Should a 17-year-old college freshman be considered a child?

Pennsylvania says yes, and that has some of the state's colleges and universities scrambling to figure out how to comply with a new child abuse protection law.

The law, Act 153, requires more extensive child abuse background checks for employees and volunteers who have "routine interaction" with children, including a 17-year-old freshman.

That means virtually all employees, could be required to get the checks, depending on how "routine interaction" is defined, Don L. Francis, president of the Association of Independent Colleges & Universities said last week to Gov. Wolf in a letter obtained by the Inquirer.

Colleges, he wrote, risk liability if they don't have all employees checked. He called the endeavor an "enormously expensive and difficult undertaking," likely to cost between $4.5 to $5 million to get checks for the 75,000 employees at his member colleges. Furthermore, the checks must be updated every three years.

"This is a steep cost to cover many individuals that will have no more interaction with children than a person working at a fast food restaurant or a bookstore," he wrote.

Francis, who declined to comment beyond his letter, asked the governor to delay the deadline for complying with the law by a year, until December 2016.

Jeffrey Sheridan, a spokesman for Gov. Wolf, said this week: "We are reviewing the issue and will make sure that the protection of children is not compromised."

The law was one of several passed by the legislature last year following the child sex abuse scandal involving Jerry Sandusky, a former Pennsylvania State University assistant football coach who was indicted in 2012 for abusing young boys on and off campus over a period of years. Sandusky is in prison serving a minimum of 30 years.

Not everyone thinks the requirement is too onerous.

The system overseeing Pennsylvania's 14 state universities including West Chester and Cheyney already has decided to have all 13,000 employees checked, said spokesman Kenn Marshall.

"It's a good idea to do everything you can to provide safeguards for anybody who comes on to our campuses," , said Marshall, of the Pennsylvania State System of Higher Education. "We just thought it was the appropriate thing to do - to make this as broad as possible, regardless of what it costs."

Though all details haven't been worked out, he said he believes the system will cover the cost for employees.

Cathleen Palm, founder of the Center for Children's Justice, based in Berks County, understands some colleges – and other agencies – are struggling to figure out which employees must be checked. But she pointed that in the case of a college, more children are going on to campus for camps and dual enrollment courses while they are in high school.

And, she said, it would be very complicated to figure which employees may have access and which may not. Getting all employees checked is probably a good idea, she said.

Some college officials though are wondering if student volunteers who give campus tours will need to have the checks. Francis said in the letter that a better definition of "routine interaction" is needed.