Wisconsin Department of Children and Families - Division of Early Care and Education
Bureau of Early Care Regulation
Child Care Licensing Procedure Manual
Documenting the complaint investigation findings on the Child Care Complaint/Incident Findings form (CFS-321-B) is an important final step in the complaint investigation process. This form is available on the BECR Intranet. To complete this form, the licensing specialist must prepare a complaint investigation narrative report that documents what was alleged, methods used to investigate the allegation(s), what was found, and what will be done in response to the findings.
The following report-writing principles should be followed in preparing a thorough and clearly written complaint investigation report:
The report should be well organized, concise and written in plain English. The report should be something that any reader – a licensee, a family member, a board member, an attorney – could read and easily understand. Since the reader may be completely unfamiliar with licensing administrative rules, avoid agency jargon and acronyms. The report should be written in chronological order. Use first person, past tense and active voice. For example, it is clearer to state “I observed…” rather than “the licensing specialist observed”. Eliminate unclear and unnecessary words.
The report should be objective, factual, descriptive and verifiable. It should not contain derogatory comments, subjective observations such as “I feel” and “I sense”, speculations, second hand information that is not verifiable, guesses at the licensee’s motivations, or the licensing specialist’s personal biases and feelings about the situation or the behavior of the persons involved in the situation. Confine the report to factual information that is information that is supported by one of the five senses, and avoid opinion statements.
The report should be sufficiently but not overly detailed. It should provide enough detail to support the findings and conclusions but need not detail everything that happened during the course of the investigation. If information is not relevant, don’t put it in.
The report should be clear in its conclusions so that every reader gets the same facts and knows precisely and unambiguously what the licensing specialist has concluded concerning the allegations, which rules were violated and what subsequent actions will be taken. The report must address who, what, when, where, and how do you know. If the reader can ask a relevant question after reading the report, the report isn’t complete.
Once the field notes have been used to write the complaint investigation findings report, it is not necessary to retain the actual field notes. If the licensing specialist had an interviewee sign notes taken during an interview to document accuracy, these should be retained for documentation should the case go to fair hearing. Field notes and everything in writing that is retained is discoverable should the case go to hearing.
The summary of the investigation and respective findings should be reported on the Child Care Complaint/Incident Findings Form, CFS-321-B, using the following standard headers:
Alleged Statutory and Rule Violations: In addition to the specific complaint allegations, this section should indicate the date, form and source of the complaint (except when anonymous). The name and title of the person who received the complaint is identified. Relate the allegations to specific administrative rule, by number. (The specific rule may also be quoted if this is needed for clarity.) If the rule violations have been identified on a CFS-294, which will be attached to the CFS-321-B, this section of the report may simply refer to the attached CFS-294 for the specific rule references. If the allegation does not relate to specific licensing rule or is referred to another agency for follow up, this should be noted.
Methods Used to Conduct the Investigation: This section should identify the licensing specialist assigned to the investigation, the date the investigation began, the dates of on-site visits, the identification and dates of collateral contacts, persons interviewed and the records and documents reviewed.
Description of the Investigative Findings: This section should specify the facts determined in the course of the investigation related to alleged statutory and administrative rule violations, which should be cited by reference number. If applicable, this section contains reference to the findings of any other involved agencies, for example, county child protective services.
Conclusions, Recommendations and Actions: This section should objectively summarize the licensing specialist’s conclusions and indicate whether each violation related to the complaint allegation is substantiated or unsubstantiated. This section should also contain citations of administrative rule violations and include the subsequent actions to be taken (with the approval of the licensing manager/licensing supervisor, if appropriate). This section includes referrals of issues uncovered in the investigation to other agencies having jurisdiction or responsibility in those areas.
All rule violations discovered during the investigation, including those unrelated to the complaint but observed during the complaint investigation, must be documented and cited on a CFS-294 form and attached to the CFS-321-B report.
The licensing manager/licensing supervisor approves the complaint investigation findings report and resulting enforcement action.
This page last updated 10/2020.