Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants or students in clinical program seeking licensure) employed by the University of Southern California, USC Health System, and their respective subsidiaries and affiliates in addition to volunteers (“USC employees”). This policy continues to apply to individuals on sabbatical, other leaves or while visiting other institutions.
1. POLICY
Issued: July 7, 2015
Last Revised: March 6, 2024
Last Reviewed: July 15, 2024
2. Policy Purpose
Mandated Reporters have an individual duty to report known or suspected abuse or neglect relating to children, elders, or dependent adults. Any employees whose positions are designated by the state of California as Mandated Reporters must understand what they are required to report, when it must be reported, and to whom. Summary information regarding the three categories of mandated reports is provided below.
The Protecting Minors Policy is a companion policy that details Mandated Reporters responsibilities specific to known or suspected abuse or neglect of minors as well as the management of university activities involving minors. Although Mandated Reporter obligations for reporting suspected child abuse and neglect are referenced in this policy, this policy does not supersede or alter any requirements set forth in the Protecting Minors Policy, which governs all Mandated Reporter requirements for reporting known or suspected child abuse and neglect.
3. Scope and Application
California law designates University of Southern California (“USC”) employees holding certain positions as “Mandated Reporters” (defined below and in Appendix A). Mandated Reporters have an individual duty to report known or suspected abuse or neglect relating to children, elders or dependent adults. USC employees whose positions are designated by the state as Mandated Reporters, or by USC policy, must understand what they are required to report, when it must be reported, and to whom. Summary information regarding the three categories of mandated reports is provided below.
Some schools and departments may offer additional guidance related to abuse reporting. Those procedures are in addition to, but do not replace, the procedures described in this policy. USC employees should refer to their department or facility for those additional abuse reporting procedures.
4. Definitions
| Term | Definition |
| Mandated Reporter | Employee who is required by law to report a particular category or type of abuse to the appropriate law enforcement or social service agency. |
| Child | Person under age 18. (Penal Code § 11165) |
| Elder | Person age 65 or older. (Welfare & Inst. Code § 15610.26) |
| Dependent Adult | Person between ages 18 and 64 with a physical or mental limitation that restricts his or her ability to carry out normal activities or protect his or her rights. Includes all people between ages 18 and 64 who have been admitted as an inpatient to a 24-hour health care facility. (Welfare & Inst. Code § 15610.23) |
| Employee | University employees, including University staff employees and non-University employees (such as employees of a staffing agency providing temporary personnel to the University) as defined in USC’s Employee Definitions policy. |
| Covered Activity | Any activity, camp, program and/or event in which the care, custody, and/or supervision of one or more Minors (other than Minors who are Employees or Students) is reasonably expected to be the responsibility of one or more Covered Activity Staff, including University Employees, Students, Volunteers, and/or Third-Party staff acting on behalf of or pursuant to a contract with the University. |
| Covered Activity Staff | All individuals reasonably expected to work with or otherwise come into Direct Contact with Minors in a Covered Activity. This includes Employees, Students, Volunteers, and Third Parties administering a Covered Activity, including all individuals employed by, contracted by, or volunteering for a Third Party in connection with a Covered Activity. |
5. Policy Details
Child Abuse/Neglect
The state of California has established various laws that seek to protect children from all forms of abuse, including the Child Abuse and Neglect Reporting Act (“CANRA”) set forth in California Penal Code §§ 11164-11174.3. CANRA imposes mandatory reporting obligations upon certain categories of employees, referred to as “Mandated Reporters” (for a full and specific list of categories defined by CANRA see California Penal Code §11165.7). However, USC seeks to promote the protection of minors more broadly by requiring that all University Employees and Covered Activity Staff, regardless of whether they qualify as Mandated Reporters under CANRA, immediately report suspected Child Abuse and Neglect, as well as all other serious incidents or violations relating to minors, to the appropriate external agencies and University officials as described in the Protecting Minors Policy (see Section 6.I. Reporting Requirements for more information, including who must report and the reporting process).
Dependent Adult/Elder Abuse
Who must report (Welfare & Inst. Code § 15630)
The following categories of employees are Mandated Reporters for elder or dependent adult abuse:
- Any employee (including support staff and maintenance staff) working in any facility that provides any elder or dependent care services
- Any employee providing direct health care or social services to an elder or dependent adult
- Health care practitioners
- Clergy
What must be reported (Welfare & Inst. Code § 15630(b))
The following general categories of incidents of abuse of an elder or dependent adult must be reported when a Mandated Reporter has observed, has knowledge of or reasonably suspects the abuse, or is told by the elder or dependent adult that such abuse has occurred:
- Physical abuse
- Abandonment
- Abduction
- Isolation
- Financial abuse
- Neglect
Injury by Firearm or Assault/Abuse
Who must report (Penal Code § 11160(a))
All healthcare practitioners, if in their professional capacity or within the scope of their employment provide medical services for a physical condition to a patient whom the health practitioner knows or reasonably suspects resulted from injury by firearm or assault/abuse must report to law enforcement.
Any health practitioner providing services in a health facility, clinic or physician’s office who knows or reasonably suspects that a patient to whom the practitioner is providing services is the victim of assaultive or abusive conduct or a firearm injury.
What must be reported (Penal Code § 11160(a)(1),(2),(d))
Healthcare practitioners must report physical injuries the healthcare practitioner knows or reasonably suspects is caused by a firearm or the result of assaultive or abusive conduct —whether inflicted by the patient or another; murder; manslaughter; mayhem; aggravated mayhem; torture; or assault with intent to commit mayhem, rape, sodomy, or oral copulation; assault with a stun gun, taser, deadly weapon, firearm, assault weapon, or machine likely to produce great bodily injury; administration of a controlled substance or anesthetic to aid in commission of a felony; battery; sexual battery; incest; rape; spousal rape; procuring a female to have sex with another man; sodomy; oral copulation; sexual penetration; lewd and lascivious acts with a child; throwing chemical substances with the intent to injure or disfigure; elder abuse; abuse of spouse, cohabitant, or an elder; or an attempt to commit any of these crimes.
Enforcement
For those who are mandated reporters under California law, failure to report is a misdemeanor punishable by up to six months in jail or a fine of up to $1000, or both (Penal Code §§ 11162, 11166(c); Welfare & Inst. Code § 15630(h)). In some cases, failure to report elder or dependent adult abuse may result in up to one year in jail or a fine of up to $5000, or both (Welfare & Inst. Code § 15630(h)).
Failure to report is serious neglect of duty that can lead to progressive discipline for both faculty and staff, including termination.
All employees who are Mandated Reporters under California law are required to sign the relevant acknowledgment forms (see Forms, below).
6. Procedures
Child Abuse/Neglect
Reporting process (Penal Code § 11166)
Suspected Child Abuse and Neglect, as well as all other serious incidents or violations relating to minors, must be immediately reported to the appropriate external agencies and University officials as described in the Protecting Minors Policy (see Section 6.I. Reporting Requirements).
Dependent Adult/Elder Abuse
Reporting procedures (Welfare & Inst. Code § 15630(c))
The appropriate reporting agency for elder and dependent adult abuse depends on the location in which the abuse occurred, not the location in which it was discovered. After a report has been made using the procedures below, follow up and status updates may be obtained via the Adult Protective Services Mandated Reporter Hotline at (888) 202-4248.
Long-term care or adult day health care center
- Immediately—Telephone report to the Long Term Care Ombudsman Program at (800) 334-9473 Monday – Friday, 8:30 a. – 5:00 p.m. or (800) 231-4024, After Hours.
- Within two working days—Written report via online reporting portal at Adult Protective Services Web Intake or on Form SOC341 “Report of Suspected Dependent Adult/Elder Abuse” to Long Term Care Ombudsman; address to be provided when making telephone report. Form available at: Report of Suspected Dependent Adult/Elder Abuse
All other settings
- Immediately—Telephone report to Adult Protective Services at (213) 351-5401 or (877) 477-3647.
- Within two working days—Written report via online reporting portal at Adult Protective Services Web Intake or on Form SOC341 “Report of Suspected Dependent Adult/Elder Abuse” faxed to (213) 738-6485. Form available at: Report of Suspected Dependent Adult/Elder Abuse
Injury by Firearm or Assault/Abuse
Reporting process (Penal Code § 11160(b))
The practitioner must report to law enforcement by
- Immediately calling local law enforcement, and
- By completing a Form OES 2-920 Suspicious Injury Report. The form should be faxed to local law enforcement.
Contact information for the Los Angeles Police Department is provided below:
Los Angeles Police Department
24/7 emergency number: dial 911
24/7 non-emergency number: 1-877-275-5273 (1-877-ASK-LAPD)
Additional Procedures
- The USC hospitals and the Herman Ostrow School of Dentistry have additional procedures related to the same categories of mandated reporting. For example, health care providers also may need to make an accounting of disclosures under this policy as required by the HIPAA Privacy Rule. See the hospital intranet for links to hospital-based Mandated Reporter information, and USC’s HIPAA policies at https://policy.usc.edu/admin/.
7. Forms
Form OES 2-920 Suspicious Injury Report
Form SOC341 Report of Suspected Dependent Adult/Elder Abuse
USC Child Abuse and Neglect Reporting Form
Suspected Child Abuse Report (SCAR) Form SS8572
USC Employee Acknowledgment on Child Abuse
USC Employee Acknowledgment on Elder Abuse
8. Responsibilities
| POSITION or OFFICE | RESPONSIBILITIES |
| Office of Youth Protection and Programming | Provides support and guidance to the USC community on matters related to youth protection and programming. |
| Office of Professionalism and Ethics | Provides support and guidance to the USC community on matters related to reporting suspicious injuries and elder abuse. |
9. Related Information
Appendix A: California abuse/neglect mandated reporters
10. Contacts
Please direct any questions regarding this policy to:
| OFFICE | PHONE | |
| Office of Professionalism and Ethics | (213) 740-5755 | ope@usc.edu |