1. Purpose
The Legacy Haven Academy Foundation (the "Academy") is dedicated to fostering a safe, supportive, and compliant environment for vulnerable youth, including orphans and homeless students aged 10-18. This policy establishes mandatory annual training requirements for all staff and faculty to ensure compliance with Internal Revenue Service (IRS) guidelines for organizations preparing for 501(c)(3) status, Arizona state regulations under the Arizona Revised Statutes (ARS) and Arizona Administrative Code (AAC), and applicable Mohave County standards. These trainings promote ethical governance, child safety, professional development, and operational excellence, aligning with the Academy's mission of trauma-informed care and resilience-building (Arizona Department of Trauma-Informed Care and Resilience Building, 2023). As the Academy has not yet received 501(c)(3) status, this policy supports preparatory compliance to facilitate tax-exempt recognition.
2. Scope
This policy applies to all Academy employees, including full-time and part-time staff (e.g., residential managers, security personnel), faculty (e.g., instructors, mentors), and contractors involved in direct child care or educational services. It encompasses annual trainings derived from regulatory mandates and best practices. Non-annual trainings (e.g., initial onboarding or quarterly sessions) are addressed in related policies such as LHA-AOP-001 (Academic Operations) and LHA-SEC-002 (Child Protection and Safeguarding). All security personnel are armed and subject to specialized training requirements.
3. Definitions
- Staff: Individuals employed in non-instructional roles, such as administrative, residential, or security personnel.
- Faculty: Individuals in instructional or mentoring roles, including teachers and academic advisors.
- Direct Care Staff: Personnel with regular unsupervised contact with students, subject to enhanced training under AAC Title 6, Chapter 5, Article 74.
- Annual Training: Required education completed within each 12-month period from the employee's hire date or the policy's effective date.
- ** Traum-Informed Care (TIC):** An approach recognizing the impact of adverse childhood experiences (ACEs), as defined by the Arizona Department of Child Safety (2020).
4. Regulatory Compliance Framework
The Academy's training requirements are informed by:
- IRS Guidelines: Best practices for governance, including annual awareness of conflict of interest, whistleblower, and document retention policies to support Form 990 compliance and 501(c)(3) eligibility (Internal Revenue Service, 2008).
- Arizona State Regulations: Mandates from ARS Title 8 (Child Safety) and AAC Title 6, Chapter 5, Article 74 (Child Welfare Agency Licensing), requiring 24 hours of annual training for direct care staff in residential group care facilities, including child abuse reporting (ARS §13-3620), de-escalation, and health/safety (Arizona Department of Health Services, n.d.). Additional requirements from AAC R9-5-403 mandate 18 hours annually for general staff.
- Mohave County Standards: Local compliance aligns with state regulations, with no unique county-level training mandates; adherence to county health inspections and zoning supports integrated safety training (Mohave County, 2024).
- Federal Overlaps: Incorporates Title IX training on sex discrimination (U.S. Department of Education, 2020), FERPA privacy training (U.S. Department of Education, n.d.), OSHA emergency preparedness, including for armed personnel (Occupational Safety and Health Administration, 2024), and cybersecurity awareness under COPPA and FERPA (Federal Trade Commission, 2024).
5. Required Annual Trainings
Trainings are consolidated to avoid duplication, with minimum hours specified where mandated. All staff and faculty must complete a core set, with role-specific additions. Documentation of completion is required, tracked via the Academy's human resources system, and acknowledged annually.
5.1 Core Trainings (Applicable to All Staff and Faculty, Minimum 18-24 Hours Total)
- Child Abuse Recognition, Mandatory Reporting, and Protection from Abuse (4-6 Hours): Training on identifying signs of abuse/neglect, reporting procedures under ARS §13-3620, guardianship claims, and child release protocols. Includes DCS-approved modules and annual acknowledgment (Arizona Department of Child Safety, 2023; LHA-ADM-002; LHA-SEC-002).
- Trauma-Informed Care (TIC) and Child Development (8 Hours): Certification in TIC, de-escalation techniques, behavior management, attachment issues, cultural sensitivity, and ACEs framework. Mandated for direct care staff under AAC R6-5-7438 (Arizona Department of Child Safety, 2020; LHA-AOP-001; LHA-DOT-001; LHA-SEC-002).
- Anti-Harassment, Non-Discrimination, and Title IX Compliance (2-4 Hours): Recognition and prevention of harassment, including sex-based discrimination, with grievance procedures (U.S. Department of Education, 2020; LHA-DIR-001).
- Privacy, Data Protection, and FERPA (2 Hours): Handling student records, opt-out notices, and data security under FERPA (U.S. Department of Education, n.d.; LHA-DIA-001).
- Cybersecurity Awareness and Incident Response (2 Hours): Policies on data protection, penetration testing review, and contingency planning for child data systems (National Institute of Standards and Technology, 2023; LHA-DIA-002).
- Governance and Ethics (2 Hours): Whistleblower policy, conflict of interest disclosures, document retention/destruction, and compensation awareness to prepare for IRS Form 990 (Internal Revenue Service, 2008; LHA-ADM-003; LHA-ADM-004; LHA-ADM-005; LHA-ADM-006).
- Health, Safety, and Emergency Preparedness (4 Hours): OSHA-compliant training on emergency response, CPR/First Aid recertification, substance abuse signs, childhood illness, and EOP drills (Occupational Safety and Health Administration, 2024; LHA-DOT-001; LHA-LOG-001).
5.2 Role-Specific Trainings
- For Residential and Direct Care Staff (Additional 8-12 Hours, Totaling 24 Hours): Child management, crisis intervention, permanency planning, professional ethics, and health procedures (AAC R6-5-7438; LHA-LOG-001).
- For Security Personnel (Additional 56-108 Hours, Totaling 74-132 Hours): OSHA emergency preparedness (2 hours), psychological evaluations, physical fitness qualification, basic firearms (8 hours), precision firearms operations (96 hours, reflecting all personnel being armed), pupil health/safety post-incident, incident response (1 hour), and general security training (40 hours) (LHA-SEC-001).
- For Faculty and Mentors (Additional 4-6 Hours, Totaling 22-30 Hours): Boundary-setting, suicide risk (ASIST certification), and educational privacy under FERPA (Arizona Department of Education, 2023; LHA-SEC-002).
- For Administrative/Financial Staff (Additional 2 Hours, Totaling 20-26 Hours): Financial literacy, fraud prevention, and gift acceptance (LHA-LOG-002; LHA-ADM-007).
Trainings may be delivered in-person, online (e.g., DCS modules), or via certified providers, with at least 50% focused on child welfare topics as per AAC requirements.
6. Procedures
- Scheduling and Completion: Human Resources will notify employees 30 days prior to their annual deadline. Trainings must be completed within the 12-month cycle, with extensions only for documented extenuating circumstances.
- Tracking and Documentation: Completion records, including certificates and acknowledgments, must be submitted to HR and retained for 5 years (per LHA-ADM-005). Annual policy sign-off confirms understanding.
- Monitoring and Compliance: The Board of Education conducts annual audits for 100% compliance. Non-compliance may result in disciplinary action, up to termination, in line with ARS Title 8 and IRS governance standards.
- Evaluation and Updates: This policy will be reviewed annually or upon regulatory changes (e.g., ARS amendments), with input from Mohave County health officials if applicable.
- Costs and Resources: The Academy will cover training costs; external providers (e.g., DCS online modules) are prioritized for efficiency.
7. Responsibilities
- Board of Education: Approve policy and oversee compliance (LHA-BOE-001).
- Human Resources: Coordinate, track, and audit trainings.
- Staff and Faculty: Complete trainings promptly and apply knowledge in daily duties.
