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August 4, 2017

Dear Office of Special Counsel,

I’d like to thank you for the assistance you have provided me through this difficult process.
Victims and survivors of sexual assault and I so deeply appreciate the attention you have given to
my complaints to this office.

I have carefully reviewed the Peace Corps’ report on the findings of the internal investigation,
which the Director of the Peace Corps tasked the Office of the Inspector General (OIG) to
conduct in response to the disclosures I made to the Office of Special Counsel (OSC) in July
2015. Before I provide feedback to specific sections of the report, I’d like to provide a few
general overarching comments related to the evidence provided, the findings and conclusions
made, and sexual assault in general that are important to consider when making the
determination as to whether or not the Peace Corps has endangered the health and safety of its
Volunteers, is in violation of the Kate Puzey Peace Corps Volunteer Protection Act of 2011
(Kate Puzey Act), and/or other laws and regulations.

First, the OIG did not actually conduct an investigation into the disclosures. Instead, the OIG
simply reviewed its old reports and evaluations and summarized them as its response to the
specific disclosures I made. While the reports and evaluations provide some useful information
and insight, they do not really respond to the disclosures. Additionally, the evidence provided in
the report highlights concerning gaps in the Peace Corps’ current policies and practices regarding
the safety and wellbeing of Volunteers. I will address both of these points in my response to the
report covering the four disclosures.

Second, the Peace Corps has made progress in developing policies and procedures for
responding to Volunteer safety and sexual assault. Yet, in my experience from working for the
Peace Corps as the Agency’s first-ever victim advocate and Director for the Office of Victim
Advocacy (OVA), I witnessed time and time again the Agency being more concerned about
“maintaining its mission” at all costs, even at the expense of its greatest asset, the Volunteers.
The Peace Corps has a historical pattern of failing to make necessary course corrections until a
Volunteer’s life has been placed at extreme risk, sometimes resulting in the untimely death of a
Volunteer, or until there has been negative media coverage focusing on the shortcomings of the
Peace Corps. The passage of the Kate Puzey Act was meant to repudiate the Peace Corps’
history, specifically as it related to crimes against Volunteers, including sexual assault.

Sexual assault disrupts a person’s life. Over the past two decades the sexual assault field has
learned that a trauma-informed response from the systems designed to support survivors can
significantly decrease the negative impact of the trauma over one’s lifetime. At the same time, a
poor response, such as a victim-blaming attitude or a lack of adequate support services, can have
a cascading effect of negative and damaging consequences that ultimately could significantly
alter the life trajectory of a survivor, which leads me to my third point.

1
While the OIG’s report states in certain areas that they did not find the Agency to be in violation
of any laws or policies, they are incorrect where the Kate Puzey Act requires the Peace Corps to
develop sexual assault policy and training that “to the extent practicable, conforms to best
practices in the sexual assault field.” The suggestions I made were aimed at instituting changes
that were well within Peace Corp’s capabilities. Further, the Peace Corps holds an overall
responsibility to the safety and wellbeing of the Volunteers.

To meet this requirement, the Peace Corps must continue to make course corrections as well as
stay apprised of developing best practices in the field of sexual assault to ensure it is providing
an environment in which exposure to the risk of sexual assault is minimized as much as possible
and Volunteers have timely access to the support services necessary to help facilitate a healthy
path to recovery. They cannot rely on outdated or ineffective policies as a justification for
compliance.

Lastly, it is critical to remain mindful of the fact that sexual assault is the most underreported of
all crimes, not only in the United States, but also across the world. According to the Rape, Abuse
and Incest National Network, two out of every three sexual assaults are unreported1 and both the
Centers for Disease Control and Prevention and the World Health Organization consider sexual
assault to be a global health problem. The evidence and conclusions provided by the OIG in the
report represent only the sexual assaults reported to the Peace Corps and do not take into
account the high number of unreported sexual assaults documented in the Peace Corps Serious
Incident Questionnaire (SIQ). In one of the documents referenced by the OIG in this report,
FINAL REPORT: The Peace Corps’ Sexual Assault Risk Reduction and Response Program, IG-
17-01-E, November 2016, the OIG states that according to the SIQ 53% of rapes, 49% of
aggravated sexual assaults, and 85% of non-aggravated sexual assaults are not reported to the
Agency with one of the significant reasons being that the Volunteer “anticipated adverse
consequences such as being required to change their site, sent home, or punished for
having violated a Peace Corps policy.” This is important in analyzing whether the Peace Corps
is sufficiently protecting the safety and wellbeing of Volunteers.

Below are my comments to the Peace Corps’ response to the OSC based on my disclosures.

Disclosure 1

The Peace Corps has placed volunteers, employees, and host country nationals at risk by
failing to take appropriate action against volunteers found to have engaged in sexual
misconduct.

Related to this disclosure, the Office of Special Counsel posed Question 1: Has the Peace
Corps taken appropriate action against each volunteer found to have engaged in sexual
misconduct? If so, describe the action taken.

1
https://www.rainn.org/statistics/criminal-justice-system
2
While the report avoided providing a direct response to this question, the information provided
discloses cases where the Agency failed to follow its own policy and identified significant gaps
in the Peace Corps’ current policies.

On page 14, the OIG provides a table that summarizes the Agency’s responses to 18 reported
incidents, which illustrates the Peace Corps’ inadequate (and inappropriate) responses to reports
of sexual misconduct by Volunteers.

 Of the 18 cases the OIG investigated, including 10 of the 11 that I included in my


interview with the OIG, the Peace Corps did not administratively separate a single
Volunteer, even those found to have violated the Sexual Misconduct Policy. Further, the
Agency took no action whatsoever in four of the cases, and completely failed to follow
Agency policy in two of the cases by granting Interrupted Service for the accused
Volunteers.

 In 5 of the 10 cases (8 of which occurred after the Sexual Assault Misconduct policy was
issued) the OIG included statements by the accused Volunteer in its investigative report
to the Agency that clearly demonstrated that the accused was in violation of the Sexual
Assault Misconduct Policy.2

2
IPS 1-12 Volunteer/Trainee Sexual Misconduct 2.0 Purpose (a): “This policy covers Sexual
Misconduct (as defined in paragraph 3.0 below) by Volunteer and Trainees. Sexual Misconduct
comprises a broad range of behavior that will not be tolerated in the Peace Corps. The Peace
Corps is committed to providing an environment free from Sexual Misconduct.” (Emphasis
added.)

“3.0 (a) ‘Effective Consent’ means words or actions that show a knowing and voluntary
agreement to engage in mutually agreed-upon activity. Effective Consent cannot be gained by
Force, by ignoring or acting in spite of the objections of another (unless those objections have
been knowingly and voluntarily withdrawn) or by taking advantage of the Incapacitation of
another if the accused knows, or a sober, reasonable person in position of the accused
should have known of such Incapacitation. Effective Consent is also absent when the activity in
question exceeds the scope of Effective Consent previously given or when Effective Consent
previously given for the activity in question has been withdrawn” (Emphasis added.)

“3.0 (c) ‘Incapacitation’ and ‘Incapacitated’ mean the physical or mental inability to make
informed, rational judgments. States of Incapacitation include, without limitation, sleep and
blackouts. If alcohol or drug use is involved, a person does not have to be intoxicated or
drunk to be considered Incapacitated. Rather, Incapacitation is determined by how the alcohol
or drug consumed impacts a person’s decision-making capacity, awareness of consequences and
ability to make informed judgments. Because Incapacitation may be difficult to discern,
Volunteers and Trainees are strongly encouraged, when in doubt, to assume that another
person is Incapacitated and therefore unable to give Effective Consent. Being intoxicated,
drunk or under the influence of drugs is not a defense to a complaint of Sexual Misconduct
under this policy.” (Emphases added.)
3
The statements are:

 CIRS 611-201393-174618 – “…he stated that he knew the victim was intoxicated,
and conceded that he may not have had her consent.”
 CIRS 411-2013125-184011 – “OIG interviewed the subject of the allegation who
acknowledged that he engaged in sexual contact with the victim without her
consent.”
 CIRS 525-2015211-163816 – “The accused Volunteer admitted the alleged
misconduct.”
 CIRS 538-201378-10610 – “The subject of the allegation admitted to knowing
that the victim was very intoxicated at the time of the sexual contact.”
 CIRS 637-2014214-171645 – “The male Volunteer said he knew the female
Volunteer had been drinking earlier and was intoxicated at the time of the
incident.”

In situations where the accused used intoxication as a defense (see 2 of the 10 cases summarized
by the OIG: CIRS 517-201437-08591 and CIRS 525-20141029-1563), it was commonplace for
the Country Directors and staff involved in the decision making process regarding violations of
the Sexual Misconduct Policy to sympathize with the accused based on their belief that they
should not be held accountable when both parties reported being intoxicated. Yet, many cases of
sexual assault occur while parties are intoxicated, and moreover, the Sexual Misconduct Policy
clearly states “being intoxicated, drunk or under the influence of drugs is not a defense to a
complaint of Sexual Misconduct under this policy.” Consent is still required, regardless of
intoxication.

Additionally, during my tenure as the Peace Corps’ victim advocate and Director of the OVA, I
advised leadership on numerous occasions of the gaps in the Agency’s policies and procedures
regarding sexual misconduct. For example, I advised leadership that:

 The Agency’s current policy regarding Volunteer resignations allows a Volunteer to


terminate service at any time, for example during an active administrative investigation
into sexual misconduct or a criminal investigation of a sexual assault. This is an
individual’s right; however, the Agency lacks any type of policy or process to document
such resignations when they occur, and the individual is able to reapply for service or
employment at a future date with no record of the alleged policy or criminal violation
documented in the Volunteer’s personnel file. The only exception is for instances of
suspected drug use and/or abuse.3 Thus, while a Volunteer accused of sexual assault
could return as a Peace Corps employee with ease, a Volunteer accused of possessing or
using marijuana would face significant hurdles in returning.

For the complete policy, see:


http://files.peacecorps.gov/documents/IPS-1-12-Interim-Policy.pdf and
http://files.peacecorps.gov/documents/IPS-1-12-Interim-Procedures.pdf
3
http://files.peacecorps.gov/documents/MS-204-Policy.pdf; Section 3.5
4
 The OIG’s conclusion also highlights the Agency’s lack of a formal process to place
documentation in a Volunteer’s record in cases of administrative separation or
resignation in lieu of administrative separation, which is a concern that I have regularly
brought to the Agency’s attention since 2012. The report claims the Agency adopted a
new practice in December 2015 to address this concern. Yet, the report omits that it took
the intense media scrutiny that erupted after I filed the whistleblower complaint with the
OSC and the Peace Corps hired a Returned Volunteer who had been accused of sexual
misconduct (CIRS 637-2014214-171645) for leadership to finally act to address this gap
in the policy. While I am very pleased to learn that the Agency has finally adopted a
practice to document these cases, the OIG did not cite to or provide a specific policy
number or Agency instruction. The OIG should also provide information as to whether
this policy or instruction has been disseminated to Posts for agency-wide
implementation.4 Given that the Peace Corps deals with well-known challenges to
institutional memory created by the 5-year rule, it is critically important that this
correction to policy be formally documented in the Peace Corps Manual. If it has been
incorporated already, I ask that the OIG provide me with the section number or copy.

 I have advised the Agency of the discrepancies in the Peace Corps standards for
responding to two serious policy violations: sexual misconduct and drug use/abuse.
Where Volunteers who have been found to be in violation of the Sexual Misconduct
Policy may be administratively separated depending on the “severity” of the sexual
misconduct, Volunteers who have been found to have violated the Agency’s policy on
drug use are “administratively separated immediately” (emphasis added). MS 204,
Volunteer Conduct, section 3.5 Drug Use, goes on to state that “Peace Corps enforces
this strict policy” because this type of behavior can “seriously jeopardize the entire Peace
Corps program, as well as the safety and health of Volunteers.” It also states that the
quality of a Volunteer’s service is not a factor in this decision, whereas in sexual
misconduct cases, a Volunteer’s past performance or likeability could influence the
outcome. The Drug Use policy also addresses unconfirmed allegations and rumors: if the
unconfirmed allegations and rumors negatively affect the credibility of the Volunteer
and/or the Peace Corps program, the Country Director may nevertheless terminate the
service of the Volunteer.

 I have advised Peace Corps that there are two terms of art in the Sexual Misconduct
Policy that need to be defined so the Agency is able to take action when an accused
Volunteer makes a statement demonstrating that Effective Consent was not provided by
the Volunteer victim. The two terms are exceptional circumstances and essential
elements of Sexual Misconduct. Clearly defining these terms in the Sexual Misconduct

4
As I have advised the Peace Corps on multiple occasions, one of its weaknesses is that it
doesn’t have a process in place to ensure that changes to policies are effectively disseminated to
Posts and staff. Thus, while Peace Corps Headquarters (located in Washington, D.C.) could
adopt various policies and instructions, the Posts, where the Volunteers serve, could have no idea
that any policy has changed.
5
Policy would not only make it less difficult for the Agency to determine if a Volunteer
violated the policy, but would also provide clearer and more uniform boundaries and
expectations for the behavior of Volunteers.

o Exceptional circumstances: The policy states that in determining whether there


are exceptional circumstances in incidents of sexual misconduct the Country
Director is allowed to consider the “seriousness” of the sexual misconduct (this is
not an option for Country Directors in incidents of Volunteers violating the
Agency’s policy on drug use). In my experience, Country Directors have
extremely broad discretion and they often simply compared the personality and
quality of service of the two Volunteers involved in the sexual misconduct
allegations. While the drug use policy does not leave it to the discretion of the
Country Director, in sexual assault cases, the Country Director is able to influence
the process if he or she “liked” a Volunteer, whether it be the Volunteer
victimized or accused. An example of this is in the case of CIRS 637-2014214-
171645. The Country Director made comments such as “This [accused] Volunteer
has a bright future. I’m worried what this [accusation] will do to his ability to get
into a Master’s Program.” Thus, even though in this case the Volunteer made an
admission which showed that he did not meet the Peace Corps’ definition of
Effective Consent, the Country and Regional Directors determined there was a
“lack of a clear outcome given conflicting statements and no corroboration.”

o Essential Elements of Sexual Misconduct:5 The crux of determining complaints of


sexual misconduct is often consent. Did the accused have the consent of the
complainant? In 7 of the 18 incidents summarized by the OIG the accused
Volunteer made a statement that clearly demonstrated that they did not receive
“Effective Consent” as defined in the Sexual Misconduct Policy. Yet, the Agency
took no action to remove the accused from service.

 The Peace Corps has failed to update IPS 1-12 Volunteer/Trainee Sexual Misconduct and
IPS 1-12 Procedures for Handling Complaints of Volunteer/Trainee Sexual Misconduct.
For example, the procedures direct Country Directors to follow a response protocol that
no longer exists, the Guidelines for Responding to Rape and Sexual Assault, and makes
reference to IPS 1-11, Immunity from Peace Corps Disciplinary Action for Victims of
Sexual Assault, which is no longer an interim policy statement.

5
If at any time the OIG notifies the Country Director that the accused Volunteer has admitted to
all of the essential elements of Sexual Misconduct (including…the absence of Effective
Consent), the Country Director may take appropriate disciplinary or other action in accordance
with the provisions set out in the Peace Corps Manual...without the need to refer the complaint to
the region's Hearing Panel.

IPS 1-12 Procedures for Handling Complaints of Volunteer/Trainee Sexual Misconduct. 4.2
Admission by Accused V/T
6
After the Peace Corps’ Sexual Misconduct Policy had been in place for about a year, I made the
following suggestions to the Peace Corps leadership as areas of improvement, specifically:

 The OIG was not the right office to be investigating allegations of sexual misconduct
when a Volunteer did not choose to make a criminal report to law enforcement, but
wished to seek administrative action pursuant to the Agency’s Sexual Misconduct Policy.
Having the OIG investigate in these circumstances created a conflict of interest between
the victim’s choice and the legal requirements of the OIG. I suggested that in cases where
the Volunteer did not wish to engage with law enforcement, the Peace Corps’ Office of
Civil Rights may be the better choice to conduct the investigation for an administrative
response to the allegation of sexual misconduct.

 One of the unintended consequences of having the OIG investigate all cases of sexual
misconduct allegations was that even when a Volunteer did not want to report to law
enforcement the OIG was still required to provide an investigative report of their findings
to the U.S. Department of Justice (DOJ). Due to this, the OIG would not issue a final
report of the investigation to the Peace Corps until the DOJ made a decision regarding
criminal charges, which in a majority of the cases was a declination of prosecution. In
addition, if a U.S. Attorney decided to pursue charges even without the victim originally
choosing to report to law enforcement, the victim would then be placed in a position to
participate in a process she or he never intended, which can be harmful to a survivor’s
recovery.

 The hearing panel process was not effective. It caused stress for the victims in that often
times the hearing panel process would move forward without involving OVA, which
precluded us from being able to provide advocacy support to the Volunteer. It also
required both Volunteers (the accused and the victim) to be on the hearing panel call,
which meant they would be in the Peace Corps office in their country of service at the
same time. This caused significant stress for the victim.

 By virtue of being the OIG, the investigators intimidated Volunteers, especially the
accused Volunteers. In these cases, the Peace Corps did not provide the same level of
support to the accused Volunteer as it did for the Volunteer victim. The Agency has a
responsibility to all of the Volunteers’ wellbeing. To ensure an equitable process, the
Agency should provide the accused Volunteers with someone who can assist and support
them (i.e.: explain the Sexual Misconduct Policy process, make referrals to counseling,
etc.).6

Unfortunately, the Peace Corps ignored or dismissed each of my concerns and/or


recommendations (with the possible exception of better documenting sexual assault violations).

6
The support person for the accused Volunteer should not be country staff nor anyone who is
involved in the Sexual Misconduct decision making process.
7
Disclosure 2

The Peace Corps has failed to provide appropriate training to protect the safety of Peace
Corps volunteers who are living with host families and working with host country
nationals.

Related to this disclosure, the Office of Special Counsel posed Question 2: “Has the Peace
Corps provided appropriate training to host families and host country coworkers to protect the
safety of Peace Corps volunteers who are living with host families and working with host
country nationals? If so, describe the training.”

The OIG did not fully investigate this disclosure. Instead, as with the first disclosure, the OIG
relied upon previous evaluations and audits and used those as the basis for its conclusion that
appropriate relationship boundaries are not an issue. In addition, by only relying on past
evaluation, audits, and investigations without specifically investigating OSC’s question and my
disclosure, the OIG has not fully or accurately responded to the specific concern posed. In fact,
the OIG concedes in the report that the previous evaluations were not designed to assess the
training of host families and counterparts on “appropriate relationship boundaries.” Yet, the OIG
concludes that “In reviewing OIG country program evaluations, the adequacy of the Agency’s
training for host families and counterparts on how to set an appropriate relationship boundary
with Volunteers has not been identified as an issue that required management’s attention or
required corrective action.” This conclusion contradicts the evidence provided in the report as
well as findings and recommendations from previous OIG reports dating back to 2011.

First, the number of reported sexual assaults involving a host family member or counterpart as
the assailant demonstrates these individuals sexually assault Volunteers. The chart on page 25 of
the Agency’s report shows that between January 2011 and December 2014 a total of 781 sexual
assaults were reported to the Peace Corps. Of those 781 sexual assaults, a host family member
was the alleged assailant in 10% of the incidents with a counterpart being the alleged perpetrator
in 6% of the incidents, for a total of 16% of all reported sexual assaults. To break it down further,
this represents approximately 125 reported sexual assaults perpetrated by a host family member
or counterpart over the four-year period. Or, to look at it in a different way, on average Peace
Corps Volunteers reported three sexual assaults perpetrated by a host family member or
counterpart every month during the four-year period. These victims are individuals who
trusted the Peace Corps to provide them with a safe living and working environment and whose
lives will forever be changed due to the Agency not considering this to be a high enough number
to be of concern to take proactive measures to reduce this risk to Volunteers. Additionally, the
16% does not include the high number of unreported sexual assaults, which if those were
captured by the SIQ would in all likelihood increase the number of known incidents perpetrated
by host families or counterparts.7

7
To my knowledge the SIQ does not capture data on offenders, meaning that it does not ask
Volunteers to identify if the offender was a Volunteer, host family member, counterpart,
unknown, etc.
8
Even though the OIG states that they asked the Volunteers open-ended questions to generate
their evaluations, Volunteers may not provide a response that touches on appropriate relationship
boundaries between host families, counterparts, and Volunteers unless specifically asked this
question. It was my experience that far too often Volunteers were told directly or indirectly by
Peace Corps staff that sexually inappropriate behavior is par for the course of serving as a
Volunteer and is something they simply must deal with. This causes Volunteers to remain silent
about the inappropriate sexual behavior for fear they will be viewed as “trouble” Volunteers or
“weak” Volunteers. Often times Volunteers are told by Peace Corps’ staff that if they were
integrating successfully into their communities they would not be experiencing such challenges.
This messaging is highly inappropriate and artificially lowers the number of reported sexual
assaults.

In addition, only currently serving Volunteers who are in country during the time of the OIG
evaluations were interviewed, thus not capturing the experience of many Volunteers. As a result,
the OIG reached an inaccurate conclusion based on skewed data. Most Volunteers who have
experienced inappropriate relationship boundaries, such as sexual assault, by a host family
member or counterpart and who reported it to the Peace Corps were forced to terminate their
service early due to the Agency’s reluctance to identify another site for them to continue their
service. Therefore, the voices of these Volunteers are not heard by the OIG and are in a sense
silenced, which lends itself to providing an illusion that inappropriate relationship boundaries
between host families, counterparts, and Volunteers is not an issue.

What is most difficult to understand regarding the Agency’s stance on this matter is that host
families and counterparts directly benefit financially and/or through other resources provided by
the Peace Corps. I am aware of instances (although due to my time away from the Agency I
cannot provide dates or countries) where the Peace Corps minimized the safety threat in order to
maintain the relationship with the host family and/or counterpart:

 In one incident a host family member sexually assaulted a female Volunteer and the
Peace Corps replaced the female Volunteer with a male Volunteer. The explanation
provided to me was that the male Volunteer would be safe since the assault was on a
female.

 In another incident a male Volunteer reported being sexually assaulted by his counterpart.
The Volunteer reported to the OVA that the Country Director told him that he, too, had
been sexually assaulted by other men in country, but that it was “no big deal.” Further,
when country staff accompanied the Volunteer back to the school so he could retrieve his
personal belongings, the Volunteer reported that the Peace Corps staff apologized to the
counterpart (the alleged perpetrator) for the inconvenience of not having a Volunteer
while he was being replaced. To my knowledge, during internal discussions it was
recommended that a female or “emotionally stronger” male Volunteer be placed at this
site.

9
 In several incidents reported to the OVA, male and female Volunteers reported that host
family members and counterparts would show them pornographic images and videos and
often times suggest they engage in the depicted sexual activity. When Volunteers
reported this to the Agency the Peace Corps staff would often minimize the behavior as a
misunderstanding.

In all of these examples, the host family and the counterpart continued to receive benefits from
the U.S. government, even though Volunteers had reported being sexually assaulted, or at risk of
being sexually assaulted, by a host family member or counterpart.
Second, the OIG concludes that they did not identify any Volunteer concerns that staff was
unresponsive to safety issues involving host families, counterparts, or sites in past evaluations.
Yet, in the OIG’s FINAL REPORT, Peace Corps’ Sexual Assault Risk Reduction and Response
Program, IG-17-01-E, November 2016 (case reviews beginning on page 46) the OIG provides
several examples of Volunteers whose safety concerns were not addressed by Peace Corps’ staff.
In this report, the OIG contends that several Volunteers expressed disenchantment with the Peace
Corps in how they were treated regarding their sites. Additionally, if the OIG had reviewed the
OVA case notes, as I encouraged them to do during my interview with the OIG, they would have
found more instances.

Third, the OIG states that MS 270 “Volunteer/Trainee Safety and Security” is the policy that
requires host families and counterparts be provided with an “appropriate orientation in order to
promote more welcoming communities, more supportive counterparts and authorities, and better-
defined roles.” In addition, the OIG states that the standards and procedures for this orientation
are contained in the “Standard Operating Procedures: Counterpart and Host Family Briefings.”
However, the content of these policies is heavily focused on what Volunteers are expected to do
to reduce their risk, such as adhering to the cultural mores on sex, relationships, personal
conduct, and appropriate dress in their country of service, and do not specifically address
appropriate sexual boundaries between host families, counterparts, and Volunteers. While the
counterpart and host family briefings appear to include gender relations, the report does not cite
specifically what must be included in this discussion with host families and counterparts.8

Subsequently, in the reports that the OIG has issued related to site safety, the “Standard
Operating Procedure: Counterpart and Host Family Briefings” is not mentioned. This leaves one
to wonder how the OIG has been able to ensure in its evaluations and audits that these briefings
have been conducted and if so, whether they have been conducted in an effective manner to
mitigate the risk of Volunteers being sexually assaulted by a host family member or counterpart.
In the FINAL REPORT, Peace Corps’ Sexual Assault Risk Reduction and Response Program,
IG-17-01-E, November 2016, the OIG referenced the lack of training provided to Post-specific
staff to ensure they are adequately trained in the necessary skills and knowledge to discuss topics

8
The OIG did not provide a citation for this procedure and it is not available on the Peace Corps
website.

10
related to sexual assault and even makes a recommendation9 to address the issue. Further, there
is no mention of the requirement of each Post to document that the briefings have been
conducted with the host families and counterparts prior to Volunteers being placed in their
sites.10

Lastly, the OIG concludes that the “law does not require the agency to provide training to host
families or counterparts on establishing appropriate relationship boundaries” and provides a
quote from the Peace Corps’ Chief of Overseas Operations: “…I’m not really clear what more I
could do, or the agency in this regards, to providing training to host country nationals that would
lessen our volunteers’ exposure to sexual assault.” The Agency is responsible for the safety of
the Volunteers, especially if the risk can be minimized by action that is within the reasonable
capabilities of the Peace Corps. In fact, the OIG acknowledges in the report that “The Peace
Corps has not developed agency-wide training curriculum for staff to provide host families and
counterparts…” This is a basic, and very achievable, first step towards lessening Volunteers’
exposure to sexual assault.

There are several reasonable actions the Peace Corps could take to reduce the risk of Volunteers
being sexually assaulted by host families and counterparts, such as:

 Develop a standardized training for the orientation of host families and counterparts that
addresses appropriate relationship boundaries, including sexual assault. This training can
then be tailored to the specific culture of each country in which the Peace Corps serves
with the assistance of country-specific staff.

 Develop a policy to ensure Posts are involved with housing and counterpart changes that
occur during a Volunteer’s service.11

9 “That the Director consider incorporating intercultural diversity and inclusion training in the
agency’s plan to improve staff capacity to deliver sexual assault risk reduction and response
training.” OIG Report, p. 26-27. (This is Recommendation #10 in the November 2016 FINAL
REPORT.)
10
Site history documentation is a recurring management challenge and issue raised by the OIG
in several past reports that I will address more fully in my response to Disclosure 3.
11
This is a common, but dangerous, practice among Posts. Usually, Post staff will identify and
develop sites (housing and counterparts) for Volunteers in advance of the Volunteers being
placed in country at the start of their service. However, often times a Volunteer will want or need
to change their site or counterpart during their service for any number of reasons. For posts that
lack resources, specifically staff, the post will tell the Volunteer to find new housing or a
counterpart and then the staff will come out to make sure it meets Peace Corps requirements. The
practice is quite backwards, dangerous to Volunteers, and against Peace Corps policy. Everyone
knows it happens, but the Agency does nothing to curb it from happening so often. This practice
was most recently documented in the OIG’s evaluation of Kosovo.

11
 Provide training to country-specific staff to increase and enhance their ability to
effectively deliver the host family and counterpart orientations, with an emphasis on
discussing appropriate relationship boundaries, including sexual assault.

 Require host families and counterparts to attend the orientation and document their
attendance in the site history file prior to Volunteers being physically placed in site.12
If a host family or counterpart does not attend the orientation a new host family or
counterpart should be identified and trained.

 Ensure all incidents involving host family members and counterparts as the perpetrators
are documented in the site history file.

 Develop a policy that states host family members and counterparts who have been
entrusted with supporting a Peace Corps Volunteer who then sexually assaults and/or
causes harm or injury to a Volunteer shall no longer benefit financially or otherwise from
the U.S. government.

I have suggested these changes to the Peace Corps leadership, to no avail.

However, I was pleased to learn that the OIG included three recommendations specifically
addressing sexual harassment in the FINAL REPORT, Peace Corps’ Sexual Assault Risk
Reduction and Response Program, IG-17-01-E, November 2016.

o Recommendation 6 – That the Director define how the agency should address the
problem of sexual harassment in relation to the sexual assault risk reduction and
response program.

o Recommendation 7 – That the Director provide guidance and support to posts to


integrate culturally appropriate training on sexual harassment into the Volunteer 27-
month learning continuum.

o Recommendation 8 – That the Director provide Volunteers with clear guidance on


how and when to report sexual harassment to the Peace Corps.

As an aside, the OIG in its response stated that “Ms. Greene alleges generally that the Peace
Corps does not involve OVA in developing training related to sexual assault even though the
Kate Puzey Act provides that OVA ‘shall help develop and update the sexual assault risk-
reduction and response training.’…Thus, OVA is not able to advise the Peace Corps on how to
improve and implement training.”

I would like to clarify that my statement is directly referencing two events that occurred during
my last year and a half as the Director of OVA in 2014 and 2015.

12
I will discuss site history files in more detail in my response to Disclosure 3.
12
A) The Kate Puzey Act requires that “The President shall establish an Office of Victim
Advocacy in Peace Corps headquarters headed by a full-time victim advocate who
shall report directly to the Director.” From 2011 to early 2014 OVA was heavily
involved with the development of the policies and procedures and training related to
the SARRRP. However, with the introduction of the Team Lead position in 2013 or
2014 (I don’t recall the exact year), OVA’s involvement diminished. The Team Lead
became the gate-keeper between the Director and myself, in that I no longer was able
to provide recommendations or advice directly to the Director. Instead, I had to rely
on and trust that the Team Lead would share my concerns and guidance with the
Director. What is important to note here is that the SARRRP Team Lead had no prior
experience working with victims or on sexual assault issues, yet was the person
advising the Director on the program.

B) In 2013 I informed the Agency of an uptick of female Volunteers reporting incidents


of sexual harassment in Morocco. The Volunteers from Morocco shared with OVA
that the country staff was dismissive of their reports and they were having a difficult
time accessing support. OVA worked with the Volunteers to gain access to
counseling and to also organize a meeting between them and staff from the Office of
Health Services and the Office of Safety and Security at headquarters where they
could share with the Peace Corps their experiences as well as suggestions for
improvements. Several months following this meeting I learned of a training that had
been developed by staff in the Office of Safety and Security, the Counseling and
Outreach Unit, and the Eastern Mediterranean and Asia (EMA) Region and delivered
to staff and Volunteers in Morocco.

Additionally, in the planning stages of developing this training, the Agency sent a
team to Morocco to explore the issue of sexual harassment, yet never informed OVA.
Upon learning of this training during a senior staff meeting, I approached the heads of
the offices that were involved in this to inquire why OVA had not been involved or
informed. The Regional Director for EMA initially ignored my requests for a meeting
and after several weeks of asking to meet with her, she had her deputy meet with me,
who questioned why I was concerned that OVA was not informed since “sexual
harassment is not a crime.”

The high rate of sexual harassment experienced by both female and male Volunteers was a
recurring issue that I shared with leadership, including the Director, throughout my entire active
employment with the Peace Corps (May 2011 to October 2015). It was always dismissed as “par
for the course of serving as a Volunteer and if Volunteer’s can’t deal with it then they shouldn’t
be a Volunteer.” Indeed, the title of the training, Coping with Unwanted Attention, reflects the
Agency’s historical downplaying of the amount, level, and type of sexual harassment that
Volunteers, especially female Volunteers, experience in country.

As I mentioned, I was pleased to learn the OIG included sexual harassment in the FINAL
REPORT, Peace Corps’ Sexual Assault Risk Reduction and Response Program, IG-17-01-E,

13
November 2016 because it validates for me that I was in tune with the needs of the very
individuals I was hired to advocate for, the Volunteers. In fact, the OIG even mentions the
Coping with Unwanted Attention training in the report:

Both Volunteers and post staff reported that the Peace Corps did not adequately prepare
Volunteers during training to deal with sexual harassment. The session Coping with
Unwanted Attention, introduced in 2014, was designed to help Volunteers cope with a
range of unwanted attention. While the session did include a case study on sexual
harassment, staff and Volunteers expressed to us that the session overall did not directly
deal with the problem of sexual harassment. The session primarily addressed verbal
harassment, such as catcalls. Volunteers reported that they felt the session did not include
sufficient opportunity to discuss sexual harassment coping strategies.

What is most frustrating about this is that this training was developed as the direct result of the
courageous Volunteers from Morocco who in 2013 begged the Peace Corps to do more to protect
and support them. But, as was far too often my experience, the Agency minimized and dismissed
these Volunteers’ concerns, and developed a training that was not responsive to the needs of the
Volunteers. The OIG continued in the report (emphases added):

“Because the SARRR training did not address the often pervasive risk of sexual
harassment, Volunteers in our focus groups said the agency did not understand or
appreciate the toll that constant harassment had on Volunteers. One Volunteer
described constant sexual harassment as a form of trauma. Another told us that other
Volunteers had elected to end their service early due to the stress of coping with sexual
assault.”

Now, four years later the OIG is recommending the Peace Corps address sexual harassment,
again demonstrating that the Agency is only willing to make the necessary changes to protect
and support Volunteers when forced. The previous leadership and the Director of the Peace
Corps (August 2012 to January 2017) owe numerous Volunteers, if not hundreds, an apology for
the lack of an appropriate response to the Volunteers’ repeated reports of sexual harassment and
their pleas for support. Those Volunteers deserved better. Instead they needlessly suffered
feelings of shame and guilt for the Peace Corps insinuations of inadequacy in that they were
deemed “not fit for service.”

Disclosure 3

The Peace Corps has failed to take adequate action to protect the safety of Peace Corps
volunteers who are traveling in countries of service.

Related to this disclosure, the Office of Special Counsel posed Question 3: “Has the Peace
Corps taken adequate steps to protect the safety of Peace Corps volunteers who are traveling
in countries of service where public transportation is inadequate? If so, describe the steps
taken.”

14
Once again, the OIG did not investigate this disclosure and instead relied upon previous
evaluations and audits. Additionally, the evidence provided in the report is not responsive to my
concern, which I explained to the OIG was Volunteer’s access to safe transportation at their sites.

The OIG concedes in the report that crimes against Volunteers on public transportation is a
serious issue representing 16% of all reported crimes. Again, as in the previous two disclosures,
this number does not include unreported crimes.13 Yet, the OIG and the Peace Corps do not
recognize this number as being significant enough for the Agency to explore ways to further
reduce this risk to Volunteers.

As I mentioned before, the Peace Corps is slow to make change unless there has been a
significant threat to Volunteers or the mission of the Agency. Two of these instances are
referenced in the OIG’s response to this disclosure. The first is the evaluation of Namibia in
which the OIG found that Volunteers were hitchhiking. I had brought this to the attention of
leadership after receiving 2 reports of Volunteers being sexually assaulted while in transit from
their site to the Peace Corps office in country. The main reason I raised this concern with
leadership was due to the fact that the Volunteers were being blamed for the assaults by in-
country staff. However, the Volunteers disclosed to me that they didn’t have access to any other
form of transportation in their site.

The other instance the OIG references in the report is Honduras, where the Peace Corps had been
aware that Volunteers were experiencing high rates of victimization while traveling on public
transportation (for example, buses were routinely stopped on certain, usually isolated, routes,
where the passengers were being robbed of all their belongings). However, the Peace Corps
didn’t close Honduras until after a female Volunteer was shot in the leg while traveling on a bus.

Prior to my removal from the OVA, there were several reports of Volunteers being drugged
while on public transportation. In one incident the Volunteer’s sister phoned the Peace Corps
stating that her brother was in danger as he had begun to slur his words and eventually passed out
while talking with her. Two of the incidents occurred in the same country, however, there were
reports of this happening in other countries as well. I recommended that the Agency send an alert
message to Volunteers warning them not to accept food or drink from anyone on public
transportation. In addition, I recommended that each Post provide Volunteers with a few
sentences in the local language to assist them with politely refusing the offer. To my knowledge,
the Peace Corps did not provide this warning to Volunteers.

Although the OIG provided many citations to Agency policy and procedure related to
transportation and site development, the report fails to mention the consideration of the
proximity of a Volunteer’s house to accessible transportation. While the distance a Volunteer
must walk or ride a bike to access transportation may be within Agency policy, it is the
environment that the Volunteer must traverse that places them in harm’s way. Often times the

13
The OIG reports in the FINAL REPORT, Peace Corps’ Sexual Assault Risk Reduction and
Response Program, IG-17-01-E, November 2016 that 50% of all crimes are unreported to the
Peace Corps.
15
roads leading from the Volunteer’s home to public transportation are desolate or surrounded with
thick bush or are busy with many people loitering in front of stores, homes, or bars. Regardless
of the type of environment, walking along these roads alone is a great risk to Volunteers
(especially female Volunteers) and although they are told to not walk alone, it is not always
possible to have a community member walk with them, which places Volunteers at extreme risk
for assault. Unless the Agency includes the geography of the routes Volunteers must travel to
access public transportation in their assessment of potential sites for Volunteers, the policies will
continue to be ineffective at mitigating this risk.

In 2016 the OIG issued three reports that include information supportive of Disclosure 2 and
Disclosure 3. They are:

 Management Advisory Report on Site History Files.14 In this report the OIG states the
purpose of the management advisory was to bring to management’s attention “systemic
deficiencies in the maintenance, organization, and use of site history files that OIG has
found at multiple posts, potentially increasing safety and security risks to Volunteers.” It
further states, “Throughout the period in question, OIG has continued to receive
complaints from Volunteers alleging that posts placed them in unsafe sites despite
previously having been notified that sites were dangerous.” Additionally, the OIG
includes a reference in the management advisory to another report issued in 2012
outlining reoccurring issues with site development and site history files dating back to
2009.15 Lastly, the management advisory includes findings from 9 country evaluations
between 2012 and 2016 demonstrating that site development and site history files are an
area in which the Peace Corps must address to meaningfully mitigate risks and threats to
Volunteer safety.

 Management and Performance Challenges. This report states that the OIG “found that
several posts did not comply with their self-identified housing criteria, and appropriate
staff (including the safety and security manager) was not always sufficiently included in
the site development process.” The report concludes that “Without housing checks and
proper site development, the Agency may place Volunteers in houses and sites that
impose increased security risks.” Based on this finding by the OIG that staff, including
the Safety and Security Manager, are not sufficiently included in the site development
process, the OIG cannot be certain that host family and counterpart orientations are being
properly delivered, as the Safety and Security Managers are also responsible for
delivering the orientation during the site development process.

14
Site history files are used by the Peace Corps to document that Agency procedures were
followed in identifying and developing sites for Volunteers, in addition to any safety and security
incidents that may occur during the time a Volunteer is posted at the specific site.
15
http://files.peacecorps.gov/multimedia/pdf/policies/PC_Recurring_Issues_OIG_Post_Audits_E
valuations_FYs_2009-2011.pdf
16
 FINAL REPORT, Peace Corps’ Sexual Assault Risk Reduction and Response Program.
This report provides a recommendation specifically referencing site safety:
o Recommendation 24: That the Director develop and communicate guidance for
overseas staff on documenting site-specific security incidents in site history files
while maintaining Volunteer’s confidentiality, and on using the information in
site history files as part of post’s site vetting process.

I acknowledge that not all crimes can be prevented and that there are inherent risks to serving as
a Peace Corps Volunteer. However, during my time at the Peace Corps, OVA responded to many
incidents involving Volunteers who had been sexually assaulted or physically assaulted (which
were more often than not attempted rapes) while attempting to access transportation at their site
or attacked while in transit that could have been prevented had the Agency done its due diligence
through the process of proper site development. I am pleased to see that the OIG has issued
reports, management advisories, and recommendations to address these issues. However, it is
deeply disappointing that these are all concerns I raised with Peace Corps leadership during my
time as the Director of OVA, yet leadership minimized these concerns as Volunteers who were
“not cut out for Peace Corps service,” and were entirely ignored and dismissed.

Safe site development is a challenge that the Peace Corps will continue to experience unless it
devotes the proper resources to addressing the issue. Currently Posts lack the staff to sufficiently
and consistently devote the necessary time and attention needed to properly identify and develop
a site for Volunteers. Each staff person with a role in site development is responsible for several
competing priorities. For example, the Peace Corps Medical Officers (PCMOs) play a significant
role in facilitating Volunteer training (pre-service training, in-service training, mid-service
training, and close of service conference), providing medical exams to all new incoming
Volunteers and Volunteers ending service, responding to routine and emergency medical needs
of Volunteers, and actively participating in site development. Likewise, the Safety and Security
Managers are responsible for keeping the Country Director and Volunteers apprised of safety
and security concerns in country, facilitating the same trainings as the PCMOs, responding to
routine and emergency Volunteer safety and security incidents, and actively participating in site
development. Proper site development requires the responsible staff to actually visit the sites,
which requires more resources than what is currently allotted.

Disclosure 4

The Peace Corps does not provide adequate counseling services to Peace Corps volunteers
who are sexually assaulted during their service with the Peace Corps.

Related to this disclosure, the Office of Special Counsel posed Question 4: “Has the Peace
Corps provided adequate counseling services to Peace Corps volunteers who have been victims
of sexual assault during their service? If so, describe the nature and duration of services
available to volunteers and the process by which the services are provided.”

The Kate Puzey Act mandates the OVA to “ensure that volunteers who are victims of sexual
assault receive the services specified in section 8B(c), and facilitate their access to such

17
services.”16 One of the services required by the Kate Puzey Act is counseling. The OIG’s
evidence, findings, and conclusions to this specific disclosure identified the gaps in current Peace
Corps policies and practices and supported my disclosure.

However, due to the limited number of cases the OIG reviewed (138), including the small
number of Volunteers interviewed (11), the findings and conclusions do not capture the
significance of Volunteer’s lack of access to counseling in the wake of a sexual assault. In
contrast, as the victim advocate and Director of OVA I interacted with and provided advocacy
services to hundreds of Volunteers, female and male, who reported being the victim of sexual
assault. During my interview with the OIG investigator and evaluators I strongly encouraged
them to access and review the OVA case notes so they could see the high number of Volunteer
complaints regarding access to counseling as well as complaints regarding the Agency’s overall
response. Based on the OIG’s finding that they do not consider this to be a systemic issue, but
rather localized to just a few cases, it is evident that they did not do so.

In the report, the OIG states that they made two recommendations to the Agency in the OIG’s
FINAL REPORT, Peace Corps’ Sexual Assault Risk Reduction and Response Program, IG-17-
01-E, November 2016 that are related to counseling services for Volunteers who are victims of
sexual assault.17 While I am pleased that the OIG made these recommendations and that the

16
The eight services are: 1) The option of pursuing either restricted or unrestricted reporting of
an assault; 2) Provision of a sexual assault response liaison (SARL) and victim’s advocate to the
Volunteer; 3) At a Volunteer’s discretion, provision of a sexual assault forensic exam in
accordance with applicable host country law; 4) If necessary, the provision of emergency health
care, including a mechanism for such Volunteer to evaluate such provider; 5) If necessary, the
provision of counseling and psychiatric medication; 6) Completion of a safety and treatment plan
with the Volunteer, if necessary; 7) Evacuation of such Volunteer for medical treatment,
accompanied by a Peace Corps staffer at the request of such Volunteer. When evacuated to the
United States, such Volunteer shall be provided, to the extent practicable, a choice of medical
providers including a mechanism for such Volunteers to evaluate the provider; and 8) An
explanation to the Volunteer of available law enforcement and prosecutorial options, and legal
representation.
17
In the OIG Report, they stated:

We noted that without timely mental health care, the Peace Corps did not provide compassionate
support to some victims who have requested counseling support. This frustrated those victims,
delayed the victim’s recovery, and may have undermined the credibility of the Peace Corps’
SARRR program. To address this issue, the OIG recommended:

That the Director develop and implement mental health access to care timeliness
standards for victims of sexual assault with a mechanism to notify management when
then standards are not met.

OIG Report, p. 38. (This is Recommendation #18 in the November 2016 FINAL REPORT.)
18
Director concurred with both, I am at the same time incredibly disheartened. Over a 4-year
period I had raised concerns related to both of these recommendations on numerous occasions to
the Agency’s leadership, including the Director. Every time, the Director of the Peace Corps
routinely dismissed my reports of Volunteers not being able to access counseling in a timely
manner, or at all in some instances, and having limits placed on the number of counseling
sessions they would be able to receive. It is quite unfortunate and incredibly disconcerting to
know that a great number of Volunteers have needlessly suffered over the years as a result of the
Director’s inaction to my repeated disclosures.

In addition, the Director’s response18 to recommendation 18 leaves an opening for Volunteers to


potentially wait a longer period than necessary to receive counseling, since the timing is based on
when a consult has been submitted by the PCMO. The response fails to include a standard for
how long following a request by a Volunteer for counseling that the PCMO should submit the
consult. From my prior experience at the Peace Corps this is where many of the delays occurred.
Also, the Agency’s response fails to take into account requests that are made directly to OVA,
which according to this standard would require the request to be submitted by the PCMO, once
again unnecessarily slowing a Volunteer’s access to counseling.

Furthermore, although the OIG describes the Agency policies and procedures relevant to
Volunteers’ access to counseling, it has been my experience that the identified procedures are not
considered best practice in the sexual assault field. Specifically, I am referring to the Agency’s
unwillingness to develop a system to streamline the process for Volunteers to receive counseling

Additionally, the OIG stated:

We concluded that some Volunteer sexual assault survivors could have been deterred from
reporting their need for counseling for fear of exceeding a perceived limit of authorized
counseling sessions, and facing the prospect of separation from the Peace Corps as a result. To
address this issue, OIG recommended:

That the Director develop specific guidance to Peace Corps medical officers to clarify the
standards and expectations for the provision of counseling services, and communicate
that guidance to Volunteers.

OIG Report, p. 38. (This is Recommendation #35 in the November 2016 FINAL REPORT.)
18
The Director concurred with recommendation 18 and will update Medical Technical Guideline
540 “A Resource Guide or the Clinical Management of Sexual Violence” to establish a standard
for Volunteers to receive care from the Peace Corps’ Counseling and Outreach Unit or in-
country provider within 72 hours after a consult has been submitted by a Peace Corps Medical
Officer.

OIG Report, p. 42. (This is the Peace Corps’ response to Recommendation #18 in the November
2016 FINAL REPORT.)

19
services when the request is made directly to a Peace Corps’ Victim Advocate. The current
practice requires the PCMO to initiate the request for a counseling consult, which in situations
where the request is made directly to OVA may significantly delay a Volunteer’s access to the
requested counseling. It was not uncommon, when notified by OVA that a Volunteer requested
counseling, for the Counseling and Outreach Unit to state they would not respond to a
Volunteer’s request for counseling until the PCMO sent the consult request. This meant that the
Victim Advocate had to contact the PCMO and request that a counseling consult be initiated, or
the Volunteer had to contact the PCMO and request the counseling even though the Volunteer
had already made the request to OVA. This process is needlessly inefficient, unduly frustrating,
and not victim-centered or trauma informed.19 Furthermore, the process is predisposed to cause a
Volunteer to have to retell details of the traumatic event to multiple individuals—again
needlessly—while attempting to receive counseling services.

The OIG states in the report that OVA staff “…explained that the PCMO is best positioned to
determine the nature and urgency of the counseling needed, and can pre-brief the assigned
counselor.” This is a significant departure from what the two Associate Victim Advocates
conveyed to me when I was the Director of OVA. In fact, this was an area of constant frustration
for our office as we were keenly aware of the unnecessary delay this causes for some Volunteers
to access counseling. The Victim Advocates are equally well positioned to initiate a counseling
request. Each of the Victim Advocates in OVA is credentialed by the National Organization for
Victim Assistance. I was credentialed at the highest level, Advanced, which requires 15,600
hours (8 years) of experience. I believe during my tenure that at least one of the Associate Victim
Advocates was also credentialed at the Advanced level with the other Associate Victim
Advocate being credentialed at the Intermediate level, which requires 7,800 hours (4 years) of
experience. That is far more experience in working with victims of crime than the PCMOs, who
as medical doctors and nurses receive approximately 10 to 20 hours of sexual assault response
training every couple of years from the Peace Corps. This in no way is meant to diminish the
years of education and experience of the PCMOs as medical doctors and nurses, but to
demonstrate that Victim Advocates and PCMOs are both capable of initiating a counseling
consult.

To ensure that a Volunteer does not have to recount the traumatic details of the sexual assault, or
wait unnecessarily to speak with a counselor, I had made several recommendations to leadership
on how the process could be more victim-centered. One such recommendation was that in
situations where a Volunteer made a request for counseling directly to OVA, the Counseling and
Outreach Unit would proactively contact the PCMO to initiate the Volunteer’s access to the
requested counseling, instead of waiting for the consult to come in from the PCMO, which could
take days. To date, I am unaware if the Agency has adopted this practice.

19
When a survivor of sexual trauma reaches out for counseling they are most often in a state of
crisis. Having to wait days or in the case of the Peace Corps up to four weeks to speak with a
counselor can cause significant harm to the long-term recovery of that survivor, especially in an
already stressful foreign environment.
20
In my original disclosure complaint to the Office of Special Counsel, I advised that the Peace
Corps was placing an artificial cap on the number of counseling sessions Volunteers were able to
receive. If a Volunteer exceeded the cap, the Volunteer was determined to be “unfit for service.”
Again, I am pleased to learn that the OIG has made a recommendation that the Peace Corps
should “develop specific guidance to Peace Corps medical officers to clarify the standards and
expectations for the provision of counseling services, and communicate that guidance to
Volunteers.” However, this recommendation alone is not sufficient to address my concern
regarding the number of counseling sessions a victim of sexual assault may receive.

Recovery from sexual assault is not instantaneous. It has been my professional experience as a
victim advocate that counseling for survivors cannot be a one-time event, meaning that it should
not be just the initial response to the trauma. It is unhealthy to expect that a Volunteer survivor of
sexual violence may not require additional “check-ins” following a counseling cycle. This sets
Volunteers up to fail, as well as have a negative long-term impact on their emotional wellbeing.
However, in the Peace Corps, Volunteers who wish to access counseling throughout their service
at various times following a sexual assault are ultimately told they “are not fit for service.” This
messaging is extremely detrimental to a Volunteer’s long-term recovery.

This culture is subtly reinforced by the Agency’s policies. In TG 545 (Peace Corps’ medical
technical guideline entitled “Sexual Assault Mental Health Assessment and Care”), it states that
counseling may take “two to three months.” While not an express cap, in my experience, this
wording has allowed Peace Corps employees to justify limiting the amount of counseling a
Volunteer receives, and further enables the Agency practice of medically separating a Volunteer
who requires continued counseling throughout their service.

Currently, Peace Corps promises that they are fully committed to victims of sexual assault and
that they will provide victims the support necessary to recover.20 However, the Peace Corps’
actual policies, such as TG 545, are too vague to ensure Volunteers receive the requisite support.
For example, to say that counseling is based on a “case-by-case approach that may take two to
three months” allows for inconsistent interpretations and applications depending on who the
counselor is, or who is the current head of the Counseling and Outreach Unit and Office of
Health Services. Indeed similarly vague policies led to the confusion regarding the six session
cap. Without clear language regarding how much counseling a Volunteer may receive following
a sexual assault and what determines when a Volunteer is no longer able to continue service,

20
Peace Corps is committed to providing a compassionate and supportive response to all
Volunteers who have been sexually assaulted. To that end, Peace Corps makes the following
commitment to our Volunteers who are victims of sexual assault. Peace Corps staff worldwide
will demonstrate this commitment to you through our words and actions.

#3 We will provide you with the support you need to aid in your recovery. Peace Corps
Commitment to Sexual Assault Victims, p. 6. (MS 243 Procedures for Responding to Sexual
Assault.)

21
Volunteers and staff will have differing expectations. There needs to be clear language and
standards to guide the counseling.

Additionally, given my knowledge of the Peace Corps’ Sexual Assault Risk-Reduction and
Response Program (SARRRP), I question the validity and reliability of the sources used by the
OIG to reach the conclusion that “The Peace Corps offered counseling to 100% of the
Volunteers in [the OIG’s] review (138 Volunteers).”

The OIG likely used the CIRS reports and/or the Volunteer Reporting Preference Statement21
(VRPS) to make this determination. Both of these sources are not 100% accurate. For example,
in CIRS there is a box that is supposed to be checked when professional counseling services are
provided. In nearly every incident of sexual assault this box is checked in CIRS even though the
CIRS reports are required to be submitted within 1-3 days following a report of a sexual assault.
Given the delays that I am aware exist in the Peace Corps’ provision of counseling to Volunteers,
it is unlikely that in every case counseling was provided within 1-3 days. Further, the Peace
Corps considers the crisis intervention that PCMOs sometimes provide to Volunteers as
professional counseling. However, PCMOs are not qualified nor trained to provide professional
counseling. PCMOs are medical doctors and nurses, not licensed mental health providers. By not
having a standard or definition for what qualifies as professional counseling, the Agency cannot
accurately count the number of cases in which professional counseling is provided by a licensed
mental health provider.

Similarly, the VRPS was developed as a mechanism for the Agency to be able to document that
it was offering Volunteers the 8 services required by the Kate Puzey Act. However, it was my
experience that the information contained in the VRPS may not be accurate for the following
reasons:

 Like CIRS, the VRPS has boxes that Volunteers and PCMOs check off to document the
services offered and the services a Volunteer would like to access. The VRPS is
separated into two sections, Restricted Reports and Standard Reports, since the services
available to Volunteers are slightly different depending on which type of sexual assault
report they would like to make. Many of the VRPS received by OVA would often times
be completed for both of the reporting options and/or every single box would be
checked.22

 There were several VRPS that were not signed by the Volunteer so it was not possible to
determine if the Volunteer had been provided the information.

 The VRPS was not completed in 100% of the sexual assaults reported to the Peace Corps.

21
VRPS is an Agency created form that is used to document the sexual assault services offered
to a Volunteer and the services that the Volunteer would like to receive.
22
Agency policy required PCMOs to provide a copy of the VRPS to OVA to be maintained in
the OVA case files.
22
 Sometime between April 2015 and October 2015 the Agency notified the PCMOs that
the OIG would be conducting the evaluation on the SARRRP related to the Kate Puzey
Act. In this notification the Agency instructed the PCMOs to ensure that all of the
required documentation for sexual assault reports was in order. I became aware of this
notification after receiving an email from a Volunteer expressing her frustration at a
PCMO. The PCMO had contacted the Volunteer and was requiring her to travel to the
Peace Corps medical office to fill out the VRPS. The reason this Volunteer was so upset
is that the VRPS she was being asked to complete was for a sexual assault she had
reported over a year ago. I don’t have access to this email (although the Agency should
have retained my emails due to the Prohibited Personnel Practice complaint), but I do
have documentation that I brought this to the attention of the Senior Advisor to the
Director, the SARRRP Team Lead, and the Chief of Staff at which time I suggested that
they provide additional guidance to the PCMOs informing them that they should not be
asking Volunteers to sign and/or complete VRPS in instances where the VRPS had not
been completed at the time the sexual assault was reported to the Peace Corps.

The OIG states in their evaluation they measured the time between the Volunteer’s request for
counseling services and the first counseling appointment. However, they do not provide their
methodology for how they measured the time. During my time at the Peace Corps, the OIG
frequently commented that it was a challenge for them to match the Critical Incident Report
System23 (CIRS) reports with the Volunteers’ medical records. To address this issue I had
repeatedly recommended to the Agency that the Volunteer medical records should be cross-
referenced with the CIRS number (or another data point from CIRS such as the Volunteer
number which is a unique number automatically generated in CIRS) and that CIRS should be
searchable by a Volunteer’s name (which it is not). The only system that was searchable by both
the CIRS number and the Volunteer’s name was the OVA database. While this may no longer be
an issue due to the Agency implementing the Coordinated Agency Response System (CARS)
Case Management System, this system was not in use for the period in which the OIG conducted
the evaluation. Nevertheless, the report does not state what source was used to determine when a
Volunteer initially requested counseling services. Was it when the Volunteer filled out the
VRPS, which may not always have been the same day the Volunteer reported the sexual assault
to the Peace Corps? Or, was it the date that the PCMO sent the counseling consult request to the
Counseling and Outreach Unit, which may have been days after the Volunteer first requested to
speak with a counselor? Or, was it the date the Volunteer made the request to OVA?

To appropriately address counseling support for Volunteers the Peace Corps must become more
transparent on exactly what they are willing to provide, and what they are able to provide, to
Volunteers who are sexually assaulted. As an institution, the Peace Corps has limitations on what
it is able to provide to Volunteers due to the budget, staffing resources, and other competing
priority. However, it must be upfront about its capabilities.

23
CIRS is the database used by the Agency to record safety and security incidents involving
Volunteers and overseas staff. It is similar to an electronic police report.
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If the Peace Corps is only capable of, or chooses to only, provide short-term counseling and
support to Volunteers who are sexually assaulted, the Agency needs to set this expectation early
in the recruitment process. This messaging should be incorporated into recruitment and
promotional materials and activities, and be provided to applicants prior to them accepting the
invitation to serve.

With that said, I strongly believe the Peace Corps is capable of providing the necessary long-
term counseling and support to Volunteers that would allow many Volunteers to complete their
service. Unfortunately, it has been my experience that the Peace Corps finds it easier to replace
Volunteer’s than it does to provide them resources to assist them in completing their service after
a traumatic event.

The next section of my response is related to overarching questions posed by the Office of
Special Counsel, and the Peace Corps’ response.

Office of Special Counsel Question 5:

Has the Peace Corps failed to inform OVA when volunteers receive requested counseling
services, when volunteers who have been victims of sexual assault leave service, and when
there are updates on criminal proceedings related to crimes against volunteers? If so, please
specify the number of times and year(s) in which the Peace Corps failed to provide this
information.

This was an ongoing issue while I was the Director of OVA. There were several occasions where
staff in the Office of Health Services and the Counseling and Outreach Unit willfully withheld
information from OVA. Additionally, the Agency refused to update policies to ensure that OVA
would receive the notifications identified in this question. The policies at the time instructed
country staff to inform specific headquarter staff other than OVA: this made it challenging for
OVA to meet its requirements under the Kate Puzey Act and hindered OVA’s ability to provide
advocacy services to Volunteers.

I am pleased to learn the CARS Case Management System has finally been implemented, as that
was a system I worked toward for three years. One of my first recommendations to the Director
was that the Peace Corps needed an agency-wide case management system to effectively and
efficiently manage crimes against Volunteers. In addition to keeping all relevant staff informed it
would also allow the Agency to identify trends and areas of improvement. Again, I am glad to
learn that this system now exists. I truly hope that it has made the flow of information to OVA
more efficient.

Office of Special Counsel Question 6:

Did any Peace Corps employee violate the Kate Puzey Act with respect to Ms. Greene’s
allegations? If so, please identify the individual(s) and specify what provision was violated.

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The OIG’s statement that my concern was more focused on the Agency as a whole and not on
specific individuals is not completely accurate. While my concern was focused on how the
Agency was implementing the Kate Puzey Act, I do believe that it was the Director’s willful
disregard of my recommendations and notifications of missteps related to the Kate Puzey Act
that is in violation of the Kate Puzey Act, most of which have been highlighted in my response to
Disclosures 1 – 4, and Question 5.

In addition, the four cases that the OIG includes in the report (pages 44–45) are representative of
the larger problem that is documented in the OVA case notes, which is that when staff deviate
from the Agency’s response protocol there isn’t any mechanism in place to address the deviation.
Without a tool to track these deviations the Agency loses the ability to improve staff response by
providing additional, more targeted training when necessary or making adjustments to Agency
policy based on information related to the circumstances of why the deviations occurred.

The OIG made a recommendation in the FINAL REPORT, Peace Corps’ Sexual Assault Risk
Reduction and Response Program, IG-17-01-E, November 2016 for the concern that “there are
no guidelines for Volunteers or staff on how to notify management if counseling services are not
provided in a timely manner.” The OIG then states, “Specifically, the Kate Puzey Act requires
the Office of Victim Advocacy to ‘ensure that volunteers who are victims of sexual assault
receive services…’ OIG believes that this office’s role in providing management oversight
should be clearly defined in agency guidance. Therefore, the OIG would like for the Director to
develop guidance on the mechanism for non-medical staff, such as the Office of Victim
Advocacy, sexual assault response liaisons, and the sexual assault risk reduction and response
program director, to notify management when the proposed standards are not met.”

As I mentioned in my response to Disclosure 4, I informed the Director on numerous occasions


that Volunteers were not receiving counseling, but she dismissed my concerns and failed to act to
correct the problem.

Office of Special Counsel Question 7:

Has the Peace Corps appropriately managed its response to instances of sexual assault against
volunteers?

My response to this question is covered in Disclosures 1-4, and Question 6 above.

Office of Special Counsel Question 8:

Has the Peace Corps’ failure to provide training to individuals who regularly interact with
volunteers and to take steps to protect volunteers in transit presented a substantial and specific
danger to public health or safety?

My response to this question is covered in Disclosures 2 and 3.

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