Human Trafficking Training Requirements for Hotels

Summary

House Bill 258 (Hotels; human trafficking training), as adopted by Chapter 751, is an act that directs the Virginia Department of Criminal Justice Services (DCJS), under the direction of the Criminal Justice Services Board, to develop an online course to train hotel proprietors and their employees, as defined in § 35.1-15.1 of the Code of Virginia, to recognize and report instances of suspected human trafficking. The act provides that such online course shall be provided at no cost to the hotel proprietors and their employees. The act requires that every hotel proprietor require its employees to complete such human trafficking training course developed by the Department or an alternative online or in-person training course approved by the Department within six months of being employed by a hotel and thereafter at least once every two years, for as long as the employee is employed by the hotel. The act has an effective date of January 1, 2023; VDH will begin enforcing these requirements starting July 1, 2023.

The Virginia Department of Health (VDH) will ensure that hotels are complying with this new requirement during their site inspections.

Curriculum Approval Information

The Code of Virginia § 35.1-15.1 allows DCJS to approve existing curriculums that are currently being used to train hotel proprietors and employees. Curriculums that are approved for use will be listed in a directory on the DCJS website to assist hotel proprietors in identifying courses that may be utilized by their staff. This approval requirement applies to both e-learning curriculums and to curriculums that are designed for in-person learning.

How do I submit my curriculum for approval? Organizations that would like to submit their curriculum for approval may download the application form from this webpage. This application form and the curriculum may be submitted for consideration to hoteltraining@dcjs.virginia.gov. The complete instructions are included in the application form.

DCJS will respond to approval applications within 60 days of the application being received, per Virginia Code § 35.1-15.1.

FAQs for Hotel Proprietors and Employees

How do I prove that my employees have been trained within the required time frame?

The Virginia Department of Health (VDH) may request hotels to show evidence that their employees have complied with this regulation at any time. Typically, this will occur during their site inspection. Hotel proprietors should be ready to show evidence that their employees have been trained. This evidence may include course completion certificates (printed or electronic) or through transcript logs from company learning management systems (LMS).

It is strongly recommended that managers maintain a file with these course completion certificates and/or LMS transcript logs after each training session is conducted.

If an employee utilizes the free e-learning course that DCJS is mandated to provide, the course certificate will be sent directly to the employee using the email address provided. DCJS will send the the transcript logs to the Virginia Department of Health at regular intervals and upon request.

When can the DCJS training course be accessed?

DCJS is currently implementing a new learning management system (LMS). This system is expected to be available to professionals by March 2023. Until this system is available, hotel employees may utilize other approved courses to fulfill this requirement.

If I use an approved course that is not provided through my employer how do I show proof of completion?

If an employee does utilize an approved course that is not provided directly through their employer, it is strongly recommended that a copy of the course completion certificate be provided to their manager. The employee should maintain a copy of this certificate as well.

I attended an in-person training event. How do I provide proof of completion?

It is the responsibility of the employee to ensure that the curriculum being used at the in-person training session has been approved for use by DCJS. Upon completion of the training session, a course completion certificate with the official agenda or an official agenda plus a copy of the attendance sign-in form may be submitted to the employee’s manager. It is strongly recommended that the employee maintain a copy of these documents as well.

I was trained on human trafficking through a course that is not approved by DCJS. Will it be accepted?

No. Only courses that have been approved by DCJS will be accepted as a fulfillment of this requirement.

How often do employees need to complete human trafficking training?

Virginia Code § 35.1-15.1 states that employees will be trained within 6 months of employment by a hotel and at least once every two calendar years thereafter, for as long as they are employed by a hotel.

Additional questions may be directed to Angella Alvernaz, State Trafficking Response Coordinator, at angella.alvernaz@dcjs.virginia.gov.