facility_name: Miami Youth Academy

summary: PREA

raw_content:
PREA AUDIT: AUDITOR’S SUMMARY
REPORT JUVENILE FACILITIES
Name of Facility: Miami Youth Academy
Physical Address: 10855 SW 84 Street, Miami, FL 33173
Date report submitted: November 3, 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: October 7, 2015
Facility Information
Facility Mailing Address: 10855 SW 84 Street, Miami, FL 33173
Telephone Number: 786-518-3263
The Facility is: Military County Federal
X Private for profit Municipal State
Private not for profit
Facility Type: Detention X Corrections Other
Name of PREA Compliance Manager: Johnny Richardson Title: Facility Administrator
Email Address: johnny.richardson@us.g4s.com Telephone Number:
786-518-3263
Agency Information
Name of Agency: G4S Youth Services, LLC
Governing Authority or
Parent Agency: NA
Physical Address: 6302 Benjamin Road, Suite 400, Tampa, FL 33643
Mailing Address: Same as Physical Address
Telephone Number: 813-514-6275
Agency Chief Executive Officer
Name: James Hill Title: CEO
Email Address: jim.hill@us.g4s.com Telephone Number: 8 1 3 - 5 1 4 - 6 2 7 5
Agency Wide PREA Coordinator
Name: Bobbi Pohlman-Rodgers Title: Sr. Director of JJDPA/PREA Compliance
954-818-5131
Email Address: bobbi.pohlman@us.g4s.com Telephone Number:
1
AUDIT FINDINGS
NARRATIVE:
Miami Youth Academy is a 24-bed residential facility for male juvenile offenders who have been
committed to the Florida Department of Juvenile Justice (DJJ). It is located in Miami, Florida and is
operated by G4S Youth Services, LLC through a contract with DJJ. The facility serves residents
ranging from 14 to 18 years of age who are classified as low to moderate risk needing Substance
Abuse Treatment Overlay Services in a residential environment. The length of stay is from three to
six months for low risk residents and six to nine months for those classified as moderate risk.
All residents receive medical services on-site which are provided by Registered Nurses and there is a
contract physician who visits the facility weekly. Mental health services are led by the Clinical
Director who supervises three Therapists; two Case Managers; Recreation Therapist; and Transition
Specialist. Additional mental health services are provided by the following contract staff:
psychiatrist; psychologist, behavior analyst, and certified addiction counselor. Education services are
provided by Miami-Dade County Public Schools through academic and career education instruction
and include all course requirements for a standard high school diploma. The treatment team for each
resident consists of a Therapist; Case Manager; Youth Care Specialist; Nurse; Assistant Facility
Administrator; and a representative from education.
A Performance Plan of goals and expectations is developed by the treatment team which meets on a
monthly basis with the resident to discuss his progress. Parents/guardians are considered a member of
the team and are invited to attend all meetings, either in person or by telephone. The facility assists
residents with completing court ordered community sanctions or service hours. The residents are
involved in groups based on the concept of restorative justice. A behavior management system
exists where a resident may earn advanced levels through positive behavior and level privileges
increase with the earning of each advanced level.
DESCRIPTION OF FACILITY CHARACTERISTICS:
There is one main building that houses the program. The front of the building contains a reception
area, administrative offices and a conference room. Beyond this section of the building is a large
area that is divided into the dayroom and the dining room; the kitchen is adjacent to the dining room.
There is also a hallway in this area and one end of the hall include the education office and two
classrooms; the other end of the hall contains the residents’ living area; medical clinic; bathroom;
laundry room; and offices. There are a total of 12 rooms with two residents assigned to each room.
Residents are provided a reasonable amount of privacy during showers, while using the toilet, and
when changing clothes. PREA related information is posted in various areas of the facility.
There is a large patio on the back of the building and grounds that provide ample space for various
recreation and other activities. A butterfly garden is maintained by residents under supervision of
staff in an area of the outside grounds. The garden is stocked with flowers that primarily attract
butterflies.
2
The number of staff currently employed at the facility that may have contact with residents is 37. In
the past 12 months there have been five contractors and two volunteers who may have contact with
residents. The number of residents admitted to the facility in the past 12 months is 66.
SUMMARY OF AUDIT FINDINGS:
An introductory conference call was held prior to the site visit and the audit process was discussed
with facility staff and the DJJ statewide PREA Coordinator. The notifications of the on-site audit
were posted in the facility prior to the site visit and pictures of the postings were forwarded to the
Auditor. The Pre-Audit Questionnaire was uploaded to a flash drive with policies and supporting
documentation and was received by the Auditor prior to the site visit. There were follow-up
communication with the Facility Administrator and additional information was provided and
information was clarified as needed. Corrective actions were discussed and implemented and
additional information was provided as needed. The Facility Administrator serves as the PREA
Compliance Manager.
The on-site audit was conducted October 7, 2015. Introductions were conducted with the Facility
Administrator, followed by a comprehensive tour of the facility. During the tour, staff members
were observed to be providing engaged supervision to the residents. Four randomly selected staff
members and six residents were interviewed. Ten specialized interviews were conducted which
included contractors and a volunteer. Direct care staff members were interviewed from all shifts.
During the on-site audit, additional documentation was provided as requested. At the conclusion of
the site visit, a close-out meeting was held with the Facility Administrator.
Number of standards exceeded: 0
Number of standards met: 37
Number of standards not met: 0
Number of standards not applicable: 4
3
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)
Policy 10-25, Prison Rape Elimination Act (PREA), provides guidelines for implementing the
facility’s approach to complying with the requirements of the PREA standards and zero-
tolerance of all forms of sexual abuse and sexual harassment. The Policy contains definitions
of prohibited behaviors regarding sexual abuse and sexual harassment. The facility’s PREA
Policy is aligned with the over-arching Florida Department of Juvenile Justice PREA Policy
(FDJJ 1919) for compliance with the standards.
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)
This standard is not applicable. The facility does not contract with other facilities for the
confinement of its 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)
Policy 10-25 and practice provide that periodic internal reviews of the staffing plan are
conducted to ensure adequate levels of staffing. A review of documents included a Staffing
Plan Assessment which was completed by DJJ’s statewide PREA Coordinator based on the
staffing requirements of the contract. The facility reports no deviations from the staffing
ratios of 1:8 during the awake hours and 1:12 during the sleeping hours. The facility uses
staff holdovers, when needed, to maintain compliance with the required ratios. Policy 10-25
identifies the staff members who are required to conduct unannounced rounds. Interviews and
documentation confirmed that the 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
4
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Policy 10-3 and staff and resident interviews revealed that cross-gender strip searches and
cross-gender frisk searches are not conducted. Policy 10-3 addresses staff conducting searches
of residents and provides the details of each type search. Facility policy and resident and staff
interviews supported that residents are able to shower, use the toilet, and change clothes
without being viewed by female staff. Policy 10-25 states and staff interviews support that
transgender or intersex residents shall not be searched or physically examined for the sole
purpose of determining their genital status. The facility completed a corrective action by
conducting enhanced training on the searches of residents, including the searches of
transgender and intersex youth as documented by training records and materials.
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)
Policy 10-25 provides that residents may not be used as interpreters unless an extended delay
in obtaining an interpreter could compromise the resident’s safety, the performance of the first
responder duties, or the investigation of the resident’s allegation. The facility may use the
Registry of Certified Court Interpreters as a resource, as well as the agency’s staff who may
serve as interpreters. Interviews with staff confirmed that staff members are used as
interpreters and for other assistance to ensure residents’ understanding of the information
provided. The PREA pamphlets are provided in other dominant languages of the facility’s
population.
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)
Policy 3-16, Employee Recruitment and Selection, and FDJJ Policy address this standard.
The Policies prohibit hiring, promoting or contracting with anyone who has been convicted of
engaging in any activity prohibited by the standard and provide directions regarding
background checks and screenings. Interviews with staff and a review of a sample of
documentation revealed that background checks are conducted as required.
Standard 115.318 Upgrades to Facilities and Technology
Exceeds Standard (substantially exceeds requirement of standard)
5
Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
This standard is Not Applicable; the facility opened in April 2014 and no additional
adjustments have been made.
Standard 115.321 Evidence Protocol and Forensic Medical Examinations
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)
Policy 10-25 provides that the facility is not responsible for conducting administrative or
criminal investigations. FDJJ 1919 and Policy 10-25 support that the FDJJ 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 local law enforcement is responsible for conducting criminal
investigations. The facility has written information regarding PREA related investigations,
provided by DJJ, to share with local law enforcement investigators. Documented
correspondence shows that the form has been received by the Miami-Dade Police
Department.
A Memorandum of Understanding exists between the Roxcy Bolton Rape Treatment Center
and the facility. Through the Roxcy Bolton Rape Treatment Center, services are provided at
Jackson Memorial Hospital and Jackson South Community Hospital to victims and non-
offending family members and relatives of the victims. The center provides comprehensive
quality medical treatment and crisis counseling by a team of doctors, nurses and therapists all
sensitively trained to work with rape victims. According to the advocacy, all services are at
no cost to the victim and are completely confidential regardless of police involvement.
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)
Policy 10-25 and FDJJ 1919 identify who is responsible for conducting the criminal and
administrative investigations and instructs staff to cooperate with investigations. Related
policies are published on the DJJ website. Additionally, the facility provides parents and
guardians a copy of the Parent Handbook that contains information regarding how parents
and residents may submit a grievance and how key staff at the facility can be contacted. All
referrals of allegations for investigations are documented by staff.
6
Standard 115.331 Employee 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)
Policies 5-1 and 5-2 address employee training. Documents and interviews show that PREA
training is provided to staff and refresher training is provided periodically to address PREA
topics. The facility maintains documentation of the receipt of PREA training and a copy of
the DJJ comprehensive PREA training curriculum. Florida DJJ provides on-line training and
facility in-house training has been conducted regarding specific areas of the standards.
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)
FDJJ 1919 and the training curriculum support that volunteers and contractors be trained on
their responsibilities regarding the zero-tolerance of sexual assault and sexual harassment.
Interviews with a volunteer and contractors supported that PREA training has been
conducted.
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)
According to Policy 10-25, resident and staff interviews, and a review of documentation, all
residents are provided PREA information during the intake process. Staff members may assist
with the PREA education for residents that are limited English proficient, visually impaired,
otherwise disabled, or have limited reading skills. Support services may be obtained from the
Registry of Certified Court Interpreters and the Florida Registry of Interpreters for the Deaf.
The PREA information is posted within the facility and there are pamphlets that are
accessible and available to all residents. Pamphlets are available in the dominant languages of
residents that are admitted to the facility. A corrective action was implemented to provide
specific information to residents regarding the services available to residents by the victim
advocacy agency if they should ever need it.
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
7
for the relevant review period)
Does Not Meet Standard (requires corrective action)
FDJJ 1919 addresses the training of the OIG Investigators, including the related policies and
procedures regarding the handling of sexual misconduct incidents and reports. Appropriate
training is provided to investigative staff regarding conducting investigations in the DJJ
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)
FDJJ 1919 and facility Policies 5-1 and 5-2 address staff training. The medical and mental
health staff members have received the training developed for those areas, as well as the
initial PREA training. The specialized training is developed by DJJ and is accessible to
medical and mental health staffs online. The medical staff does not conduct forensic medical
examinations.
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)
Policies 9-1, 8-14 and FDJJ 1919 provide information regarding screening for risk of
victimization and abusiveness. It is required that all residents are screened for risk of
victimization and abusiveness within 24 hours of intake. The screening is conducted using the
DJJ objective instrument, Screening for Vulnerability to Victimization and Sexuality
Aggressive Behavior (VSAB). The VSAB is used to obtain the information outlined in the
standard. Interviews of residents and staff and a review of documentation confirmed that
objective screening instruments are used to assess risk. The process provides for the
resident’s risk to be re-assessed periodically.
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)
Policies 9.3, 8-14 and FDJJ 1919 address this standard regarding the information from the
VSAB and other risk screening instruments and outline how the information is to be used to
8
help determine housing and program assignments with the goal of keeping all residents safe.
The facility prohibits placing gay, bisexual, transgender or intersex residents in specific
housing or making other assignments solely based on how they self-identify or their status.
There was no indication of any resident held in isolation or segregated housing because they
were at risk for sexual victimization.
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)
Policies 8-3, 10-25 and FDJJ 1919 address this standard. Residents may report allegations of
sexual abuse or sexual harassment by telephone, using the abuse hotline. There are also
additional 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 complete a grievance form; talk to any staff member; complete a Let’s Talk form
requesting to see a Case Manager, shift mentor, or an administrative staff; and third parties
may report allegations. Resident and staff interviews support the ways a resident may report
allegations and the information is also provided in the resident handbook.
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)
Policy 8-4 provides the details regarding completing and responding to a grievance,
including an emergency grievance. Completed grievances may be given to the Grievance
Officer or placed in the locked grievance box. When an emergency grievance is received, it
is immediately provided to the Facility Administrator, per Policy 8-4. A response is provided
to the resident immediately and the policies and procedures for reporting allegations of
sexual abuse and sexual harassment are initiated. Policy 8-4 also allows for the receipt of
reports from third parties and that third parties may assist residents in filing grievances.
Policy 10-25 and the Employee Handbook provide staff with the required information for
reporting sexual abuse and sexual harassment of residents.
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)
9
Does Not Meet Standard (requires corrective action)
Policy 10-25 addresses this standard and requires the Facility Administrator to ensure that
residents have access to outside victim advocates for emotional support services. There is
documentation of a Memorandum of Understanding between the facility and the Roxcy
Bolton Rape Treatment Center-Jackson Health Systems. Services were confirmed through a
telephone interview with a representative of the agency. Among other services, the agency
will provided residents with an advocate present during the forensic examination; emotional
support; crisis intervention; and information and referrals. The facility provides residents
with reasonable and confidential access to their attorneys or other legal representation and
reasonable 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)
Policies 8-3 and 10-25 address third-party reporting. Information is provided through posters
that are located in areas of the facility, accessible to the public, residents and staff members.
The FDJJ website contains information regarding third-party reporting.
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)
Policies 8-3, 10-25 and FDJJ 1919 provide that all staff report any knowledge, suspicion, or
information regarding an incident of sexual abuse, sexual harassment or incidents of retaliation
within two hours. Policy 10-25 prohibits staff from revealing any related information to
anyone other than to the extent necessary to make treatment, investigation and other security
and management decisions. Staff interviews revealed that they are aware of the requirement
regarding their reporting duties and understand that they are mandated reporters.
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)
Policy 10-25 instructs staff to take immediate action to keep residents safe when they learn
that there is substantial risk of imminent threat of sexual abuse. Interviews with staff
10
confirmed their knowledge of this policy and they were able to verbalize measures they would
take to protect residents who are at substantial risk of imminent sexual abuse. Safety tips for
self-protection are listed in the resident handbook. It was not determined during the past year
that a resident was at substantial risk of sexual abuse.
Standard 115.363 Reporting to Other Confinement Facilities
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)
Policy 19-25 and FDJJ 1919 address the requirements of this standard. It is reported that
during this audit period, the facility has not received any reports from a resident about an
incident of abuse occurring while they were confined in another facility. The Facility
Administrator is aware of the policy regarding reporting to other confinement facilities.
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)
Policy 10-25 details the first responder duties. Initial training and a refresher was conducted
with staff through a combination of online statewide training and in-house training. Staff
interviews revealed that they are aware of the steps to take if they are the first responder.
During this audit period, there has been no allegation of sexual abuse.
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)
The facility has a written institutional plan, Sexual Abuse Incident Coordinated Response
Plan, which outlines the coordinated actions of the various identified staff and it is aligned
with FDJJ 1919.
Standard 115.366 Preservation of Ability to Protect Residents From Contact With Abusers.
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the standard
11
for the relevant review period)
Does Not Meet Standard (requires corrective action)
This standard is not applicable. The facility does not maintain 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)
Policy 10-25 and FDJJ 1919 provide protection to residents and staff from retaliation. The
retaliation monitor is identified by Policy 10-25 as the PREA Compliance Manager and is
charged with observing whether or not retaliation occurs after a resident or staff reports
allegations of sexual abuse or cooperates with an investigation. Policy 10-25 identifies items to
be monitored to determine whether retaliation is occurring and the staff interviews supported
the Policy. There have been no allegations of sexual assault or sexual harassment during this
audit period.
Standard 115.368 Post Allegation Protective Custody
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)
This standard is not applicable. Segregated housing is not used at this facility to house
residents who allege sexual abuse.
Standard 115.371 Criminal and Administrative Agency 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)
Policy 10-25, FDJJ 1919 and staff interviews provide that administrative investigations are
conducted by the OIG and criminal investigations are conducted by local law enforcement.
The Florida Department of Children and Families are also called when there is an allegation
of sexual abuse. The Policies direct facility staff to cooperate with investigations.
Standard 115.372 Evidentiary Standards for Administrative Investigations
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)
FDJJ 1919 provides that the OIG, responsible for administrative investigations, impose 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)
FDJJ 1919 allows for the victim to be informed that the investigation has been concluded and
Policy 10-25 provides that the Facility Administrator notifies the victim or victim’s parents or
legal guardians. There have been no criminal or administrative investigations of alleged
resident sexual abuse conducted during this audit period.
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)
Does Not Meet Standard (requires corrective action)
Policy 3-3 provides that disciplinary sanctions, up to and including termination for those staff
that violate the facility’s sexual abuse and sexual harassment zero-tolerance policy. The
facility reports that during this audit period, no staff has violated agency or facility policy
regarding sexual abuse or sexual harassment
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)
13
FDJJ 1919 requires that any contractor or volunteer who engages in sexual abuse be
prohibited from contact with residents. It also provides for contractors and volunteers who
engage in sexual abuse to be reported to law enforcement agencies and to relevant licensing
bodies. Policy 10-25 prohibits sexual activity between residents and volunteers and
contracted personnel. The facility ensures that volunteers and contractors have a clear
understanding that a sexual relationship with a resident is strictly prohibited and is a serious
breach of conduct. An interview with a volunteer confirmed the related orientation and
training for volunteers. During this audit period, there have been no allegations of sexual
assault or sexual harassment regarding a contractor or volunteer.
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)
Policy 8-1 addresses the administrative process and the measures to be taken regarding major
rule violations. This information is also addressed in the resident handbook. A resident may
also be referred to law enforcement for charges and possible removal from the facility. Policy
10-25 states that anyone reporting in good faith shall be immune from any civil or criminal
liability.
Standard 115.381 Medical and Mental Health Screenings; History of Sexual Abuse
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)
Policy 10-25 and FDJJ 1919 address the sections of this standard, including providing for a
follow-up meeting with a medical or mental health practitioner within 14 days when the
resident discloses any prior incidents of sexual abuse whether victim or perpetrator. Policy
supports that information related to sexual victimization or abusiveness that occurred in an
institutional setting is limited to medical and mental health practitioners and those staff, based
on their need to know. Observation of files show that medical and mental health staff members
maintain documentation of the services they provide to the residents.
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)
Policy 7-30 and FDJJ 1919 address this standard. Staff interviews and review of practices
revealed that documentation regarding crisis intervention services will be maintained by
14
medical and mental health staff as required. Observations of files show that medical and
mental health staff members maintain secondary materials that document services to residents.
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)
Policies 10-25 and 7-30 and interviews with medical and mental health staff confirmed that
on-going medical and mental health care will be provided for sexual abuse victims and
abusers, as appropriate. Policy 10-25, staff interviews and document review revealed that
medical and mental health services are consistent with the community level of care.
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)
Policy 10-25 and FDJJ 1919 provide for an incident review to be conducted within 30 days of
the completion of an investigation. The Policies outline the requirements of the standard for
discussion and review by the incident review team. The Policies also identifies the positions
that comprise the team.
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)
FDJJ 1919 and documentation confirm that FDJJ collects incident-based, uniform and
aggregated data regarding allegations of sexual abuse at facilities under its direct control
using a standardized instrument. The agency and the facility will provide DOJ with data as
requested.
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)
15
FDJJ 1919 addresses this standard on a statewide basis. The collected and aggregated data
will be reviewed to assess and improve the effectiveness of the PREA related efforts and
initiatives. The Policy also states that an annual report will be prepared that will provide an
assessment of the agency’s progress in addressing sexual misconduct. The annual report was
reviewed.
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)
FDJJ 1919 provide that all data collected will be maintained for at least 10 years after the
initial collection date. According to the Policy, the report will be approved and posted on the
agency’s website, accessible to the public, as required by the standard. The practice is that the
report is posted on the agency’s website.
AUDITOR CERTIFICATION:
The auditor certifies that the contents of the report are accurate to the best of his/her knowledge and
no conflict of interest exists with respect to his or her ability to conduct an audit of the agency under
review.
November 3, 2015
Auditor Signature Date
16

report_type: PREA