Human Trafficking Awareness Training for Health Care Professionals

Human Trafficking Awareness Training for Health Care Professionals

Human Trafficking Awareness Training for
May 6, 2022
Health Care Professionals
Kristin Finklea
Human trafficking occurs throughout the United States, and traffickers exploit
Specialist in Domestic
vulnerable individuals for commercial sex and forced labor in a variety of legal and
Security
illegal industries. U.S. efforts to counter trafficking in persons broadly involve

prevention and awareness training, investigations and prosecutions of trafficking
Elayne J. Heisler
offenses, and protection for victims. With respect to identifying victims and protecting
Specialist in Health
them from further exploitation, certain industries—such as the health care industry—are
Services
uniquely positioned to recognize potential signs of trafficking. Some studies have

indicated that many trafficking victims come in contact with medical professionals at

some point during their exploitation, and health care professionals may be well situated
to recognize indicators of human trafficking.
One key challenge in taking action to counter human trafficking is accurately identifying its victims. Various
federal departments and agencies have developed efforts to enhance awareness of human trafficking. Many of
these programs target awareness training to multiple industry sectors. One program is specifically focused on the
health care industry. The Department of Health and Human Services (HHS) administers the Stop, Observe, Ask,
and Respond (SOAR) to Health and Wellness Training Program. The SOAR Program trains professionals and
organizations to recognize potential signs of human trafficking in health care, behavioral health, public health, and
social services settings, and to respond appropriately. It provides survivor and clinician-informed trainings to
teach professionals to (1) understand the types of and common risk factors for trafficking, (2) identify individual
and environmental indicators of trafficking, (3) screen individuals and identify potential victims using a trauma-
informed and person-centered approach, and (4) coordinate with relevant stakeholders to deliver appropriate care.
The SOAR Program also has an online, on-demand training component, SOAR Online, which is a series of
training modules, jointly provided by the Postgraduate Institute for Medicine, that qualify for continuing
education and continuing medical education credits. There are modules tailored for behavioral health, public
health, health care, and social service professionals, as well as for professionals serving specific communities or
in particular settings.
While the SOAR Program is one path to educate health providers in recognizing trafficking, additional programs
may be considered. Health provider training to recognize human trafficking could occur at multiple points in time:
during formal education (e.g., medical or nursing school), during clinical training (e.g., as part of medical
residency training or nurse clinical training), and while in active practice (e.g., as part of the requirements to
obtain or maintain a license). Generally, the federal role at each of these points may be limited because schools
and clinical training programs set training content, and states license health professionals. However, policymakers
may consider several options for influencing this training. For instance, the federal government could use funding
to encourage schools and training programs to develop and implement trafficking awareness training. Also, states
can choose whether to require such training for licensed health professionals, and the federal government could
consider providing incentives to states that require this or similar training.
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Contents
Conceptualizing Human Trafficking ............................................................................................... 1
Evidence for Human Trafficking Awareness Training for Health Care Professionals .................... 2
Federal Role in Countering Human Trafficking .............................................................................. 3
The Role of Awareness Training ..................................................................................................... 4
Federal Human Trafficking Awareness Efforts ......................................................................... 5
SOAR to Health and Wellness Training Program ............................................................... 6
The Role of Health Professionals in Identifying Human Trafficking .............................................. 7
Core Competencies ................................................................................................................... 7
When to Conduct Awareness Training for Health Care Professionals ............................................ 8
Training During Formal Health Professional Education ........................................................... 8
Training During Supervised Clinical Training .......................................................................... 9
Training During Clinical Practice ........................................................................................... 10
Concluding Observations ............................................................................................................... 11

Contacts
Author Information ......................................................................................................................... 11

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Human Trafficking Awareness Training for Health Care Professionals

uman trafficking occurs throughout the United States, and traffickers exploit vulnerable
individuals for commercial sex and forced labor in a variety of legal and illegal
H industries. U.S. efforts to counter trafficking in persons broadly involve prevention and
awareness training, investigations and prosecutions of trafficking offenses, and protection for
victims. With respect to protecting victims from further exploitation, workers in certain industries
are uniquely positioned to identify potential signs of victimization. For instance, health care
professionals may be well situated to recognize trafficking indicators because victims of
trafficking may experience a wide range of acute and chronic health issues directly related to their
victimization. Some studies have indicated that many trafficking victims come in contact with
medical professionals at some point during their exploitation.1
This report provides an overview of human trafficking and the role that awareness training may
have in protecting victims and preventing exploitation. It outlines existing human trafficking
awareness training programs, including those tailored to health care professionals. It also
discusses the federal role in health professional training and federal efforts to encourage provider
training in certain topics as context for potential policy considerations related to human
trafficking awareness training. The report concludes with a discussion of potential policy options
going forward.
Conceptualizing Human Trafficking
Human trafficking in the United States is broadly conceptualized as having two categories: sex
trafficking and labor trafficking. Some metrics suggest that in the United States, U.S. citizens
may more often be victims of sex trafficking than labor trafficking and that noncitizens may more
often be victims of labor trafficking than sex trafficking.2 Federal statutes do not formally define
human trafficking or trafficking in persons. Rather, the Victims of Trafficking and Violence
Protection Act of 2000 (TVPA; P.L. 106-386, as amended) defines severe forms of trafficking in
persons to mean:
(A) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion,
or in which the person induced to perform such act has not attained 18 years of age; or
(B) the recruitment, harboring, transportation, provision or obtaining of a person for labor
or services, through the use of force, fraud, or coercion for the purpose of subjection to
involuntary servitude, peonage, debt bondage, or slavery.3
Under the TVPA, force, fraud, or coercion are necessary elements to establish trafficking of an
adult victim, but they are not necessary elements to establish sex trafficking of a victim under age
18. The movement of persons across jurisdictional boundaries is not necessary to establish that
human trafficking has occurred.
While comprehensive data on the prevalence of human trafficking in the United States are not
available, some snapshots of data exist. For instance, the National Human Trafficking Hotline
produces reports that include data on potential trafficking situations.4 In 2020, the hotline

1 Corinne Schwarz, Erik Unruh, and Katie Cronin et al., "Human Trafficking Identification and Service Provision in the
Medical and Social Service Sectors," Health and Human Rights Journal, vol. 18, no. 1 (June 2016), pp. 181-192.
2 U.S. Department of State, 2021 Trafficking in Persons Report: United States, https://www.state.gov/reports/2021-
trafficking-in-persons-report/united-states/. This is based on individuals receiving trafficking victim services provided
by the U.S. Department of Health and Human Services.
3 22 U.S.C. §7102.
4 See National Human Trafficking Hotline, Hotline Statistics, at https://humantraffickinghotline.org/states. The data
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received information on 10,583 potential cases of human trafficking in the United States. Of
these, about 72% were categorized as sex trafficking, about 10% as labor trafficking, about 3% as
both sex and labor trafficking, and about 15% as unspecified. Federal prosecutions generally
follow this pattern, as the United States prosecutes more individuals for sex trafficking than for
labor trafficking offenses.5
Evidence for Human Trafficking Awareness
Training for Health Care Professionals
Researchers have assessed that many human trafficking victims have likely had contact with a
health care provider during the period when they were trafficked. Though estimates vary, some
have projected that more than two-thirds of trafficking victims may have encountered a health
care provider during their victimization. The most common health care setting where victims
present is emergency departments, though victims have also reported being seen at clinics such as
urgent care clinics and health centers.6
When victims come in contact with a health care provider during their victimization, they may be
seen for conditions both related and unrelated to their trafficking. However, certain health
conditions may be more common among trafficked individuals, and teaching health providers to
recognize the possible association between these conditions and trafficking may aid in victim
identification. The Massachusetts Medical Society, in its guidebook for its member physicians,
advised that trafficking victims may present to health providers with a range of physical injuries
such as burns, branding or tattoos, and firearm and knife wounds. They also note that organ
trafficking victims may present in health care settings, and that one of the health conditions found
in trafficking victims is scarring from unattended prior injuries, which may also occur in other
types of trafficking. Further, children and adolescent trafficking victims may be at risk for
physical, cognitive, emotional, and developmental health consequences such as delayed growth,
malnutrition, and long-term health effects of untreated childhood illnesses. The Massachusetts
Medical Society has also advised that trafficking victims may lack basic access to health services
so may present with evidence of neglect, untreated medical and dental conditions, and lack of
standard care such as routine immunizations.7 For example, some researchers have found that
signs of neglect and sexually transmitted infections are common among those who are sex
trafficked.8 In addition, focus groups of trafficking survivors have found long-term behavioral

tracked by the hotline only include those reports of trafficking the hotline receives, and thus represent an unknown
subset of total human trafficking cases in the United States.
5 U.S. Department of State, 2021 Trafficking in Persons Report: United States, https://www.state.gov/reports/2021-
trafficking-in-persons-report/united-states/.
6 See, for example, Laura J. Lederer and Christopher A. Wetzel, "The Health Consequences of Sex Trafficking and
Their Implications for Identifying Victims in Health Care Facilities," Annals of Health Law, vol. 23 (2014), pp. 61-89.
This study included nearly 100 respondents. It is similar in size to a number of other studies in this area (see pp. 63-65).
7 Alpert EJ et al., Human Trafficking Guidebook on Identification, Assessment, and Response in the Health Care
Setting, Massachusetts General Hospital: Human Trafficking Initiative and Massachusetts Medical Society
Commission Violence Intervention and Prevent, Waltham, MA, September 2014.
8 See, for example, Laura J. Lederer and Christopher A. Wetzel, "The Health Consequences of Sex Trafficking and
Their Implications for Identifying Victims in Health Care Facilities," Annals of Health Law, vol. 23 (2014), pp. 61-89;
and Tanise L. Branche, Schyler Edwards, and Richa Pursani, "Human Sex Trafficking," Topics in Obstetrics &
Gynecology, vol. 39, no. 11 (July 31, 2019), pp. 1-6.
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health consequences among this population.9 Though these may be present, they may be more
challenging for health providers to identify.
Health providers may also be able to recognize trafficking victims by asking questions about their
lives or observing contextual factors such as discrepancies in the victim’s history or an
explanation for a medical condition that is inconsistent with the injury that is presented.10 While
some victims have reported that health providers do ask questions, some survivors have also
reported that providers often do not recognize trafficking.11 Some victims have also reported that
while physicians asked about their lives, the providers did not recognize that the victims were
being trafficked and did not intervene.
Altogether, this suggests that health care professionals, like others, may face challenges
recognizing and appropriately responding to trafficking victims for multiple reasons, including
that evidence of trafficking can be readily concealed; it further suggests a potential need for
specified training. Indeed, a number of studies have found that health providers generally lack
training to recognize indicators of human trafficking.12 While some health professional groups
and schools have developed resources to increase health provider awareness, trainings generally
vary with respect to content and scope, and there has been little evaluation of their effectiveness.13
Federal Role in Countering Human Trafficking
For over two decades, Congress has been legislating to counter human trafficking in the United
States. Through the TVPA and its subsequent reauthorizations, Congress has enacted legislation
aimed at preventing human trafficking, strengthening criminal laws to investigate and prosecute
traffickers more effectively, and providing protections and services for survivors. Through the
TVPA, related anti-trafficking legislation, and administrative initiatives, the federal role in
countering trafficking continues to be centered on the core themes of prevention, prosecution, and
protection.14
Prevention. Efforts to prevent human trafficking are broad, from expanding community outreach
and awareness training about vulnerable populations to reducing demand for sex and labor
trafficking. Prevention activities may be thought of in three categories:
 Primary prevention. This includes efforts to prevent exploitation before individuals are
victimized.

9 See, for example, Laura J. Lederer and Christopher A. Wetzel, "The Health Consequences of Sex Trafficking and
Their Implications for Identifying Victims in Health Care Facilities," Annals of Health Law, vol. 23 (2014), pp. 61-89.
10 Alpert EJ et al., Human Trafficking Guidebook on Identification, Assessment, and Response in the Health Care
Setting, Massachusetts General Hospital: Human Trafficking Initiative and Massachusetts Medical Society
Commission Violence Intervention and Prevent, Waltham, MA, September 2014.
11 Laura J. Lederer and Christopher A. Wetzel, "The Health Consequences of Sex Trafficking and Their Implications
for Identifying Victims in Health Care Facilities," Annals of Health Law, vol. 23 (2014), pp. 61-89.
12 See discussion in Lisa P. Hachey and Julia C. Phillippi, "Identification and Management of Human Trafficking
Victims in the Emergency Department," Advanced Emergency Nursing Journal, vol. 39, no. 1 (2017), pp. 31-51.
13 Roy Ahn et al., "Human Trafficking: Review of Educational Resources for Health Professionals," American Journal
of Preventive Medicine, vol. 44, no. 3 (March 2013), pp. 283-289.
14 White House, The National Action Plan to Combat Human Trafficking, December 2021.
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 Secondary prevention. This includes efforts to identify trafficking victims and provide
an immediate response, including providing emergency and medical care to respond to
short-term consequences.
 Tertiary prevention. This includes longer-term efforts including providing rehabilitative
services that aim to prevent further victimization. 15
In other words, in addition to federal efforts to prevent exploitation before individuals are
victimized, additional efforts are aimed at identifying human trafficking victims in order to rescue
them and protect them from further exploitation; for instance, a number of federal agencies
administer public awareness campaigns to help recognize the signs of trafficking, identify
potential victims, and respond appropriately.16 These efforts directly intersect with activities to
provide services and ongoing protection to support trafficking victims.
Prosecution. Most federal human trafficking cases are investigated by the Federal Bureau of
Investigation (FBI) and U.S. Immigration and Customs Enforcement, Homeland Security
Investigations (ICE HSI), who coordinate with other agencies as appropriate. The U.S.
Department of Justice (DOJ) prosecutes these cases.17
Protection. Several departments—primarily DOJ, the U.S. Department of Health and Human
Services (HHS), and the U.S. Department of Labor (DOL)—have programs, or administer grants
that are designed to support and provide ongoing protection to trafficking victims. Such
assistance may include temporary housing, independent living skills, cultural orientation,
transportation, job training, mental health counseling, and legal assistance. Some may view these
protection activities as part of tertiary prevention.
The Role of Awareness Training
One key challenge in taking action to counter human trafficking is accurately identifying
potential victims and survivors.18 Awareness training is a central component of efforts to educate
the public and certain professions about the signs of human trafficking and give them the tools to
identify and protect victims. While there have been some federal efforts to enhance awareness
training, advocates, subject matter experts, and policymakers have questioned whether more can
be done in this space. Among the priority action items outlined in The National Action Plan to
Combat Human Trafficking released in December 2021, many contain elements to enhance
community awareness and professional training to prevent trafficking as well as identify and
protect victims.

15 For more information about primary, secondary, and tertiary prevention, see U.S. Department of Health and Human
Services, Information Memorandum: Definitions and Principles to Inform Human Trafficking Prevention, April 24,
2019.
16 The U.S. Department of Homeland Security’s (DHS’s) Blue Campaign is one such example. More information on
the Blue Campaign is available at https://www.dhs.gov/blue-campaign.
17 More information on DOJ’s efforts to counter human trafficking is available at
https://www.justice.gov/humantrafficking/department-justice-components. More information on the FBI’s role in
investigating human trafficking is available at https://www.fbi.gov/investigate/violent-crime/human-trafficking. For
information on ICE HSI’s role in investigating human trafficking, see https://www.ice.gov/features/human-trafficking.
18 White House, The National Action Plan to Combat Human Trafficking, December 2021.
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Federal Human Trafficking Awareness Efforts
Various federal agencies have developed efforts to enhance awareness of human trafficking,
including the following:19
 DOJ, through the Office for Victims of Crime (OVC) Training and Technical
Assistance Center, provides practitioner-driven, evidence-based training and
technical assistance to service providers, stakeholders, human trafficking task
forces, victims, and communities—including schools, law enforcement,
LGBTQI+ programs, foster care programs, homeless shelters, and medical
providers.20 DOJ also runs a Faces of Human Trafficking campaign, which
includes a video series and materials such as fact sheets and posters to raise
human trafficking awareness for the community, service providers, law
enforcement, and prosecutors.21
 DHS runs the Blue Campaign, a national public awareness campaign to inform
the public, law enforcement, and industry partners on the indicators of human
trafficking and appropriate responses to potential cases.22 Some trainings are
tailored to individuals in certain industry sectors, such as first responders, youth
care professionals, or hospitality workers. Some elements of the Blue Campaign
involve partnerships with other federal agencies; for instance, through the Blue
Lightning Initiative, the Department of Transportation (DOT) partners with U.S.
Customs and Border Protection (CBP) to train airline personnel to identify
potential instances of human trafficking.23
 DOT runs the Transportation Leaders Against Human Trafficking initiative.24
This initiative engages transportation and travel industry stakeholders to counter
human trafficking through five key areas: industry leadership, industry education
and training, policy development, information sharing and analysis, and public
awareness and outreach.
 HHS, through the Office of Trafficking in Persons, has a National Human
Trafficking Training and Technical Assistance Center (NHTTAC), which
provides training and technical assistance to enhance the public health response
to human trafficking as well as professional development for survivors.25
Specifically, the NHTTAC administers the Stop, Observe, Ask, and Respond
(SOAR) to Health and Wellness Training Program, which trains professionals

19 While this section does not provide a comprehensive listing of federal human trafficking awareness efforts, it is
intended to be illustrative of significant efforts. More information about human trafficking awareness training efforts
across the federal government is available at https://www.state.gov/humantrafficking-public-awareness-training/.
20 For more information about this training and technical assistance, see https://ovc.ojp.gov/program/human-
trafficking/training-and-technical-assistance. See also, White House, The National Action Plan to Combat Human
Trafficking, December 2021.
21 For more information about this campaign, see https://ovc.ojp.gov/program/human-trafficking/faces-of-human-
trafficking.
22 For more information about the Blue Campaign, see https://www.dhs.gov/blue-campaign.
23 More information on the Blue Lightning Initiative is available at https://www.dhs.gov/blue-campaign/blue-lightning-
initiative.
24 More information on this initiative is available at https://www.transportation.gov/TLAHT.
25 More information on the NHTTAC is available at https://nhttac.acf.hhs.gov/home.
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and organizations to address human trafficking in health care, behavioral health,
public health, and social services settings.26
Many of the federal human trafficking awareness programs are targeted toward a broad audience
that cuts across various demographics and multiple industry sectors. While some, such as DOJ’s
awareness training efforts, may reach medical professionals, one federal awareness training
program—the SOAR to Health and Wellness Training Program specifically, and exclusively—
targets its trainings to the health care industry.
SOAR to Health and Wellness Training Program
The SOAR to Health and Wellness Training Program (hereinafter, SOAR Program) was
developed following a 2008 HHS National Symposium on the Health Needs of Human
Trafficking Victims. One outcome of the symposium was a push for increased human trafficking
training for health care professionals in diverse disciplines.27 In response, HHS piloted the SOAR
Program in 2014,28 and Congress authorized the program through the SOAR to Health and
Wellness Act of 2018 (P.L. 115-398).29 The SOAR Program provides survivor and clinician-
informed trainings to teach health care professionals to (1) understand the types of and common
risk factors for trafficking, (2) recognize individual and environmental indicators of trafficking,
(3) screen individuals and identify potential victims using a trauma-informed and person-centered
approach, and (4) coordinate with relevant stakeholders to deliver appropriate care.30 These
trainings are provided to individuals, organizations, and community groups, and there are both
online (live virtual as well as on-demand) and in-person options available. In FY2021, HHS
funded a five-year pilot grant program to allow for local adaptation of SOAR Program-related
technical assistance training.31
The on-demand training, SOAR Online, is a series of training modules, jointly provided by the
Postgraduate Institute for Medicine, that qualify for continuing education and continuing medical
education credits. Currently, there are modules tailored for behavioral health, public health, health
care, and social service professionals, as well as for professionals serving specific communities
(such as professionals serving indigenous communities) or in particular settings (such as school-
based professionals).32 Most of the professionals receiving SOAR trainings—nearly 96%—have
been reached through the SOAR Online on-demand training modules.33
Policymakers may look to how HHS evaluates the effectiveness of the SOAR Program. While
there are output data on the number of professionals who have received SOAR training through
virtual and in-person channels, data on the program outcomes, if gathered, are not publicly

26 For more information on the SOAR Program, see https://nhttac.acf.hhs.gov/soar.
27 HHS, “Testimony from Katherine Chon on Trafficking Awareness Training for Health Care Act of 2014,” October 8,
2014. See also HHS, National Symposium On the Health Needs of Human Trafficking Victims: Post-Symposium Brief,
July 14, 2009.
28 HHS, “Statement by Katherine Chon, Director, Office on Trafficking in Persons, Administration for Children and
Families, U.S. Department of Health and Human Services, Before the Tom Lantos Human Rights Commission, United
States House of Representatives,” January 15, 2020.
29 42 U.S.C. §300d–54.
30 HHS, SOAR Program, https://nhttac.acf.hhs.gov/soar.
31 HHS, Administration for Children and Families, Justifications of Estimates for Appropriations Committees, FY2023.
32 For more information about the SOAR Online modules, see https://nhttac.acf.hhs.gov/soar/soar-for-individuals/soar-
online.
33 HHS, Administration for Children and Families, Justifications of Estimates for Appropriations Committees, FY2022.
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available. For instance, policymakers may look to how the SOAR trainings may have contributed
to professionals’ identifying suspected instances of human trafficking and taking actions to
coordinate with stakeholders to ensure that victims receive appropriate care. As mentioned, data
on human trafficking, in general, are lacking. And, more nuanced data on how instances of human
trafficking may have been uncovered—and the trainings that may have contributed to this—do
not appear to be collected or studied.
The Role of Health Professionals in Identifying
Human Trafficking
As noted, research has indicated that many human trafficking victims may come into contact with
a health care provider during their ongoing victimization. Much of the research on this topic has
focused on sex trafficking victims and using reproductive health conditions such as evidence of
rape or sexually transmitted infections to help identify trafficking victims.34 However, providers
may also be trained to recognize signs of neglect, injuries, and behavioral signs, such as victims
with gaps in their medical history as indicators of various forms of trafficking.35
While some types of health care providers may be more likely to encounter trafficked individuals,
the core competencies of human trafficking awareness campaigns designed for health care
professionals, discussed below, focus on the health care system as a whole. Trafficking victims
may be identified in different types of health care settings by many different types of health care
providers or others who work in health care settings. Core competencies developed for health
care settings address providing appropriate, trauma-informed care to trafficking survivors,
regardless of where in the health care system they may be identified.36
Core Competencies
As part of efforts to standardize training, the federal government, through HHS partnerships with
health providers, has developed a set of core competencies for recognizing and responding to
human trafficking in health care provider awareness campaign. These core competencies are
targeted toward clinicians, health education institutions, and health systems.37 The overarching

34 See, for example, Laura J. Lederer and Christopher A. Wetzel, "The Health Consequences of Sex Trafficking and
Their Implications for Identifying Victims in Health Care Facilities," Annals of Health Law, vol. 23 (2014), pp. 61-89;
and Tanise L. Branche, Schyler Edwards, and Richa Pursani, "Human Sex Trafficking," Topics in Obstetrics &
Gynecology, vol. 39, no. 11 (July 31, 2019), pp. 1-6.
35 Alpert EJ et al., Human Trafficking Guidebook on Identification, Assessment, and Response in the Health Care
Setting, Massachusetts General Hospital: Human Trafficking Initiative and Massachusetts Medical Society
Commission Violence Intervention and Prevent, Waltham, MA, September 2014.
36 “Trauma-informed care acknowledges the need to understand a patient’s life experience in order to delivery effective
care, and has the potential to improve patient engagement, treatment, adherence, health outcomes, and provider and
staff wellness.” It includes a set of competencies and clinical guidelines that may be tailored to the type of treatment
that the patient requires. See Christopher Menschner and Alexandra Maul, Key Ingredients for Successful Trauma-
Informed Care Implementation, Center for Health Care Strategies, Issue Brief, April 2016,
https://www.samhsa.gov/sites/default/files/programs_campaigns/childrens_mental_health/atc-whitepaper-040616.pdf,
p. 1.
37 HHS, Administration for Children and Families, National Human Trafficking Training and Technical Assistance
Center, Core Competencies for Human Trafficking Response in Health Care and Behavioral Health Systems, February
2021, https://nhttac.acf.hhs.gov/sites/default/files/2021-02/Core%20Competencies%20Report%20%282%29.pdf.
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competency is the ability to use a trauma- and survivor-informed, culturally responsive approach
to care. Six additional core competencies involve
 understanding the nature and epidemiology of trafficking, including social
determinants of health;
 evaluating and identifying the factors that put individuals at risk of being
trafficked;
 evaluating the needs of individuals who have experienced, or are at risk of
experiencing, trafficking;
 providing patient-centered care;
 using legal and ethical standards; and
 integrating trafficking prevention strategies into clinical practice and systems of
care. 38
When to Conduct Awareness Training for Health
Care Professionals
Health provider training to recognize human trafficking could occur at multiple points in time:
 during formal education (e.g., medical or nursing school),
 during clinical training (e.g., as part of medical residency training or nurse
clinical training), and
 during active practice (e.g., as part of the requirements to obtain or maintain a
license).
Federal efforts to mandate training may be limited at each of these points. Generally, states
regulate the practice of health care through specific practice acts (e.g., states’ Nurse Practice
Acts). As part of this, states are responsible for licensing health care providers. The licensing
process generally includes actions such as verifying an applicant’s education, whether the
applicant has passed the relevant required examinations,39 and whether the applicant has had
sufficient relevant clinical training. Though states generally follow similar procedures for
licensure, they may also have state-specific licensure requirements. Such requirements may be
related to initial licensure (e.g., the number of clinical hours required to obtain licensure) or to
maintaining licensure (e.g., the amount and type of clinical education required). These
requirements can vary among states.
Training During Formal Health Professional Education
The federal government’s role in regulating the content of educational curricula is limited. In
general, the U.S. Department of Education (ED) requires that schools meet certain standards to be
eligible to participate in student loan programs under Title IV of the Higher Education Act (P.L.
89-329). These requirements include that a school be accredited by an agency that ED

38 Ibid.
39 Generally, completing a health professional education program is required to take the relevant licensing examination.
In medicine, licensing examinations include multiple steps, with initial steps taking place during medical school.
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recognizes.40 While accreditation is voluntary at the school level, individuals must have attended
an accredited school to be eligible to obtain a state license; in practice, this means licensed health
care providers will have obtained a degree from an accredited school. For example, physicians
must have attended a school accredited by the Liaison Committee on Medical Education to be
licensed as a medical doctor (MD) or must have attended an osteopathic medical college
accredited by the Commission on Osteopathic College Accreditation to be licensed as a doctor of
osteopathic medicine (DO).41 The accreditors set broad standards for curricula that include
content to demonstrate mastery of the specific health profession.
The federal role in health professional school curricula is generally to provide competitive grants
to schools to develop curricula in certain topic areas. In this scenario, schools are not required to
implement specific curricula, but they receive funding as an incentive to do so. Within HHS, the
Health Resources and Services Administration (HRSA) awards grants to health professional
schools to develop and implement curricula in a number of topic areas. Examples include grant
programs to support developing coursework in integrating behavioral health training into primary
care and primary care into dental training.42
Training During Supervised Clinical Training
After completing formal education, members of a number of health professions are required to
obtain structured, supervised clinical training. The number of hours (or years) varies by health
profession and by specialty. The longest duration of training is for medical school graduates, and
is referred to as medical residency or graduate medical education (GME). This training is for a
minimum of three years and some specialties require additional years (e.g., plastic surgery
residency lasts six years). Physicians must complete an accredited residency program to be
eligible to be licensed by a state to practice independently. As with the content of educational
programs, the federal government does not regulate the content of clinical training programs.
Similar to educational programs, clinical training programs must be accredited to be eligible for
federal support. GME is the largest federal investment in health professional workforce training,
with the majority of funding being used for Medicare graduate medical education payments to
hospitals; these payments are provided to hospitals via formula and hospitals do not need to
include specific training activities to receive them. 43 As with school-level training, the federal
government has grant programs related to clinical training. In general, federal grant programs
have focused on expanding clinical training opportunities rather than modifying the content of
such training. Examples of grants to expand training include HRSA’s funding of additional GME
positions in addiction medicine.44 Though the federal role in developing clinical curricula is

40 For more information, see CRS Report R43826, An Overview of Accreditation of Higher Education in the United
States.
41 American Association of Medical Colleges, "LCME Accreditation," https://www.aamc.org/services/first-for-
financial-aid-officers/lcme-accreditation; and American Osteopathic Association, “Commission on Osteopathic College
Accreditation,” https://osteopathic.org/accreditation/.
42 HHS, HRSA, Justification of Estimates for Congressional Committees, FY2023, pp. 114, 122-123,
https://www.hrsa.gov/sites/default/files/hrsa/about/budget/budget-justification-fy2023.pdf.
43 For more information, see CRS Report R44376, Federal Support for Graduate Medical Education: An Overview;
and CRS In Focus IF10960, Medicare Graduate Medical Education Payments: An Overview.
44 HHS, HRSA, Justification of Estimates for Congressional Committees, FY2023, p. 149,
https://www.hrsa.gov/sites/default/files/hrsa/about/budget/budget-justification-fy2023.pdf.
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limited, HRSA has funded grants to enhance training in providing care to rural and underserved
populations in primary care medical residency programs.45
Training During Clinical Practice
After a health provider is licensed to practice independently, states generally require continuing
education to maintain licensure (the number of hours required varies among states). States may
also require that health providers complete training in particular topics. For example, Texas
requires its physicians to complete 2 of the 48 hours of continuing education required every two
years to be in medical ethics—which includes among the potential ethics topics training in human
trafficking prevention.46
Providers must take a minimum number of hours of continuing education training, but they may
generally choose topic areas. For instance, providers may choose to take training in human
trafficking awareness to fulfill some of the required continuing education credits. The federal role
has largely been to fund the development and dissemination of continuing education training. The
previously mentioned SOAR Program training is an example; this training may be used to meet
continuing education requirements for physicians, pharmacists, pharmacy technicians,
psychologists, nurses, dentists, and social workers, among others.47 Members in multiple
Congresses have shown interest in supporting continuing education for health providers in human
trafficking awareness. For instance, legislation introduced in the 114th Congress would have
required HHS’s Agency for Healthcare Research and Quality to award grants to health
professional schools to, among other things, develop curricula or materials for recognizing and
responding to human trafficking.48
Additionally, a number of health professional associations encourage their providers to become
informed and trained in recognizing and treating victims of human trafficking. For example, the
American College of Obstetricians and Gynecologists, the organization that represents
obstetricians and gynecology physicians, has developed recommendations to improve awareness
among its membership to prepare its providers to take recognize and take action if they encounter
trafficking victims while providing care.49 Similarly, the Emergency Nurses Association, which
represents emergency department nurses, has a position statement on the role of its providers in
recognizing and responding to human trafficking and has published research on the need for
emergency nurses to receive training on trafficking identification.50 Beyond the work of

45 Ibid, p. 117.
46 Federation of State Medical Boards, “Continuing Medical Education: Board-by-Board Overview,”
https://www.fsmb.org/siteassets/advocacy/key-issues/continuing-medical-education-by-state.pdf.
47 For more information on the SOAR Program and its eligibility for continuing education credits, see
https://nhttac.acf.hhs.gov/soar/soar-for-individuals/soar-online. As other examples, the federal government provides
support to develop continuing education in Alzheimer’s disease and dementia and supports educational institutions to
disseminate that training. See HHS, Health Resources and Services Administration, Justification of Estimates for
Congressional Committees, FY2023” https://www.hrsa.gov/sites/default/files/hrsa/about/budget/budget-justification-
fy2023.pdf, p. 139.
48 See the Trafficking Awareness Training for Health Care Act of 2015 (H.R. 398/S. 205, 114th Congress). This
legislation was not enacted.
49 American College of Obstetricians and Gynecologists, “Committee Opinion: Human Trafficking” Number 787,
September 2019, https://www.acog.org/clinical/clinical-guidance/committee-opinion/articles/2019/09/human-
trafficking.
50 Emergency Nurses Association, “Human Trafficking,” https://www.ena.org/quality-and-safety/human-trafficking;
and Amber Egyud et al., "Implementation of Human Trafficking Education and Treatment Algorithm in the Emergency
Department," Journal of Emergency Nursing, vol. 43, no. 6 (April 2017), pp. 526-531.
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individual health professional groups, HEAL (Health, Education, Advocacy, Linkage) is a
multidisciplinary group of health professionals that compiles resources and research for health
providers to address trafficking.51
Concluding Observations
As policymakers continue to explore the federal role in human trafficking training for health care
professionals, they may consider a variety of policy options, which may include examining the
efficacy of existing federal efforts, enhancing or modifying existing programs, or establishing
new programs.
While there are a number of federal programs that may involve training for health care
professionals, one—the SOAR Program—provides tailored training in human trafficking
awareness. In its current form, the SOAR Program provides free training to health professionals
through live virtual and in-person trainings and through its SOAR Online on-demand training
modules. HHS is currently looking to expand the SOAR program by offering a pilot
demonstration program to adapt the trainings to the local level. Policymakers may continue to
evaluate the effectiveness of the SOAR Program through direct oversight or by requiring
evaluations from watchdogs such as the HHS Inspector General or Government Accountability
Office. If policymakers were interested in modifying the program, Congress could make changes
to the authorizing statute or direct activities through the appropriations process.
Mandating health provider training is limited at the federal level because states license health
professionals. One option the federal government could consider is mandating such training for
the health professionals it employs directly, for example at facilities operated by the U.S.
Department of Defense, the U.S. Department of Veterans Affairs, and the Indian Health Service
within HHS.52 As mentioned, the federal government provides grants to health professional
schools to support education and training in certain topic areas such as primary care. The federal
government could also provide grants to health professional schools or health providers to
implement the SOAR Program or a similar training program, or could give preference when
awarding certain grants to health professional schools or health providers that have implemented
trafficking awareness training programs. Similarly, some states require or recommend trafficking
awareness training as part of continuing education requirements to remain licensed, so another
option for the federal government would be to provide granting preference to states that have
such requirements in place.

Author Information

Kristin Finklea
Elayne J. Heisler
Specialist in Domestic Security
Specialist in Health Services

51 HEAL Trafficking, “Health, Education, Advocacy, Linkage: Because Human Trafficking is a Health Issue: About
HEAL,” https://healtrafficking.org/about-heal/.
52 The Indian Health Service may be of interest as some have found high rates of trafficking among the American
Indian and Alaska Native population. See National Congress of American Indians, “Tribal Insight Brief: Human & Sex
Trafficking: Trends and Responses Across Indian Country,” Spring 2016, https://www.ncai.org/policy-research-
center/research-data/prc-publications/TraffickingBrief.pdf.
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Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in
its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or
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