It is 100% suggestive.

• laying down
• short shorts
• knees up
• cheeks out, crotch just barely covered

I see it’s a popular tactic to accuse the whistleblowers as being the ones with the real problem, which is a bullshit attempt to suppress discourse on the topic. I have another idea: that maybe those who claim that this picture isn’t sexual have been overexposed to much harder child sexual content, and as a result this picture doesn’t register on their radar. Speaking as someone who has not been exposed to any child sexual material, this is immediately, obviously meant to titillate.