What happens when the government fails to regulate Christian reform schools? One academy in Georgia is just the beginning.
This is the second in a two-part series examining the therapeutic Christian boarding school Shepherd’s Hill Academy and its founder Trace Embry. You can read the first part here.
Shepherd’s Hill Academy is a Georgia-based Christian boarding school with a history of alleged abuse, conversion therapy for LGBTQ teens, and religious indoctrination. If it were just one school, it could be viewed as an alarming anomaly.
But this is not the story of just one school.
When it comes to the state of education in this country, politicians and community leaders regularly debate the merits of charter and public school reform, standardized testing, federalized curriculums, and universal pre-K at the local, state, and federal levels. What is often missing from these conversations are reform schools, wilderness boot camps, and “therapeutic” boarding schools where there has been a worrying lack of oversight and regulation for decades.
The majority of these institutions are privately run, and many are connected with a church or have a foundational religious component. Brandy Zadrozny reported last June for The Daily Beast on the allegations of abuse at Blue Creek Academy, a now-shuttered Christian reform school for at-risk teenage boys, in West Virginia. She wrote:
“As in many other states, religious private schools in West Virginia aren’t held to the same standards as their nonreligious counterparts. Though the ways in which they are exempt varies from state to state, for many schools that operate with a religious mission — 80% of private schools nationwide — accreditation or licensing, the hiring of certified teachers or the approval of curriculum, or even simply notifying the state as to its existence is completely voluntary.”
Last June, actor Jeremy Jordan brought national attention to this issue when he started a GoFundMe campaign to assist in getting his teenage cousin released from the therapeutic boarding school associated with Heartlight Christian Ministries. Jordan claimed that his 17-year-old cousin was sent to the “East Texas Christian boarding facility for troubled teens to ‘pray away the gay.’” She was released a few days after his campaign made headlines. Mark Gregston, founder and executive director of Heartlight Ministries, released a statement denying that the girl was there against her will and that the facility practices any form of conversion therapy. (The girl has never gone public with her story.)
There are other institutions across the country that echo SHA’s practices, including religious indoctrination (Wings of Faith Academy in Missouri helps girls with “spiritual confusion”; New Lifehouse Academy in Oklahoma scores student behavior on metrics including “spiritual development”) and abuse (a Tampa Bay Times investigation from 2012 detailed cases of abuse at several Christian homes and boarding schools in Florida; 22 boys were removed from a Christian boarding school in Alabama last year due to allegations of abuse).
While institutions like these have at least faced scrutiny in the past, it’s hard to imagine them being met with resistance from political leaders in 2017.
Under the auspices of the Trump administration and powerful far-right politicians and pundits, religious indoctrination has been propped up as a key element of educational development. Evangelical leaders have been celebrating what they see as the end of government intrusion on matters of faith and family, and recently confirmed Education Secretary Betsy DeVos has a history of steering tax dollars away from public schools and toward private, often religious, alternatives. Mother Jones reported that DeVos’ $100 million in donations over the last decade “show an overwhelming emphasis on funding Christian schools [and] evangelical missions.”
Meanwhile, the administration has made it clear that the anti-LGBT measures common at these religious camps and treatment centers will have its support. Before assuming her cabinet post, DeVos donated millions to anti-LGBTQ organizations that advocate for conversion therapy. And as governor of Indiana, Mike Pence not only provided businesses in the state the legal right to discriminate against LGBTQ individuals in an effort to protect so-called religious freedom, but proposed taking federal dollars away from HIV/AIDS prevention by redirecting that funding “toward those institutions which provide assistance to those seeking to change their sexual behavior.”
Of course, there are many Christian therapeutic programs and boarding camps that don’t engage in abusive practices. But governmental oversight is necessary to ensure that institutions aren’t allowed to harm students. And it’s clear from looking at SHA and other schools that this oversight, as it exists, fails to protect children.
The Oversight Gap
Shepherd’s Hill Academy operated unlicensed and unsupervised by the state of Georgia for more than 10 years. It was not until September of 2010 that Georgia’s Department of Human Services (DHS) and its Office of Residential Child Care (ORCC), now the Residential Child Care Licensing (RCCL) unit, was forced to investigate the school. And that only happened after it received a complaint from a social worker, alleging, “[I]t appears to us they are ‘driving without a license.’”
After an investigation was concluded, four months after the initial complaint was filed, Carol S. Winstead, then-program director of Georgia’s ORCC, sent an official letter stating that within 45 days, SHA must either cease operation or submit an application for an Outdoor Child Caring Program (OCCP) license. This license covers child-caring institutions that provide “room, board and watchful oversight along with a variety of outdoor activities taking place in a wilderness or camp environment that are designed to improve the emotional and behavioral adjustment of children.” All of the academy’s activities, save for the academic portion of the program, are governed under this license.
The initial license was received and went into effect on January 3, 2012. That is 15 months after the initial complaint was filed with the state of Georgia’s Department of Human Services (DHS) and approximately 11 years after Trace and Beth Embry first started treating troubled teenagers on their farm.
Shepherd’s Hill Academy operated unlicensed and unsupervised by the state of Georgia for more than 10 years.
According to documents provided by the DHS, SHA repeatedly failed their on-site inspections and off-site evaluations during the licensing process, including having too many residents for the allotted land area. Though it has since been licensed for a reduced capacity of 36 residents, instead of the 50 it once had, SHA has still failed its annual inspection each year since becoming licensed by the state in 2012.
Despite this, SHA has managed to stay in business, likely due to a bureaucratic idiosyncrasy. If violations are found, the ORCC requires a “Plan of Correction” to be submitted within 10 business days. As long as the ORCC approves the plan — at their discretion, they may permit the institution to submit a revised plan — there are no penalties. SHA has presumably been able to stay in business because of this process.
Trace Embry himself has been the source of licensure violations as well. According to the state of Georgia’s rules and regulations for Outdoor Child Caring Programs, the administrator or executive director of a program:
“…shall have a master’s degree from an accredited college or university and a minimum of three years of increasingly responsible experience in the human service, mental health or health care field, or a bachelor’s degree plus five years experience in the field of child care, human services, mental health, at least two of which includes supervisory and/or administrative responsibility.”
Yet Embry, who is listed as the executive director of Shepherd’s Hill Academy Inc. on all official documents, has no college degree. Rebecca Bombet Basile, former employee at Shepherd’s Hill, testified to a court of appeal that “Trace Embry and his wife, Beth Embry, run the program, but neither has a college degree.” Records from Toccoa Falls College (TFC) provided by the National Student Clearinghouse confirm that Mr. Embry was enrolled at TFC from 1991 through 1998, but he did not obtain a degree from the school.
This isn’t necessarily unusual; according to DHS, the third most requested waiver in 2013 for OCCP programs in the state was for the “Education/Experience for Director/Human Service Professional.” Confirmed by documents provided by the DHS, Trace Embry and Shepherd’s Hill Academy have, in fact, received a waiver for this requirement. The waiver was granted in April 2011 during the licensing process because “[Trace Embry] has over 10 years of experience…[and] will employ staff who possesses the required educational credentials.” The waiver was renewed in June of both 2014 and 2015.
It is not merely coincidence that the “over 10 years of experience” referenced in the waiver approval memo is the same decade during which SHA operated illegally.
During the summer of 2011, Beth Embry repeatedly requested that SHA not be required to comply with two rules, mandating that all incoming students receive both a physical exam and psychological or psychiatric evaluation prior to admission. Beth provided numerous reasons as to why SHA should be excused from wholly complying with these rules, including their faith-based status, the “high standard for moral character” of the parents, and the alleged risk involved to both the “well-being of the prospective student” and the “integrity of [the student’s] family dynamics.” Notably, Beth repeatedly asked the state to take into consideration SHA’s 10-year history, and in one instance claimed “a precedent has been set as we have successfully operated…for over a decade.”
While these numerous requests were denied, SHA has violated these rules on more than one occasion since receiving their license. A license loses all its credibility if its requirements are routinely not met; it is merely another piece of paper that gives organizations the legal protection to abuse children.
A license loses all its credibility if its requirements are routinely not met. It is merely another piece of paper that gives organizations the legal protection to abuse children.
Meanwhile, despite these troublesome practices, Trace and Beth Embry have worked hard to ensure that Shepherd’s Hill Academy looks aboveboard on first look. As advertised on their website, SHA is accredited by the Georgia Accrediting Commission (GAC) and licensed by Georgia’s Department of Human Services (DHS).
But as confirmed by the executive director of GAC, an independent state-approved agency, the accreditation only applies to the academic portion of SHA. That is, the lectures and classes that happen on the main campus—not the equine therapy or the beekeeping or the construction projects.
SHA also advertises their membership in the American Association of Christian Schools (AACS) and their state chapter, the American Association of Christian Counselors (AACC), and the National Association of Therapeutic Schools and Programs (NATSP). These are membership organizations to which member schools pay fees to be included in their network. For example, NATSAP is a trade association, not a federal or state-approved agency. As stated on their site, it “does not provide oversight of our member programs, believing that responsibility lies with the licensing and accrediting agencies.”
The issues at Shepherd’s Hill are alarmingly neither unique nor the worst that have been reported. Residential treatment programs and therapeutic boarding schools across the country have had enough horrific incidents connected with deceptive marketing and a distressing deficit in state oversight to prompt a congressional hearing.
The issues at Shepherd’s Hill are alarmingly neither unique nor the worst.
At the request of Representative George Miller, a Democrat from California, in April 2008, a hearing was held before the House Committee on Education and Labor on “Child Abuse and Deceptive Marketing by Residential Programs for Teens.” Addressing the hearing’s chairman Miller in a letter, Jill Ohanesian-Ryan wrote that her daughter was admitted to what they understood to be a “therapeutic boarding school” called Hidden Lake Academy (HLA) in Dahlonega, Georgia.
But HLA was not licensed, even though it was marketed as such to other states and accepted out-of-state Individual Education Program (IEP) students and children under the No Child Left Behind Act. According to HLA’s attorney’s own written words to Carol Winstead, then-program director of residential childcare at Georgia’s DHS, “therapeutic is a marketing term.” Peer group counselors, she noted, were also not licensed by the state of Georgia.
For these therapeutic boarding schools, catering to troubled teens, ‘therapeutic’ is simply a marketing term.
Incidentally, each state handles students who require an IEP differently, making it difficult to transfer a student with an IEP to an out-of-state program. Residential programs like HLA found a way through this and advertised heavily out of state. Shepherd’s Hill also takes advantage of this, stating on their site, “We are able to accommodate a variety of Individualized Educational Plans (IEP) adjustments.” And as their sitemap exposes, they are trying to take advantage of search-engine results by having regional advertising for hundreds of cities across the country in nearly all 50 states.
Ohanesian-Ryan also wrote that she and several other parents contacted Georgia authorities — among them, Winstead, of the ORCC — “regarding the misrepresentations and abuses at HLA,” and that ORCC refused to take action until a class-action suit brought public attention.
When an investigation into Hidden Lake Academy finally occurred, Ohanesian-Ryan testified that investigators discovered “suicide attempts, rapes, cuttings, broken bones, zip tying, cold cocking and the like [that] were never reported to CPS” by HLA, the local sheriff’s department, the local hospital, or any other responsible institutions. She affirms, “Despite the CPS report of 2006, ORS granted HLA two consecutive six month temporary licenses.” She was assured by the ORS that if HLA failed to comply with the regulations during their temporary licensure, they would be shut down. But, she said, “Nothing had changed; [they] did not shut them down.”
In 2012, another federal investigation took place at a different DHS facility in Georgia, which alleged that agents were “destroying, delaying, changing and falsifying child abuse reports.” Former DHS Commissioner Clyde Reese III claimed in a statement in response to this raid, “the safety of children was ‘a fundamental guiding principle.’”
Troublingly, the state of Georgia failed in its oversight and regulation of HLA during the early years of SHA’s unmonitored operation — and it appears a disregard for the physical, emotional, and mental health of the children placed in therapeutic boarding schools in the state of Georgia has remained consistent.
The official titles, employees, and therapeutic programs may change, but the disregard for the physical, emotional, and mental health of the children placed in therapeutic boarding schools remains constant.
Moreover, it’s not just Georgia that has contended with regulatory issues. A lack of sufficient oversight has been documented in Florida and Iowa, and one online guide to Christian boarding schools openly notes that:
“…some states do not provide much oversight for programs designated as Christian Programs, or Christian Boarding Schools. This may be due to the desire to keep church and state separate. At any rate many Christian programs, Christian boot camps, and Christian boarding schools do not have a lot of regulations mandated by the state they are located in.”
How Many More?
In a promotional video produced by SHA, a parent of a student talks about her “investigation” into abuse allegations at the farm. “I found out from Trace Embry that there was a website where someone posted these inflammatory, derogatory statements,” she begins. “I went home and looked them up and I read them. And I could find no evidence of truth in any of them.” She goes on to say that she “went to the state of Georgia to find out if there were any complaints against the school,” and nothing was credibly substantiated.
This video, uploaded in 2014, only two years after SHA was licensed, is referencing abuse allegations during the decade SHA was unmonitored by the state of Georgia. The aforementioned mismanagement, neglect, and abuse cover-ups that occurred for years at the offices meant to monitor facilities like Shepherd’s Hill — on behalf of children — puts into serious doubt whether the state did or did not receive complaints concerning Trace and Beth Embry’s “discipleship clinic.”
The Embrys have concluded on more than one occasion that some of their students are suffering from demonic possession, which is why they are “brainwashing [them] with the blood of the lamb.” Trace Embry, who has no medical training or college degree, believes that students who have been diagnosed by professionals with very real and treatable mental illnesses are actually suffering from too much technology use, the overconsumption of media, and a lack of religious conviction.
The Embrys long for the day when a teacher could paddle a student for alleged misbehavior without any legal consequences. They believe that teenagers who profess to have same-gender sexual attraction or are questioning their gender assigned to them at birth are being influenced by “Old Dark Eyes” and were sexually abused at a young age. They confer with ultra-religious counselors who are not licensed in their state, don’t hold nationally recognized certification, and believe that a smartphone is akin to carrying “Sodom and Gomorrah in your pocket.”
And all the while, the state of Georgia has given Shepherd’s Hill Academy a stamp of approval where children’s safety is a “fundamental guiding principle.”
How many more children have to suffer before SHA — which, it’s been noted, “brings in a lot of revenue for the county” — is shut down? How long before others like it are, too? There were enough allegations of abuse, with accompanying state-level cover-ups, concerning residential programs for teens in 2008 for a congressional hearing to take place.
This is only one school, in one state. How many more are there?
Fact-checking by Maxine Builder.