all students (ages 10-18) per AAC R6-5-7437, ensuring consistency across all grade levels (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Arizona-Specific Analysis: LHA’s housing is classified as a "residential group care facility" under ARS Title 8, Chapter 4, Article 9, requiring licensing by the Arizona Department of Child Safety (DCS) Office of Licensing and Regulation (OLR) for facilities serving more than four minors (congregate care) (Arizona Revised Statutes, Title 8, Chapter 4, Article 9, 2025). Mohave County’s Zoning Ordinance (2023) permits educational-residential uses in Rural Living (RL) or Rural Commercial (RC) zones with conditional use permits (CUPs) for dormitories/group homes; single-family homes fit R-1/R-2 zones but cannot exceed unrelated occupancy limits (typically 6-8 persons) (Mohave County, AZ, 2023). Fire and building codes adopt the 2021 International Building Code (IBC) and International Fire Code (IFC) statewide, with Mohave County amendments for desert climate (e.g., enhanced ventilation) (International Code Council, 2021a, 2021b). Gender separation complies with Title IX, which prohibits discrimination based on sex in education programs, focusing on biological sex as clarified in the 2024 Title IX Final Rule (Education Amendments of 1972, 2024). Yard maintenance introduces liability under ARS §33-1551 (limited for educational users) but requires DCS oversight (Arizona Revised Statutes, Title 33, 2025). Estimated compliance costs include DCS licensing (6-12 months, $500-1,000 fee), Mohave County CUP ($2,000+), and annual inspections. Non-compliance risks license revocation and Every Student Succeeds Act (ESSA) funding loss (Every Student Succeeds Act, 2015). Residential managers live in separate on-campus quarters and do not cohabitate with students, with duties focused on non-class hours. Federal overlays include Child Abuse Prevention and Treatment Act (CAPTA) for mandatory reporting and Fair Labor Standards Act (FLSA) for wage/overtime (Child Abuse Prevention and Treatment Act, 1974; Fair Labor Standards Act, 1938). Mohave County enforces through health inspections and zoning compliance. Annual DCS audits ensure adherence; violations may result in license suspension.

This policy integrates federal, state, and local requirements, with residential manager duties excluding daytime awake student supervision (handled by instructors at 1:6) and supervision ratios standardized at 1:10 awake and 1:15 sleep for all grades. It reflects the updated Title IX framework, emphasizing sex-based protections. Consult DCS OLR (602-364-2538) and Mohave Development Services (928-757-0903) for site-specific approvals; annual reviews required under AAC R6-5-7401 (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

General Requirements Applicable to All Housing (Arizona/Mohave-Specific)

Zoning, Building Permits, and Construction Standards

• Facilities require a Mohave County Conditional Use Permit (CUP) for "educational institutions with dormitories" in RL/RC zones (Mohave County Zoning Ordinance §300-500); site plan review for setbacks (20-50 ft), parking (1 space/3 students), and flood plain avoidance per General Plan 2020 (Mohave County, AZ, 2023).
• Building permits via Mohave Development Services: Adopt 2021 IBC (Group R-2 for dorms/apartments) with local amendments (Ordinance 2021-03) for seismic/wind loads; inspections for foundations, plumbing (IPC 2021) (International Code Council, 2021a).
• No "group home" reclassification if >8 unrelated minors—treat as institutional; comply with ARS §9-463.01 for county zoning consistency (Arizona Revised Statutes, Title 9, 2025).

Fire Safety (2021 IFC/NFPA Integration)

• Arizona adopts 2021 IFC statewide (AAC R2-13-104); Mohave enforces via annual inspections: Sprinklers mandatory in sleeping areas; 1-hour fire walls between units; evacuation plans for 5-12th graders (International Code Council, 2021b).
• Drills quarterly; CO detectors per NFPA 72 (National Fire Protection Association, 2021).

ADA Compliance

• Federal, unchanged; Arizona enforces via DCS for licensed facilities (AAC R6-5-7410) (Americans with Disabilities Act, 1990; Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Health, Sanitation, and Ventilation

• Mohave County Environmental Health inspects for sanitation (Ordinance §11-251): Hot water 110-120°F; pest control quarterly; no lead paint in pre-1978 structures (Mohave County, AZ, 2023).
• AZ DHS Bureau of Child Care Licensing (for school-age care): Weekly cleaning, mold prevention (RH <60%); ventilation per IMC 2021 (15 cfm/person) (International Code Council, 2021c).

Gender Separation and Privacy

• Title IX (2024 amendments) requires sex-segregated housing based on biological sex for minors in educational programs; locks on all bathroom doors to ensure privacy (Education Amendments of 1972, 2024).
• ARS §15-112: Schools prohibit discrimination based on sex, race, or other protected classes (Arizona Revised Statutes, Title 15, 2025).

Child Welfare and Educational Stability

• DCS licensing mandatory (ARS §8-501 et seq.): Trauma-informed care; mandatory abuse reporting (ARS §13-3620); family contact plans (Arizona Revised Statutes, Title 8, Chapter 4, Article 9, 2025).
• ESSA/FERPA unchanged; Arizona Department of Education (ADE) oversight for foster youth stability (Every Student Succeeds Act, 2015; Family Educational Rights and Privacy Act, 1974).

Specific Requirements for Grades 5-8: Dormitory-Style Housing

• Licensing: Classified as "congregate care" (up to 10 children/home); DCS application includes background checks (Level 1 fingerprinting, ARS §41-1758.01) (Arizona Revised Statutes, Title 8, Chapter 4, Article 9, 2025).
• Room Design: Min. 70 sq ft/child (IBC §1207); individual storage compliant (International Code Council, 2021a).
• Bathrooms: Jack-and-Jill allowed with privacy doors (AAC R6-5-7435); accessible per DCS (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).
• Supervision: During non-class hours, 1:10 awake, 1:15 sleep (AAC R6-5-7437); no co-ed based on biological sex. Daytime supervision by instructors at 1:6 ratio during class/campus activities (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Specific Requirements for Grades 9-11: Apartment-Style Housing

• Unit Design: Max 10 residents (DCS limit); kitchenettes supervised (no open flames unsupervised, IFC §606) (International Code Council, 2021b).
• Occupancy: CUP required for multi-family in R-2 zone (4,000 sq ft min. lot) (Mohave County, AZ, 2023).
• Supervision: During non-class hours, 1:10 awake, 1:15 sleep (AAC R6-5-7437); life skills training documented (AAC R6-5-7420). Daytime supervision by instructors at 1:6 ratio (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Specific Requirements for Grade 12: Single-Family Home-Style Housing

• Unit Design: Fits R-1 zone (min. 7,200 sq ft lot); private rooms ≥100 sq ft (Mohave County, AZ, 2023).
• Independence: Emancipated minors (ARS §12-2451) may sign agreements, but DCS guardianship oversight (Arizona Revised Statutes, Title 12, 2025).
• Supervision: During non-class hours, 1:10 awake, 1:15 sleep (AAC R6-5-7437); weekly check-ins. Daytime supervision by instructors at 1:6 ratio (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Common Areas, Yards, and Maintenance

• Common Areas: Fire-rated separations (IFC §709); DCS-approved appliances (International Code Council, 2021b).
• Yard Maintenance: Student-led permitted under supervision (1:10 ratio during non-class hours); school liable for injuries (ARS §33-1551 limits recreational liability but not for supervised programs—require parental waivers). Comply with Mohave nuisance codes (grass <12 inches, Ordinance §11-251); no pesticides without EPA approval (Arizona Revised Statutes, Title 33, 2025; Mohave County, AZ, 2023).
• Liability: DCS requires insurance ($1M min.); joint responsibility for damages (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Residential Managers: Requirements, Training, Duties, and Legal Obligations

This section details requirements for the 32 residential managers at LHA, responsible for overseeing student housing during non-instructional hours, ensuring safety, and supporting the well-being of vulnerable youth (ages 10-18, grades 5-12). Managers comply with DCS regulations (AAC Title 6, Chapter 5, Article 74), with duties focused on evening/night hours as daytime supervision is handled by instructors at a 1:6 ratio (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025). With 32 managers, 24/7 coverage is maintained for non-class hours, emphasizing swing (3:00 PM–11:00 PM) and night (11:00 PM–7:00 AM) shifts with consistent supervision ratios of 1:10 awake and 1:15 sleep across all grades (AAC R6-5-7437) (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Legal Requirements for Residential Managers

Qualifications and Hiring

• General Qualifications (AAC R6-5-7431): Managers must be at least 21 years old, hold relevant certifications (e.g., CPR/First Aid), and demonstrate capacity to perform essential functions without communicable diseases posing risks to children. They must have verified two years of prior employment in child care or related fields via reference checks and at least three non-relative references attesting to character, knowledge, and skills (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).
• Background Checks (AAC R6-5-7431, DCS Policy 15-32): Prior to hiring and every five years, managers undergo comprehensive checks including: Level 1 fingerprint clearance card (A.R.S. §41-1758.03), Arizona Central Registry check for substantiated abuse/neglect, and out-of-state registry checks if resided elsewhere in the past five years. They must certify (notarized) no awaiting trials or convictions for specified crimes (e.g., sexual abuse of a minor, murder, child abuse, aggravated assault). No employment if convicted or pending such offenses; no contact with children if history of certain acts (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025; Arizona Revised Statutes, Title 41, 2025).
• Health Screening: Physical exam by licensed practitioner before starting and every two years; free from communicable diseases (e.g., TB testing per Arizona Department of Health Services). Immunization records required (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).
• Prohibitions: Cannot reside with students; must adhere to non-discrimination under Title IX (sex-based) and Fair Housing Act (Education Amendments of 1972, 2024; Fair Housing Act, 1968).

Supervision and Staffing Ratios (AAC R6-5-7437)

• Non-class awake hours (e.g., after school): 1:10 for all students (ages 10-18, standardized for consistency across grades 5-12).
• Sleep hours: 1:15 for all students (ages 10-18); at least 1 manager per building where students sleep, with on-call support for emergencies.
• Staffing Plan: LHA must maintain a written plan ensuring 24/7 coverage for non-instructional hours, adjusted for student needs (e.g., higher ratios for trauma-informed care under Family First Prevention Services Act) (Family First Prevention Services Act, 2018; Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025). Daytime class/campus supervision by instructors at 1:6 ratio, relieving managers. With 32 managers, shifts rotate to cover peak non-class needs, ensuring no solo supervision until trained.

Other Legal Obligations

• Mandatory Reporting (A.R.S. §13-3620): Report suspected abuse/neglect immediately to DCS or law enforcement (Arizona Revised Statutes, Title 13, 2025).
• Liability and Insurance: LHA carries $1M minimum liability insurance; managers covered under workers’ comp (A.R.S. Title 23) (Arizona Revised Statutes, Title 23, 2025).
• Recordkeeping: Document all interactions, incidents, and training per FERPA and DCS standards (Family Educational Rights and Privacy Act, 1974; Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Required Training for Residential Managers

Training aligns with AAC R6-5-7433, with a written LHA plan including evaluation methods (e.g., quizzes, observations) (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).

Initial Orientation (Before Solo Supervision)

• Familiarization with LHA philosophy, policies (confidentiality, client rights, behavior management, emergencies, medications, infection control).
• CPR/First Aid certification (American Red Cross or equivalent).
• De-escalation, physical restraint (if approved), health screening, cultural sensitivity, trauma-informed care, and child welfare laws.
• Duration: Minimum 40 hours, completed within first week.

Ongoing Annual Training

• Full-time managers: At least 24 hours, covering job-specific topics including:
  • Child management and discipline techniques.
  • Crisis intervention, behavior management.
  • Health care procedures, communicable diseases.
  • CPR/First Aid recertification.
  • Attachment/separation issues, cultural/ethnic sensitivity.
  • Professional ethics, permanency planning.
  • Additional for shelters/group care: Signs of substance abuse, childhood illness.
• Evaluation: Annual performance reviews; DCS-approved providers for certification.

Training logs maintained; non-compliance leads to suspension.

Daily Duties for Residential Managers (Emphasis on Non-Class, Swing/Night Shifts)

Duties focus on supervision, safety, and support during non-instructional hours, as daytime class/campus activities are supervised by instructors at a 1:6 ratio. Managers rotate 8-12 hour shifts for work-life balance, emphasizing swing (3:00 PM–11:00 PM) and night (11:00 PM–7:00 AM) shifts. General duties include enforcing policies, documenting incidents, and coordinating with instructors/day staff.

Swing Shift (e.g., 3:00 PM–11:00 PM, Post-Class)

• Supervise after-school routines: Homework assistance, meal oversight, recreational activities in dorms/apartments/homes (1:10 ratio).
• Conduct headcounts, monitor common areas/yards for safety (e.g., fire hazards, maintenance issues).
• Facilitate life skills sessions (e.g., yard care for grade 12, supervised at 1:10 ratio).
• Address behavioral issues using de-escalation; document per behavior management policies (AAC R6-5-7456) (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).
• Prepare for bedtime: Ensure sex-segregated buildings secure, bathrooms checked.
• Handover to night shift: Report incidents, student status to managers and morning instructors.

Night Shift (e.g., 11:00 PM–7:00 AM)

• Monitor sleeping students: Hourly rounds, check for medical/emotional needs (e.g., nightmares in trauma-affected youth) at 1:15 ratio.
• Respond to emergencies: Activate protocols for medical, fire, or behavioral crises; mandatory reporting if needed.
• Maintain security: Lock checks, surveillance monitoring, prevent unauthorized access.
• Light administrative: Update logs, prepare morning reports for instructors.
• Support early risers: Assist with personal care before transition to instructors.

General/Overlapping Duties (Non-Class Hours)

• Ensure daily needs met: Hygiene, nutrition, emotional support during evenings/nights.
• Supervise staff (if senior managers), coordinate with instructors for student transitions.
• Facility upkeep: Inspect rooms, bathrooms, common areas for sanitation (ASHRAE/ADA compliant) (American Society of Heating, Refrigerating and Air-Conditioning Engineers, 2022; Americans with Disabilities Act, 1990).
• Promote independence: Guide grades 9-12 in shared responsibilities (e.g., yard maintenance with 1:10 supervision).
• Trauma-Informed: Build relationships, recognize abuse signs, foster permanency.

Duties documented daily; performance evaluated quarterly.

Implementation, Enforcement, and Review

• Licensing Process: Submit DCS Form CW-001; 90-day approval; renew annually ($200 fee) (Arizona Administrative Code, Title 6, Chapter 5, Article 74, 2025).
• Accreditation: Align with ADE standards; Mohave inspections semi-annually (Mohave County, AZ, 2023).
• Enforcement: DCS audits; Title IX coordinator mandatory for sex-based discrimination; report violations to OLR (Education Amendments of 1972, 2024).
• Review: Biennial or per ARS changes; legal counsel for Mohave variances and Title IX updates (Arizona Revised Statutes, Title 8, Chapter 4, Article 9, 2025).

This policy ensures LHA’s mission aligns with Arizona and Mohave County compliance, with consistent supervision ratios (1:6 daytime by instructors, 1:10 awake non-class, 1:15 sleep by managers) and Title IX requirements focusing on biological sex-based protections. Contact DCS OLR (602-364-2538) and Mohave Development Services (928-757-0903) for pre-application consultations.