REFUGE HOUSE, INC.

PURPOSE:

To establish Refuge House's commitment to preventing human trafficking through comprehensive training of all staff and caregivers, and age-appropriate prevention education for children, youth, and young adults in care, as mandated by the T3C Blueprint Standards for Universal Human Trafficking Prevention Training.

POLICY:

Refuge House recognizes that children in foster care face elevated vulnerability to human trafficking due to histories of abuse, neglect, placement instability, and other risk factors. In alignment with T3C Blueprint Standards (Pages 18-19), Refuge House is committed to implementing Universal Human Trafficking Prevention Training across ALL T3C Service Packages to create multiple layers of protection for children in care.

This commitment includes:

1. Staff and Caregiver Training: All Refuge House staff members and foster caregivers will receive comprehensive human trafficking prevention training that addresses trafficking dynamics, risk factors, indicators, trauma considerations, response protocols, and reporting requirements.

2. Child Prevention Education: Age-appropriate prevention information will be shared with all children, youth, and young adults in care through methods that respect their developmental stage, trauma history, and individual readiness.

3. Trauma-Informed Approach: All training and education will align with TBRI® (Trust-Based Relational Intervention) principles, recognizing that effective prevention requires relationship-based, empowering, and trauma-sensitive delivery.

4. Universal Application: Human trafficking prevention training requirements apply universally to ALL T3C Service Packages. There are no exemptions based on service package type.

TRAINING REQUIREMENTS:

Staff Training

All Refuge House staff will complete Human Trafficking Prevention Training:

• Existing Staff: Within 90 days of policy adoption
• New Staff: Within 30 days of hire, before unsupervised client contact
• Annual Refresher: As required by DFPS curriculum updates

Caregiver Training

All foster caregivers will complete Human Trafficking Prevention Training:

• Prospective Caregivers: Prior to initial licensure approval
• Current Caregivers: Within 30 days of policy adoption
• Annual Refresher: As required by DFPS curriculum updates

Child Prevention Education

Prevention education will be provided to all children, youth, and young adults through:

• Service plan integration
• Monthly home visits
• One-on-one caregiver conversations
• Therapeutic interventions (when clinically appropriate)

PACKAGE-SPECIFIC TRAFFICKING RISK CONSIDERATIONS

While Universal Human Trafficking Prevention Training applies to ALL Service Packages, certain populations served by specialized packages may present elevated trafficking risk factors requiring enhanced awareness and screening.

Substance Use Support Services

Youth receiving Substance Use Support Services may present elevated trafficking risk due to:

• Substance use as both recruitment tool and control mechanism by traffickers
• Exchange of substances for sex or labor (survival trafficking)
• Traffickers targeting youth with substance use disorders as vulnerable
• Substance use resulting from or exacerbated by trafficking experiences
• Co-occurrence of trafficking and substance use in youth histories

Enhanced Awareness Required: Staff and caregivers working with youth in this package must apply heightened vigilance to trafficking indicators, recognizing the strong correlation between substance use and trafficking victimization.

Short-Term Assessment Support Services

The assessment period presents a critical screening opportunity because:

• Children entering Short-Term Assessment may have undisclosed trafficking histories
• Comprehensive assessment can identify previously unrecognized trafficking indicators
• Assessment findings inform Service Package recommendation and safety planning
• Short placement duration requires prompt identification and response

Assessment Integration: Trafficking indicator screening must be integrated into the comprehensive assessment process, with findings documented for transition to receiving Service Package.

T3C Treatment Foster Family Care

Youth receiving Treatment Foster Family Care may present elevated trafficking risk due to:

• Serious mental, emotional, and behavioral challenges may result from trafficking trauma
• High-acuity youth may exhibit trafficking-related behaviors (running, sexual acting out, distrust of adults)
• Intensive services may uncover previously undisclosed trafficking experiences
• Youth with complex trauma histories are at increased vulnerability

Clinical Integration: Human trafficking considerations must be integrated into clinical assessment and treatment planning, with Treatment Director providing oversight for trafficking-related clinical concerns.

PACKAGE-SPECIFIC SCREENING AND RESPONSE

Substance Use Support Services Screening

In addition to universal screening at admission:

• Initial SU Assessment: Substance use assessment must include questions about how substances were obtained, including any exchange for substances
• Treatment Team Awareness: All providers working with SU youth must be trained on trafficking-substance use correlations
• Ongoing Monitoring: Case Manager and caregiver must monitor for trafficking indicators throughout placement, with heightened awareness during early recovery when youth may be most vulnerable
• Disclosure Protocol: If trafficking history is disclosed during substance use treatment, immediate response per TR-HT-01.1 reporting requirements

Short-Term Assessment Screening

Within the comprehensive assessment framework:

• Assessment Coordinator Training: Treatment Director overseeing assessments must ensure trafficking indicators are considered across all assessment domains
• Multi-Domain Review: Trafficking indicators may present in medical, behavioral, mental health, and developmental assessments
• Documentation for Transition: Any identified or suspected trafficking indicators must be documented in Transition Summary for receiving Service Package
• Expedited Response: Given short placement duration, any trafficking concerns require immediate response per TR-HT-01.1

Treatment Foster Family Care Screening

Within intensive clinical services:

• Clinical Assessment Integration: Licensed Therapist and Treatment Director must consider trafficking in differential diagnosis and treatment planning
• Behavior Interpretation: Staff trained to interpret high-risk behaviors (running, sexual acting out, unexplained resources) through trafficking lens
• Therapeutic Response: If trafficking history identified, treatment goals must address trafficking-related trauma
• Step-Down Planning: Trafficking history or risk must be addressed in step-down planning and communicated to receiving placement

CURRICULUM SELECTION:

Refuge House adopts the DFPS Universal Human Trafficking Prevention Training: A Foundation for Texas Residential Providers and Caregivers as the primary curriculum. This curriculum:

• Meets all T3C Blueprint requirements
• Aligns with TBRI® principles
• Provides age-appropriate prevention strategies
• Includes Train-the-Trainer certification through DFPS LearningHUB

Alternative or supplemental curricula may be adopted with DFPS approval, provided they meet or exceed the evidence-based standards of the DFPS curriculum.

REPORTING:

All staff and caregivers are mandatory reporters and must immediately report any suspected human trafficking to:

• Law enforcement (911 for emergencies)
• DFPS Statewide Intake (1-800-252-5400)
• National Human Trafficking Hotline (1-888-373-7888)
• Refuge House Program Director

Reporting requirements and response protocols are detailed in TR-HT-01.1.

QUALITY ASSURANCE:

Refuge House will monitor compliance with this policy through:

• Quarterly training compliance reviews
• Monthly case file audits for prevention education documentation
• Annual program effectiveness evaluation
• Incident analysis for any trafficking-related concerns

DEFINITIONS:

• Human Trafficking: A form of modern-day slavery involving the use of force, fraud, or coercion to exploit individuals for labor, services, or commercial sex acts
• Sex Trafficking: Recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person for the purpose of a commercial sex act through force, fraud, or coercion, or involving a minor
• Labor Trafficking: Recruitment, harboring, transportation, provision, or obtaining of a person for labor or services through force, fraud, or coercion for the purpose of involuntary servitude, peonage, debt bondage, or slavery
• Survival Trafficking: Exchange of sex or labor for basic needs such as food, shelter, or substances
• TBRI®: Trust-Based Relational Intervention, Refuge House's evidence-informed treatment model

REFERENCES:

• T3C Blueprint Standards: Pages 18-19 (Universal Human Trafficking Prevention Training)
• TAC Chapter 749 Minimum Standards: §749.43 (Required Training); §749.911 (Pre-Service Training)
• DFPS 24-Hour RCC Requirements (FY26)
• DFPS Universal Human Trafficking Prevention Training: A Foundation for Texas Residential Providers and Caregivers (Fall 2024)
• Trafficking Victims Protection Act (TVPA)
• Texas Human Trafficking Prevention Task Force
• FC-SU-01 Substance Use Support Services Policy (elevated trafficking risk provisions)
• FC-STASS-01 Short-Term Assessment Support Services Policy (assessment integration)
• FC-TFFC-01 T3C Treatment Foster Family Care Support Services Policy (clinical integration)

RELATED PROCEDURES:

• TR-HT-01.1 Universal Human Trafficking Prevention Training Procedure
• FC3-01.1 Individual Service Planning Procedure
• FC-SU-01.1 Substance Use Support Services Procedure
• FC-STASS-01.1 Short-Term Assessment Support Services Procedure
• FC-TFFC-01.1 T3C Treatment Foster Family Care Support Services Procedure

FORMS/ATTACHMENTS:

• Human Trafficking Prevention Training Completion Certificate
• Child Prevention Education Documentation Form
• Human Trafficking Concern Report Form
• Training Compliance Tracking Report

Package-Specific Screening Supplements:

• Substance Use Trafficking Indicator Checklist
• Assessment Period Trafficking Documentation Template
• Clinical Trafficking Assessment Integration Guide (TFFC)

This policy document establishes the governing principles for Universal Human Trafficking Prevention Training. The corresponding procedure document (TR-HT-01.1) operationalizes these principles by providing specific implementation details (who, when, where, and how). While policies require Board approval and remain relatively stable, procedures may be updated by the Executive Director to adapt to regulatory changes, technological advancements, or operational improvements without requiring Board approval, provided such changes maintain alignment with the policy's intent.