The first abuse and neglect policy guidelines for adults with developmental disabilities were developed in for Dane County Department of Human Services, Adult Community Services Division, Developmental Disabilities Section (DCACS). They were researched and written by a group of individuals who work with people with developmental disabilities. Over the past eleven years, much has been learned in Dane County about responding to abuse, neglect, and unlawful activity towards people with developmental disabilities. Consumers of DCACS services have shared better ways to receive support, caregivers have contributed insight, and agencies have collaborated with DCACS to explore when and why abuse happens. People working in the developmental disabilities service system in Dane County have joined with people in the criminal justice, sexual assault, and domestic violence systems at the county and state levels to fashion better responses to abuse of vulnerable people.
With these new understandings and alliances, the work group reconvened in to formulate updated policy guidelines to respond to abuse. The guidelines were again revised in . These guidelines represent many hours of discussion amongst the group members, interviews with professionals in the criminal justice and developmental disabilities systems, and research of laws and articles. The policies are modeled after best practices represented in the elder abuse, sexual assault, and domestic violence service systems. The Department of Health and Family Services’ Wisconsin Caregiver Program provides a framework for screening agency staff.
The purpose of these policy guidelines is to give residential, vocational, and support broker agencies under contract with DCACS consistent direction for reporting abuse and for responding to the needs of abused consumers.
Policies don’t keep people safe. Nor do these policy guidelines outline comprehensive prevention strategies. Agencies must provide employees with sufficient training regarding prevention of abuse and response to allegations of abuse towards the people they support. DCACS, in collaboration with consumers, agency staff, and other caregivers, will continue assessing and refining ways to prevent and respond to abuse.
- Abuse and Neglect Workgroup
- Ellen Baur
- Formerly of Work Alternatives for Rural Communities
- Monica Bear
- Case Manager Supervisor, Adult Community Services
- Maya Fairchild
- Abuse and Neglect Contact, Adult Community Services
- Roy Froemming
- Attorney in private practice, formerly of Wisconsin Coalition for Advocacy
- Olwen Blake
- Executive Director, REM
- Christine White
- Legal Advocate for People with Developmental Disabilities
Thank you to the many people who reviewed the Policy Guidelines. Special thanks to:
- Dyann Hafner
- Dane County Corporation Counsel
Olwen Blake, Maya Fairchild, Dyann Hafner, Kim Turner, Dan Rossiter, and Christine White reviewed the Revised Guidelines.
Original and revised Guidelines written by Christine White
Abuse Resource Handbook compiled by Christine White
Using These Guidelines
The guidelines and accompanying Abuse Resource Handbook should be viewed in their entirety. Reading both the Guidelines and Handbook will give residential, vocational, and support broker agencies that are developing internal abuse and neglect policies an idea of how to proceed, as well as the laws and best practice behind required policy. Agencies have flexibility to create and implement policies that best meet their agency and consumer needs, and which incorporate required components of the guidelines. The parts delineated in bold are requirements of DCACS, and, by contract must appear in residential, vocational, and support broker agencies’ policies. The remainder is considered best practice by DCACS, and is therefore not mandated, but “strongly encouraged”. (Handbook 1-Schedule A)
Definition of Agencies/Agency Staff
“Agencies,” as used in these guidelines, refers to any agency or entity under contract with Dane County Human Services, Adult Community Services Division, Developmental Disabilities Section. “Agency staff” refers to employees of Residential, Vocational, and/or Support Broker Agencies that contract with DCACS. Directors of agencies or their specific designees are responsible for carrying out the directives of these policy guidelines.
Definition of Abuse
“Abuse,” as used in these guidelines, refers to any sexual abuse; physical abuse, abandonment; neglect; financial exploitation; domestic abuse; confinement, restraint, and/or isolation without legal authority; forcible administration or misuse of medication; stalking; emotional abuse, disrespectful, or demeaning statements or behavior towards consumers; harassment; intimidation; or illegal activity that victimizes a consumer.
Mandatory (Required) Reporting
Agencies shall report to the DCACS Abuse and Neglect Contact all suspected or known abuse towards any adult with developmental disabilities for whom the agency provides services using DCACS funding. A verbal report shall be made within 24 hours or on the next business day after the abuse is noticed. A written report shall be submitted to the Abuse and Neglect Contact at DCACS within 2 weeks, and shall include any reports obtained from law enforcement. Agencies must use the County Critical Incident Report to document each allegation of abuse.
Employees of each agency shall develop internal systems for reporting and documenting abuse. Every employee of the agency is required to report incidents of abuse or neglect. The employee shall be able to report suspected or known abuse/neglect without fear of reprisal, even when the suspected abuser is a fellow employee. Minimally this will include immediately notifying the agency Fact-Finder (see below) of suspected abuse and designating who will call the DCACS Abuse and Neglect Contact.
Agencies are strongly encouraged to provide appropriate legal and disciplinary consequences to employees who abuse consumers.
Compliance with DCACS contract requirements does not necessarily mean agencies have complied with all other laws and mandated reporting requirements to other Wisconsin entities, such as to the Department of Health and Family Services.
Agencies shall assign at least two employees or persons under contract with the agency who will be responsible for internal fact-finding when abuse is suspected towards any consumer who receives DCACS funding and who is supported by that agency. At least one Fact-Finder shall be available to the agency at any given time. The Fact-Finders must have clear authority to ask questions and receive answers from other employees, to interview people privately, to view records, to take charge of evidence before law enforcement arrives, to take action necessary for the safety of the consumer, and to take action necessary for an effective fact-finding response. Ideally, a Fact-Finder will be a long-term employee who possesses an understanding of how abuse occurs and is prevented.
In many cases, no fact-finding will be necessary as it will be apparent abuse has occurred or the consumer has reported abuse or law enforcement has been contacted.
Agency Fact-Finders or their designees shall report suspected abuse to the Abuse and Neglect Contact within 24 hours, even if fact-finding is not completed.
Fact-finding should be done by the agency where the abuse occurred, the agency which is most directly involved or, if the abuse occurred in a setting other than a residential or vocational agency, by the agency which first recognizes the abuse. Residential, Vocational, and Support Broker Agencies will need to communicate and share information with one another to decide who will do the fact-finding and to accomplish effective fact-finding.
The DCACS Abuse and Neglect Contact may choose to conduct the fact-finding or an agency director may request that the Abuse and Neglect Contact conduct the fact-finding when:
- There is a conflict of interest.
- The alleged abuser is a guardian, parent, or other family member.
The DCACS Abuse and Neglect Contact and/or Legal Advocate for People with Developmental Disabilities are available to consult on fact-finding issues.
Agencies shall cooperate with and provide information to the DCACS Abuse and Neglect Contact as requested.
All Fact-Finders shall attend meetings and training provided by DCACS on best practices for agency internal fact-finding. This training will include information on interviewing, documentation, understanding behavior, sexual abuse and assault, domestic violence, bruises and other physical injuries, evidence, report writing, reporting requirements, and the role of law enforcement. Fact-Finders are not criminal investigators, but are expected to know how to gather enough information to make immediate safety decisions on behalf of the consumer and when to involve state licensing personnel and law enforcement. (Agencies may borrow videotapes of the training and handouts from Maya Fairchild or Christine White.)
Personnel Considerations for Agencies
Employment Application Process
Agency directors are strongly encouraged to familiarize themselves with Wisconsin employment law and attend training on this topic.
- References must be thoroughly checked on all applicants considered for hire.
- Any applicant considered for employment must complete a Background Information Disclosure (BID) form and the agency or other employer must keep these BID forms on file. Probationary employment may begin after a satisfactory BID is received, but it is strongly recommended that consumers not be left alone with a new employee until the background check is completed.
- The Employee Directory is a listing of all persons who quit or are terminated from employment with residential, vocational, and broker agencies under contract with DCACS. A mere listing in the Directory does not signify that an applicant has either a positive or negative work record; rather it is a source for determining the applicant’s work history and references.
Agencies shall register all employees who have quit or been terminated by e-mailing or calling the Employee Directory (firstname.lastname@example.org, or (608) 242-6470) and shall provide the following information:
- Date of birth
- Employer name
- Dates of employment
Agencies considering an applicant for hire shall contact the Employee Directory to see if the applicant is listed. If the applicant is in the Directory, the hiring agency shall call all previous agencies under contract with DCACS with which the applicant has worked. Agencies shall respond within 48 hours to inquiring agencies currently under contract with DCACS, providing any and all pertinent information (allowable under labor law) that will assist in a hiring decision. A sample form “Re-Employment Questionnaire” is included in the Handbook.
Background Check Requirements
Criminal background checks must be completed on any person who:
- Is considered for employment using DCACS funding, including those hired through Self-Directed Services;
- Is over 18 and is living with employees of the agency who live in the same residence as the consumer.
Resources for Completing Background Checks
- Check www.doj.state.wi.us/dles/cib/crimback.asp for more information on background checks.
- Agencies must submit a Wisconsin Criminal History Record Request to the Department of Justice (DOJ) on all prospective employees. The box entitled “Caregiver - General” must be checked to obtain full information for a caregiver background check. Agencies are strongly encouraged to have background checks done every four years on all current employees.
- When the DOJ check is completed, the agency will receive a letter from DOJ, which shall be kept on file.
- An applicant’s misstatements on his or her application would normally be sufficient reason for the applicant not to be hired.
- Agencies are strongly encouraged to use the Wisconsin Circuit Court Automation Program (CCAP) website as an adjunct to background checks: wcca.wicourts.gov/index.xsl. (Check “Case Search” and type in the first and last name.) This web site will access Criminal Summary Reports for most Wisconsin counties. Note whether the applicant was actually convicted of the charges. This check alone does not satisfy the background checks requirement nor does it contain details about the circumstances of a case. A search on CCAP that fails to find a record does not mean that the applicant does not have a record.
- Agencies are strongly encouraged to check the Wisconsin Caregiver Misconduct Registry website at www.dhfs.state.wi.us/caregiver/misconduct.HTM.
- Agencies are strongly encouraged to submit a Driver’s Record Information Request on applicants being considered for positions that require transporting a consumer: www.dot.wisconsin.gov/drivers/forms/mv2896.pdf.
- Agencies are strongly encouraged to call the Wisconsin Sex Offender Registry Information access line at 1-800-398-2403. Agencies must have the applicant’s full name, exact birth date and either the social security number or driver’s license number. This is a 24-hour automated system, which will give information on certain offenders since . The Sex Offender website can also be used knowing only the first and last name of a person. offender.doc.state.wi.us/public
- Agencies are strongly encouraged to check an applicant’s military records, if applicable. All persons no longer active in the Armed Forces receive DD214s upon discharge. The DD214 provides information concerning the person’s military discharge status. Anything other than “honorable” may indicate a concern needing further exploration. The Wisconsin Department of Veteran’s Affairs, which can be reached at (608) 266-1311, may help veterans obtain new copies of their DD214 and help employers understand the DD214.
- Agencies shall make a good faith effort to obtain out-of-state conviction records for employees who resided out of state at any time during the three years preceding the date of the search. Information on this can be obtained at www.doj.state.wi.us/dles/cib/sclist.asp.
- Agencies shall not employ any person as a caregiver or who is expected to have regular, direct contact with a consumer, whose criminal behavior or past work performance is substantially related to the care of the consumer and indicates the person would be a danger to or would negatively affect the consumer’s well-being.
- Agencies shall include in their personnel policies a provision which would require all employed staff, contracted persons, or persons residing with employees who live at the same residence with consumers to notify the agency director or designee within one week when that person has been charged with or has been convicted of any crime.
- Agencies shall not permit any child under the age of 18 to be in a caregiver role of a developmentally disabled person, including children living in the home of the caregiver. Exceptions may be supervised volunteer or student intern programs.
- Supervisors in residential agencies are strongly encouraged to frequently visit the homes they support and to maintain an open dialog with caregivers about the caregivers’ concerns and supervisor’s observations.
- When a live-in direct support staff is discharged due to suspected abuse, residential agencies are strongly encouraged to have a supervisor accompany the discharged employee back into the home to remove his or her belongings and that the removal of belongings is done immediately. Locks may need to be changed.
- Agencies are strongly encouraged to have procedures to ensure that discharged employees do not remove any property, but their own belongings, from the premise.
Agencies shall offer the following training as soon as feasible after hiring employees who will have any direct contact with consumers:
- Orientation to the agency’s own abuse and neglect policies and protocol for reporting abuse within the agency.
- Recognizing abuse and neglect, including signs of physical and sexual abuse.
- Reporting abuse to Fact-Finders and law enforcement, and mandatory (required) reporting to DCACS.
- Consequences for not following agency policies and procedures.
- Awareness of laws related to people with developmental disabilities and abuse.
- Recognizing subtle forms of abuse, disrespect, and power and control by agency staff.
Recommended abuse prevention training for all agencies:
- Managing Threatening Confrontations
- Power and Control: Learning to Use it Respectfully
The role of the guardian is to protect the ward’s interests and the guardian is accountable to the court for his or her actions in fulfilling this role. Agencies are also responsible for protecting the consumer, whether or not the consumer is under guardianship. Agencies may take necessary actions, distinct from the authority of the guardian, to protect the consumer from harm. Consumers under guardianship may also take necessary actions, to the extent they are capable, to protect themselves, just as could any citizen.
Exceptions of reporting abuse to a guardian are if the guardian is suspected of the abuse, is protecting or is in collusion with the abuser, or is acting in conflict with his or her role of protecting the consumer. Otherwise, when a consumer under guardianship has been the victim of abuse or criminal activity, agencies must involve the guardian as follows:
- Notify the guardian as soon as feasible after potential abuse is discovered.
- Provide the guardian with complete information to enable the guardian to make informed decisions on behalf of the consumer.
- Advise the guardian as soon as feasible whenever law enforcement has been notified.
- Encourage the guardian to be involved in planning for the consumer’s safety and well-being.
- Permit the guardian to take necessary additional steps necessary to protect the consumer.
If the guardian is suspected of the abuse, has an apparent conflict of interest related to the abuse, is failing to take necessary steps to protect the consumer, cannot be reached or is unresponsive in regards to the abuse, agencies shall document this and verbally report it to the DCACS Abuse and Neglect Contact and Adult Protective Services (242-6479) if the consumer is under Protective Placement, or the Probate Court (266-4331) as soon as feasible.
Notifying Law Enforcement
Agency staff shall contact law enforcement immediately if a crime has been committed and the consumer is in immediate need of protection.
Agency staff has the authority to contact law enforcement when such enforcement is reasonably necessary to provide protection or prevent re-victimization of a consumer.
If a crime has been committed against a consumer, but he or she is safe from harm, agency staff should make reasonable efforts, considering the consumer’s abilities, to determine if he or she wishes to contact law enforcement. The guardian of a consumer should be included in this decision.
Agency staff is strongly encouraged to assist and support consumers in their efforts to contact law enforcement for self-protection or for other protective legal measures.
The agency Fact-Finder shall be called immediately whenever law enforcement is contacted for a consumer who is a victim of crime.
Agencies shall notify the consumer’s guardian as soon as feasible whenever law enforcement is contacted.
Agencies are strongly encouraged to call and page the Legal Advocate for People with Developmental Disabilities when law enforcement is contacted for consumers who are victims of crime.
When contacting law enforcement, agency staff is strongly encouraged to be professional and mindful of confidentiality issues. Sharing information directly related to the crime, the safety of the consumer, and how the victim communicates is generally important to share with law enforcement. Because most information about a consumer is confidential, the agency director should be consulted before agency staff share information about the consumer’s diagnosis, IQ, behavioral concerns, veracity, or other like information about the consumer.
After a report has been made to law enforcement, it is neither the consumer’s nor the agency’s decision to bring criminal charges. A victim of crime may share his/her wishes regarding charges with the District Attorney’s (DA) office. Charging a crime is at the sole discretion of the DA.
Agencies shall not retaliate against employees who make good faith reports of suspected abuse to law enforcement, DCACS, Wisconsin Coalition for Advocacy, or the Department of Health and Family Services, which includes the Bureau of Aging and Long-Term Care Resources and the Bureau of Quality Assurance.
If a decision is made not to contact law enforcement regarding a sexual assault, the agency is strongly encouraged to preserve relevant available information regarding the suspected abuse and document the decision not to contact law enforcement.
There shall be no sexual contact under any circumstances between an agency employee and any consumer while the employee is in a position funded by DCACS.
Wisconsin Statute 940.225 defines sexual assault. The definition of 2nd degree sexual assault may pertain to some people with developmental disabilities.
Immediately after a sexual assault:
- Agency staff shall check the consumer for injuries and attend to his or her physical and psychological safety. The environment shall be made safe. In circumstances where this is not feasible, agency staff shall move the consumer to a safe environment. Agency staff is strongly encouraged to contact the Legal Advocate for People with Developmental Disabilities or a Rape Crisis Center legal advocate as soon as feasible. A legal advocate can accompany the consumer to a physical exam and be there for law enforcement questioning.
- Agencies must make a sexual assault examination available to consumers after a sexual assault where there is penetration of some sort or evidence on the body of the consumer. The sexual assault examination shall be documented. Agency staff is strongly encouraged to take the consumer for a sexual assault exam by a Sexual Assault Nurse Examiner (SANE) at Meriter Hospital Emergency Room as soon as feasible within 96 hours. These nurses are specially trained to examine females and males for signs of sexual assault and can take forensic evidence at the same time. Consumers with Medical Assistance and those who are uninsured may use the SANE services. SANE exams are not recommended when sexual touching happened over clothes or it is clear that there was no penetration, injury or physical evidence. In addition to a SANE exam or if the assault happened more than 96 hours prior, agency staff is strongly encouraged to take the consumer to his or her doctor to be examined for injuries, pregnancy, Sexually Transmitted Diseases, or other concerns.
- A spare set of clothing and shoes should be taken to the exam, as the clothing may be taken by law enforcement for evidence. A consumer who has been sexually assaulted and wishes to have forensic evidence taken at the time of the exam should be advised to avoid urinating, douching, taking a shower or cleaning her/himself in any way, brushing teeth, drinking fluids or rinsing the mouth, or changing clothes before the exam. Physical evidence, such as bed sheets, clothing, towels, washcloths, rugs or anything at the scene of the sexual assault should not be touched before law enforcement arrives.
Agencies shall have policies prohibiting agency staff behavior which is injurious to consumers including, but not limited to, punching; hitting; slapping; pinching; arm-twisting; inflicting bruises, welts, punctures, swelling, scratches, and fractures; burning, use of unauthorized restraints; pushing; kicking; dragging; spitting; or otherwise causing bodily harm to consumers. Agencies shall provide training to agency staff regarding these policies.
Immediately after physical abuse is noticed, agency staff shall check the consumer for injuries and attend to his or her physical and psychological safety. The environment shall be made safe. In cases where this is not feasible, agency staff shall move the consumer to a safe environment. Agencies must make medical attention available to the consumer immediately after physical abuse is known or suspected. The medical examination shall be documented.
Agencies shall document all bruises and injuries, regardless of their origin, as soon as such bruising or injuries are observed.
Agencies shall have policies prohibiting abandonment, which occurs when a consumer is intentionally left by agency staff without supervision under any circumstance that a consumer requires supervision for his or her safety. Agencies shall provide training to agency staff regarding these policies.
Each consumer shall have a plan for self-supervision ranging from zero to twenty-four hours. The plan shall be reviewed at least annually. Agencies shall develop policies that address emergency back up plans for staff and regular check-in plans for consumers who are unable to obtain help when direct service workers have not arrived.
Agencies shall have clear policies regarding the handling of consumers’ funds. Policies shall include prohibition against taking a consumer’s money or items belonging to the consumer for any unauthorized reason. This includes, but is not limited to, stealing money or personal items; borrowing money or personal items; rearranging money in an account; transferring money to a caregiver’s account; using the consumer’s resources, such as telephone, computer and television, in such a way that incurs extra expense for the consumer; buying groceries or other items for the caregiver using the consumer’s money. Agencies shall provide training to agency staff regarding these policies.
Agencies shall have clear policies regarding the handling of consumers’ medications. Policies shall include prohibitions against any intentional mismanagement of a consumer’s medication by agency staff. This includes, but is not limited to, stealing medication for personal use; chemical restraint for staff convenience; misrepresenting consumer needs for medication in order to obtain prescriptions for personal use; and giving medication to the individual supported without necessary or medical justification. Agencies shall provide training to agency staff regarding these policies.
Agencies shall have policies prohibiting behavior by agency staff which, because of the failure to provide adequate food, shelter, clothing, medical care or dental care, creates a significant danger to the physical or mental health of a consumer. Agencies shall provide training to agency staff regarding these policies.
In Wisconsin Statute section 968.075(a), domestic abuse applies to spouses or former spouses, an adult with whom the person resides or formerly resided, or an adult with whom the person has a child in common. A live-in direct support staff person who physically or sexually abuses a consumer in his or her care may be charged under domestic abuse statutes, in addition to other statutes which may apply.
Law enforcement officers are mandated to arrest the primary physical aggressor in a domestic abuse incident if they determine that a person is committing or has committed domestic abuse, and that the person’s actions constitute the commission of a crime. The victim may not have input regarding whether or not to bring charges against an abuser.
There are various types of restraining orders and injunctions available through civil court. For purposes of a domestic restraining order, domestic abuse must be committed
by an adult family member or adult household member against another adult family member or adult household member, by an adult caregiver against an adult who is under the caregiver’s care, by an adult against his or her adult former spouse, by an adult against an adult with whom the individual has or had a dating relationship, or by an adult against an adult with whom the person has a child in common. A consumer or his or her guardian may choose to obtain a restraining order as a way to safeguard the consumer in a domestic abuse situation. The Legal Advocate for People with Developmental Disabilities or a legal advocate from Domestic Abuse Intervention Services can assist with restraining orders and/or other domestic abuse issues.
Some agency staff relationships with consumers contain subtle forms of power and control similar to those found in domestic abuse relationships. Agencies are strongly encouraged to develop policy with consequences to address disrespect, emotional abuse, and harassment of consumers.
Agencies are strongly encouraged to develop plans for consumers regarding foreseeable emergencies. Residential agency staff is strongly encouraged to keep all medications and essential medical and emergency information in an easily accessible place for Emergency Medical Technicians (EMTs) to see. Consumers who do not live with direct service workers should be encouraged to keep emergency and medical information, or the location of such information, where it can be easily spotted by an EMT, such as on the outside of the refrigerator.
Agency staff have the authority to contact emergency medical services if a consumer is in immediate need of medical attention.
Agency staff shall notify the agency Fact-Finder as soon as feasible regarding any medical emergency that is related to abuse or illegal activity.
Law enforcement may conduct a death investigation when a citizen dies in a setting other than a hospital or licensed nursing or hospice facility. Exceptions may be when a consumer dies under the care of a hospice program or death was expected. The coroner may be called to the scene and agency staff may be questioned about events leading up to the death.
Agency staff shall notify the agency Fact-Finder and the coroner or law enforcement as soon as feasible upon the unexpected death of a consumer in a setting other than a hospital or licensed nursing facility.
Agencies shall call the Abuse and Neglect Contact at DCACS within 24 hours or on the next business day of any death. This includes unexpected deaths in a hospital or licensed nursing facility. A County Critical Incident Report must be filled out and submitted to the Abuse and Neglect Contact within 2 weeks.
Agencies are strongly encouraged to provide opportunities for grief counseling for consumers when the death of someone close to them has occurred.
Safety Planning and Follow-Up
Agencies are strongly encouraged to work with consumers to develop safety plans, which should be reviewed every six months and following an allegation of abuse.
Planning for safety may include:
- Teaching consumers how to use a house key.
- Teaching consumers protective behaviors.
- Encouraging consumers to report abuse.
- Evaluating the isolation of a living situation.
- Encouraging consumers to carry current identification or to develop “safety cards” containing:
- Consumer’s name, address, and phone number.
- Agency contact person, phone and pager numbers.
- Guardian name and phone number.
- Teaching consumers to show safety cards or identification to law enforcement or medical personnel when assistance is needed.
Victims of abuse need immediate support and may need this support for many months. Agencies are strongly encouraged to obtain support for victims of abuse through resources such as the Rape Crisis Center, Domestic Abuse Intervention Services, psychotherapy, the Legal Advocate for People with Developmental Disabilities, and/or ongoing counseling through the agency.
Agencies are strongly encouraged to develop sexuality policies, which at minimum should include providing sexuality education to consumers, helping consumers understand consent in sexual relationships, and teaching consumers correct language or alternative forms of communication for sexual concepts.
Residential agencies are strongly encouraged to assess staff and house-mate compatibility with consumers to ensure the home environment meets the consumers’ safety requirements.
When agencies identify gaps in the safety of consumers they support, they are strongly encouraged to bring the issue to the Dane County Quality Assurance Board for multidisciplinary team solutions.
Agencies are strongly encouraged to review all Support Plans of consumers every six months.
Agencies are strongly encouraged to review their agency abuse and neglect policies and procedures yearly, and following an allegation of abuse, to improve safety for consumers.