The U.S. Nonprofit Safeguarding Crosswalk Project Founder & Principal Researcher: Saba Gul, LL.M.
The Crosswalk Project

The U.S. Nonprofit Safeguarding Crosswalk Project

An open-access structural framework bridging international standards and U.S. domestic compliance.

Crosswalk Project Overview. A foundational summary outlining the Project’s scope and core objectives. Download: PDF · Word

The project is often shortened to “the PSEA Crosswalk,” after the international standard it maps — the IASC Six Core Principles Relating to Sexual Exploitation and Abuse. The tools themselves use the broader PSEAH framing, which adds harassment, and sit inside safeguarding, the umbrella duty.

What this project is Three narrowing bands. Safeguarding is the duty: an organization must never harm the people it serves. PSEAH is the proven method: two decades of international practice against sexual exploitation, abuse, and harassment. The Crosswalk is the legal proof: which international obligations U.S. law does and does not anchor, and tools that close the gap for each organization. Safeguarding the duty: an organization must never harm the people it serves. PSEAH the proven method: two decades of international practice against sexual exploitation, abuse, and harassment. The Crosswalk the legal proof: which international obligations U.S. law does and does not anchor, and tools that close the gap for each organization.
Figure 4 — What this project is. Safeguarding is the duty, PSEAH is the proven method, and the Crosswalk is the legal proof connecting the two for U.S. nonprofits.

The problem

The nonprofit sector operates on an implicit trust to safeguard its beneficiaries, and that trust is not anchored by a legal duty of general application. Module 1 of this project takes the international safeguarding standard — the IASC Six Core Principles — decomposes it into thirteen discrete, testable obligations, and maps each against United States law.

The finding is precise and falsifiable: not one of the thirteen obligations is anchored by a United States requirement of general application that both reaches nonprofits as a class and protects the people they serve. Coverage exists, but it is confined to a certified sub-sector, conditioned on particular federal funding, directed at employees rather than participants, or triggered only after harm. Where a federal requirement does reach an organization, it is candid about how far it goes:

NSCHC requirements are baseline screening procedures. Organizations should institute a holistic framework for safeguarding beneficiaries of service.

— AmeriCorps, National Service Criminal History Check Manual.

The requirement applies to AmeriCorps grantees and subrecipients; the framework it calls for is left to each organization to build.

The sector’s front line is also largely unpaid. In 2023, 75.7 million Americans (28.3 percent) formally volunteered through an organization, against 12.8 million paid nonprofit jobs in 2022, yet United States law allocates protective duties by employment status rather than by the aid relationship itself. The design problem is solved in one certified sub-sector, where a complete operational regime governs Medicare- and Medicaid-certified long-term care facilities. The scope problem is not.

(For the full mapping and citations, see the Module 1 crosswalk PDF and the Research page.)

The method

The project runs a four-step iterative cycle:

  1. Map: Analyzes each obligation of the international standard against U.S. law.
  2. Convert: Translates findings into adoptable, open-access tools.
  3. Collect: Gathers structured feedback from organizations adapting the tools.
  4. Publish: Releases revised versions and new modules incorporating that feedback.

The project now also measures. The Washington Safeguarding Baseline 2026 — the project’s first empirical study — tested what a random sample of Washington nonprofits actually shows the public about safeguarding, and found the gap Module 1 predicted: near-universal compliance with the governance disclosures federal law asks for, and near-total silence on the safeguarding protections no law requires. Read the results → baseline-2026.html

All outputs are released under a Creative Commons Attribution 4.0 license and deposited on Zenodo as versioned records with permanent DOIs (Module 1 crosswalk, 10.5281/zenodo.22022939; toolkit, 10.5281/zenodo.23002214). The work is built to be checked: every row of the crosswalk can be tested against a primary legal source, and documented corrections improve the map rather than undermine it.

How the project measures progress A five-step loop: Tools, then Adoption, then Notice and feedback, then Baseline Index, then Next version, feeding back into Tools. Center label: Research, practice, evidence. 1 Tools free policy, self-assessment, and training (CC BY 4.0) 2 Adoption boards adopt; organizations run the 32-indicator self-assessment 3 Notice & feedback adopters send a Notice of Adoption and feedback, anonymous by default 4 Baseline Index responses build the National Safeguarding Baseline Index 5 Next version findings revise the research and the tools Research → practice → evidence
  1. 1. Tools — Free policy, self-assessment, and training (CC BY 4.0)
  2. 2. Adoption — Boards adopt; organizations run the 32-indicator self-assessment
  3. 3. Notice & feedback — Adopters send a Notice of Adoption and feedback, anonymous by default
  4. 4. Baseline Index — Responses build the National Safeguarding Baseline Index
  5. 5. Next version — Findings revise the research and the tools, which feed back into Tools
  6. Research → practice → evidence.
Figure 5 — How the project measures progress. Each published version is revised using evidence from the organizations that adopt it.

How organizations participate

Organizations adopt and adapt the free tools to their own context.

Organizations that find the work useful can say so in writing, and that feedback directly shapes the next published version of each tool. Participation is framed as a research contribution: the more adopters report what worked and what did not, the more accurate and usable each subsequent version becomes.

The roadmap

With all four tools now published (see the toolkit) and Washington Safeguarding Baseline 2026 — first edition published September 2026, planned further work includes additional crosswalk modules covering ST/SGB sections 4 and 6 in full, the Core Humanitarian Standard, and the Keeping Children Safe standards, baseline studies of additional states, together with a fifty-state appendix and revised toolkit editions informed by adopters. A maturity-model methodology module is planned as a later stage.

The Crosswalk Project is an independent, unincorporated research program founded by Saba Gul in 2026. It is not a consultancy and offers no paid services.