The Interim Report on the Feasibility of a National Child Abuse Registry, published in 2009, described an initial feasibility assessment that was conducted internally by HHS staff. The interim report was developed based on analysis of the statutory language in the Adam Walsh Act, a literature review, and discussions with experts who have considered issues related to state child abuse registries as well as related federal efforts such as sex offender registries and information systems used to produce criminal background checks. The interim report identified many of the key challenges that would exist in combining existing state databases into a national registry and included four conclusions:
- Potential benefits of a national child abuse registry are largely unknown.
- A lack of incentives for participation could result in a database that includes little information and fails to fulfill its intent.
- Before implementation could begin, legislative change would be needed to permit the collection of sufficient information to accurately identify perpetrators.
- Clarification is required on several key issues that are ambiguous in the authorizing statute; these must be resolved either within HHS or by Congress before implementation could proceed.
The interim report also discussed due process issues with respect to a national registry, noting that "there can be no federal substitute for procedural protections at the state or local level."
The interim report determined that there are very substantial challenges involved in establishing a national child abuse registry and that while it would be possible to overcome the statutory limitations and other challenges, doing so would involve substantial costs and could be burdensome to the state and local child protective services systems a national child abuse registry is intended to help. In addition, it was not clear whether or by how much child safety would be improved through a national database of child maltreatment perpetrators.
The full interim report may be found attached to this report as Appendix 3.