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The Plan prioritizes the importance of research throughout objectives. It is important to note that research on trafficking will look different based on the types of trafficking, especially when attempting to quantify the problem. It is also important to recognize how many victims are misidentified as criminals, such as in trafficking cases where victims are charged with prostitution, or how many victims are not identified ...more »
The Core Values of the Initial Framework the Plan reads, “Services should be accessible for all trafficking victims, regardless of race, color, national origin, disability, religion, age, gender, sexual orientation, gender identity, immigration status, or type of trafficking (sex or labor).” This fails to address system involvement, which is especially relevant to domestic minor sex trafficking victims or victims that ...more »
The Plan calls for uniform definitions by FY2014; however, many of these policies will be created in FY2013, To reinforce the assertion of collaborative and consistent research it would be important to have these definitions consistent in the timeline. For instance, the Plan does not address what qualifies a trafficking victim or what the process is for a trafficking victim to obtain services from federal agencies such ...more »
Victims of trafficking should not be criminalized on related charges such as prostitution. The inconsistencies between federal and state laws that often re-victimize a survivor should be addressed.
The use of the word “child” in this report in relation to types of trafficking should be carefully considered, as it may reinforce misconceptions that domestic minor sex trafficking victims are prepubescent, especially to buyers who view purchasing sex from adolescents and exploited adults as a victimless crime. We would suggest using words such a “youth,” “juvenile sex trafficking,” “minor sex trafficking,” “minors,” ...more »
The Plan outlines the need to identify promising practices. Although this is important, the Plan should reinforce the important reality that a uniform method of treatment is not applicable to every identified survivor, and the treatment environment required will change to the extent the survivor embraces the healing process. Providers must assess the individualized needs of survivors and place them into the most suitable ...more »
Objective 8 should be expanded to included evaluation of current state child welfare agencies’ licensing policies and practices for shelter services and how they may provide barriers to services for domestic minor sex trafficking victims. As demonstrated in the National Colloquium Report: Shelter and Services Evaluation for Action [http://sharedhope.org/wp-content/uploads/2013/05/National-Colloquium-2012-Report-B.pdf] ...more »
Training in trauma-informed practices mentioned in the report should be expanded to include law enforcement investigating cases against traffickers to prevent re-traumatization of the victim during the interview process.
The Plan does not clearly outline how it will prioritize and leverage products and programs that have already been created by NGOs or state level agencies to avoid duplication of efforts. NGOs that have already created education, identification and outreach tools can provide a wealth of resources and knowledge to support the implementation of all parts of the Plan such as Objective 4 or in the development of training ...more »
It is unclear under Objective 7 whether general training and evidence-based training initiatives by OJJDP will reach youth in detention either to identify them or to provide services. It would be helpful for the plan to clarify whether there is a priority to identify and serve victims that may be involved in the juvenile justice system, including those in detention, and the Plan should make it a priority to address this ...more »
Objective 5 of the Plan does not clearly engage service providers, NGOs and survivors. Because of their first- hand experience, these entities can play a critical role in identifying resources gaps, specifically for data collection in collaboration with HSTC.
In Objective 6, especially with regard to identification, the juvenile justice system is not addressed. Juvenile sex trafficking victims are often misidentified as criminals through status offence charges like prostitution or are involved in the juvenile justice system on unrelated charges. Pilot programs intended to screen for sex trafficking indicators like Shared Hope International’s Intervene tool reinforce that many ...more »