Appendix B: Public Comments

ANDREW M. CUOMO
Governor

SHEILA J. POOLE
Commissioner

August 19, 2020
U.S. Department of Health and Human Services
Administration for Children and Families
Office of Planning, Research and Evaluation
Submitted via e-mail: OPREinfocollection@acf.hhs.gov
Re: 85 FR 38371
Proposed Information Collection Activity; “Identifying and Addressing Human Trafficking in Child
Welfare Agencies” (New Collection)
To Whom This May Concern:
The New York State Office of Children and Family Services (OCFS) is pleased to submit the following
comments in response to the above-referenced proposed information collection activity that was
published in the Federal Register, 85 FR 38371, on Friday, June 26, 2020. NYS OCFS is the state
agency that manages implementation and provides oversight of the child welfare response to child
trafficking and exploitation in New York State. This includes the implementation of relevant portions of the
Preventing Sex Trafficking and Strengthening Families Act, Families First Prevention Services Act, and
the New York State Safe Harbour: NY Program.
Supporting accurate identification and quality services for youth impacted by trafficking and exploitation in
New York State is part of the core mission of our agency. NYS OCFS has authored multiple screening
tools to better identify these youth, as well as a mandatory law enforcement referral process as required
by federal law. OCFS has gone beyond federal mandates by driving the development of locally
responsive, child welfare-led responses to child exploitation and trafficking through the Safe Harbour: NY
Program. In addition to implementing these responses in NY, OCFS has also consulted with a large
number of other state child welfare agencies as they develop their own responses to this issue.
Additionally, OCFS is a founding member of the national Child Welfare Human Trafficking Collaborative
and the collaborative’s steering committee.
Based on our own experiences, and those of our local and national partners, it is clear that more
information is needed on best practice in quickly and unobtrusively identifying survivors of child trafficking,
as well as providing those youth with effective specialized services. NYS OCFS strongly supports ACF’s
proposed data collection as part of the study “Identifying and Addressing Human Trafficking in Child
Welfare Agencies” to explore child welfare practice in screening for human trafficking and the relationship
between screening and specialized services.
In order to maximize the practical utility of this study, NYS OCFS recommends that interviews be
conducted with states of varying sizes and that the study focus on those states that have made the most
progress in this area of practice. NYS OCFS further recommends that interviews be conducted with states
that directly implement child welfare services, as well as states that implement child welfare services at

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the county level with state oversight. Additionally, it will be critical that Tribal leaders are engaged in
interviews so insights into practice improvement with native communities and nations can be gleaned.
In addition, to further maximize the practical utility of this study, NYS OCFS recommends that ACF
publish a list of identified tools that most appropriately identify youth in accordance with the Preventing
Sex Trafficking and Strengthening Families Act mandate. Such tools would be most useful if they are
easy to implement, cause no additional trauma to youth, and accurately identify survivors and youth atrisk of all ages, races, sexual orientations, gender identities, and from communities of all densities (rural,
suburban, and urban).
Furthermore, NYS OCFS believes that in order to align the requirements of the Preventing Sex Trafficking
and Strengthening Families Act and the Families First Prevention Services Act, information from this
study will be most useful when it speaks not only to the factors listed above, but also to the most
appropriate services that can support the healing of identified youth. At present, OCFS is not aware of
any evidence-based models of care for youth with commercial sexual exploitation experience (CSEC)
who are placed in a foster care setting or who are receiving aftercare services. Therefore, NYS OCFS
believes that this area of practice would benefit from further study.
Finally, NYS OCFS encourages all the ACF research concerning youth trafficking and exploitation to
engage youth and survivors of all gender identities in meaningful ways. In addition to garnering the input
of those youth most impacted by our systems, their participation in the research, study design, execution,
conclusion drawing and presentation, would create meaningful opportunities for paid employment. This
opportunity would lend itself as both a protective factor for youth and survivors alike and truly capture
successful versus unsuccessful screening and specialized service practices being utilized.
Thank you for the opportunity to provide these comments. OCFS appreciates the ACF’s interest in our
state’s experiences and ideas on how to identify youth who are at-risk or have survived trafficking and
exploitation and services to support their healing. We hope our comments will be thoughtfully considered
and used to support federal efforts to compile information and provide guidance and technical assistance
to states in furtherance of the shared goals. Should you have any questions or need further clarification,
we would be pleased to provide additional information.

Sincerely,

Nina Aledort, PhD.
Deputy Commissioner
Youth Development and Partnerships for Success

52 Washington Street, Rensselaer, NY 12144 │ ocfs.ny.gov