SBA Non-Discrimination and Child Abuse Policies

*Posted May 29, 2020
**Updated February 2/2023

Saint Edward’s School has received a loan pursuant to the Paycheck Protection Program administered by the Small Business Administration (“SBA”). This policy is intended to demonstrate good faith compliance with the regulations issued by the SBA and by other governmental agencies enforcing the laws that attach to the School due to the School’s receipt of federal financial assistance through the SBA loan. This policy shall remain in place from the time the School receives the SBA funding until the loan is paid or forgiven. 

School Compliance Officer
Saint Edward’s School identifies the following individuals to act as its Compliance Officer under this policy:

Title IX Compliance Officer:
Shelli Greaves
Section 504 Compliance Officer:  
Shelli Greaves

The Compliance Officer shall be responsible for coordinating the School’s effort to meet its responsibilities under this policy. The Compliance Officer will receive and investigate any complaints filed under this policy and make recommendations to the Head of School for the prompt and equitable resolution of complaints.  The School will provide its Compliance Officer and staff appropriate training on this policy and their obligations hereunder.

Non-discrimination, Anti-harassment, Non-retaliation
Saint Edward’s School acknowledges its obligations to prohibit discrimination, harassment, or retaliation on the basis of race, color, national origin, age, sex, disability/handicap, or religion in admission to its educational programs, activities, and services, and in employment opportunities or processes.  Retaliation against an individual for filing a complaint under this policy or participating in the informal or formal resolution is prohibited. 

Academic and Non-Academic Services for Persons with Disabilities
Saint Edward’s School remains committed to excellence in educational programming and acknowledges its obligation to ensure that no otherwise qualified individual with a disability shall, solely by reason of his/her disability, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. This includes both academic and non-academic services, such as counseling, extracurricular services, athletics, transportation, health services, recreational activities, clubs, and other activities.  
Saint Edward’s School will also assess its ability to make reasonable accommodations to disabled individuals to permit such persons to participate in and enjoy the benefits of the School’s programs and activities so long as doing so does not fundamentally alter the nature of the School’s program.  Individuals who seek an accommodation should contact Shelli Greaves.

Employment Obligations for Applicants and Employees with Disabilities
Saint Edward’s School acknowledges its obligation under the SBA regulations and laws applicable to recipients of federal financial assistance to prohibit discrimination against any employee or applicant based upon his/her disability. This obligation extends to all aspects of employment, including the hiring and employment processes.
Saint Edward’s School will also assess its ability to make reasonable accommodations to disabled individuals so long as doing so does not create an undue hardship.  Individuals who seek an accommodation should contact Shelli Greaves, Saint Edward’s School’s Compliance Officer for Section 504.
Facilities Access
Saint Edward’s School acknowledges its obligation under the SBA regulations to operate its programs and activities in existing facilities so they are readily accessible to qualified individuals with disabilities. The location in facilities (or movement of classes, meetings, etc. to other facilities) will be scheduled in a manner that will not knowingly deny a student, employee, parent, or visitor with a disability the opportunity to participate on the same basis as such persons without disabilities. Accommodations may be provided to allow access to educational programming or meetings. 

Complaint Procedure
Who may make a complaint? 
A person (student, parent, employee, or applicant) may use this complaint procedure to report a concern or allegation that s/he is being denied an equal opportunity to access Saint Edward’s School’s education programs, activities or services, including employment opportunities. 

Who can a complaint be made to? 
A complaint may be reported to the Compliance Officer, an Administrator, or to a staff member. Any complaint received by an Administrator or staff member shall be promptly reported to a Compliance Officer for handling.  

How do you file a complaint? 
A complaint may be made verbally or in writing. The School has an SBA Complaint Form available for those who choose to use it.
A complaint may also be filed with the SBA directly by sending a letter to the Administrator, Small Business Administration (SBA), Washington, D.C. 20416.

Or you can file a complaint with the Department of Education’s Office of Civil Rights (OCR).
OCR’s electronic complaint form is at the following website:

You may also email OCR’s
Discrimination Complaint Form or your own signed letter to If you write your own letter, please include the information identified above.

Are there timelines for filing a complaint?
Timelines are flexible, but a person with a complaint should try to report it within thirty (30) calendar days after an alleged discriminatory incident. If the complaint is filed directly with the SBA or OCR, it must be filed within 180 days of the alleged discriminatory action.

How long will it take to have a complaint handled? 
While Saint Edward’s School will try to handle the complaint as expeditiously as possible, there can be unexpected or unforeseen circumstances that cause delay. Complaints involving a handicap/disability and request for accommodation will be promptly referred to a 504 team for handling. Those complaints that require an investigation will be completed within thirty (30) days of the complaint, if possible. Should more time be required, the Compliance Officer will notify the complainant. 

Informal complaint process
This policy provides an individual the option of filing an informal complaint (verbally or in writing), which allows a fuller range of options in facilitating prompt resolution of an issue(s). It is the choice of the individual complaining whether to initially pursue an informal complaint procedure. The Compliance Officer, or her designee, shall explore an informal resolution with the complainant, which may involve providing advice to the complainant on how to handle the issue(s) or reviewing this policy with persons involved in the issue. If the matter involves the conduct of another person, an informal resolution could involve a meeting with the complainant and that person provided both individuals agreed. Resolution through this informal procedure will be promptly explored. At any time, the complainant may request to end the informal procedure to move to the formal complaint process.

Formal complaint process
An individual may file a formal complaint (verbally or in writing) under this policy. The complainant may use the SBA Complaint Form that the School can provide or should provide the following information: a statement of the complaint that identifies the issue, provides pertinent facts, identifies those involved, and states what remedy is sought. If the complainant does not provide a written statement, the Compliance Officer will prepare a statement for the complainant to review for accuracy after interviewing him/her. 

The Compliance Officer, or her designee (“Investigator”) shall begin a formal investigation into a complaint within three (3) business days of receipt. Should the complaint allege another person engaged in discriminatory, harassing, or retaliatory conduct (“respondent”), the Investigator shall notify her that a complaint was filed, provide a statement of the nature of the allegations, and provide a copy of this policy and any other applicable school policy. The Investigator shall interview the complainant and any respondent as well as witnesses reasonably believed to have relevant information. The Investigator shall also consider relevant documents submitted by any person interviewed. The respondent may submit a written response to the complaint within seven (7) calendar days of being notified of the complaint. 

At the conclusion of the investigation, the Compliance Officer shall submit the written report of the investigator to the Head of School along with recommendations as to whether and how this policy was violated and a proposed remedy for the situation.  

The Head of School or his designee shall review the Compliance Officer’s report and issue a final decision, or, remand the matter back to the Investigator for further investigation. If remanded, the specific areas or issues to be investigated further shall be identified. Once the investigation is complete to the satisfaction of the Head of School, he shall issue a final written decision as to whether and how this policy was violated as well as any remedial corrective action that will be taken to redress the matter and prevent further violations. Any corrective action must be age-appropriate and timely. The decision of the Head of School shall be final and shall be communicated to the complainant and respondent separately and simultaneously as directed by the Head of School.

Florida Statutes require that all school personnel immediately report to the Department of Children and Families (DCF) any knowledge or reasonable cause to suspect that a child has been abused, neglected, or abandoned.  Abuse includes sexual abuse by another child. 

Any willful act or threatened act that results in any physical, mental, or sexual injury or harm that causes or is likely to cause the child’s physical, mental, or emotional health to be significantly impaired.  

When a child is deprived of necessary food, clothing, shelter, or medical treatment or a child is permitted to live in an environment when such deprivation or environment causes the child’s physical, mental, or emotional health to be significantly impaired or to be in danger of being significantly impaired. 

A situation in which the parent or caregiver responsible for the child’s welfare makes no significant contribution to the child’s care and maintenance.  This includes leaving a child without adult supervision or an arrangement appropriate for the child’s age or mental or physical condition, so that the child is unable to care for the child’s own needs or another’s basic needs or is unable to exercise good judgment in responding to any kind of physical or emotional crisis. 

Any sexual behavior by a child toward another child which occurs without consent, without equality (lacking the same level of power in the relationship), or as a result of coercion, including making obscene phone calls, the showing or taking of lewd photographs, or varying degrees of direct sexual contact, such as fondling, digital penetration, rape, and various other sexually aggressive acts.  

To a child’s health or welfare can occur when any person: 

Inflicts or allows to be inflicted upon the child physical, mental, or emotional injury, including willful acts causing injuries such as:
o    Sprains, dislocations, or cartilage damage.
o    Bone or skull fractures.
o    Brain or spinal cord damage.
o    Intracranial hemorrhage or injury to other internal organs.
o    Asphyxiation, suffocation, or drowning.
o    Injury resulting from the use of a deadly weapon.
o    Burns or scalding.
o    Cuts, lacerations, punctures, or bites.
o    Permanent or temporary disfigurement.
o    Permanent or temporary loss or impairment of a body part or function.

Purposely gives a child poison, alcohol, drugs, or other substances that substantially affect the child’s behavior, motor coordination, or judgment or that results in sickness or internal injury.

Inflicts inappropriately or excessively harsh disciplinary action that is likely to result in physical injury, mental injury, or emotional injury. Corporal discipline may be considered excessive or abusive when it results in any of the following or other similar injuries those injuries set forth in a. through j. above.

Commits, or allows to be committed, sexual battery, or lewd or lascivious acts, against the child.

Reports of abuse must be made to the state by calling the toll-free Abuse Hotline at (800) 962-2873. If you would like assistance in making the report, you may contact the Head of School.  Seeking assistance from the School’s administration does not satisfy your obligation to report child abuse directly to DCF. After you have made a report, please notify the Head of School so the School can assist with investigations and/or ensure that appropriate personnel are watchful for sign of future potential abuse of the child(ren) in question.    Employees who report concerns of suspected abuse, abandonment, or neglect are expected to cooperate in any investigation by child protective services. 

It is a third-degree felony to fail to report suspected abuse, abandonment, or neglect.  In addition, an educator’s teaching certificate may be suspended from any person who knowingly failed to report child abuse, abandonment, or neglect. 

Under the provisions of Florida Stat. § 39.203, employees who, in good faith, report suspected child abuse, neglect, or abandonment are immune from civil or criminal liability for reporting such information and participating in any investigation.  Other than the report itself and communication with the Head of School, the information about the suspected child abuse, abandonment, or neglect should remain confidential for the protection of the child.  You will not be penalized by the School for reporting abuse in good faith.   

If you have received information reflecting that any person who may visit the school’s campus (student, employee, parent, spouse of an employee, family member, volunteer, or contractor) has been accused, arrested, or convicted of any type of potential abuse or sexual misconduct toward any other person, you must immediately report such information to the Head of School. 

In addition, employees are reminded of their obligations to report employee misconduct that affects the health, safety, or welfare of children, in accordance with our Interaction, Conduct, and Ethics Standards Required of All Employees, found in this handbook. Failure to do so will result in disciplinary action and could result in the suspension of an educator’s teaching certificate.