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Comparison of State versus Church Audits
by Carolyn Disco

Survivor Support Chairman

New Hampshire Voice of the Faithful

April 1, 2008


The bishops claim one thing,

the state finds something very different. . .


Child protection programs have been developed and implemented in Catholic dioceses throughout the United States since the sexual abuse scandal broke in 2002. The United States Conference of Catholic Bishops (USCCB) has done what they call audits, not in the financial sense, but annual reviews of their implementation of the Charter for the Protection of Children and Young People, 1. known popularly as the Dallas Charter.


We in New Hampshire have an unparalleled opportunity to evaluate USCCB audits because Bishop John McCormack also agreed to five annual audits by the New Hampshire Attorney General. That was part of a plea bargain agreement in 2002 2. to avoid criminal prosecution of the Diocese for child endangerment.


So, we can read and compare for ourselves what church-sponsored audits concluded, versus what independent law enforcement audits found.


There are striking differences at the outset:

1)      USCCB auditors have no right of access to personnel files or other confidential materials.3.

2)      USCCB audits/surveys do not count allegations against the following abusers:

a.       religious order brothers (Benedictine, Franciscan, etc.) since technically they are not

considered clergy 4. 

b.      victims of seminarians who did not go on to ordination 5.

c.       mentally handicapped victims whose abuse did not begin before their 18th birthdays 6.


A Merrimack man abused by two seminarians who left is not counted as a victim under this standard.


Compare 2005 results


Because the Diocese’s court challenge delayed the beginning of state audits for two years, 2005 is the first year when both church and state audits were completed. It is important, however, to decipher when site visits were conducted to compare results more accurately. So, who said what, in sequence: August 2004 USCCB, June 2005 AG, November 2005 USCCB?


US Conference of Catholic Bishops 2004:

l The diocese is found to be compliant with all Articles of the Charter for the Protection on (sic)

Children and Young People.” 7.



How can the bishops find full compliance, when ten months later, the attorney general finds this:


Attorney General 2005:

 l “The Diocese has exhibited a general level of ineffectiveness in enforcing compliance with the

Agreement and its own policies. This ineffectiveness has resulted in: repeated missed deadlines for implementation of the policies, incomplete training, incomplete written acknowledgements, lack of background checks, and unfilled positions…The level of compliance with the policies and agreement at the local level is inconsistent at best. No site was 100% compliant…in one parish


only 16% of employees or volunteers who worked with children had a sex offender registry check completed…Even at the diocesan level, compliance was not 100%. Eight and one-half percent of priests had not signed the acknowledgements – an express requirement that should have been completed more than 2 years ago.” 8. Only one paragraph in a five-page letter mentioned some accomplishments.


US Conference of Catholic Bishops 2005: (site visits five months after the state auditors’ visits)

l Based on the information furnished to The Gavin Group, Inc. on January 6, 2006, the Diocese of

Manchester is now in compliance with Article 13 (screening) of the Charter for the Protection of Children and Young People. The Diocese remains non-compliant with Article 12 (training) based on the fact that the majority of children are still to be trained. Please advise me when the training of the children is completed.” 9.


A diocese could be in full compliance one year (2004), and not the next (2005), because the goals were movable. For example, as long as a training program had been selected before, a diocese was compliant, even if it was not implemented. 10.


In addition to audits by the USCCB, church-sponsored audits were done on the diocesan level by the Diocesan Review Board. Their results could be expected to, and did correlate with the complimentary findings of their national counterparts.


Diocesan Review Board 2005:  (audit visits the same month as the state auditors) 

l “…most parishes and Catholic schools were in substantial compliance with the (screening

of church personnel) requirements… the Diocesan Review Board concludes that substantial compliance (in training of personnel) was found throughout the Diocese, although compliance with the administrator's record keeping compliance varied.” 11.  


The state audit criticized the Diocesan Review Board for prepping personnel in advance of visits by DRB auditors: “Such reviews should not be predicated by advanced notice to the selected parishes as this could potentially alter the results of the review.” 12.  


So, whose audits provide the most trustworthy, believable assessment? The attorney general’s detailed analysis, or the bishops’ generalized conclusions on both the national and local levels?


In addition, the AG audit alone revealed the case of Priest A,13. removed for inappropriate conduct, sent for treatment, returned to ministry, again removed, with revelations of his accessing up to 10,000 pages of pornography, including possibly child pornography. No report was made to the AG’s office for four months, and then done only as a courtesy, according to the Diocese, apparently because no abuse of a minor was alleged.


The AG asked the Diocese two years in a row 14. 15. to develop a policy for handling inappropriate conduct as a possible precursor warning sign of potential sexual misconduct. The first request was apparently ignored; the second request may or may not be addressed in the third state audit released today, covering 2007.


Compare 2006 results


Again, who said what?


Attorney General 2006:

l As an initial matter, I commend the Diocese on making significant advances toward implementing

an effective program for the protection of children. The 2005 Audit identified substantial deficiencies in the Diocese’s compliance program. Following the release of the 2005 Audit, the Diocese provided the State with a detailed action plan explaining the steps that the Diocese intended



to take to correct these deficits. Based on the 2006 Audit, it appears that the Diocese has fulfilled those benchmarks…


“Despite these laudable actions, the 2006 Audit has identified some critical gaps that need to be corrected…Tone At The Top. One of the most troubling findings…is the lack of “acceptance or commitment to cooperation with a process” exhibited by senior members of the Diocese…particularly Fr. Edward Arsenault…There appeared to be a reticence to answer some questions, as well as either a misunderstanding or disregard for terms describing commonly accepted practices such as ‘self-reporting’ and ‘testing for verification,’ as well as the suggestion that there was no risk of a priest not being removed timely.” 16. Transmittal letter p.1-2


It does not appear the Diocese independently verified documentation at the parishes, schools or camps…” 16. Transmittal letter p. 3 of 4


“…consideration should be given to making this body (the Diocesan Review Board) more independent, more empowered and in some way, at least partly accountable for the Program’s effectiveness…The responsibilities of the DRB previously included a regular compliance audit…and a report to the Christian Faithful (about it)…the Policy no longer requires the DRB report to the Christian Faithful…” 16. Report p. 18 of 134, #11 and #12


“The review of diocesan policies dealing with sexual abuse…involving minors has been changed… from being required every two years to…only every four years.” 16. Report p. 15 of 134, #6


US Conference of Catholic Bishops 2006:   

l “Based on the analysis of the results of the 2006 Focused Audit (of only Article 12, training) of the

Diocese of Manchester, you have been found to be in compliance with the Charter for the Protection of Children and Young People.   

The conclusions reached as to the compliance of your Diocese with the Charter for the Protection of Children and Young People are based on the completeness and accuracy of the information furnished by the Diocese to The Gavin Group, Inc. during the course of this audit.” 17.


Diocesan Review Board 2006:  

l ”In as much as the Diocese of Manchester was audited both by the New Hampshire Attorney

General’s Office designee (KPMG, LLP) and the United States Conference of Catholic Bishops (USCCB) in 2006, the Diocesan Review Board opted to forego an additional agreed-upon procedures audit by Howe, Riley and Howe (HRH). Notably, the USCCB recently notified the Diocese that it was found to be in compliance with the Charter for the Protection of Children and Young People for 2006.”


“The Board found that significant progress has been made in the screening and training of church personnel who regularly work with minors…Substantial progress has been made… with respect to background screening of Church personnel…site reviews, which have already begun, involve a thorough examination of records and files and meetings with key staff.


“The first site visits will be paid to those parishes or schools that faced some challenges in complying with the screening and training requirements of the Policy.

Based on its work and successes in 2006, it is obvious that the Office for Ministerial Conduct has taken responsibility for ensuring compliance with the terms of the Policy.”


Are all these audits discussing the same Manchester diocese? Attorney General Kelly Ayotte accused Arsenault of playing “word games” and a lack of candor. Arsenault walked out of a meeting with state



auditors 15 minutes after it started. He engaged in a charade in which he forced the lead auditor to repeat a question from a second auditor that everyone had just heard clearly. Only the lead auditor was allowed to speak to Arsenault directly. Read more. 18.


2007 results


US Conference of Catholic Bishops 2007:   

l Based on the analysis of the results of the 2007 Full Audit of the Diocese of Manchester, you have

been found to be in compliance with the Charter for the Protection of Children and Young People.


The conclusions reached as to the compliance of your Diocese with the Charter for the Protection of Children and Young People are based on the completeness and accuracy of the information furnished by the Diocese to The Gavin Group, Inc. during the course of this audit. 19.


The Diocese is fully compliant with the Dallas Charter. This is the first year, however, that dioceses did not have a grace period in which to reach compliance.20. 


It is worth noting that in the first four bishops’ annual audits from 2003 through 2006, dioceses were given two tries at the apple. An initial audit in late summer or early fall would reveal certain deficiencies, which then led to a list of required actions. If the required actions were completed by the end of the year, then the diocese would be in full compliance. Nationally, about 74% of dioceses would be in compliance in the first round, but by the end of the year usually over 95% or more would make the second round.21. It was the second round results that were trumpeted in full court press each year. There is no such leeway in the AG audits; the first grade is the actual result.


Attorney General 2007:

l What these results are will be released today in the third of four annual state audits.


We hope for good news, but are chastened by the record to date when it comes to trusting the Diocese to act forthrightly.


The last state audit will be done this year, after which there will be no way to compare church audits with truly independent evaluations.



References and links

1.  Dallas Charter http://www.usccb.org/ocyp/charter.shtml revised 2005

2.  Agreement  http://www.bishop-accountability.org/downloads/NH_Agreement_12_10_02.pdf

3.  No access to personnel files http://www.usccb.org/ocyp/annualreport.pdf p. 5 (15 of 72) hard copy p. 6, para 2 under “Completeness/Accuracy”

4.  Religious brothers excluded http://www.usccb.org/ocyp/annualreport.pdf p. 60 (70 of 72) Appendix C, 2nd paragraph under “Allegations” and p. 61 (71 of 72) top of page

5.  Seminarians excluded http://www.bishop-accountability.org/resources/resource-files/churchdocs/FinalSurvey.pdf p.9 of 33, last question, bottom of page

6.  Mentally handicapped http://www.bishop-accountability.org/resources/resource-files/churchdocs/FinalSurvey.pdf p.12 of 33, 2nd para under Victim Survey

7.  USCCB 2004 audit results for Manchester – http://www.usccb.org/ocyp/dioceses04/manchesternh.shtml scroll to compliance section

8.  AG 2005             – transmittal letter http://doj.nh.gov/publications/nreleases/pdf/Letter.pdf p. 2, 2nd and last para; p. 3, 1st and 2nd para.

                   – report http://doj.nh.gov/publications/nreleases/033006diocese_report.html entire report, but esp. Executive Summary at p. 5 of 39, beginning at para 6, through end of p. 6 at http://doj.nh.gov/publications/nreleases/pdf/NH_AG_Final_Report.pdf

9.  USCCB 2005 audit results for Manchester (one paragraph letter from Gavin Group) removed from diocesan website – copy in personal files; only media release available http://www.catholicnh.org/child-safety/reports-and-updates/media-release---2005-gavin-group-audit-033006/ . Release erroneously states that Gavin letters for 11/25/05 and 1/6/06 are posted. I wrote the webmaster on 12-21-07 asking they be posted; no reply to date.

10.  Compliance terms http://www.usccb.org/ocyp/dioceses04/2004annualreport.pdf top of p.22 of 62

11. Diocesan Review Board 2005 http://www.catholicnh.com/media/files/child-safety/2005%20Diocesan%20Review%20Board%20Audit%20Report%20-%2001.12.06.pdf  p. 3 of 5, 2nd and last paragraphs

12. AG 2005            – http://doj.nh.gov/publications/nreleases/pdf/NH_AG_Final_Report.pdf p. 38-39 of 39

13.  Priest A – AG 2005 audit  http://doj.nh.gov/publications/nreleases/pdf/Exhibit_G_Priest_A_addendum.pdf

14.  AG inappr. conduct 2005 http://doj.nh.gov/publications/nreleases/pdf/NH_AG_Final_Report.pdf p.20 of 39, 2nd para #5

15.  AG inappr. conduct 2006 http://doj.nh.gov/publications/nreleases/pdf/050407KPMG_Diocese_report.pdf  p.18 of 134, 6th para #5b, and p. 25 of 134, 7th para # e.2

16.  AG 2006           – transmittal letter http://doj.nh.gov/publications/diocese_Bishop_Letter_2007.pdf  p. 1-2

                                – report http://doj.nh.gov/publications/nreleases/pdf/050407KPMG_Diocese_report.pdf  entire report, but esp. Executive Summary p. 6-7 of 134

17.  USCCB 2006 audit results for Manchester – http://www.catholicnh.org/media/files/child-safety/2006%20USCCB%20Audit.pdf one page with two sentences

18.  Arsenault          – “Diocese’s new web site hides some uncomfortable truths” 10-22-07


19.  USCCB 2007 audit results for Manchester http://www.catholicnh.org/media/files/child-safety/2007%20USCCB%20Audit.pdf one page with two sentences

20.  Grace period USCCB 2007 audit results – http://www.usccb.org/ocyp/annualreport.pdf p. 3 (13 of 72) left column, last bullet

21.  Required actions 2004 example http://www.usccb.org/ocyp/dioceses04/2004annualreport.pdf p.21 of 62 last two para, p.22 first para


(Every effort is made to find current links to footnotes, particularly on the diocesan website. It sometimes posts, moves, removes and then reposts documents, so it can be difficult periodically to locate them.)



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