WASHINGTON, D.C. – A former member of the Pontifical Commission for the Protection of Minors has said that proposals made by Cardinal Donald Wuerl in the wake of the Theodore McCarrick scandal do not go far enough.

Marie Collins, who is herself a survivor of clerical abuse, also said that the actions taken by Church leaders thus far in response to the McCarrick allegations, are not sufficient to resolve the problem.

On August 3, Wuerl released a “pastoral reflection” on the McCarrick crisis. In it, the Archbishop of Washington noted it was “particularly disheartening” that the Church had already been through the pain and trauma of addressing sexual abuse and episcopal failures in 2002, but quoted St. John Paul II, saying “We must be confident that this time of trial will bring a purification of the entire Catholic community.” He also pointed out that earlier work by U.S. bishops, including the Dallas Charter, could be revisited and built upon.

In response, Marie Collins told Catholic News Agency that Wuerl “speaks as if the issue had already been addressed when we know this is not the case.”

Wuerl’s reflection also praised Pope Francis for his “strong and decisive” response to the McCarrick allegations, calling it an example to follow.

On July 28, the pope accepted McCarrick’s resignation from the college of cardinals and directed him to live in “seclusion, prayer, and penance” pending the outcome of a canonical process. This followed the similar acceptance by the pope of the resignations of five Chilean bishops in the wake of the abuse scandal still unfolding in that country.

Collins, who resigned from the Pontifical Commission for the Protection of Minors in March 2017, said that episcopal resignations were no substitute for a proper determination of guilt and formal punishment following a canonical trail. She said that allowing bishops to effectively remove themselves following public scandal was not a credible means of resolving the crisis.

“Asking for resignations is not the same thing as having a proper, transparent, penal process,” she said, “no proper structure has been put in place to hold bishops or religious leaders to account.”

Wuerl’s reflection noted that, in 2002, U.S. bishops issued a “Statement of Episcopal Commitment” which bound them to self-report allegations made against them to the Apostolic Nuncio, and to similarly report allegations they received against other bishops.

Wuerl said the statement could “serve as the nucleus of a more effective mechanism” for holding bishops accountable. Collins was deeply skeptical of the suggestion.

“It is disturbing that Cardinal Wuerl speaks of revising the very unsatisfactory Statement of Episcopal Committeemen that accompanied the Dallas Charter when what is needed is that the Charter itself should be revised to cover all clerics and religious.”

A spokesman for the Archdiocese of Washington, D.C., told CNA that the cardinal’s comments were intended as a “contribution to an important and ongoing conversation.”

“Cardinal Wuerl was drawing attention to the Statement of Episcopal Commitment, to highlight what the U.S. bishops can build upon.”

“He feels it is important for the Church, and especially for victims, that time isn’t wasted reinventing the wheel. The Statement and the Charter could be built upon and improved, and might be useful in that way. But if the bishops decide to go in another direction, that’s also an option.”

In a separate media interview, given on August 5, Wuerl suggested that the USCCB could form a committee or panel of bishops with the authority to investigate allegations, and even persistent rumors concerning individual bishops, such as those which were reportedly in wide circulation concerning McCarrick.

Collins told CNA that the Pontifical Commission for the Protection of Minors had already drawn up a set of safeguarding guidelines, approved by the pope, but that it has been left up to bishops’ conferences to take notice of the Commission’s recommendations.

“The Safeguarding Guidelines template which the Pontifical Commission for the Protection of Minors drew up, and which was approved by the pope, is on the Commission website” she pointed out, also noting that unlike the Dallas Charter “the Commission’s guideline do not exclude bishops – they refer to ‘clerics and religious’.”

Echoing previous criticisms made about the way the Pontifical Commission’s work had been adopted, Collins said that although the guidelines were meant to be a binding standard, they have not yet become normative.

“The original intention was to disseminate the guidelines to all bishops’ conferences globally as best practice and to hold all local policies to this standard, instead, they are now simply a resource on the website to take or leave.”

When asked what a credible response to the McCarrick scandal might look like, Collins  called for a serious commitment to transparency by the Church, both in Rome and in dioceses.

“There must be transparency around every action that is taken in response to a report of any sort of abuse or exploitation. The use of the ‘pontifical secret’ to restrict the information available to victims in canonical trials should end – this was recommended to the Holy Father by the PCPM last September, but there has been no word as to whether the recommendation has been approved or not.”

Collins said that real reform would need to be dramatic, and could include a national body charged with inspecting dioceses.

“Each diocese should open itself to an annual audit by an independent body, with diocesan bishops making all their files available.  This is done in Ireland by the National Board for Safeguarding Children in the Catholic Church and their audits are published.”

“The NBSCCI are not completely independent but they are a central office not connected to any one diocese.”

In his Pastoral Reflection, Wuerl has said that any review of policy must be more than just canonical and procedural. The cardinal said any revised version must include “an expansive theological and moral perspective” and recognize the need for “fraternal correction” among bishops.