summary: PREA

raw_content:
PREA AUDIT: AUDITOR’S SUMMARY
REPORT JUVENILE FACILITIES
Name of Facility: Alachua Academy
Physical Address: 3430 NE 39th Ave., Gainesville, FL 32609
Date report submitted: March 30, 2015
Auditor information: Shirley L. Turner
Address: 3199 Kings Bay Circle, Decatur, GA 30034
Email: shirleyturner3199@comcast.net
Telephone number: 678-895-2829
Date of facility visit: March 9, 2015
Facility Information
Facility Mailing Address: Same as Physical Address
Telephone Number: 321-264-4033
The Facility is: Military County Federal
Private for profit Municipal State
X Private not for profit
Facility Type: Detention Correction X Other: Residential
Name of PREA Compliance Manager: Vicki Donaldson Title: Program Director
Email Address: vickydonaldson@nafi.com Telephone Number:
352-872-5152
Agency Information
Name of Agency: National American Family Institute
Governing Authority or Parent Agency: NA
Physical Address: 26 Howley Street, Peabody, MA 01960
Mailing Address: Same as Above
Telephone Number: 978-882-4850
Agency Chief Executive Officer:
Name: Yitzhak Bakal Title: President
Telephone 978-882-4850
Email Address: yitzhakbakal@nafi.com
Number:
Agency Wide PREA Coordinator
Name: Deb Yates Title: Regional Director
Email Address: debyates@nafi.com
Telephone Number: 240-405-9904
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AUDIT FINDINGS
NARRATIVE:
The Alachua Academy is located in Gainesville, Florida and is operated by National American
Family Institute, Incorporated through a contract with the Florida Department of Juvenile Justice
(DJJ). It is a 24-bed moderate risk residential program that serves female juvenile offenders between
the ages of 13-18. The facility serves females in need of substance abuse treatment services and the
average length of stay is seven months. The psychotherapeutic services include individual, group and
family counseling; cognitive skills training; and relapse prevention training.
Medical services are provided on-site by a full-time Licensed Practical Nurse, a contract physician
who visits the facility once weekly, and a contract Registered Nurse who provides nursing oversight
as needed. Mental health services are provided by the Clinical Director and two Therapists. The
contract psychiatrist is on-site twice a month and the Case Manager and Assistant Case Manager are
in the mental health unit. The education staff consists of the school principal, two teachers and a
teacher’s aide. The residents participate in academic subjects, GED preparation and vocational
activities.
The facility has a behavior management system where residents earn points as they progress
throughout the day. An accumulation of points assists the residents in achieving different levels where
the privileges and responsibilities increase with each level. A Point Store exists where residents may
spend their earned points on an array of items. Based on the amount of points earned, purchases can
include an additional stamp and/or additional phone call.
DESCRIPTION OF FACILITY CHARACTERISTICS:
There is one main building that houses the program. The front of the building contains administrative
offices. Beyond this area is a large dayroom space which is divided into two areas, where one area
serves as the dining room. There is a long hallway where one end contains offices and two
classrooms. The other end of the hall contains the residents’ rooms and the medical clinic area. The
residents’ bathroom and laundry room are located on the housing wing. Residents are provided a
reasonable amount of privacy during showers, while using the toilet, and when changing clothes.
There is a large patio on the back of the building and adjacent grounds that provide ample space for
various outside recreation and other activities.
There are 24 double occupancy rooms in the housing wing and they are attractively painted,
decorated, and accessorized in coordinated colors. The occupants of each room have their names and
pictures posted on the wall outside of their room. Direct care staff provides engaged supervision of
residents in daily activities and during the residents’ movement to and from activities and services.
.
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SUMMARY OF AUDIT FINDINGS:
The notifications of the on-site audit were posted in buildings of the facility prior to the site visit.
Photographs were taken of the posted notices and the photographs were electronically sent to this
Auditor, noting their posted locations. Telephone conversations were held with the Program
Director who also serves as the PREA Compliance Manager to review the PREA audit processes.
The Pre-Audit Questionnaire, facility policies and supporting documentation were uploaded to a
flash drive, which was received by the Auditor prior to the on-site audit. After reviewing the
information, notes were sent to the Program Director to seek clarity of information and to note the
additional documents needed. In response to the issues noted, additional information was provided
and discussed prior to and during the site visit and corrective actions were taken to provide clarity of
procedures and practices.
The on-site audit was conducted on March 9, 2015. An entrance meeting was held with the Program
Director. After the meeting, a staff member from the overnight shift was interviewed by the Auditor.
Following the interview, a comprehensive tour of the facility was conducted by the Program
Director. During the tour, staff members were observed to be providing direct supervision and were
actively engaged with the residents. Random staff, specialized staff and residents were interviewed
during the on-site audit. The interviews of both staff and residents revealed their general knowledge
of PREA and the related procedures. The staff members interviewed were aware of the zero-
tolerance policy against sexual assault and sexual harassment and understood their duties and
responsibilities regarding PREA. The residents interviewed demonstrated their knowledge of what
PREA means and how to report sexual assault and sexual harassment. At the conclusion of the
audit, a summary of the findings were provided in a review with the Program Director.
Number of Standards Exceeded: 0
Number of Standards Met: 39
Number of Standards Not Met: 0
Number of Standards Not Applicable: 2
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Standard 115.311 Zero Tolerance of Sexual Abuse and Sexual Harassment.
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The Alachua Academy has a zero-tolerance PREA Policy against sexual assault and sexual
harassment which details how the facility will implement its approach to preventing,
detecting, and responding to sexual abuse. The facility’s PREA Policy is aligned with the
Florida Department of Juvenile Justice’s PREA Policy 1919 (FDJJ 1919). Both policies
contain definitions of the prohibited behaviors and sanctions for those who participate in such
behaviors. The Program Director, in charge of the facility, has been identified as the PREA
Compliance Manager.
Standard 115.312 Contract With Other Entities for the Confinement of Residents.
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
X Standard Not Applicable
Auditor Comments:
The facility does not contract with other agencies for the confinement of residents.
Standard 115.313 Supervision and Monitoring
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy requires that the facility implement an approved staffing plan and that it is
documented when deviations from the staffing plan occur. The facility reports that there have
been no deviations from the staffing plan. A review of documents showed a requirement for
the annual review and internal requirements of staffing by the Program Director. The Shift
Supervisors develop the work schedules for direct care staff; they are reviewed by the
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Assistant Program Director; and a final review is conducted by the Program Director to
ensure adherence to the staffing plan. Hold-over staff members are identified on the work
schedule, in advance, to fill in as needed or a person is called in from the part-time work pool.
The PREA Policy and facility practice provide for unannounced rounds that are completed by
management staff. The Policy also prohibits staff from alerting each other of the rounds
occurring. A review of documentation and staff interviews confirmed that unannounced
rounds occur.
Standard 115.315 Limits to Cross Gender Viewing and Searches
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy prohibits staff from searching a transgender or intersex resident to
determine the resident’s genital status. It further states that cross-gender strip searches, cross-
gender pat-down searches, and cross-gender visual body searches are prohibited except in
exigent circumstances that require immediate action. The reasons for such searches are to be
documented. Staff training includes the searching of residents. The viewing of residents by
opposite gender staff while they are showering, changing clothes, and performing bodily
functions is not permitted, unless there are exigent circumstances.
The facility reports no cross-gender pat-down, strip or body cavity searches of residents
during this audit period. All staff and residents interviewed revealed that cross-gender
searches do not occur. The PREA Policy requires staff of the opposite sex to announce their
presence when entering the housing area where residents may be showering, changing clothes
or performing bodily functions. Interviews with staff and residents confirmed this practice.
Standard 115.316 Residents With Disabilities and Residents Who are Limited English
Proficient
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
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Auditor Comments:
According to the PREA Policy, the facility will not rely on resident interpreters, resident
readers or any kind of resident assistance except when a delay in obtaining interpreter
services would jeopardize a resident’s safety or an investigation. Language Line Solutions is
an outside resource for the facility. Support will also be provided by staff members who
speak Spanish, the education staff and mental health staff, as needed.
Standard 115.317 Hiring and Promotion Decisions
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and other facility policies provide for background checks on all employees
and a process that includes the elements of the standard and FDJJ policies. According to the
policies, a review of documentation and interviews with staff, applicants and employees are
asked about previous misconduct. Documentation provided and interviews with staff
confirmed that prior to the hiring of an employee or contractor, background checks are
conducted.
Standard 115.318 Upgrades to Facilities and Technology
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
A camera system is used for monitoring activities in conjunction with direct supervision by
staff. The system enables staff to observe activities in various areas. During this audit period
two cameras were replaced, as well as a recording device installed that will have real time
monitoring and the ability to record up to 30 plus days before re-writing.
Standard 115.321 Evidence Protocol and Forensic Medical Examinations
Exceeds Standard (substantially exceeds requirement of standard)
6
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Documentation was presented which shows that the Program Director is working with the
Alachua County Community Support Services/Victim Services & Rape Crisis Center to
finalize a Memorandum of Understanding for victim advocacy services. The facility’s PREA
Policy provide for the services of a Sexual Assault Nurse Examiner (SANE), Sexual Assault
Forensic Examiner (SAFE) or another qualified medical practitioner. The forensic
examination, which will be of no cost to the victim, will be performed at Shands Jacksonville
Hospital where SANE services will be available. There has not been a need for a forensic
medical examination during this audit period.
According to FDJJ 1919, the facility is not responsible for conducting administrative or
criminal investigations. The DJJ Office of the Inspector General (OIG) is responsible for
conducting administrative investigations; the Florida Department of Children and Families
(DCF) is responsible for conducting allegations of child abuse; and the Gainesville Police
Department is responsible for conducting criminal investigations. The PREA Compliance
Form which contains the PREA requirements regarding investigations will be provided to the
investigators from the Police Department as needed.
Standard 115. 322 Policies to Ensure Referrals of Allegations for Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and FDJJ 1919 identify the agencies that will conduct the criminal and
administrative investigations. Both documents instruct the facility staff to cooperate with the
OIG investigations and provide that an administrative or criminal investigation is completed
for allegations of sexual abuse and sexual harassment. During the past 12 months, there were
no allegations of sexual abuse or sexual harassment. Policy regarding the referral of
allegations of sexual abuse or sexual harassment for an investigation is posted on the DJJ
website and posted in the facility, available to the public.
Standard 115.331 Employee Training
Exceeds Standard (substantially exceeds requirement of standard)
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X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy provides information regarding staff training. Employees receive training
on the facility’s zero-tolerance policy and through FDJJ. The staff training is comprehensive
of the key areas referenced in the standard. A review of the training documents and
interviews with staff confirm that training is provided in accordance with the standard and the
facility and FDJJ policies.
Standard 115. 332 Volunteer and Contractor Training
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
According to the PREA Policy, all volunteers and contractors who have contact with
residents must be trained on their responsibilities and the FDJJ prepared course regarding
sexual assault prevention, detection, and response is used. Receipt of the training is
documented as confirmed through document review.
Standard 115.333 Resident Education
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy requires that all newly admitted residents receive information about the
facility’s zero-tolerance policy and how to report incidents or suspicions of sexual
misconduct. Residents receive comprehensive education and according to the PREA Policy,
periodic review of the information. A signed acknowledgement statement by the resident of
having received the training is maintained and resident and staff interviews support that the
resident education occurs. PREA education will be provided through accessible formats for
residents who are limited English proficient, deaf, visually impaired, or otherwise disabled,
as needed. Support services will be provided by Language Line Solutions and facility staff.
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Standard 115.334 Specialized Training: Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ 1919 states that staff in the OIG will be trained on the related policies and procedures
regarding the handling of sexual misconduct incidents and reports. The investigators have
been trained in conducting allegations in the FDJJ settings.
Standard 115.335 Specialized Training: Medical and Mental Health Care
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and FDJJ 1919 address this standard. Documentation shows that the
medical and mental health staff members have completed on-line specialized training
provided by FDJJ. Forensic medical examinations are not conducted by the facility medical
staff.
Standard 115.341 Screening for Risk of Victimization and Abusiveness
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy contains a section that outlines the process of screening for risk of
victimization and abusiveness and the information to be obtained. The Screening for
Vulnerability to Victimization and Sexually Aggressive Behavior (VSAB) instrument is
completed on each resident. Staff and resident interviews and a review of documentation
confirmed that the screening is being conducted.
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Standard 115.342 Use of Screening Information
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The facility uses the information from the VSAB to assist in determining housing and other
program assignments, according to the PREA Policy. Additionally, the Client Services
Policy outlines the classification process, use of the VSAB and the information obtained, and
guidance regarding re-classification. The PREA Policy prohibits placing gay, bisexual,
transgender, or intersex residents into confinement based solely on such identification or
status. Housing and program assignments require determinations on each transgender or
intersex resident on a case by case basis. The facility prohibits considering gay, bisexual,
transgender, or intersex identification or status as an indicator of likelihood of being sexually
abusive.
The PREA Policy provides direction for the conditions of placing a resident in isolation,
including using that measure only as a last resort. There have been no residents isolated in
the last 12 months because she was at risk of sexual victimization. Staff interviews and
review of VSABs supported the policies and practices. Residents confirmed through their
interviews that VASBs are being administered.
Standard 115.351 Resident Reporting
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
There are internal ways a resident may report allegations of sexual abuse; sexual harassment;
retaliation for reporting; and staff neglect or other violation(s) that lead to abuse. A resident
may talk to any staff member; complete a grievance form and place it in the grievance box;
complete a Request to Speak form, requesting to speak to specific staff and place it in the
Request to Speak box; utilize the DJJ hotline; and third parties may report allegations to the
facility or place a call to the abuse hotline. Reporting information is outlined in the PREA and
Administrative Services Policies. The Resident Handbook provides information regarding the
grievance system and residents’ rights and PREA related information is posted within the
facility. Resident interviews revealed that they are aware of the reporting methods available
to them.
.
10
Standard 115.352 Exhaustion of Administrative Remedies
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and the Resident Handbook contain information regarding the grievance
system. A locked grievance box is posted in the living area and a Request to Speak box is
posted in the dayroom. Regarding a PREA related grievance, the resident is directed to fill in
their name, time and date of the grievance and put it in the box where identified staff checks
the box. The resident is not required to use the informal process for any situation regarding
sexual abuse. When a grievance is received, it is treated as an allegation of abuse and the
reporting procedures are implemented for investigation by the OIG, DCF or local law
enforcement. There were no emergency grievances received, alleging substantial risk of
imminent sexual abuse within this audit period.
Standard 115.353 Resident Access to Outside Confidential Support Services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy states that all of the residents will have access to outside victim advocacy
services. Documentation was reviewed showing collaboration between the Program Director
and the Sexual Assault Program Manager of the Alachua County Victim Services & Rape
Crisis Center in anticipation of signing a Memorandum of Understanding. The PREA Policy
and staff and resident interviews revealed that residents have confidential access to their
attorney or other legal representative and access to their parents or legal guardians.
Standard 115.354 Third-Party Reporting
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
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Auditor Comments:
The facility provides methods for third-party reporting of sexual abuse. Related information
is posted in areas of the facility accessible to the public, such as the lobby, visitation area and
other areas of the facility. PREA information is available on the DJJ website regarding the
reporting of sexual abuse or sexual harassment. The PREA Policy provides that staff shall
accept reports made by a third-party.
Standard 115.361 Staff and Agency Reporting Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and the Florida Administrative Code Rule 63F-11 address this standard.
All staff members are required to immediately report any allegation of sexual misconduct;
youth-on-youth sexual activity; retaliation; and situations that may have contributed to
sexual misconduct or harassment. These allegations must be reported to the Central
Communications Center (CCC), DCF and local law enforcement, as required by mandatory
reporting laws and facility and agency policies. The PREA Policy states that staff members
are prohibited from revealing any related information to anyone other than those who are
involved in treatment, investigation and other security and management decisions.
Standard 115.362 Agency Protection Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
According to the facility’s PREA and Administrative Services Policies, when staff learns
that a resident is subject to substantial risk of imminent sexual abuse, immediate action must
be taken to protect the resident. The facility reports that there have been no incidents in the
last 12 months where the facility took any action in regards to a resident being in substantial
risk of imminent sexual abuse.
Standard 115.363 Reporting to Other Confinement Facilities
Exceeds Standard (substantially exceeds requirement of standard)
12
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
According to the PREA Policy, upon receiving an allegation that a resident was sexually
abused while confined in another facility, the Director will notify the head of that facility or
the appropriate office as soon as possible but no later than 72 hours after receiving the
allegation. FDJJ 1919 requires notifying the appropriate investigative agency of all
allegations of sexual abuse. In the past 12 months, there has not been a report of any
allegations of sexual abuse occurring to a resident while she was in another facility.
Standard 115.364 Staff First Responder Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The staff first responder duties are incorporated in the PREA Policy and are aligned with the
requirements of FDJJ 1919. The PREA Policy outlines the first responder duties and the
response for non-direct care staff members. Staff interviews confirmed that they are
knowledgeable of their duties as a first responder.
Standard 115.365 Coordinated Response
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The facility’s coordinated response plan is aligned with FDJJ 1919 and the requirements of
the standard. Interviews with staff revealed that they are familiar with the institutional plan.
The plan coordinates the actions to be taken among facility first responders and other staff in
response to an incident of sexual abuse.
Standard 115.366 Preservation of Ability to Protect Residents from Contact with Abusers
Exceeds Standard (substantially exceeds requirement of standard)
13
Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
X Standard Not Applicable
Auditor Comments:
This standard is not applicable. The facility does not maintain any collective bargaining
agreements.
Standard 115.367 Agency Protection Against Retaliation
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy addresses this standard and it is the responsibility of the Assistant Program
Director to monitor for retaliation against residents and staff members who report sexual
abuse or sexual harassment. FDJJ 1919 and the PREA Policy require that if the retaliation
conduct is identified, the monitoring would be conducted for at least 90 days and longer if
needed. There have been no incidents of retaliation reported in the past 12 months.
Standard 115.368 Post Allegation Protective Custody
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy addresses the use and conditions of segregated housing. However, the
reported practice is that isolation is not used. If there is a need to separate residents for their
safety, the Policy will provide guidance on how it should be handled and the services
residents are required to receive.
Standard 115.371 Criminal and Administrative Agency Investigations
Exceeds Standard (substantially exceeds requirement of standard)
14
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and FDJJ 1919 provide direction for this standard. Administrative
investigations are conducted by the OIG and criminal investigations are conducted by the
Gainesville Police Department. The DCF is also called when there is an allegation of sexual
abuse and they may conduct a concurrent investigation. Both Policies direct staff to
cooperate with the OIG investigations.
Standard 115.372 Evidentiary Standards for Administrative Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The OIG, responsible for administrative investigations, imposes a standard of a preponderance
of the evidence for determining whether allegations are substantiated.
Standard 115.373 Reporting to Residents
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ 1919 and the facility’s PREA Policy allow for the victim to be informed that an
investigation has been concluded. At the conclusion of an OIG investigation, the victim or the
victim’s parents or legal guardian will be notified unless the allegation is unfounded. The
Policies require that all allegations be documented.
Standard 115.376 Disciplinary Sanctions for Staff
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
15
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy provides for disciplinary sanctions for staff to be up to and including
dismissal for violation of the PREA policies against sexual abuse and sexual harassment. It
states that the presumptive disciplinary sanction for staff who engages in sexual abuse will
be termination. In the past 12 months, no staff has been terminated or has resigned for
violating the facility’s PREA related policies.
Standard 115.377 Corrective Action for Contractors and Volunteers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and FDJJ 1919 state that any contractor or volunteer engaging in sexual
abuse of residents will be subject to referral to local law enforcement regarding criminal
charges and to relevant licensing bodies. FDJJ 1919 requires that the contractor or volunteer is
prohibited from having contact with residents. During the past 12 months, no contractor or
volunteer has been reported to law enforcement or any investigative agency for allegations of
sexual abuse.
Standard 115.378 Disciplinary Sanctions for Residents
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy addresses this standard. Residents found in violation of the facility’s zero
tolerance policy will receive disciplinary sanctions only after a formal disciplinary process.
There have been no criminal or administrative investigations of sexual abuse in the last 12
months.
Standard 115.381 Medical and Mental Health Screenings; History of Sexual Abuse
Exceeds Standard (substantially exceeds requirement of standard)
16
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
According to the PREA Policy, residents who disclose prior sexual victimization or who
disclose previously perpetrating sexual abuse during an intake screening will be offered a
follow-up meeting with a medical or mental health practitioner within 24 hours of the intake
screening. It also requires informed consent from residents 18 years of age and older before
reporting information about prior sexual victimization that did not occur at the facility. Staff
interviewed confirmed awareness of the policy and procedure.
Standard 115.382 Access to Emergency Medical and Mental Health Services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy requires that treatment services to every victim will be provided at no cost
to the victim and whether or not the resident names the abuser or cooperates with the
investigation. It also states that access to the services will be timely and unimpeded and the
scope and nature of the services will be based on the professional judgment of the medical
and mental health staff. Interviews with staff confirmed their knowledge of the procedures.
Standard 115.383 Ongoing Medical and Mental Health Care for Sexual Abuse Victims and
Abusers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy addresses ongoing medical and mental health care for sexual abuse
victims and abusers. It also provides for the appropriate tests to be provided and that the
facility will attempt to obtain a mental health evaluation within 30 days of learning of
resident-on-resident abusers and offer treatment deemed appropriate by a mental health
practitioner.
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Standard 115.386 Sexual Abuse Incident Reviews
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The PREA Policy and FDJJ 1919 provide information regarding the incident review team
and its role. The PREA Policy details the make-up of the sexual abuse incident review team
and the elements to be considered in their assessments of incidents. Interviews with staff
revealed that they understand the purpose of the incident review process.
Standard 115.387 Data collection
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ 1919 and interviews with staff confirmed that DJJ collects incident-based, uniform and
aggregated data regarding allegations of sexual abuse at facilities under its direct control
using a standardized instrument and set of definitions. Policy requires the collection of
accurate, uniform data for every allegation of sexual assault. The agency provides DOJ with
data as requested. The PREA Policy addresses the facility’s role in data collection.
Standard 115.388 Data Review for Corrective Action
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ 1919 addresses this standard. The statewide PREA Coordinator will review the collected
and aggregated data to assess and improve the effectiveness of the PREA related efforts and
initiatives. The Policy also states that an annual report will be prepared. A review of
documentation confirms this practice.
18
Standard 115.389 Data Storage, Publication and Destruction
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
According to FDJJ 1919 and the PREA Policy, it is required that data is collected and
securely retained for 10 years. The aggregated PREA data is reviewed and all personal
identifiers are removed. A review of documentation confirmed the practice.
AUDITOR CERTIFICATION:
The auditor certifies that the contents of the report are accurate to the best of her knowledge and no
conflict of interest exists with respect to her ability to conduct an audit of the agency under review.
March 30, 2015
Auditor Signature Date
19


state: FL

facility_name: Alachua Academy

summary: PREA

raw_content:
PREAAUDITREPORT (cid:134)(cid:134) INTERIM (cid:134)■ FINAL
JUVENILE FACILITIES
AuditorInformation
Auditor name: FloraBrooksBoyd
Address:5RosemountCourt,Blythewood,SouthCarolina29016
Email:fbb4577@aol.com
Telephonenumber:(803)312-5199
Date of facilityvisit:May13-14,2015
FacilityInformation
Facility name:AlachuaRegionalJuvenileDetentionCenter
Facilityphysical address:3440NE39thAvenue,Gainesville,Florida32600
Facilitymailing address:(ifdifferentfromabove) Same
Facility telephonenumber:(352)955-2105
The facilityis: Federal ■ State County
Military Municipal Private for profit
Private not for profit
Facility type: Correctional ■ Detention Other
Name of facility’s Chief Executive Officer:ForrestHallam
Number of staff assigned to the facility in the last 12 months: 56
Designed facility capacity: 48
Current population of facility:36
Facility security levels/inmate custody levels: Secure
Age range of the population: 8-18
Nameof PREAComplianceManager:ForrestHallam Title: Superintendent
Emailaddress:forrest.hallam@djj.state.fl.us Telephonenumber: (352)955-2105
Agency Information
Nameof agency:FloridaDepartmentofJuvenileJustice
Governingauthority or parentagency:(ifapplicable)Same
Physicaladdress:2737CenterviewDrive,Tallahassee,Florida32399
Mailingaddress:(ifdifferentfromabove)Same
Telephonenumber:(850)717-2533
AgencyChiefExecutiveOfficer
Name: Title:
ChristinaK.Daly DJJSecretary
Emailaddress:christy.daly@djj.state.fl.us Telephonenumber: (850)413-7143
Agency-WidePREACoordinator
Name: GeneMcMahon Title: StatewidePREA
Emailaddress: gene.mcmahon@djj.state.fl.us Telephonenumber: 850-688-0550
PREA Audit Report 1
AUDITFINDINGS
NARRATIVE
AlachuaRegionalJuvenileDetentionCenter(ARJDC)isahardwaresecurefacilityoperatedbytheFloridaDepartmentofJuvenileJustice
(FDJJ)thatservesyouthbetweentheagesof8and18yearsoldfromAlachuaandelevensurroundingcountieswhoaredetained
pendingadjudication,dispositionorplacementincommitmentfacilities.Thefacilitywasoriginallybuiltin1983asa56bedfacility.In2000,
anadditional20bedhousingunitwasaddedtohoweverduetorecentreductionsinfacilitybeds,ARJDCisnowconsidereda48bed
facility.Theaveragedailypopulationis30residentswithanaveragelengthofstayof12days.
Thefacilityoperateswithatotaloffifty-sixfulltimeemployeesincludingaSuperintendent,twoAssistantSuperintendents,aStaff
Assistant,aMaintenanceMechanic,aFoodServiceDirector,andthreefoodserviceworkers,sevenJuvenileJusticeDetentionOfficer
Supervisors(JJDOS),nineteenJuvenileJusticeDetentionOfficersII(JJDO)andtwenty-oneJJDOI's.
Thefacilityprovidessupervisionofyouthinasafe,secureandhumaneenvironment.Servicesforyouthincludeeducation,mentalhealth,
substanceabuseandhealthcare.MedicalandMentalHealthservicesarecontractedthroughCorrectCareSolutions(CCS).Medicaland
MentalHealthServicesareavailabletoyouthsevendaysaweek.Thecontractedstaffconsistsofaphysicianwhoisatthefacilityoncea
week,anAdvancedRegisteredNursePractitioner,twoRegisteredNurses,aLicensedPracticalNurse,apart-timeMedicalRecordsClerk
aswellasaLicensedandanunlicensedMentalHealthCounselorandapsychiatristwhovisitsthefacilityweekly.
EducationalservicesarefundedbytheFloridaDepartmentofEducationthoughtheAlachuaCountySchoolDistrictwhichcontractswith
NorthAmericanFamilyInstitute(NAFI)toprovideeducationalservices.Thereare threeteachers andaprincipaltoprovidethe
alternativeeducationprogramming.Thefacilityrecentlybegancollaboratingwithananimalrescuesheltertofosterpuppiesthataretoo
youngforadoption.Residentshavetheopportunitytocareforandreceivecompanionshipfromthepuppieswhilesocializingand
providingthepuppiesbasicinteractionskills.Thefacilityhasanarrayofvolunteerfaithbasedgroupsthatprovidefaithandworship
servicesaswellasbiblestudythroughouttheweek.Residentshavebeeninvolvedinpaintingthefacilityandwithstaffguidancehave
createdmultiplemuralsthroughoutthefacility.
PREA Audit Report 2
DESCRIPTIONOF FACILITYCHARACTERISTICS
Thephysicalplantconsistsofonemainbuildingwhichcontainsadministrativeoffices,adininghall,kitchen,conferenceroom,three
classrooms,amultipurposeroom,anintakearea,threeisolationroomsandfourhousingmodules.Thereare3housingmodulesformales
andoneforfemaleresidents.Sleepingroomsareequippedwithatoiletandsink.Eachmodulehasacommunityshowerroomwithsinks.
Thedininghallalsoservesasthevisitationareaforfamilies.Visitationisconductedfourtimesaweek.
Thefacilityisequippedwithavideosurveillancesystemwhichincludes71cameras.Rooms/officeswithoutcamerasaredesignatedbya
"RedDot"overthedoorwaytoindicateyoutharenotallowedaccesstothatroom/office.
PREA Audit Report 3
SUMMARY OF AUDITFINDINGS
Thenotificationoftheon-siteauditwaspostedonMarch23,2015morethansixweekspriortothefirstdateoftheon-siteaudit.The
postingofthenoticeswasverifiedbyphotographsreceivedelectronicallyfromthefacility’sPREAComplianceManager.Thephotographs
indicatednoticeswerepostedinvariouslocationsthroughoutthefacilityincludingthehousingunitandadministrativeareas.
ThePre-AuditQuestionnaire,policiesandsupportingdocumentationwerereceivedonApril14,2015uploadedtoaUBSflashdrive.A
reviewoftheflashdrivefilesrevealedthequestionnairewascompletedproperlyandkeydocumentswereprovided.
Theon-siteauditwasconductedMay13-14,2015.Aftermeetingwiththefacility’smanagementstaffandtworegionaloffice
representatives,acompletetourofthefacilitywasconducted.Duringthetour,youthwereobservedtobeunderconstantsupervisionof
thedirectcarestaffwhileinvolvedinschoolandotheractivities.Observationrevealeda1:8stafftoresidentsratiowasmaintained.The
housingmoduleswerebrightlypaintedwithmuralsonthewalls.Showerstallshadshowercurtainstoallowresidents’privacywhiletaking
showersinthecommunityrestrooms.Observationofthesurveillancesystemmonitorsinthemaincontrolroom,revealedtoiletsin
isolationroomsandthemedicalexamareahavebeenblacked-outtoeliminatethepossibilityofcross-genderviewing.
Overthetwo-dayon-sitevisit,14staffmembers,includingtwocontractorsanddirectcarestafffromallthreeshifts,wereinterviewed.
Overall,theinterviewsrevealedstaffareknowledgeableofPREAstandardsandwereabletoarticulatetheirresponsibilities.Eight
residents,includingatransgenderresidentwerealsointerviewed.Residentswereinformedoftheirrighttobefreefromsexualabuseand
harassmentandhowtoreportsexualabuseandharassment.Thetrainingrecordsofstaffinterviewedandthefilesofresidents
interviewedwerereviewedalongwithpolicies/proceduresandothersecondarydocumentation.
Thefacilitywasfoundtobeincompliancewithallapplicablestandardsasindicatedbelowanddetailedthroughoutthisreport.
Number ofstandards exceeded: 0
Number ofstandards met: 3 9
Number ofstandards notmet:0
Number of standards not applicable: 2
PREA Audit Report 4
Standard 115.311Zero tolerance of sexual abuse and sexual harassment; PREA Coordinator
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFacilityOperatingProcedure(FOP)-PREAmandateszero-toleranceofsexualabuseandsexualharassmentandoutlineshowthe
facilitycarriesoutitsapproachtopreventing,detectingandrespondingtosexualabuseandsexualharassment.Thepolicyincludes
definitionsofprohibitedbehaviorsandsanctionsforthosefoundtohaveparticipatedinprohibitedbehaviors.Thepolicyalsoprovides
strategiesandresponsesforreducingandpreventingsexualabuseandharassment.
ARJDCisajuveniledetentioncentergovernedandoperatedbytheFDJJwhichemploysanagency-widePREACoordinatorwhoisinan
upper-levelmanagementpositionwithintheagency.ThePREACoordinator'sinterviewrevealedhehassufficienttimeandauthorityto
develop,implementandoverseetheagency’seffortstocomplywithPREAstandardsinalloperatedandcontractedfacilities.Thefacility’s
SuperintendentservesasthePREAComplianceManager.AninterviewwiththePREAComplianceManagerrevealedhehassufficient
timetooverseethefacility’sPREAcomplianceeffortsandtoperformhisotherduties.
Standard 115.312Contracting with other entities for the confinement of residents
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJhasapproximately50contractswithprovidersfortheconfinementofjuvenilesinresidentialfacilitiesthroughouttheStateofFlorida.
Areviewofasignedcontractrevealedprovider’sagreementtocomplywithallrequirementsandstandardsofthePrisonRapeElimination
Act28CFRPart115asoutlinedinFDJJPolicy1919.Allnewandrenewedcontractsincludetherequirement forproviderstobein
compliancewithPREAstandards.
PREA Audit Report 5
Standard115.313Supervision and monitoring
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresthefacilitytodevelop,implementanddocumentanapprovedstaffingplan.Althoughthereisnomandatein
policyfora1:8stafftoresidentratioduringwakinghoursora1:16stafftoresidentratioduringsleepinghours,thestaffingplandoes
reflecttheratiosasrequiredbythisstandard.Thestaffingplanisbaseduponthefacility’scapacityof48residents.ARJDCFOP-PREA
requiresthefacilitytodocumentdeviationsfromthestaffingplanontheShiftReporthoweverduetothefacility’shold-overpolicy;there
werenodeviationsfromtheplantoreview.
DocumentationoftheannualreviewofthestaffingplandatedSeptember25,2014wasreviewedandfoundtobeincompliancewithall
elementscontainedin(d)-1ofthisstandard.
ARJDCutilizesvideomonitoringcombinedwithdirectstaffsupervisiontoprotectresidentsfromsexualabuseandsexualharassment.
Documentationofunannouncedroundsconductedbyintermediateandupperlevelstaffwerereviewedandrevealedunannounced
roundsarebeingconductedonallshiftsandinallareasofthefacility.
Standard115.315Limits to cross-gender viewing and searches
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAprohibitscross-genderstripsearches,orpatdownsearchesofyouth,exceptinexigentcircumstances.Staffand
residentinterviewsverifiedthatthepracticeisconsistentwiththepolicy.Theprohibitionofcross-gendervisualbodycavitysearchesis
addressedinARJDCFOP-PREAandwasverifiedduringstaffinterviews.
ARJDCFOP-PREAstatesthefacilitymustbeconfiguredtoallowresidentstoshower,performbodilyfunctionsandchangeclothing
withoutstaffoftheoppositesexviewingtheirbodies.Staffandresidentinterviewsconfirmthereisnocross-genderviewingbysamesex
staffandotherresidentswhileshowering,usingthetoiletorwhiledressing.Duringthetourofthemaincontrolroom,toiletsinthe
confinementroomswereobservedtobeblacked-outonthemonitor,eliminatingthepossibilityofcross-genderviewing.
FDJJPolicy1919PREArequiresoppositegenderstaff,volunteersandcontractorsenteringhousingunitstoannouncethemselves.This
practicewasverifiedduringstaffandresidentinterviews.
ARJDCFOP-PREAprohibitsthesearchofatransgenderorintersexresidentsolelyforthepurposeofdeterminingtheresident’sgenital
statusandstaffinterviewsverifiedcompliance.
PREA Audit Report 6
Standard 115.316Residents with disabilities and residents who are limited English proficient
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresaccommodationsbemadetoensureresidentswithdisabilitiesorwhoarelimitedEnglishproficientare
providedmeaningfulaccesstoallaspectsofthefacility’seffortstoprevent,protectandrespondtosexualabuseandharassment.This
policyalsostatesthefacilityprohibitstheuseofresidentinterpreter,residentreadersoranykindofresidentassistantsexceptwhena
delayinobtaininginterpretersservicescouldjeopardizesaresident’ssafety.Residentandstaffinterviewsverifiedthatresidentsarenot
usedasinterpreters,assistantsorreadersforotherresidents.
ARJDCPolicyFOP-PREAdescribeshowinterpretersorotherservicesneededtoassistresidentswithdisabilitiesorresidentswhomay
belimitedEnglishproficientwillbeprovidedeitherbyqualifiedstafforoutsideresources,suchasthelocalschooldistrict.TheStateof
FloridahasaMemorandumofUnderstanding(MOU)withtheLanguageLineforinterpretiveserviceswhichisavailabletothefacilityas
needed.NAFIprovideddocumentationthatresidentswithdisabilitieswillbeprovidedwithaccommodationstoensureproper
communicationofthefacility’sPREAproceduresandpractices.
ARJDCFOP-PREArequiresstafftoprovidePREAinformationinaformatassessabletoallresidentsincludingthosewhomaybelimited
Englishproficient,deaf,visuallyimpairedorotherwisewithadisability,aswellastoresidentswhohavelimitedreadingskills.
Standard 115.317Hiring and promotion decisions
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresthatcriminalbackgroundchecksbeconductedeveryfiveyears.Applicantsarerequiredtosign
acknowledgingmaterialomissionregardingmisconduct,orfalseinformationaregroundsfortermination.
Aninterviewwithhumanresourcesstaffanddocumentation revealedcriminalbackgroundchecksareconductedandthatquestions
regardingpastconductareaskedandrespondedtoduringtheinterviewprocess.Additionally,contractprovidersandvolunteerswhohave
contactwithresidentsarerequiredtohavecriminalbackgroundchecks.
ARJDCFOP-PREAdoesnotrequireconsultingwiththechildabuseregistrybeforehiringorenlistingservicesofanycontractorwhohas
contactwithresidents.ThePREACoordinatorprovideddocumentationthatFloridaStatelawdoesnotallowFDJJtocontacttheabuse
registryforthepurposeofscreeningapplicants.
PREA Audit Report 7
Standard 115.318Upgrades to facilities and technologies
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDChasnotacquiredanynewfacilitiesorupdatedsurveillancetechnologysinceAugust20,2012.Thevideomonitoringsystemwas
assessedduringtheannualreviewofthestaffingplanonSeptember25,2014.AnewDVRsystemwasrecentlypurchasedandinstalled.
___________________Noupgradeswererecommendedtoenhancethefacility’sabilitytoprotectyouthfromsexualabuseandnoblind
spotswereidentified.
Standard 115.321Evidence protocol and forensic medical examinations
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresstafftoreportallegationsofsexualabusetolocallawenforcement(theAlachuaCountySheriff’s
Department)forcriminalinvestigationsandtotheFloridaCentralAbuseHotLineandFDJJ’sCentralCommunicationCenter(CCC).
ARJDCdoesnothaveaMOUordocumentedattemptstoobtainaMOUwiththeAlachuaCountySheriff’sDepartmenthoweverthe
ARJDCFOP-PREArequireswhentheinvestigatingagencyarrivesatthefacilitytoconductaninvestigation,facilitystaffwillprovidea
copyofDirective3-05fromDJJInspectorGeneralrequestingtheinvestigativeagencytofollowuniformevidenceprotocolwhich
maximizesthepotentialforobtainingusablephysicalevidenceforcriminalprosecution.
ARJDChasaMOUwiththeAlachuaCountyVictimServicesandRapeCrisisCenterforvictims’advocacyandcounselingservices.
DocumentationwasprovidedthatresidentsexualassaultvictimswillbetakentotheShandsNorthFloridaRegionalHospitalforaforensic
medicalexaminationbyaSANEcertifiedmedicalexaminerasverifiedduringaninterviewaAlachuaCountyVictimServicesandRape
Crisis representative.
PPRREEAA Audit Report 8
Standard 115.322Policies to ensure referrals of allegations for investigations
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequirestheimmediatereferralofallsexualabuseallegationstolocallawenforcement,theFloridaAbuseHotLine
andCCC.Inthepast12months,ARJDChashadnoallegationsofsexualabuseandreceivednoallegationsthatoccurredatanother
facility.InterviewswiththeSuperintendentandotherstaffverifiedtheirknowledgeofthepolicy’srequirements.
FDJJ’swebsiteincludesaPREAsectionwhichincludesinvestigativeresponsibilitiesforconductinginvestigationsofallegationsofsexual
abuse.
Standard 115.331Employee training
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREA,thetrainingcurriculum,stafftrainingrecordsandstaffinterviewsindicatestaffreceivePREAtrainingduringinitial
trainingandannuallyduringrefreshertraining.Specifictopicsasoutlinedinthepolicyandthecurriculumareconsistentwiththis
standard’srequirementsandistailoredtothefacility’smaleandfemaleresidentpopulation.
Allemployeesaretrainedasnewhiresregardlessoftheirpreviousexperience.Employeestrainingrecordswerereviewedandstaff
interviewsverifiedstaffcomprehensionoftheirresponsibilitiesrelatingtoPREAstandards.
PREA Audit Report 9
Standard 115.332Volunteer and contractor training
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresvolunteersandcontractproviderswhohavecontactwithresidentstobetrainedontheirresponsibilitieson
sexualmisconductprevention,detection,reportingandrespondingtosexualabuse,assaultorsexualharassment.FOP-PREArequires
volunteersandcontractorstobetrainedontheirresponsibilitiesusingthePREAtrainingcourseontheFDJJwebsiteandcompletionof
thetrainingisverifiedbyanacknowledgmentformwhichmustbesignedbythevolunteer/contractorandthefacility’strainingcoordinator
orshiftsupervisor.
InterviewswithtwocontractprovidersandavolunteerrevealedtheyareknowledgeableconcerningtheirresponsibilitiesrelativetoPREA
andtheagency’szerotolerancepolicyregardingsexualabuseandharassment.
Standard 115.333Resident education
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresresidentstoreceivecomprehensiveeducationregardingthefacility’szerotolerancepolicyandhowtoreport
sexualabuseandsexualharassment.Duringintake,residentsviewtheagency'sPREAvideo,staffexplainthePREAhandoutand
residentssignverifyingtheyreceivedtheinformation.Documentationofresident’ssignatureswerereviewedandconfirmedduring
residentinterviews.Allresidentsinterviewedstatedtheyreceivedthisinformationthesamedaytheyarrivedatthefacilityandperiodically
thereafter.
StaffpresentthePREAinformationinamannerthatisaccessibletoallresidents.Ifneeded,thefacilityhasinternalandexternal
resourcestoprovidetranslationservices,hearingandvisualimpairmentservicesforresidentswithdisabilitiesorwhomaybelimited
Englishproficient.
ResidentinterviewsrevealedtheyaresomewhatknowledgeableoftheVictims’AdvocacyCenterandtheservicestheyprovide.
PREA Audit Report 10
Standard 115.334Specialized training: Investigations
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
TheAlachuaCountySheriff’sDepartmentandtheFloridaDepartmentofChildrenandFamiliesconductcriminalinvestigationsinto
allegationsofsexualabuse.ARJDCdoesnotconductanyinvestigationsthereforethisstandarddoesnotapply.
Standard 115.335Specialized training: Medical and mental health care
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresPREAtrainingforallemployeesandspecializedtrainingformedicalandmentalhealthstaff.CorrectCare
Solutions,themedicalandmentalhealthprovider,ensuresthatspecializedtrainingisprovidedformedical/mentalhealthstaff.
Thetrainingcurriculumanddocumentationofthespecializedtrainingwasreviewed.Interviewswithmedicalandmentalhealthstaffalso
verifiedcompliancewiththisstandard.
Facilitynursesdonotconductforensicexaminations.
PREA Audit Report 11
Standard 115.341Screening for risk of victimization and abusiveness
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJ’sVulnerabilitytoVictimizationandSexuallyAggressiveBehavior(VSAB)formsarecompletedbytheagency'sprobationstaff
howeverARJDCFOP-PREArequiresthecompletionof VSABifyoutharriveatthefacilitywithoutacompletedform.Documentationand
residentinterviewsrevealedthatriskscreeningsarebeingconductedandindicatedtheywereaskediftheyhaveeverbeensexually
abused,whethertheyidentifywithbeinggay,lesbian,bi-sexual,transgenderorintersex,iftheyhaveanydisabilities,andwhetherthey
thinktheyareindangerofsexualabuseatthefacility.
Areviewofresidentsfilesrevealedriskscreeningsarecompletedandplacedinresident'sfiles.
Standard 115.342Use of screening information
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresvictimizationscreeninginformationtobereviewedandsignedbystaffwhodeterminearesident’sroom
assignmentandtheroom’sproximitytodirectcarestafftoensureresident’ssafety.ThefacilityalsoutilizestheClassificationAlerts
Systemtoensurethatstaffworkingdirectlywithresidentsareadvisediftheresidentisidentifiedasbeingatriskforvictimizationorposing
arisk.
ARJDCFOP-PREAprecludeslesbian,gay,bi-sexual,transgenderandintersex(LGBTI)residentsfrombeingplacedinaparticular
moduleandstatesthatLGBTIidentificationorstatusisnotanindicatoroflikelihoodofbeingsexuallyabusive.Transgenderorintersex
resident’sownviewwithrespecttohis/hersafetyisgivenseriousconsiderationasevidencedbythefactatransgendermaleresidentwas
housedinthefemalemodulebecauseheexpressedseriousconcernsregardinghissafety,ifhousedwithmaleresidents.Residentsinthe
femalemodulearehousedinsinglerooms.
Transgenderandintersexresidentsaregiventheopportunitytoshowerseparatelyfromotheryouth.Staffinterviewsalsoverified
compliancewiththisstandard.
PREA Audit Report 12
Standard 115.351Resident reporting
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAprovidesmultiple-waysforresidentstoprivatelyreportsexualabuse,sexualharassment,retaliationandstaffneglect
includingtellingastaffmember,callingFloridaAbuseHotLine,completingaPREAreportingformanddepositingitaPREAboxlocatedin
eachhousingmodule.
FOP-PREArequiresresidentstohaveonewayofreportingsexualabuseandsexualharassmenttoapublicorprivateentityorofficethat
isnotapartoftheagency.ResidentsmaycalltheFloridaAbuseHotLineortheVictim'sAdvocacyCenter.Signsarepostedthroughout
thefacilitywiththehotlinenumbers.
FOP-PREArequiresstafftoallowresidentstouseatelephonetocallahotlineuponrequest,withouthavingtoobtainstaffpermission
andthatmandatesstaffnottoquestionresidentsaboutthereasonforthecall.Staffaretodialthehotlinenumber,handthephonetothe
residentandremainatadistancethatallowstheresidenttohaveaprivateconversation.
Standard 115.352Exhaustion of administrative remedies
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAstatesthefacilityisexemptfromthisstandardbecauseitdoesnothaveadministrativeproceduresinplacefor
residentstoreportallegationsofsexualabuseandsexualharassment.
PREA Audit Report 13
Standard 115.353Resident access to outside confidential support services
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAensuresresidentsareprovidedaccesstooutsideconfidentialsupportiveservices.Thefacilityhasobtainedasigneda
MOUwiththeAlachuaCountyVictim'sAdvocacyCenterforatwenty-fourhouradayconfidentialsexualassaulthotline,supportduring
forensicexaminationsandthreeface-to-facefollow-upcounselingsessions.PosterscontainingtheCenter'shotlinenumber,mailing
addressandbasicinformationabouttheservicewerepostedthroughoutthefacilityandresidentinterviewsrevealedtheyaresomewhat
knowledgeableabouttheservices.
Attorneysandotherlegalrepresentativesareprovidedwithreasonableandprivateaccesstoresidents,uponrequest.Residentsmaycall
theirparents/legalguardiansandreceivevisitsfromthemuptofourtimesaweek.
Standard 115.354Third-party reporting
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJ’swebsiteprovidesthepublicwithinformationregardingthird-partyreportingofsexualabuseorsexualharassmentonbehalfofa
resident.Residentinterviewsrevealedtheirawarenessofreportingsexualabuseorsexualharassmenttoothersoutsideofthefacility
includingtheirparents/legalguardians.
PREA Audit Report 14
Standard 115.361Staff and agency reporting duties
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCstaffaremandatedreportersandarerequiredbyARJDCFOP-PREAandFDJJPolicy1919toimmediatelyreportanyknowledge,
suspicionorinformationtheyreceiveregardingsexualabuseandharassment,retaliationagainstresidentsorstaffwhoreportany
incidentsoranystaffneglectorviolationofresponsibilitiesthatmayhavecontributedtoanincidentorretaliation.Randomstaffinterviews
alsohelpedtoverifythefacility’scompliancewiththisstandard.
Aninterviewwiththenurseconfirmedherresponsibilitytoinformresidents18yearsoldofherdutytoreportandlimitationsof
confidentiality.
Standard 115.362Agency protection duties
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresstafftotakeimmediateactiontoprotectaresidentwhenhe/sheisidentifiedasbeingsubjecttosubstantial
riskofimminentsexualabuse.Therewerenoresidentsidentifiedasbeingatriskforsexualabuseinthepast12months,asrevealedin
interviewswiththeSuperintendentandrandomstaff.
PREA Audit Report 15
Standard 115.363Reporting to other confinement facilities
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequirestheSuperintendenttonotifytheheadofanotherfacilitywithin72hoursuponreceivinganallegationthata
residentwassexuallyabusedwhileconfinedatanotherfacility.Duringthepast12months,therewerenoallegationsreceivedthata
residentwasabusedwhileconfinedtoanotherfacilityandtherewerenoallegationofsexualabusereceivedbyARJDCfromother
facilities.
Standard 115.364Staff first responder duties
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresstafftotakespecificstepstorespondtoareportofsexualabuseincluding;separatingtheallegedvictimfrom
theabuser;preservinganycrimescenewithinaperiodoftimethatstillallowsforthecollectionofphysicalevidence;requestthealleged
victimnottakeanyactionthatcoulddestroyphysicalevidence;andensurethattheallegedabuserdoesnottakeanyactiontodestroy
evidence,iftheabusetookplacewithinatimeperiodthatstillallowsforthecollectionofphysicalevidence.Randomstaffinterviews
revealedconsiderableknowledgeofactionstobetakenuponlearningthataresidentwassexuallyabused.
Therewerenoallegationofsexualabuseduringthepast12months.
PREA Audit Report 16
Standard 115.365Coordinated response
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresthedevelopmentofawrittenplantocoordinateactionstakeninresponsetoanincidentofsexualassault
amongstafffirstresponders,medical,andfacilityleadership;however,aplanwasnotavailable.Thefacility’scoordinatedstaffresponse
planwasreviewedandisincompliancewiththisstandard.
InterviewswiththeSuperintendentandotherstaffrevealedthattheyareknowledgeableoftheirdutiesinresponsetoanallegationof
sexualabuse.
Standard 115.366Preservation of ability to protect residents from contact with abusers
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJisnotacollectivebargainingagencythereforethisstandardisnotapplicable.
PREA Audit Report 17
Standard 115.367Agency protection against retaliation
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJPolicy1919PREArequirestheprotectionofresidentsandstaffwhohavereportedsexualabuseorharassmentorwhohave
cooperatedinasexualabuseorsexualharassmentinvestigation.Themonitoringwilltakeplaceforaperiodof90daysorlonger,as
needed.OneoftheAssistantSuperintendentisresponsibleformonitoringretaliation.Therewerenoincidentsofretaliationinthepast12
months.
Standard 115.368Post-allegation protective custody
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
AccordingARJDCFOPPREAaresidentwouldonlyberestrictedtohis/hersingleroomoranisolationroomasalastmeasuretokeepa
residentwhoallegedsexualabusesafeandthenonlyuntilanalternativemeansforkeepingtheresidentsafecanbearranged.There
werenoresidentsexualabuseallegationsinthepast12months.
PREA Audit Report 18
Standard 115.371Criminal and administrative agency investigations
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAstatesthatFDJJdoesnotconductcriminalinvestigationsofresidents’allegationsofsexualabuse.Locallaw
enforcement(AlachuaCountySheriff’sDepartment)andtheFloridaDepartmentofChildrenandFamiliesconductcriminalinvestigations.
FDJJ’sOfficeofInspectorGeneral(OIG)reviewsallegationstoidentifyanymisconductbystaffrelatedtoFDJJregulatoryguidance.
TherewerenoinvestigationsofallegedresidentsexualabuseatARJDCduringpast12months.
Standard 115.372Evidentiary standard for administrative investigations
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAstatesthefacilityshallimposenostandardhigherthanapreponderanceoftheevidenceindeterminingwhether
allegationsofmisconductbystaffissubstantiated.
PREA Audit Report 19
Standard 115.373Reporting to residents
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequirestheSuperintendenttonotifyresidentswhoallegedsexualabusewhenthefacilitylearnsthatthealleged
abuserhasbeenindictedonchargesorconvictedonachargerelatedtosexualabusewithinthefacility.ThepolicyalsostatestheOIG
willnotifyresidentsandparents/guardianswhetheranallegationhasbeendeterminedtobesubstantiated,unsubstantiatedorunfounded.
Therewerenocriminalandadministrativeinvestigationsduringthepast12months.
Standard 115.376Disciplinary sanctions for staff
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134) ■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
AJDCFOP-PREAmandatesstaffdisciplinarysanctionsuptoandincludingterminationforviolatingtheagency’ssexualabuseorsexual
harassmentpolicies.Thepolicyalsomandatestheviolationbereportedtolocallawenforcement.Noemployeeshavebeenterminatedor
disciplinedinthepast12monthsforviolationofthefacility’ssexualabuseorharassmentpolicies.
PREA Audit Report 20
Standard 115.377Corrective action for contractors and volunteers
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresvolunteersandcontractorsinviolationofthefacility’spoliciesandproceduresregardingsexualabuseand
harassmentofresidentstobereportedtolocallawenforcementunlesstheactivitywasclearlynotcriminalandtorelevantlicensing
bodies.ThiswasverifiedduringaninterviewwiththeSuperintendent.Therehavebeennoallegationsofvolunteersorcontractorssexual
abuseorsexualharassmentreportedinthepast12months.
Standard 115.378Disciplinary sanctions for residents
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREAstatesthatresidentsmayreceivedisciplinarysanctionsfollowinganadministrativefindingoracriminalinvestigation
thatresidentengagedinyouth-on-youthsexualabuseandsanctionsshallbecommensuratewiththenatureandcircumstancesofthe
sexualabuse,theresident’sdisciplinaryhistory,andthesanctionsimposedforcomparableoffensesbyotherresidentswithsimilar
histories.Therewerenoadministrativeorcriminalfindingsofguiltforresident-on-residentsexualabuseinthepast12months.
PREA Audit Report 21
Standard 115.381Medical and mental health screenings; history of sexual abuse
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresresidentswhodiscloseahistoryofsexualabuseorwhodisclosepreviouslyperpetratingsexualabusetobe
referredformedicalandmentalhealthscreeningserviceswithin24hoursofthescreening.Staffinterviewsverifiedcompliancewiththis
standardanddocumentationdemonstratingtheimmediatenotificationofthemedicalandmentalhealthstaffwasprovided.
Medical/mentalhealthstaffobtaininformedconsentfromresidents18yearsofage.
Standard 115.382Access to emergency medical and mental health services
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnot meetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequirestimelyandunimpededaccesstoemergencymedicaltreatment,crisisinterventionservicesandvictim
advocacyservices.AresidentvictimwouldbetransportedtotheShandsNorthFloridaRegionalHospitalforaforensicexaminationatno
costtothevictim.Medicalstaffarerequiredtodocumenttheresponseandtimelinessofemergencymedicaltreatmentandfollow-up.
PREA Audit Report 22
Standard 115.383Ongoing medical and mental health care for sexual abuse victims and abusers
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresthatamedicalandmentalhealthevaluationandtreatment,asdeterminedbymedical/mentalhealthstaff,be
offeredtoresidentvictimsofsexualabuse.Interviewswithmedicalandmentalhealthstaffrevealedtheirawarenessofthepolicy's
requirements.
Standard 115.386Sexual abuse incident reviews
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequirestheSuperintendenttoconductasexualassaultincidentreviewteammeetingwithin30daysofthe
conclusionofeachinvestigation.Thepolicymandatesreviewteamparticipationtoincluderegionalofficestaff, AssistantSuperintendent,
facilitysupervisor,medicalandmentalhealthstaff,andOIGstaff,ifOIGinvestigatedtheincident,TheFDJJPREACoordinatorwill
prepareareportofthereviewteam’sfindingsandsubmitthereporttotheAssistantSecretaryforDetentionServices,regionalofficestaff
andthefacility’s Superintendent.
Therewerenocriminalinvestigationsofsexualabuseinthepast12months.
PREA Audit Report 23
Standard 115.387Data collection
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJusesastandardizedinstrumentwithdefinitionstocollectaccurate,uniformdataforeveryallegationofsexualassault.The
instrumentincludesthedatanecessarytoanswerallquestionsfromthemostrecentversionoftheSurveyofSexualviolenceconducted
bytheDepartmentofJustice.ARJDCFOP-PREAstatestheCCCwillcollectalldatarelatingtoPREA. Areviewoftheannualreport
revealeditwascompletedaccordingtothisstandard.
Standard 115.388Data review for corrective action
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
(cid:134)■ MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
FDJJ’sannualreportforfiscalyear2013-2014indicates32PREArelatedallegationsreportedbydetentioncentersandresidential
facilitiesthroughouttheagencyhowevertherewerenoPREArelatedincidentsindicatedforARJDC.TheFDJJPREACoordinatorreviews
datatoimprovetheeffectivenessofitsprevention,protectionandresponsepolicies,practicesandtraining.Theannualreportismade
availabletothepubliconFDJJ’swebsite.
PREA Audit Report 24
Standard 115.389Data storage, publication, and destruction
(cid:134) Exceeds Standard (substantially exceeds requirementof standard)
■
(cid:134) MeetsStandard (substantial compliance;complies in all material ways withthe standard for the
relevantreview period)
(cid:134) Does NotMeetStandard (requires corrective action)
Auditor discussion,includingthe evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility doesnotmeetstandard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
ARJDCFOP-PREArequiresthatsexualabuseandsexualharassmentdatabecollectedandsecurelyretainedfor10yearsaccordingto
theStateofFlorida’srecordsretentionschedule.TheannualreportismadeavailabletothepubliconFDJJ’swebsite.
AUDITOR CERTIFICATION
I certify that:
(cid:133)■ The contents of this reportare accurateto the bestof my knowledge.
(cid:133)■ No conflictof interest existswith respecttomy ability toconductan auditof the agencyunder
review, and
(cid:133)■ I have not included in the final report any personally identifiable information (PII) about any
inmate or staff member, except where the names of administrative personnel are specifically
requested in the report template.
May28,2015
_
AuditorSignature Date
PREA Audit Report 25

source: DJJ

report_type: PREA

program_name_raw: alachua regional juvenile detention center