state: FL

summary: PREA - Year 3 Cycle 3

raw_content:
Prison Rape Elimination Act (PREA) Audit Report
Juvenile Facilities
☐
Interim ☒ Final
☐
Date of Interim Audit Report: Click or tap here to enter text. N/A
If no Interim Audit Report, select N/A
Date of Final Audit Report: March 10. 2022
Auditor Information
Name: Robert Manville Draf Email: robertmanville9@gmail.cm
Company Name: Correctional Management and Communications Group, LLC
Mailing Address: 168Dogwood Drive City, State, Zip: Milledgeville, Ga. 31061
Telephone: 912-486-0004 Date of Facility Visit: 2/17-2/18/2022
Agency Information
Name of Agency: Vivant
Governing Authority or Parent Agency (If Applicable): Click or tap here to enter text.
Address: 1131 Eagetree Lane City, State, Zip: Huntsville, Al. 35801
Mailing Address: Click or tap here to enter text. City, State, Zip: Click or tap here to enter text.
The Agency Is:
☐
Military
☒
Private for Profit
☐
Private not for Profit
☐ ☐ ☐ ☐
Municipal County State Federal
Agency Website with PREA Information: www.vivant.com/html/prea.html
www.djj.state.fl.us/partners/prison-rape-elimination-act-(prea)
Agency Chief Executive Officer
Name: Tom Kenny
Email: Tom.Kenny@vivantbh.com Telephone: 951-401-1713
Agency-Wide PREA Coordinator
Name: Kimberly Nicholson
Email: Kimberly.nicholson@vivantbh.com Telephone: 941-526-8763
PREA Coordinator Reports to: Number of Compliance Managers who report to the PREA
Coordinator:
Tom Kenny 0
Facility Information
PREA Audit Report – v7 Page 1 of 125 West Palm Beach Youth Academy
Name of Facility: Palm Beach Youth Academy
Physical Address: 9680 Weisman Way City, State, Zip: West Palm Beach, Fl. 33411
Mailing Address: Click or tap here to enter text. City, State, Zip: Click or tap here to enter text.
☐ ☒ ☐
The Facility Is: Military Private for Profit Private not for Profit
☐ ☐ ☐ ☐
Municipal County State Federal
Facility Website with PREA Information: www. djj.state.fl.us/partners/prison-rape-elimination-act-(prea)
☐ ☒
Has the facility been accredited within the past 3 years? Yes No
If the facility has been accredited within the past 3 years, select the accrediting organization(s) – select all that apply (N/A if
the facility has not been accredited within the past 3 years):
☐
ACA
☐
NCCHC
☐
CALEA
☐
Other (please name or describe: Click or tap here to enter text.
☒
N/A
If the facility has completed any internal or external audits other than those that resulted in accreditation, please describe:
Click or tap here to enter text.
Facility Administrator/Superintendent/Director
Name: Dr. Sharrad Walker
Email: sharrad.walker@palmbeachyafl.com Telephone: 561-333-0664
Facility PREA Compliance Manager
Name: Demetreus Jones
Email:
demetreus.jones@palmbeachyafl.com Telephone: 561-333-0664
☐
Facility Health Service Administrator N/A
Name: Florence Andre
Email: Florence.andre@palmbeachyafl.com Telephone: 561-333-0664
Facility Characteristics
Designated Facility Capacity: 78
Current Population of Facility: 32
Average daily population for the past 12 months: 33
Has the facility been over capacity at any point in the ☐ ☒
Yes No
past 12 months?
PREA Audit Report – v7 Page 2 of 125 West Palm Beach Youth Academy
Which population(s) does the facility hold?
☐
Females
☒
Males
☐
Both Females and Males
Age range of population: 14-19
Average length of stay or time under supervision 9-12 months
Facility security levels/resident custody levels High Risk
Number of residents admitted to facility during the past 12 months 33
Number of residents admitted to facility during the past 12 months whose length of
33
stay in the facility was for 72 hours or more:
Number of residents admitted to facility during the past 12 months whose length of
33
stay in the facility was for 10 days or more:
Does the audited facility hold residents for one or more other agencies (e.g. a State
correctional agency, U.S. Marshals Service, Bureau of Prisons, U.S. Immigration and
☐
Yes
☒
No
Customs Enforcement)?
☐
Federal Bureau of Prisons
☐
U.S. Marshals Service
☐
U.S. Immigration and Customs Enforcement
☐
Bureau of Indian Affairs
☐
U.S. Military branch
Select all other agencies for which the audited ☐ State or Territorial correctional agency
facility holds residents: Select all that apply (N/A if
☐
the audited facility does not hold residents for any County correctional or detention agency
other agency or agencies):
☐
Judicial district correctional or detention facility
☐
City or municipal correctional or detention facility (e.g. police lockup or
city jail)
☐
Private corrections or detention provider
☐
Other - please name or describe: Click or tap here to enter text.
☒
N/A
Number of staff currently employed by the facility who may have contact with
26
residents:
Number of staff hired by the facility during the past 12 months who may have contact
26
with residents:
Number of contracts in the past 12 months for services with contractors who may
0
have contact with residents:
Number of individual contractors who have contact with residents, currently
0
authorized to enter the facility:
Number of volunteers who have contact with residents, currently authorized to enter
0
the facility:
Physical Plant
PREA Audit Report – v7 Page 3 of 125 West Palm Beach Youth Academy
Number of buildings:
Auditors should count all buildings that are part of the facility, whether residents are
formally allowed to enter them or not. In situations where temporary structures have
been erected (e.g., tents) the auditor should use their discretion to determine whether
8
to include the structure in the overall count of buildings. As a general rule, if a
temporary structure is regularly or routinely used to hold or house residents, or if the
temporary structure is used to house or support operational functions for more than a
short period of time (e.g., an emergency situation), it should be included in the overall
count of buildings.
Number of resident housing units:
Enter 0 if the facility does not have discrete housing units. DOJ PREA Working Group
FAQ on the definition of a housing unit: How is a "housing unit" defined for the
purposes of the PREA Standards? The question has been raised in particular as it
relates to facilities that have adjacent or interconnected units. The most common
concept of a housing unit is architectural. The generally agreed-upon definition is a
space that is enclosed by physical barriers accessed through one or more doors of
various types, including commercial-grade swing doors, steel sliding doors,
interlocking sally port doors, etc. In addition to the primary entrance and exit,
additional doors are often included to meet life safety codes. The unit contains
sleeping space, sanitary facilities (including toilets, lavatories, and showers), and a
6
dayroom or leisure space in differing configurations. Many facilities are designed with
modules or pods clustered around a control room. This multiple-pod design provides
the facility with certain staff efficiencies and economies of scale. At the same time, the
design affords the flexibility to separately house residents of differing security levels,
or who are grouped by some other operational or service scheme. Generally, the
control room is enclosed by security glass, and in some cases, this allows residents
to see into neighboring pods. However, observation from one unit to another is
usually limited by angled site lines. In some cases, the facility has prevented this
entirely by installing one-way glass. Both the architectural design and functional use
of these multiple pods indicate that they are managed as distinct housing units.
Number of single resident cells, rooms, or other enclosures: 84
Number of multiple occupancy cells, rooms, or other enclosures: 0
Number of open bay/dorm housing units: 5
Number of segregation or isolation cells or rooms (for example, administrative,
2
disciplinary, protective custody, etc.):
Does the facility have a video monitoring system, electronic surveillance system, or ☒ ☐
Yes No
other monitoring technology (e.g. cameras, etc.)?
Has the facility installed or updated a video monitoring system, electronic surveillance ☒ ☐
Yes No
system, or other monitoring technology in the past 12 months?
Medical and Mental Health Services and Forensic Medical Exams
Are medical services provided on-site?
☒
Yes
☐
No
Are mental health services provided on-site?
☒
Yes
☐
No
☐
On-site
☒
Where are sexual assault forensic medical exams Local hospital/clinic
provided? Select all that apply. ☒
Rape Crisis Center
☐ Other (please name or describe: Click or tap here to enter text.)
Investigations
PREA Audit Report – v7 Page 4 of 125 West Palm Beach Youth Academy
Criminal Investigations
Number of investigators employed by the agency and/or facility who are responsible
for conducting CRIMINAL investigations into allegations of sexual abuse or sexual 0
harassment:
☐
Facility investigators
When the facility received allegations of sexual abuse or sexual harassment (whether
☐
staff-on-resident or resident-on-resident), CRIMINAL INVESTIGATIONS are conducted Agency investigators
by: Select all that apply.
☒
An external investigative entity
☐
Local police department
☒
Local sheriff’s department
Select all external entities responsible for CRIMINAL ☐
State police
INVESTIGATIONS: Select all that apply (N/A if no
external entities are responsible for criminal ☐
A U.S. Department of Justice component
investigations)
☐
Other (please name or describe
☐
N/A
Administrative Investigations
Number of investigators employed by the agency and/or facility who are responsible
for conducting ADMINISTRATIVE investigations into allegations of sexual abuse or 13 Fl. DJJ Inspector General
sexual harassment?
When the facility receives allegations of sexual abuse or sexual harassment (whether ☐
Facility investigators
staff-on-resident or resident-on-resident), ADMINISTRATIVE INVESTIGATIONS are
☐
conducted by: Select all that apply Agency investigators
☒
An external investigative entity
☐
Local police department
☐
Local sheriff’s department
Select all external entities responsible for
☐
ADMINISTRATIVE INVESTIGATIONS: Select all that State police
apply (N/A if no external entities are responsible for ☐
A U.S. Department of Justice component
administrative investigations)
☒ Other (please name or describe: Fl. DJJ Inspector General)
☐
N/A
PREA Audit Report – v7 Page 5 of 125 West Palm Beach Youth Academy
Summary of Audit Findings
The summary should include the number and list of standards exceeded, number of standards met, and
number and list of standards not met.
Auditor Note: No standard should be found to be “Not Applicable” or “NA”. A compliance determination
must be made for each standard.
Standards Exceeded
Number of Standards Exceeded: 1
List of Standards Exceeded: Standard 115.341: Screening for risk of
victimization and abusiveness
Standards Met
Number of Standards Met: 40
Standards Not Met
Number of Standards Not Met: Click or tap here to enter text.
List of Standards Not Met: Click or tap here to enter text.
PREA Audit Report – v7 Page 6 of 125 West Palm Beach Youth Academy
Post-Audit Reporting Information
General Audit Information
Onsite Audit Dates
1. Start date of the onsite portion of the audit: 2/17/2022
2. End date of the onsite portion of the audit: 2/18/2022
Outreach
3. Did you attempt to communicate with community-based
organization(s) or victim advocates who provide services ☒ ☐
Yes No
to this facility and/or who may have insight into relevant
conditions in the facility?
a. If yes, identify the community-based organizations
Palm Beach County Victim Services
or victim advocates with whom you corresponded:
Audited Facility Information
4. Designated Facility Capacity: 78
5. Average daily population for the past 12 months: 33
6. Number of inmate/resident/detainee housing units:
DOJ PREA Working Group FAQ on the definition of a housing
unit: How is a "housing unit" defined for the purposes of the
PREA Standards? The question has been raised in particular as
it relates to facilities that have adjacent or interconnected units.
The most common concept of a housing unit is architectural. The
generally agreed-upon definition is a space that is enclosed by
physical barriers accessed through one or more doors of various
types, including commercial-grade swing doors, steel sliding
doors, interlocking sally port doors, etc. In addition to the primary
entrance and exit, additional doors are often included to meet life
safety codes. The unit contains sleeping space, sanitary facilities
(including toilets, lavatories, and showers), and a dayroom or
leisure space in differing configurations. Many facilities are 6
designed with modules or pods clustered around a control room.
This multiple-pod design provides the facility with certain staff
efficiencies and economies of scale. At the same time, the
design affords the flexibility to separately house inmates of
differing security levels, or who are grouped by some other
operational or service scheme. Generally, the control room is
enclosed by security glass, and in some cases, this allows
residents to see into neighboring pods. However, observation
from one unit to another is usually limited by angled site lines. In
some cases, the facility has prevented this entirely by installing
one-way glass. Both the architectural design and functional use
of these multiple pods indicate that they are managed as distinct
housing units.
☐ ☐
Yes No
7. Does the facility ever hold youthful inmates or
☒
youthful/juvenile detainees? N/A for the facility type audited (i.e., Community Confinement
Facility or Juvenile Facility)
Audited Facility Population on Day One of the Onsite Portion of the Audit
Inmates/Residents/Detainees
PREA Audit Report – v7 Page 7 of 125 West Palm Beach Youth Academy
8. Enter the total number of inmates/residents/detainees
housed at the facility as of the first day of the onsite 32
portion of the audit:
9. Enter the total number of youthful inmates or
youthful/juvenile detainees housed at the facility on the 32
first day of the onsite portion of the audit:
10. Enter the total number of inmates/residents/detainees
with a physical disability housed at the facility as of the 0
first day of the onsite portion of the audit:
11. Enter the total number of inmates/residents/detainees
with a cognitive or functional disability (including
intellectual disability, psychiatric disability, or speech 0
disability) housed at the facility as of the first day of the
onsite portion of the audit:
12. Enter the total number of inmates/residents/detainees
who are Blind or have low vision (visually impaired)
0
housed at the facility on the first day of the onsite portion
of the audit:
13. Enter the total number of inmates/residents/detainees
who are Deaf or hard-of-hearing housed at the facility on 0
the first day of the onsite portion of the audit:
14. Enter the total number of inmates/residents/detainees
who are Limited English Proficient (LEP) housed at the
0
facility as of the first day of the onsite portion of the
audit:
15. Enter the total number of inmates/residents/detainees
who identify as lesbian, gay, or bisexual housed at the
1
facility as of the first day of the onsite portion of the
audit:
16. Enter the total number of inmates/residents/detainees
who identify as transgender, or intersex housed at the
0
facility as of the first day of the onsite portion of the
audit:
17. Enter the total number of inmates/residents/detainees
who reported sexual abuse in this facility who are
0
housed at the facility as of the first day of the onsite
portion of the audit:
18. Enter the total number of inmates/residents/detainees
who reported sexual harassment in this facility who are
0
housed at the facility as of the first day of the onsite
portion of the audit:
19. Enter the total number of inmates/residents/detainees
who disclosed prior sexual victimization during risk
1
screening housed at the facility as of the first day of the
onsite portion of the audit:
20. Enter the total number of inmates/residents/detainees
who are or were ever placed in segregated
housing/isolation for risk of sexual victimization housed 0
at the facility as of the first day of the onsite portion of
the audit:
21. Enter the total number of inmates/residents/detainees
who are or were ever placed in segregated
housing/isolation for having reported sexual abuse in 0
this facility as of the first day of the onsite portion of the
audit:
22. Enter the total number of inmates/residents detained
solely for civil immigration purposes housed at the
0.
facility as of the first day of the onsite portion of the
audit:
23. Provide any additional comments regarding the Palm Beach Youth Academy is a drug treatment
population characteristics of inmates/residents/detainees
facility that received youth from Florida
in the facility as of the first day of the onsite portion of
Department of Juvenile Justice. Most of the
PREA Audit Report – v7 Page 8 of 125 West Palm Beach Youth Academy
the audit (e.g., groups not tracked, issues with identifying residents interviewed have been in multiple
certain populations).
programs
Note: as this text will be included in the audit report, please
do not include any personally identifiable information or other
information that could compromise the confidentiality of any
persons in the facility.
Staff, Volunteers, and Contractors
Include all full- and part-time staff employed by the facility, regardless of their level of contact with inmates/residents/detainees
24. Enter the total number of STAFF, including both full- and
part-time staff employed by the facility as of the first day 26
of the onsite portion of the audit:
25. Enter the total number of CONTRACTORS assigned to
the facility as of the first day of the onsite portion of the 0
audit who have contact with inmates/residents/detainees:
26. Enter the total number of VOLUNTEERS assigned to the
facility as of the first day of the onsite portion of the audit 0
who have contact with inmates/residents/detainees:
27. Provide any additional comments regarding the
population characteristics of staff, volunteers, and
contractors who were in the facility as of the first day of
the onsite portion of the audit.
Click or tap here to enter text.
Note: as this text will be included in the audit report, please
do not include any personally identifiable information or other
information that could compromise the confidentiality of any
persons in the facility.
Interviews
Inmate/Resident/Detainee Interviews
Random Inmate/Resident/Detainee Interviews
28. Enter the total number of RANDOM
INMATES/RESIDENTS/DETAINEES who were 18
interviewed:
☒
Age
☐
Race
☒
Ethnicity (e.g., Hispanic, Non-Hispanic)
☐
29. Select which characteristics you considered when you Length of time in the facility
selected random inmate/resident/detainee interviewees: ☒
Housing assignment
☐
Gender
☒ Other (describe) Previous Program Placements
☐
None (explain) Click or tap here to enter text.
I interviewed staff assigned to the facility from
30. How did you ensure your sample of random
inmate/resident/detainee interviewees was DJJ. The assignments are based on resident’s
geographically diverse? need and geographic area when possible.
31. Were you able to conduct the minimum number of ☒ ☐
random inmate/resident/detainee interviews? Yes No
a. If no, explain why it was not possible to interview the
minimum number of random Click or tap here to enter text.
inmate/resident/detainee interviews:
32. Provide any additional comments regarding selecting or There were no barriers to completing the
interviewing random inmates/residents/detainees (e.g.,
interviews. There was an inmate on inmate
any populations you oversampled, barriers to completing
interviews, barriers to ensuring representation, etc.). assault during the audit and one resident was out
PREA Audit Report – v7 Page 9 of 125 West Palm Beach Youth Academy
to medical emergency and one resident was in a
Note: as this text will be included in the audit report, please do
holding room awaiting transfer. I did not interview
not include any personally identifiable information or other
information that could compromise the confidentiality of any these two youth as it could escalate the incident.
persons in the facility. The facility operations supervisor indicated that
the altercation was not sexual motivated. The
local law enforcement was interviewing staff and
residents at the time of the audit for assault on
staff.
Targeted Inmate/Resident/Detainee Interviews
33. Enter the total number of TARGETED
INMATES/RESIDENTS/DETAINEES who were
interviewed:
As stated in the PREA Auditor Handbook, the breakdown of
targeted interviews is intended to guide auditors in
interviewing the appropriate cross-section of
inmates/residents/detainees who are the most vulnerable to
sexual abuse and sexual harassment. When completing
questions regarding targeted inmate/resident/detainee
interviews below, remember that an interview with one
inmate/resident/detainee may satisfy multiple targeted
interview requirements. These questions are asking about the
number of interviews conducted using the targeted
inmate/resident/detainee protocols.
3
For example, if an auditor interviews an inmate who has a
physical disability, is being held in segregated housing due to
risk of sexual victimization, and disclosed prior sexual
victimization, that interview would be included in the totals for
each of those questions. Therefore, in most cases, the sum of
all the following responses to the targeted
inmate/resident/detainee interview categories will exceed the
total number of targeted inmates/residents/detainees who
were interviewed.
If a particular targeted population is not applicable in the
audited facility, enter "0".
34. Enter the total number of interviews conducted with
youthful inmates or youthful/juvenile detainees using the N/A
“Youthful Inmates” protocol:
☐
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the
Click or tap here to enter text.
PAQ; documentation reviewed onsite; and
discussions with staff and other
inmates/residents/detainees).
35. Enter the total number of interviews conducted with
inmates/residents/detainees with a physical disability
0
using the “Disabled and Limited English Proficient
Inmates” protocol:
PREA Audit Report – v7 Page 10 of 125 West Palm Beach Youth Academy
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the I interviewed the nurse, who indicated there were
PAQ; documentation reviewed onsite; and no resident with any physical disabilities
discussions with staff and other
inmates/residents/detainees).
36. Enter the total number of interviews conducted with
inmates/residents/detainees with a cognitive or
functional disability (including intellectual disability,
0
psychiatric disability, or speech disability) using the
“Disabled and Limited English Proficient Inmates”
protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited I interviewed the clinical director who indicated
facility (e.g., based on information obtained from the
there were no cognitive disabled residents at the
PAQ; documentation reviewed onsite; and
discussions with staff and other facility.
inmates/residents/detainees).
37. Enter the total number of interviews conducted with
inmates/residents/detainees who are Blind or have low
0
vision (visually impaired) using the “Disabled and
Limited English Proficient Inmates” protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited I interviewed the nurse, who indicated there were
facility (e.g., based on information obtained from the
no resident with any physical disabilities. I also did
PAQ; documentation reviewed onsite; and
discussions with staff and other not see any disabled residents during the tour.
inmates/residents/detainees).
38. Enter the total number of interviews conducted with
inmates/residents/detainees who are Deaf or hard-of-
0
hearing using the “Disabled and Limited English
Proficient Inmates” protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
PREA Audit Report – v7 Page 11 of 125 West Palm Beach Youth Academy
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the I interviewed the nurse, who indicated there were
PAQ; documentation reviewed onsite; and no resident with any physical disabilities
discussions with staff and other
inmates/residents/detainees).
39. Enter the total number of interviews conducted with
inmates/residents/detainees who are Limited English
0
Proficient (LEP) using the “Disabled and Limited English
Proficient Inmates” protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the I asked resident and staff if there were anyone at
PAQ; documentation reviewed onsite; and the facility that did not speak English
discussions with staff and other
inmates/residents/detainees).
40. Enter the total number of interviews conducted with
inmates/residents/detainees who identify as lesbian, gay,
1
or bisexual using the “Transgender and Intersex Inmates;
Gay, Lesbian, and Bisexual Inmates” protocol:
☐
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the
Click or tap here to enter text.
PAQ; documentation reviewed onsite; and
discussions with staff and other
inmates/residents/detainees).
41. Enter the total number of interviews conducted with
inmates/residents/detainees who identify as transgender
0
or intersex “Transgender and Intersex Inmates; Gay,
Lesbian, and Bisexual Inmates” protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited I interview the nurse and clinical director who
facility (e.g., based on information obtained from the
stated they did not have any transgender or
PAQ; documentation reviewed onsite; and
discussions with staff and other intersex resident at the facility.
inmates/residents/detainees).
PREA Audit Report – v7 Page 12 of 125 West Palm Beach Youth Academy
42. Enter the total number of interviews conducted with
inmates/residents/detainees who reported sexual abuse
0
in this facility using the “Inmates who Reported a Sexual
Abuse” protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the Interviewed direct care staff, residents, clinical
PAQ; documentation reviewed onsite; and supervisor, medical and Facility Administrator.
discussions with staff and other
inmates/residents/detainees).
43. Enter the total number of interviews conducted with
inmates/residents/detainees who disclosed prior sexual
victimization during risk screening using the “Inmates 1
who Disclosed Sexual Victimization during Risk
Screening” protocol:
☐
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited
facility (e.g., based on information obtained from the
Click or tap here to enter text.
PAQ; documentation reviewed onsite; and
discussions with staff and other
inmates/residents/detainees).
44. Enter the total number of interviews conducted with
inmates/residents/detainees who are or were ever placed
in segregated housing/isolation for risk of sexual
0
victimization using the “Inmates Placed in Segregated
Housing (for Risk of Sexual Victimization/Who Alleged to
have Suffered Sexual Abuse)” protocol:
☒
Facility said there were “none here” during the onsite portion
a. If 0, select why you were unable to conduct at least of the audit and/or the facility was unable to provide a list of
the minimum required number of targeted these inmates/residents/detainees.
inmates/residents/detainees in this category: ☐
The inmates/residents/detainees in this targeted category
declined to be interviewed.
b. If 0, discuss your corroboration strategies to
determine if this population exists in the audited Interviewed direct care staff, residents, clinical
facility (e.g., based on information obtained from the supervisor, medical and Facility Administrator.
PAQ; documentation reviewed onsite; and
discussions with staff and other
inmates/residents/detainees).
45. Provide any additional comments regarding selecting or
interviewing random inmates/residents/detainees (e.g., The facility housed 32 residents; 18 residents
any populations you oversampled, barriers to completing
were interviewed. Residents that came from
interviews, barriers to ensuring representation, etc.).
other program were oversampled and included all
Note: as this text will be included in the audit report, please do residents that transferred to the facility from other
not include any personally identifiable information or other
programs.
information that could compromise the confidentiality of any
persons in the facility.
PREA Audit Report – v7 Page 13 of 125 West Palm Beach Youth Academy
Staff, Volunteer, and Contractor Interviews
Random Staff Interviews
46. Enter the total number of RANDOM STAFF who were
16
interviewed:
☐
Length of tenure in the facility
☐
Shift assignment
☐
Work assignment
47. Select which characteristics you considered when you
selected RANDOM STAFF interviewees (select all that ☐ Rank (or equivalent)
apply):
☒ Other (describe) All staff that were working at the
facility on each shift on each day of the onsite
audit were interviewed.
☐
None (explain) Click or tap here to enter text.
48. Were you able to conduct the minimum number of ☒ ☐
RANDOM STAFF interviews? Yes No
☐
Too many staff declined to participate in interviews
☐
Not enough staff employed by the facility to meet the
minimum number of random staff interviews (Note: select this
option if there were not enough staff employed by the facility
a. If no, select the reasons why you were not able to
or not enough staff employed by the facility to interview for
conduct the minimum number of RANDOM STAFF
both random and specialized staff roles).
interviews (select all that apply):
☐
Not enough staff available in the facility during the onsite
portion of the audit to meet the minimum number of random
staff interviews.
☐
Other (describe) Click or tap here to enter text.
b. Describe the steps you took to select additional
RANDOM STAFF interviewees and why you were still
Click or tap here to enter text.
unable to meet the minimum number of random staff
interviews:
49. Provide any additional comments regarding selecting or
interviewing random staff (e.g., any populations you
The center is maintaining staff to meet the
oversampled, barriers to completing interviews, etc.).
mandatory ration of staff to residents. In order to
Note: as this text will be included in the audit report, please accomplish this mandate staff or working
do not include any personally identifiable information or other
overtime and callbacks are utilized.
information that could compromise the confidentiality of any
persons in the facility.
Specialized Staff, Volunteers, and Contractor Interviews
Staff in some facilities may be responsible for more than one of the specialized staff duties. Therefore, more than one interview
protocol may apply to an interview with a single staff member and that interview would satisfy multiple specialized staff interview
requirements.
50. Enter the total number of staff in a SPECIALIZED STAFF
role who were interviewed (excluding volunteers and 8
contractors):
51. Were you able to interview the Agency Head?
☒
Yes
☐
No
a. If no, explain why it was not possible to interview the
Click or tap here to enter text.
Agency Head:
52. W
Di
e
re
re
c t
y
o
o
r/
u
S
a
u
b
p
l
e
e
r i
t
n
o
t e
in
n
t
d
e
e
rv
n
i
t
e
o
w
r
t
t
h
h
e
e i
W
r d
a
e
rd
si
e
g
n
n
/F
e
a
e?
ci l ity ☒
Yes
☐
No
PREA Audit Report – v7 Page 14 of 125 West Palm Beach Youth Academy
a. If no, explain why it was not possible to interview the
Warden/Facility Director/Superintendent or their Click or tap here to enter text.
designee:
53. Were you able to interview the PREA Coordinator?
☒
Yes
☐
No
a. If no, explain why it was not possible to interview the
Click or tap here to enter text.
PREA Coordinator:
☒ ☐
Yes No
54. Were you able to interview the PREA Compliance ☐
N/A (N/A if the agency is a single facility agency or is
Manager?
otherwise not required to have a PREA Compliance Manager per
the Standards)
a. If no, explain why it was not possible to interview the
Click or tap here to enter text.
PREA Compliance Manager:
☐
Agency contract administrator
☒
Intermediate or higher-level facility staff responsible for
conducting and documenting unannounced rounds to identify
and deter staff sexual abuse and sexual harassment
☐
Line staff who supervise youthful inmates (if applicable)
☐
55. Select which SPECIALIZED STAFF roles were Education and program staff who work with youthful inmates
interviewed as part of this audit (select all that apply):
(if applicable)
☒
Medical staff
☒
Mental health staff
☐
Non-medical staff involved in cross-gender strip or visual
searches
☒
Administrative (human resources) staff
PREA Audit Report – v7 Page 15 of 125 West Palm Beach Youth Academy
☒
Sexual Assault Forensic Examiner (SAFE) or Sexual Assault
Nurse Examiner (SANE) staff
☒
Investigative staff responsible for conducting administrative
investigations
☐
Investigative staff responsible for conducting criminal
investigations
☒
Staff who perform screening for risk of victimization and
abusiveness
☐
Staff who supervise inmates in segregated housing/residents
in isolation
☒
Staff on the sexual abuse incident review team
☒
Designated staff member charged with monitoring retaliation
☐
First responders, both security and non-security staff
☒
Intake staff
☐
Other (describe) Click or tap here to enter text.
56. Did you interview VOLUNTEERS who may have contact ☐ ☒
Yes No
with inmates/residents/detainees in this facility?
a. Enter the total number of VOLUNTEERS who were
0
interviewed:
☐
Education/programming
☐
b. Select which specialized VOLUNTEER role(s) were Medical/dental
interviewed as part of this audit (select all that ☐
Mental health/counseling
apply):
☐
Religious
☐
Other
57. Did you interview CONTRACTORS who may have contact ☐ ☒
with inmates/residents/detainees in this facility?
Yes No
a. Enter the total number of CONTRACTORS who were
0
interviewed:
☐
Security/detention
☐
Education/programming
b. Select which specialized CONTRACTOR role(s) were ☐ Medical/dental
interviewed as part of this audit (select all that
☐
apply): Food service
☐
Maintenance/construction
☐
Other
58. Provide any additional comments regarding selecting or The facility does not have any contractor or
interviewing specialized staff (e.g., any populations you
volunteers at this time. The facility has a contract
oversampled, barriers to completing interviews, etc.).
to provide educational programs through the
Note: as this text will be included in the audit report, please Palm Beach County School System. At the time
do not include any personally identifiable information or other
of the audit the facility was utilizing distance
information that could compromise the confidentiality of any
persons in the facility. education programs.
Site Review and Documentation Sampling
Site Review
PREA Audit Report – v7 Page 16 of 125 West Palm Beach Youth Academy
PREA Standard 115.401(h) states, “The auditor shall have access to, and shall observe, all areas of the audited facilities.” In order to
meet the requirements in this Standard, the site review portion of the onsite audit must include a thorough examination of the entire
facility. The site review is not a casual tour of the facility. It is an active, inquiring process that includes talking with staff and inmates to
determine whether, and the extent to which, the audited facility’s practices demonstrate compliance with the Standards. Note:
discussions related to testing critical functions are expected to be included in the relevant Standard-specific overall determination
narratives.
59. Did you have access to all areas of the facility?
☒
Yes
☐
No
a. If no, explain what areas of the facility you were
Click or tap here to enter text.
unable to access and why.
Was the site review an active, inquiring process that included the following:
60. Reviewing/examining all areas of the facility in
accordance with the site review component of the audit
☒
Yes
☐
No
instrument?
a. If no, explain why the site review did not include
Click or tap here to enter text.
reviewing/examining all areas of the facility.
61. Testing and/or observing all critical functions in the
facility in accordance with the site review component of ☒ ☐
Yes No
the audit instrument (e.g., intake process, risk screening
process, PREA education)?
a. If no, explain why the site review did not include
testing and/or observing all critical functions in the Click or tap here to enter text.
facility.
62. Informal conversations with inmates/residents/detainees ☒ ☐
Yes No
during the site review (encouraged, not required)?
63. Informal conversations with staff during the site review ☒ ☐
Yes No
(encouraged, not required)?
During the comprehensive tour of the facility, posted signs
were also observed regarding general PREA information
and contact numbers for reporting sexual abuse or sexual
harassment. Also presented was the phone number and
address for the Palm Beach County Victim Services and the
telephone number for the local sheriff’s department and
the Central Communication Centers (CCC). Telephone calls
to the Palm Beach County Victim Services and CCC were
answered by a live person. There is an office that is utilized
64. Provide any additional comments regarding the site by the resident to make these phone calls. There are also
review (e.g., access to areas in the facility, observations,
telephones in each housing unit and one telephone is in
tests of critical functions, or informal conversations).
the multipurpose area for residents to speed dial these
Note: as this text will be included in the audit report, please programs. At the time of the audit the telephone did not
do not include any personally identifiable information or other
work. The facility administrator was working to have this
information that could compromise the confidentiality of any
telephone reconnected during the tour. It was not a
persons in the facility.
corrective action plan required since the telephones in the
living units were operational. During the tour, youth were
observed to be under constant supervision of the staff
while involved in various activities. PREA signage (in bold
and colorful print) was displayed in all areas frequented by
the residents. They include how to make an allegation, end
the silence, PREA notice of audit, telephone numbers, and
general information about PREA poster. The tour included
all areas of the facility which included but was not limited
PREA Audit Report – v7 Page 17 of 125 West Palm Beach Youth Academy
to Intake, all housing units, medical, food services,
programming, and education areas. The facility was clean
and well maintained. Signs are located in the entrance of
each housing unit that states, staff, contractors, and
volunteers announced themselves prior to entering the
housing area of the opposite gender. During the tour there
was always a minimum of a one to six or less ratio to
residents. In the early morning visit to the faciity there was
a ratio of 1 to 8 ratios in the housing units during the day.
During the tour of the faciity on the second morning there
was a 1 to 12 ratio. Questions were answered by staff
during informal interviews regarding resident activities
and program services as the tour progressed throughout
the facility. The site visit also included the outside
grounds. During the tour, the intake process was
described, and the daily scheduled activities and staff
supervision were discussed by the Superintendent/PREA
Manager. There were no new admissions during the site
visit. Staff readily explained activities as different facility
areas were visited. Resident informal interviews confirmed
that the residents have multiple ways to make an
allegation including the telephone. Several of the resident
showed me the office that can be used to talk to your
lawyer, parent and to make a call to the local law
enforcement or to the victim advocate. Staff of the
opposite gender, must announce their presence when
entering the housing unit or any area where a resident
shower, change clothes, or perform bodily functions. All
residents interviewed stated the staff members announce
their presence prior to entering the housing unit. This
practice was experienced and observed during the tour.
The shower area has shower curtains for privacy. The
facility has individual rooms with a toilet in their room.
Resident indicated that staff knock on their door prior to
looking in the room during count. The medical room has a
shower around the examination area and the staff
indicated they close the door and use the shower when
they examine residents. Medical Request Forms,
PREA/grievance forms, and the locked boxes for each are
posted in the common area, accessible to all residents,
staff and visitors. All residents have access to writing
utensils needed for completing the forms. The staff to
resident ratio was observed to be met in all areas of the
facility during the on-site tour. The camera monitoring
system, in addition to mirrors, support the direct
supervision provided by staff.
Documentation Sampling
Where there is a collection of records to review—such as staff, contractor, and volunteer training records; background check records;
supervisory rounds logs; risk screening and intake processing records; inmate education records; medical files; and investigative
files—auditors must self-select for review a representative sample of each type of record.
PREA Audit Report – v7 Page 18 of 125 West Palm Beach Youth Academy
65. In addition to the proof documentation selected by the
agency or facility and provided to you, did you also
☒
Yes
☐
No
conduct an auditor-selected sampling of documentation?
The auditor requested random personnel background
checks and reviewed 10 employee training records two
contractor files and two volunteer files. The employee
records included three staff that had been employed at
the facility more than 5 years, 3 of the staff were
promoted and four of the staff were employed in the last
12 months check was completed and is maintained on file
in the personnel’s office. The auditor requested some
specific and some random training files for employees.
Including in the specific list was training staff, director,
PCM, shift supervisor and ten random monitors. Medical
staff receive the same specialized training as Department
medical staff. The training files were requested and
66. Provide any additional comments regarding selecting
reviewed. The medical and mental health staff have
additional documentation (e.g., any documentation you
oversampled, barriers to selecting additional received specialized training for Sexual Abuse and
documentation, etc.).
victimization Ten residential records were reviewed
utilizing the worksheet provided by the PREA Resource
Note: as this text will be included in the audit report, please do
not include any personally identifiable information or other Center. Included in the review was age, date of arrival,
information that could compromise the confidentiality of any date of initial PREA orientation, date of comprehensive
persons in the facility.
PREA training, initial Vulnerability Screening and
rescreening after resident had been at the facility twenty
five to thirty days. A review of the residential records also
included resident referrals for mental health or victim
advocate programs. The resident’s file contained
documentation of Intake Screening, Intake PREA
notification, rescreening and formalized PREA education.
All time requirements were met on each area. Logbook
documentation of PREA rounds were reviewed during the
tour. The auditor asked to review Investigative files,
however there were no files available during the audit.
The FDJJ PREA coordinator provided the auditor
information on two investigations.
Sexual Abuse and Sexual Harassment Allegations and Investigations in this Facility
Sexual Abuse and Sexual Harassment Allegations and Investigations Overview
Remember the number of allegations should be based on a review of all sources of allegations (e.g., hotline, third-party, grievances)
and should not be based solely on the number of investigations conducted.
Note: For question brevity, we use the term “inmate” in the following questions. Auditors should provide information on inmate,
resident, or detainee sexual abuse allegations and investigations, as applicable to the facility type being audited.
67. Total number of SEXUAL ABUSE allegations and investigations overview during the 12 months preceding the audit, by
incident type:
Instructions: If you are unable to provide information for one or more of the fields below, enter an “X” in the field(s) where information
cannot be provided.
# of allegations that had
# of sexual abuse # of criminal # of administrative both criminal and
allegations investigations investigations administrative
investigations
PREA Audit Report – v7 Page 19 of 125 West Palm Beach Youth Academy
Inmate-on-inmate
0 0 0 0
sexual abuse
Staff-on-inmate
2 1 2 1
sexual abuse
Total 2 1 2 1
a. If you were unable to provide any of the information
above, explain why this information could not be Click or tap here to enter text.
provided.
68. Total number of SEXUAL HARASSMENT allegations and investigations overview during the 12 months preceding the
audit, by incident type:
Instructions: If you are unable to provide information for one or more of the fields below, enter an “X” in the field(s) where information
cannot be provided.
# of allegations that had
# of sexual harassment # of criminal # of administrative both criminal and
allegations investigations investigations administrative
investigations
Inmate-on-inmate
0 0 0 0
sexual harassment
Staff-on-inmate
0 0 0 0
sexual harassment
Total 0 0 0 0
a. If you were unable to provide any of the information
above, explain why this information could not be Click or tap here to enter text.
provided.
Sexual Abuse and Sexual Harassment Investigation Outcomes
Sexual Abuse Investigation Outcomes
Note: these counts should reflect where the investigation is currently (i.e., if a criminal investigation was referred for prosecution and
resulted in a conviction, that investigation outcome should only appear in the count for “convicted.”) Do not double count. Additionally,
for question brevity, we use the term “inmate” in the following questions. Auditors should provide information on inmate, resident, and
detainee sexual abuse investigation files, as applicable to the facility type being audited.
69. Criminal SEXUAL ABUSE investigation outcomes during the 12 months preceding the audit:
Instructions: If you are unable to provide information for one or more of the fields below, enter an “X” in the field(s) where information
cannot be provided.
Referred for Indicted/Court
Ongoing Convicted/Adjudicated Acquitted
Prosecution Case Filed
Inmate-on-inmate
0 0 0 0 0
sexual abuse
Staff-on-inmate
0 0 0 0 0
sexual abuse
Total 0 0 0 0 0
a. If you were unable to provide any of the information
above, explain why this information could not be Click or tap here to enter text.
provided.
PREA Audit Report – v7 Page 20 of 125 West Palm Beach Youth Academy
70. Administrative SEXUAL ABUSE investigation outcomes during the 12 months preceding the audit:
Instructions: If you are unable to provide information for one or more of the fields below, enter an “X” in the field(s) where information
cannot be provided.
Ongoing Unfounded Unsubstantiated Substantiated
Inmate-on-inmate
0 0 0 0
sexual abuse
Staff-on-inmate
0 1 1 0
sexual abuse
Total 0 1 1 0
a. If you were unable to provide any of the information The information was provided by the FDJJ PREA
above, explain why this information could not be
coordinator.
provided.
Sexual Harassment Investigation Outcomes
Note: these counts should reflect where the investigation is currently. Do not double count. Additionally, for question brevity, we use the
term “inmate” in the following questions. Auditors should provide information on inmate, resident, and detainee sexual harassment
investigation files, as applicable to the facility type being audited.
71. Criminal SEXUAL HARASSMENT investigation outcomes during the 12 months preceding the audit:
Instructions: If you are unable to provide information for one or more of the fields below, enter an “X” in the field(s) where information
cannot be provided.
Referred for Indicted/Court
Ongoing Convicted/Adjudicated Acquitted
Prosecution Case Filed
Inmate-on-inmate
0 0 0 0 0
sexual harassment
Staff-on-inmate
0 0 0 0 0
sexual harassment
Total 0 0 0 0 0
a. If you were unable to provide any of the information
above, explain why this information could not be Click or tap here to enter text.
provided.
72. Administrative SEXUAL HARASSMENT investigation outcomes during the 12 months preceding the audit:
Instructions: If you are unable to provide information for one or more of the fields below, enter an “X” in the field(s) where information
cannot be provided.
Ongoing Unfounded Unsubstantiated Substantiated
Inmate-on-inmate
0 0 0 0
sexual harassment
Staff-on-inmate
0 0 0 0
sexual harassment
Total 0 0 0 0
a. If you were unable to provide any of the information
above, explain why this information could not be Click or tap here to enter text.
provided.
Sexual Abuse and Sexual Harassment Investigation Files Selected for Review
Sexual Abuse Investigation Files Selected for Review
PREA Audit Report – v7 Page 21 of 125 West Palm Beach Youth Academy
73. Enter the total number of SEXUAL ABUSE investigation
2
files reviewed/sampled:
The incidents happened prior to the present
vendor assuming the facility and the files were
a. If 0, explain why you were unable to review any
maintained by the FDJJ PREA coordinator.
sexual abuse investigation files:
He provided the pertinent information to the
Auditor.
☒ ☐
74. Did your selection of SEXUAL ABUSE investigation files Yes No
include a cross-section of criminal and/or administrative ☐
N/A (N/A if you were unable to review any sexual abuse
investigations by findings/outcomes?
investigation files)
Inmate-on-inmate sexual abuse investigation files
75. Enter the total number of INMATE-ON-INMATE SEXUAL
0
ABUSE investigation files reviewed/sampled:
☐ ☒
76. Did your sample of INMATE-ON-INMATE SEXUAL ABUSE Yes No
investigation files include criminal investigations? ☐
N/A (N/A if you were unable to review any inmate-on-inmate
sexual abuse investigation files)
☐ ☒
77. Did your sample of INMATE-ON-INMATE SEXUAL ABUSE Yes No
investigation files include administrative investigations? ☐
N/A (N/A if you were unable to review any inmate-on-inmate
sexual abuse investigation files)
Staff-on-inmate sexual abuse investigation files
78. Enter the total number of STAFF-ON-INMATE SEXUAL
2
ABUSE investigation files reviewed/sampled:
☒ ☐
79. Did your sample of STAFF-ON-INMATE SEXUAL ABUSE Yes No
investigation files include criminal investigations? ☐
N/A (N/A if you were unable to review any staff-on-inmate
sexual abuse investigation files)
☒ ☐
80. Did your sample of STAFF-ON-INMATE SEXUAL ABUSE Yes No
investigation files include administrative investigations? ☐
N/A (N/A if you were unable to review any staff-on-inmate
sexual abuse investigation files)
Sexual Harassment Investigation Files Selected for Review
81. Enter the total number of SEXUAL HARASSMENT
0
investigation files reviewed/sampled:
a. If 0, explain why you were unable to review any
There were no allegation of sexual harassment
sexual harassment investigation files:
82. Did your selection of SEXUAL HARASSMENT ☐ Yes ☐ No
investigation files include a cross-section of criminal
☒
and/or administrative investigations by N/A (N/A if you were unable to review any sexual harassment
findings/outcomes? investigation files)
Inmate-on-inmate sexual harassment investigation files
83. Enter the total number of INMATE-ON-INMATE SEXUAL
0
HARASSMENT investigation files reviewed/sampled:
☐ ☐
84. Did your sample of INMATE-ON-INMATE SEXUAL Yes No
HARASSMENT investigation files include criminal ☒
N/A (N/A if you were unable to review any inmate-on-inmate
investigations?
sexual harassment investigation files)
PREA Audit Report – v7 Page 22 of 125 West Palm Beach Youth Academy
☐ ☐
85. Did your sample of INMATE-ON-INMATE SEXUAL Yes No
HARASSMENT investigation files include administrative ☒
N/A (N/A if you were unable to review any inmate-on-inmate
investigations?
sexual harassment investigation files)
Staff-on-inmate sexual harassment investigation files
86. Enter the total number of STAFF-ON-INMATE SEXUAL
0
HARASSMENT investigation files reviewed/sampled:
☐ ☐
87. Did your sample of STAFF-ON-INMATE SEXUAL Yes No
HARASSMENT investigation files include criminal ☒
N/A (N/A if you were unable to review any staff-on-inmate
investigations?
sexual harassment investigation files)
☐ ☐
88. Did your sample of STAFF-ON-INMATE SEXUAL Yes No
HARASSMENT investigation files include administrative ☒
N/A (N/A if you were unable to review any staff-on-inmate
investigations?
sexual harassment investigation files)
89. Provide any additional comments regarding selecting
and reviewing sexual abuse and sexual harassment
investigation files.
There were two allegation of sexual abuse, and
Note: as this text will be included in the audit report, please each investigative report was reviewed.
do not include any personally identifiable information or other
information that could compromise the confidentiality of any
persons in the facility.
Support Staff Information
DOJ-certified PREA Auditors Support Staff
90. Did you receive assistance from any DOJ-CERTIFIED
PREA AUDITORS at any point during this audit?
☐
Yes
☒
No
Remember: the audit includes all activities from the pre-onsite
through the post-onsite phases to the submission of the final
report. Make sure you respond accordingly.
a. If yes, enter the TOTAL NUMBER OF DOJ-CERTIFIED
PREA AUDITORS who provided assistance at any Click or tap here to enter text.
point during the audit:
Non-certified Support Staff
91. Did you receive assistance from any NON-CERTIFIED
SUPPORT STAFF at any point during this audit?
☐
Yes
☒
No
Remember: the audit includes all activities from the pre-onsite
through the post-onsite phases to the submission of the final
report. Make sure you respond accordingly.
a. If yes, enter the TOTAL NUMBER OF NON-
CERTIFIED SUPPORT STAFF who provided Click or tap here to enter text.
assistance at any point during the audit:
Auditing Arrangements and Compensation
☐
The audited facility or its parent agency
☐
My state/territory or county government (if you audit as part of
a consortium or circular auditing arrangement, select this
92. Who paid you to conduct this audit? option)
☒
A third-party auditing entity (e.g., accreditation body,
consulting firm)
☐
Other
PREA Audit Report – v7 Page 23 of 125 West Palm Beach Youth Academy
PREA Audit Report – v7 Page 24 of 125 West Palm Beach Youth Academy
PREVENTION PLANNING
Standard 115.311: Zero tolerance of sexual abuse and sexual harassment;
PREA coordinator
All Yes/No Questions Must Be Answered by The Auditor to Complete the Report
115.311 (a)
▪ Does the agency have a written Policy mandating zero tolerance toward all forms of sexual
abuse and sexual harassment? ☒ Yes ☐ No
▪ Does the written Policy outline the agency’s approach to preventing, detecting, and responding
to sexual abuse and sexual harassment? ☒ Yes ☐ No
115.311 (b)
▪ Has the agency employed or designated an agency-wide PREA Coordinator? ☒ Yes ☐ No
▪ Is the PREA Coordinator position in the upper-level of the agency hierarchy? ☒ Yes ☐ No
▪ Does the PREA Coordinator have sufficient time and authority to develop, implement, and
oversee agency efforts to comply with the PREA standards in all of its facilities? ☒ Yes ☐
No
115.311 (c)
▪ If this agency operates more than one facility, has each facility designated a PREA compliance
manager? (N/A if agency operates only one facility.) ☒ Yes ☐ No ☐ NA
▪ Does the PREA compliance manager have sufficient time and authority to coordinate the
facility’s efforts to comply with the PREA standards? (N/A if agency operates only one facility.)
☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the evidence relied upon in making the
compliance or non-compliance determination, the auditor’s analysis and reasoning, and the auditor’s
PREA Audit Report – v7 Page 25 of 125 West Palm Beach Youth Academy
conclusions. This discussion must also include corrective action recommendations where the facility does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
115.311 (a): Florida Department of Juvenile Justice is committed to a zero-tolerance standard for
incidents of sexual abuse and sexual harassment. The agency has developed and implement policies to
comply with PREA standards for Juvenile Facilities. The FDJJJ and other stakeholders associated with
FDJJ are committed to preventing, detecting, and responding to sexual abuse and sexual harassment.
Everyone has the right to be free from sexual abuse, sexual harassment, neglect, and exploitation. This
includes not being subjected to sexually assaultive, abusive, and/or harassing behavior from staff and
other residents. DJJ policies establishes that all facilities, staff, residents, volunteers, contractors, or
visitor are committed to a zero-tolerance standard for incidents of sexual abuse and sexual
harassment. Residents with disabilities are afforded the same rights and will be provided access to
interpreters, presented material to effectively communicate with those residents who have intellectual
disabilities, limited reading skills, blind or have low vision. Residents will have access to interpreters
who can interpret effectively, accurately, and impartially, both receptively and expressively, using any
necessary specialized vocabulary. Interpreters will be provided through local community resources.
Residents with disabilities have equal opportunity to participate in and benefit from all aspects of West
Palm Beach Youth Academy’s (WPBYA) efforts to prevent, detect, and respond to sexual abuse and
sexual harassment.
115.311 (b): Florida Department of Juvenile Justice employees a PREA Coordinator that oversees the
efforts to comply with the PREA standards in all Juvenile Facilities under the umbrellas of the FDJJ. The
PREA coordinator reports to an upper management staff and ensures that all its facilities have a PREA
Compliance Manager with sufficient time and authority to coordinate the facilities PREA efforts. Vivant
appointed a PREA coordinator that reports to the President who have sufficient time and authority to
develop, implement, and oversee agency efforts to comply with the PREA standards in all of its
facilities.
115.311 (c): The facility has a PREA compliance manager that oversee the implementation of all PREA
standards and ensures compliance with PREA standards. In interview he indicated he had the time to
conducts his duties.
Compliance was determined by review of the FDJJ and WPBYA organizational chart and interviews with
the PREA coordinator and PREA compliance manager.
Standard 115.312: Contracting with other entities for the confinement of
residents
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.312 (a)
If this agency is public and it contracts for the confinement of its residents with private agencies or
PREA Audit Report – v7 Page 26 of 125 West Palm Beach Youth Academy
other entities including other government agencies, has the agency included the entity’s obligation
to adopt and comply with the PREA standards in any new contract or contract renewal signed on or
after August 20, 2012? (N/A if the agency does not contract with private agencies or other entities
for the confinement of residents.) ☐ Yes ☐ No ☒NA
115.312 (b)
▪ Does any new contract or contract renewal signed on or after August 20, 2012 provide for
agency contract monitoring to ensure that the contractor is complying with the PREA standards?
(N/A if the agency does not contract with private agencies or other entities for the confinement
of residents.) ☐ Yes ☐ No ☒ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
The facility does not contract with other facilities to provide supervision of residents. FDJJ requires all
contractor facilities to conduct PREA audits every three years and comply will al l PREA standards. The
contract also allows for FDJJ to conduct mock audits, specific standards audits, and any investigations
based on PREA standards. FDJJ employees a full time PREA coordinator and any other resources
needed to assist private facilities in staying abreast of all PREA Audit Report – v6 Page 15 of 108
Everglades Youth Academy PREA standards and mandates. The FDJJ proactive supervision in
establishing a PREA culture from the Agency Director, Assistant Directors, Regional Supervisors, and
programs staff on the State Level provides evidence of the agency meets compliance with this
standard. Compliance was determined by review of PREA contract with DJJ.
Standard 115.313: Supervision and monitoring
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.313 (a)
PREA Audit Report – v7 Page 27 of 125 West Palm Beach Youth Academy
▪ Does the facility have a documented staffing plan that provides for adequate levels of staffing
and, where applicable, video monitoring, to protect residents against sexual abuse?
▪ ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Generally accepted juvenile detention and
correctional/secure residential practices? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Any judicial findings of inadequacy? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Any findings of inadequacy from Federal investigative
agencies? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Any findings of inadequacy from internal or external
oversight bodies? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: All components of the facility’s physical plant (including
“blind-spots” or areas where staff or residents may be isolated)? ☒Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: The composition of the resident population? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: The number and placement of supervisory staff? ☒ Yes
☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Institution programs occurring on a particular shift? ☒ Yes
☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Any applicable State or local laws, regulations, or
standards? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration the prevalence of substantiated and unsubstantiated
incidents of sexual abuse? ☒ Yes ☐ No
▪ In calculating adequate staffing levels and determining the need for video monitoring, does the
staffing plan take into consideration: Any other relevant factors? ☒ Yes ☐ No
115.313 (b)
PREA Audit Report – v7 Page 28 of 125 West Palm Beach Youth Academy
▪ Does the agency comply with the staffing plan except during limited and discrete exigent
circumstances? ☒ Yes ☐ No
▪ In circumstances where the staffing plan is not complied with, does the facility document all
deviations from the plan? (N/A if no deviations from staffing plan.) ☐ Yes ☐ No ☒ NA
115.313 (c)
▪ Does the facility maintain staff ratios of a minimum of 1:8 during resident waking hours, except
during limited and discrete exigent circumstances? (N/A if the facility is not a secure juvenile
facility per the PREA standards definition of “secure”.)
☒ Yes ☐ No ☐ NA
▪ Does the facility maintain staff ratios of a minimum of 1:16 during resident sleeping hours,
except during limited and discrete exigent circumstances? (N/A if the facility is not a secure
juvenile facility per the PREA standards definition of “secure”.) ☒Yes ☐ No ☐ NA
▪ Does the facility fully document any limited and discrete exigent circumstances during which the
facility did not maintain staff ratios? (N/A if the facility is not a secure juvenile facility per the
PREA standards definition of “secure”.) ☒ Yes ☐ No ☐ NA
▪ Does the facility ensure only security staff are included when calculating these ratios? (N/A if the
facility is not a secure juvenile facility per the PREA standards definition of “secure”.) ☒ Yes ☐
No ☐ NA
▪ Is the facility obligated by law, regulation, or judicial consent decree to maintain the staffing
ratios set forth in this paragraph? ☒ Yes ☐ No
115.313 (d)
▪ In the past 12 months, has the facility, in consultation with the agency PREA Coordinator, assessed,
determined, and documented whether adjustments are needed to: The staffing plan established
pursuant to paragraph (a) of this section? ☒ Yes ☐ No
▪ In the past 12 months, has the facility, in consultation with the agency PREA Coordinator,
assessed, determined, and documented whether adjustments are needed to: Prevailing staffing
patterns? ☒ Yes ☐ No
▪ In the past 12 months, has the facility, in consultation with the agency PREA Coordinator,
assessed, determined, and documented whether adjustments are needed to: The facility’s
deployment of video monitoring systems and other monitoring technologies? ☒ Yes ☐ No
▪ In the past 12 months, has the facility, in consultation with the agency PREA Coordinator,
assessed, determined, and documented whether adjustments are needed to: The resources the
facility has available to commit to ensure adherence to the staffing plan? ☒ Yes ☐ No
115.313 (e)
PREA Audit Report – v7 Page 29 of 125 West Palm Beach Youth Academy
▪ Has the facility implemented a Policy and practice of having intermediate-level or higher-level
supervisors conduct and document unannounced rounds to identify and deter staff sexual
abuse and sexual harassment? (N/A for non-secure facilities) ☒ Yes ☐ No ☐ NA
▪ Is this Policy and practice implemented for night shifts as well as day shifts? (N/A for non-secure
facilities) ☒ Yes ☐ No ☐ NA
▪ Does the facility have a Policy prohibiting staff from alerting other staff members that these
supervisory rounds are occurring, unless such announcement is related to the legitimate
operational functions of the facility? (N/A for non-secure facilities) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Staff to youth ratio docs
Staffing Plan
Unannounced Tours
Department of Juvenile Justice Policy 1919 – PREA
PREA Pre-Audit Questionnaire
Resident Daily Rosters
115.313 (a): Each year during the agency reviews of staffing includes needs for cameras, staffing or
rearranging the staffing plan to meet the required staff in order to maintain a safe and secure
operation. Their staffing plan’s annual reviews conducted in 2021 were found to be in compliance with
this standard. The staffing plan included: 1) Generally accepted detention and correctional/secure
residential practices. (2) Any judicial findings of inadequacy. (3) Any findings of inadequacy from
Federal investigative agencies. (4) Any findings of inadequacy from internal or external oversight
bodies. (5) All components of the facility’s physical plant (including “blind spots” or areas where staff
or residents may be isolated). (6) The composition of the resident population. (7) The number and
placement of supervisory staff. (8) Institution programs occurring on a particular shift. (9) Any
applicable State or local laws, regulations, or standards. (10) The prevalence of substantiated and
PREA Audit Report – v7 Page 30 of 125 West Palm Beach Youth Academy
unsubstantiated incidents of sexual abuse; and (11) Any other relevant factors. The facility did not
report deviations from the staffing plan during the past 12 months. The staffto-youth ratios of a
minimum of 1: 8 during the resident waking and minimum of 1:12 during sleeping hours is always
maintained, the facility has a mechanism in place for call outs and staff volunteer to stay over if
needed. EYA utilizes staff monitoring to protect the residents from sexual abuse and harassment.
Based on conversations with the PREA coordinator and facility administrator it was obvious that the
facilities review all areas of the center for additional staffing and resident movement in order to meet
the requirement of this standard. The direct care staff were noted to be located throughout the center
during the tour or review of cameras monitoring. The facilities utilize the standard of minimum of 1 to
8 direct care staff during waking hours and minimum of 1 to 12 during sleeping hours. Random
interviewed direct care confirmed that they are assigned based on activities at each unit which will
impact the staffing plan. The random staff stated that the center does not count control operators
toward meeting this requirement. The facility administrator provided a daily roster that indicates the
staffing utilized during the prior 24 hours. All residents are assigned a therapist that provides group
and individual counseling programs. During these sessions, residents are supervised by cameras or out
of sound supervision by youth workers.
115.313 (b): The facility administrator provided a daily roster that indicates the staffing utilized during
the prior 24 hours. During the pandemic the center had to reduce the resident capacity in order to
provide staff that ensured compliance with the staff to resident ratios. The center also provided
overtime pay and utilized management staff to me the mandates of the staff to resident ratios. The
auditor reviewed the staffing schedules for the past 90 days and found that the facility was providing
overtime pay for staff on a routing basis. However, there were no instances when the mandatory staff
requirement were not met.
115.313 (c): The FDJJ Policy 1919 – PREA mandates that the staffing plan will be reviewed and
approved by the PREA coordinator at least yearly. Under contract with FDJJ private vendor must
provide the annual staffing plan each year to be approved by the FDJJJ PREA coordinator and
contracting division of FDJJJ. The facility staffing plan for 2021 was submitted in August 2021. FDJJ
conducts an extensive review of all areas of private facilities and assesses the need for additional
cameras, staffing programing, and overall operation of the facility.
115.313 (e): The Facility administrator and Regional Administrator both conduct and document
unannounced rounds on all shifts and all areas of the facility to monitor and deter staff sexual abuse
and harassment. Each shift supervisor makes rounds several times during each shift. It is the Policy of
FDJJ that staff are not to inform other staff when the shift supervisor, facility manager or regional
administrators are making rounds. During the tour the auditor reviewed the logbooks in all housing
units and noted that the shift supervisor, operations manager and facility administrator had signed to
logbook a minimum of one a day for the last three week excluding weekends. Shift supervisor and
operations manager had signed the logbooks on each day including weekends.
Compliance was determined by review of policies, documentation and interview with staff confirm
compliance with this standard. Staff could not meet with the auditor until they were properly relieved
to ensure the facility always had a 1 to 8 ratio during waking hours and a ratio of 1 to 12 during
sleeping hours.
PREA Audit Report – v7 Page 31 of 125 West Palm Beach Youth Academy
Standard 115.315: Limits to cross-gender viewing and searches
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.315 (a)
▪ Does the facility always refrain from conducting any cross-gender strip or cross-gender visual
body cavity searches, except in exigent circumstances or by medical practitioners?
☒ Yes ☐ No
115.315 (b)
▪ Does the facility always refrain from conducting cross-gender pat-down searches in non-exigent
circumstances? ☒ Yes ☐ No ☐ NA
115.315 (c)
▪ Does the facility document and justify all cross-gender strip searches and cross-gender visual
body cavity searches? ☒ Yes ☐ No
▪ Does the facility document all cross-gender pat-down searches? ☒ Yes ☐ No
115.315 (d)
▪ Does the facility have policies that enable residents to shower, perform bodily functions, and
change clothing without nonmedical staff of the opposite gender viewing their breasts, buttocks,
or genitalia, except in exigent circumstances or when such viewing is incidental to routine cell
checks? ☒ Yes ☐ No
▪ Does the facility have procedures that enable residents to shower, perform bodily functions, and
change clothing without nonmedical staff of the opposite gender viewing their breasts, buttocks,
or genitalia, except in exigent circumstances or when such viewing is incidental to routine cell
checks? ☒ Yes ☐ No
▪ Does the facility require staff of the opposite gender to announce their presence when entering
a resident housing unit? ☒ Yes ☐ No
▪ In facilities (such as group homes) that do not contain discrete housing units, does the facility
require staff of the opposite gender to announce their presence when entering an area where
residents are likely to be showering, performing bodily functions, or changing clothing? (N/A for
facilities with discrete housing units) ☒ Yes ☐ No ☐ NA
115.315 (e)
▪ Does the facility always refrain from searching or physically examining transgender or intersex
residents for the sole purpose of determining the resident’s genital status? ☒ Yes ☐ No
PREA Audit Report – v7 Page 32 of 125 West Palm Beach Youth Academy
▪ If a resident’s genital status is unknown, does the facility determine genital status during
conversations with the resident, by reviewing medical records, or, if necessary, by learning that
information as part of a broader medical examination conducted in private by a medical
practitioner? ☒Yes ☐ No
115.315 (f)
▪ Does the facility/agency train security staff in how to conduct cross-gender pat down searches
in a professional and respectful manner, and in the least intrusive manner possible, consistent
with security needs? ☒ Yes ☐ No
▪ Does the facility/agency train security staff in how to conduct searches of transgender and
intersex residents in a professional and respectful manner, and in the least intrusive manner
possible, consistent with security needs? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
FDJJ 1919 – Searches
PREA Statement of preference
Cross-gender and transgender pat searches facilitator guide
Guidance on Cross-Gender and Transgender Pat Searches-HD(2)
Training Video on Guidance on Cross Gender and LBGTQ searches
PAQ
115.315 (a): Based on interviews with staff and residents there have been no cross-gender pat down
searches in the last 12 months. Policy FDJJ 1919 – Searches mandates the facility always refrain from
conducting any cross-gender strip or cross-gender visual body cavity searches, except in exigent
circumstances or by medical practitioners.
PREA Audit Report – v7 Page 33 of 125 West Palm Beach Youth Academy
115.315 (b): FDJJ 1919 – Searches mandates the facility always refrain from conducting any cross-
gender pat down except in exigent circumstances. All staff interviewed indicated they have never
conducted a cross-gender search. All resident interviewed stated they had never been searched by a
female staff.
115.315 (c): The facility did not have any transgender or intersex resident at the facility. All cross
gender searches are documented. According to the PAQ there were no cross gender searches during
the last 12 months.
115.315 (d): A tour of the center found that all areas that are utilized for housing residents have
necessary barriers to allow resident to shower without being viewed by person of the opposite gender
and privacy from other residents during the showering process. All resident stated they are allowed to
change clothes and shower in private. A review of the cameras noted there were no cameras that
provided views of the shower or toilet areas in any of the units. All staff of the other gender always
announce their presence when entering a housing unit. There are reminders poster placed at the
entrance of each housing unit. Staff and resident confirm that staff announce their presence and will
knock on the door prior to looking in during counts.
115.315 (e): Agency Policy prohibits searching or physically examining a transgender or intersex youth
for the sole purpose of determining the youth’s genital status. Policy mandates that If a resident’s
genital status is unknown, the facility determine genital status during conversations with the resident,
by reviewing medical records, or, if necessary, by learning that information as part of a broader
medical examination conducted in private by a medical practitioner. Prior to arriving at the WPBYA
residents are screened by an assessment center and will be provided with mental health, medical
documentation. The Clinical Supervisor stated she would meet with the resident and take into
consideration of his/her sexual orientation and treat them accordingly.
115.315 (f): A review of the staff training plan includes intervention techniques and standards required
to be utilized prior to conducting any searches. Interview with random staff confirmed they had
received training on intervention techniques. This training included conducting cross gender searches
in a professional and respectful manner.
Compliance was determined by review of polices, watching the cross gender video, and interview with
resident and staff.
Standard 115.316: Residents with disabilities and residents who are limited
English proficient
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.316 (a)
▪ Does the agency take appropriate steps to ensure that residents with disabilities have an equal
opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect,
and respond to sexual abuse and sexual harassment, including: Residents who are deaf or hard
of hearing? ☒ Yes ☐ No
PREA Audit Report – v7 Page 34 of 125 West Palm Beach Youth Academy
▪ Does the agency take appropriate steps to ensure that residents with disabilities have an equal
opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect,
and respond to sexual abuse and sexual harassment, including: Residents who are blind or
have low vision? ☒ Yes ☐ No
▪ Does the agency take appropriate steps to ensure that residents with disabilities have an equal
opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect,
and respond to sexual abuse and sexual harassment, including: Residents who have intellectual
disabilities? ☒ Yes ☐ No
▪ Does the agency take appropriate steps to ensure that residents with disabilities have an equal
opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect,
and respond to sexual abuse and sexual harassment, including: Residents who have psychiatric
disabilities? ☒ Yes ☐ No
▪ Does the agency take appropriate steps to ensure that residents with disabilities have an equal
opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect,
and respond to sexual abuse and sexual harassment, including: Residents who have speech
disabilities? ☒ Yes ☐ No
▪ Does the agency take appropriate steps to ensure that residents with disabilities have an equal
opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect,
and respond to sexual abuse and sexual harassment, including: Other? (if "other," please
explain in overall determination notes.) ☒ Yes ☐ No
▪ Do such steps include, when necessary, ensuring effective communication with residents who
are deaf or hard of hearing? ☒ Yes ☐ No
▪ Do such steps include, when necessary, providing access to interpreters who can interpret
effectively, accurately, and impartially, both receptively and expressively, using any necessary
specialized vocabulary? ☒ Yes ☐ No
▪ Does the agency ensure that written materials are provided in formats or through methods that
ensure effective communication with residents with disabilities including residents who: Have
intellectual disabilities? ☒ Yes ☐ No
▪ Does the agency ensure that written materials are provided in formats or through methods that
ensure effective communication with residents with disabilities including residents who: Have
limited reading skills? ☒ Yes ☐ No
▪ Does the agency ensure that written materials are provided in formats or through methods that
ensure effective communication with residents with disabilities including residents who: Are
blind or have low vision? ☒ Yes ☐ No
115.316 (b)
▪ Does the agency take reasonable steps to ensure meaningful access to all aspects of the
agency’s efforts to prevent, detect, and respond to sexual abuse and sexual harassment to
residents who are limited English proficient? ☒ Yes ☐ No
PREA Audit Report – v7 Page 35 of 125 West Palm Beach Youth Academy
▪ Do these steps include providing interpreters who can interpret effectively, accurately, and
impartially, both receptively and expressively, using any necessary specialized vocabulary?
☒ Yes ☐ No
115.316 (c)
▪ Does the agency always refrain from relying on resident interpreters, resident readers, or other
types of resident assistants except in limited circumstances where an extended delay in
obtaining an effective interpreter could compromise the resident’s safety, the performance of
first-response duties under §115.364, or the investigation of the resident’s allegations?
☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
Department of Juvenile Justice Policy- 1919 PREA
PREA contract language
Special Needs poster
115.316 (a): DJJ includes polices and directives that residents with disabilities and residents who are
limited English Proficient mandates that the agency shall take appropriate steps to ensure that
residents with disabilities (including, for example, residents who are deaf or hard of hearing, those who
are blind or have low vision, or those who have intellectual, psychiatric, or speech disabilities), have an
equal opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent,
detect, and respond to sexual abuse and sexual harassment. Such steps shall include, when necessary
to ensure effective communication with residents who are deaf or hard of hearing, providing access to
interpreters who can interpret effectively, accurately, and impartially, both receptively and
expressively, using any necessary specialized vocabulary. In addition, the agency shall ensure that
written materials are provided in formats or through methods that ensure effective communication
with residents with disabilities, including residents who have intellectual disabilities, limited reading
skills, or who are blind or have low vision.
PREA Audit Report – v7 Page 36 of 125 West Palm Beach Youth Academy
Residents receive information explaining the agency’s zero tolerance Policy in an ageappropriate
fashion including how to report incidents or suspicions of sexual abuse or sexual harassment in the
appropriate manner, taking into consideration age, disabilities, sexual orientation, and language.
The comprehensive education is accessible to all residents, including those who are limited English
proficient, deaf, visually impaired, or otherwise disabled as well as to the residents who have limited
reading skills. If the youth report a deficiency or the staff are aware of a deficiency in any of these
areas, they will report to the supervisor the need for an additional resource. The supervisor will notify
the facility administrator who will contact the appropriate community resource services. Arrangements
will be made for an interpreter who can interpret effectively, accurately, and impartially, both
receptively and expressively, using any necessary specialized vocabulary, when necessary. In all
circumstances this center will not rely on resident interpreters.
All special needs youth shall be offered the ability to have any rules or grievance procedures read orally
and explained to them. At a minimum, the following special needs are to be addressed:
When youth 9 years or younger are admitted into the facility the following procedures must be
followed:
• During awake activities, these youth shall be separated from the general population or assigned to an
officer who will maintain constant sight and sound supervision of the youth. During sleep time, normal
supervision shall be provided.
• These youth shall be placed in sleeping rooms by themselves whenever possible. If it is not possible
to provide individual sleeping rooms, they shall be placed in a room with an appropriate youth based
on the classification process and selected in conjunction with the medical and mental health staff.
• Facility mental health and medical personnel shall assess youth weekly to determine any special
needs. The results of the assessment, including recommendations for care, shall be reported to the
Superintendent. The Superintendent or designee shall review the reports and take necessary action.
• The Detention Superintendent or designee shall immediately notify the Regional Director, DJJ Legal
Counsel, the CCC and the Circuit Probation Office upon the admission of a youth 9 years of age or
younger. These parties shall work together to coordinate with the court and the parent/legal guardian
for alternative placement and/or delivery of services and release from secure detention.
• The Regional Director or designee is responsible for ensuring necessary assistance is provided to the
detention center to assist in meeting the needs of those youth.
When youth are identified as having developmental disabilities who have been determined as unable
to function in the general population are admitted to the facility, the following procedures shall be
followed:
• These youth shall be documented in the Facility and Mod logbook on each shift and on the shift
report, and if applicable, documented in JJIS and FMS.
• During awake activities, these youth shall be separated from the general population or assigned to an
officer who will maintain constant sight and sound supervision of the youth. During sleep time, normal
supervision shall be provided.
PREA Audit Report – v7 Page 37 of 125 West Palm Beach Youth Academy
When any other special circumstances that makes providing all the aspects of the PREA program are
presented, based on interview with the clinical therapist, education lead teacher, operation manager
and facility administrator the team would utilize the 504 previsions of the Special Education Standards
to secure whatever resources are required to meet the education requirements and would use this
same resource to ensure compliance with the PREA standards.
115.316 (b): The facility has bilingual staff and a contract for language services. The facility also has
access to language sign language staff. Staff would read all information required for an orientation into
the facility and the comprehensive PREA training for residents that can’t read.
115.316 (c): FDJJ Policy 1919 mandates for resident that are ELP arrangements will be made for an
interpreter who can interpret effectively, accurately, and impartially, both receptively and expressively,
using any necessary specialized vocabulary, when necessary. In all circumstances this center will not
rely on resident interpreters.
Compliance was determined by review of Policy, language line contract, and interviews with clinical
supervisor director, education lead teacher, operations manager, facility administrator and PREA
compliance manager.
Standard 115.317: Hiring and promotion decisions
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.317 (a)
▪ Does the agency prohibit the hiring or promotion of anyone who may have contact with
residents who: Has engaged in sexual abuse in a prison, jail, lockup, community confinement
facility, juvenile facility, or other institution (as defined in 42 U.S.C. 1997)? ☒ Yes ☐ No
▪ Does the agency prohibit the hiring or promotion of anyone who may have contact with
residents who: Has been convicted of engaging or attempting to engage in sexual activity in the
community facilitated by force, overt or implied threats of force, or coercion, or if the victim did
not consent or was unable to consent or refuse? ☒ Yes ☐ No
▪ Does the agency prohibit the hiring or promotion of anyone who may have contact with
residents who: Has been civilly or administratively adjudicated to have engaged in the activity
described in the question immediately above? ☒ Yes ☐ No
▪ Does the agency prohibit the enlistment of services of any contractor who may have contact
with residents who: Has engaged in sexual abuse in a prison, jail, lockup, community
confinement facility, juvenile facility, or other institution (as defined in 42 U.S.C. 1997)?
☒ Yes ☐ No
▪ Does the agency prohibit the enlistment of services of any contractor who may have contact
with residents who: Has been convicted of engaging or attempting to engage in sexual activity in
the community facilitated by force, overt or implied threats of force, or coercion, or if the victim
did not consent or was unable to consent or refuse? ☒Yes ☐ No
PREA Audit Report – v7 Page 38 of 125 West Palm Beach Youth Academy
▪ Does the agency prohibit the enlistment of services of any contractor who may have contact
with residents who: Has been civilly or administratively adjudicated to have engaged in the
activity described in the question immediately above? ☒Yes ☐ No
115.317 (b)
▪ Does the agency consider any incidents of sexual harassment in determining whether to hire or
promote anyone who may have contact with residents? ☒ Yes ☐ No
▪ Does the agency consider any incidents of sexual harassment in determining whether to enlist
the services of any contractor who may have contact with residents? ☒ Yes ☐ No
115.317 (c)
▪ Before hiring new employees, who may have contact with residents, does the agency perform a
criminal background records check? ☒ Yes ☐ No
▪ Before hiring new employees, who may have contact with residents, does the agency consult
any child abuse registry maintained by the State or locality in which the employee would work?
☒Yes ☐ No
▪ Before hiring new employees who may have contact with residents, does the agency, consistent
with Federal, State, and local law, make its best efforts to contact all prior institutional employers
for information on substantiated allegations of sexual abuse or any resignation during a pending
investigation of an allegation of sexual abuse? ☒ Yes ☐ No
115.317 (d)
▪ Does the agency perform a criminal background records check before enlisting the services of
any contractor who may have contact with residents? ☒ Yes ☐ No
▪ Does the agency consult applicable child abuse registries before enlisting the services of any
contractor who may have contact with residents? ☒ Yes ☐ No
115.317 (e)
▪ Does the agency either conduct criminal background records checks at least every five years of
current employees and contractors who may have contact with residents or have in place a
system for otherwise capturing such information for current employees? ☒ Yes ☐ No
115.317 (f)
▪ Does the agency ask all applicants and employees who may have contact with residents directly
about previous misconduct described in paragraph (a) of this section in written applications or
interviews for hiring or promotions? ☒ Yes ☐ No
PREA Audit Report – v7 Page 39 of 125 West Palm Beach Youth Academy
▪ Does the agency ask all applicants and employees who may have contact with residents directly
about previous misconduct described in paragraph (a) of this section in any interviews or written
self-evaluations conducted as part of reviews of current employees? ☒ Yes ☐ No
▪ Does the agency impose upon employees a continuing affirmative duty to disclose any such
misconduct? ☒ Yes ☐ No
115.317 (g)
▪ Does the agency consider material omissions regarding such misconduct, or the provision of
materially false information, grounds for termination? ☒ Yes ☐ No
115.317 (h)
▪ Does the agency provide information on substantiated allegations of sexual abuse or sexual
harassment involving a former employee upon receiving a request from an institutional
employer for whom such employee has applied to work? (N/A if providing information on
substantiated allegations of sexual abuse or sexual harassment involving a former employee is
prohibited by law.) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
FDJJ 1919 PREA
djj-employee-handbook-02052018-final
FDJJ 1800 - Background screening and Hiring practice
10 Personnel Files
PREA questionnaire
115.317 (a): DJJ or agency shall not hire or promote anyone who may have contact with youth and shall not
enlist the services of any contractor who may have contact with youth, who.
PREA Audit Report – v7 Page 40 of 125 West Palm Beach Youth Academy
1. Has engaged in sexual abuse in a prison, jail, lockup, community confinement facility, juvenile facility, or other
institution (as defined in 42 U.S.C. 1997).
2. Has been convicted of engaging or attempting to engage in sexual activity in the community facilitated by
force, overt or implied threats of force, or coercion, or if the victim did not consent or was unable to consent or
refuse; or
3. Has been civilly or administratively adjudicated to have engaged in or attempting to engage in sexual activity
in the community facilitated by force, overt or implied threats of force, or coercion, or if the victim did not
consent or was unable to consent or refuse.
4. DJJ shall consider any incidents of sexual harassment in determining whether to hire or promote anyone, or to
enlist the services of any contractor, who may have contact with youth.
5. Before hiring new employees who may have contact with youth, the division shall adhere to DJJ 106.3
Background Check
6. DJJ shall ensure that a criminal background records check has been completed, and consult applicable child
abuse registries, before enlisting the services of any contractor who may have unsupervised contact with youth.
During initial interviews, prospective employees, interns, and volunteers shall be informed of the background
check procedure. DJJ shall require the following background checks on all DJJ staff, volunteers, interns, and
contractors and any applicant that is being considered for employment or promotion with DJJ:
1. Criminal background or records check.
2. Sexual offender registry check; and
3. Child abuse and neglect registry check.
115.317 (b): The Agency Policy states any incidents of sexual harassment by a staff member will be taken into
consideration if the staff member is eligible for promotion. Prior to a promotion the facility will conduct a
promotion board. Prior to meeting with the board, the applicant completes a questionnaire that includes all
areas of the standard. The interview questions for employment also address previous misconduct. The evidence
shows the facility considers any incident of sexual harassment in determining whether to hire or promote
anyone, or to enlist the services of any contractor, who may have contact with residents. Policy states any
incidents of sexual harassment by a staff member will be taken into consideration if the staff member is eligible
for promotion. The interview questions for employment also address previous misconduct. The evidence shows
the facility considers any incident of sexual harassment in determining whether to hire or promote anyone, or to
enlist the services of any contractor, who may have contact with residents.
115.317 (c): During initial interviews, prospective employees, interns, and volunteers shall be informed of the
background check procedure. DJJ shall require the following background checks on all DJJ staff, volunteers,
interns, and contractors and any applicant that is being considered for employment or promotion with DJJ:
1. Criminal background or records check.
2. Sexual offender registry check; and
3. Child abuse and neglect registry check.
The human resources staff indicated in interviewed and confirmed by reviewing personnel files that she
conducts a reference check on all prospective employees. This check include any past history of sexual abuse,
sexual harassment including sexual harassment toward other staff.
115.317 (d): DJJ shall ensure that a criminal background records check has been completed, and consult
applicable child abuse registries, before enlisting the services of any contractor who may have unsupervised
contact with youth.
PREA Audit Report – v7 Page 41 of 125 West Palm Beach Youth Academy
115.317 (e): DJJ shall conduct background checks on all DJJ staff, volunteers, interns, and contractors every five
(5) years, or sooner. This was confirmed by reviewing background check for staff with 5 year or more tenure at
the facility.
115.317 (f): The agency asks applicants about previous misconduct described in paragraph (a) of this section in
written applications or during interviews for hiring or promotions. The facility does a yearly staff appraisal and
sexual abuse, or sexual harassment is part of that appraisal.
115.317 (g): FDJJ 1800 - Background screening and Hiring practice mandates that employees and volunteers will
report any arrest, which include any notice to appear in court for a criminal Charge, to their immediate
supervisor within 24 hours of the arrest or receipt of the notice to appear. Failure to report may result in
disciplinary action up to and including termination.
Material omissions regarding such misconduct, or the provision of materially false information, shall be grounds
for termination. FOP states material omissions regarding such misconduct, or the provision of materially false
information, shall be grounds for termination. Based on the review of the documentation and the interview with
the Facility Administrator, the evidence shows the facility follows this provision of the standard.
115.317 (h): Unless prohibited by law, the agency shall provide information on substantiated allegations of
sexual abuse or sexual harassment involving a former employee upon receiving a request from an institutional
employer for whom such employee has applied to work. The interview with the Facility Administrator confirmed
the facility would provide this information if requested to do so. Policy and FOP states the information would be
provided when requested unless it is prohibited by law to provide the information.
Compliance with the standard was determined by review of policies, personnel files, and interviews with
Personnel supervisor agency head and facility administrator.
Standard 115.318: Upgrades to facilities and technologies
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.318 (a)
▪ If the agency designed or acquired any new facility or planned any substantial expansion or
modification of existing facilities, did the agency consider the effect of the design, acquisition,
expansion, or modification upon the agency’s ability to protect residents from sexual abuse?
(N/A if agency/facility has not acquired a new facility or made a substantial expansion to existing
facilities since August 20, 2012, or since the last PREA audit, whichever is later.)
☐ Yes ☐ No ☒ NA
115.318 (b)
▪ If the agency installed or updated a video monitoring system, electronic surveillance system, or
other monitoring technology, did the agency consider how such technology may enhance the
agency’s ability to protect residents from sexual abuse? (N/A if agency/facility has not installed
or updated a video monitoring system, electronic surveillance system, or other monitoring
technology since August 20, 2012, or since the last PREA audit, whichever is later.)
☐ Yes ☐ No ☒ NA
PREA Audit Report – v7 Page 42 of 125 West Palm Beach Youth Academy
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The facility has not made any substantial upgrades to the camera system since 2019 when the facility
had a total upgrade in their monitoring capabilities. This information was noted on the last PRE audit.
The facility is in compliance with this standard. Based on FDJJ Policy 1919 when there is substantial
expansion to the facility, the ability to protect residents and staff from sexual abuse will be reviewed
and ensured. During the on-site tour, the video surveillance system was observed, and all cameras
were pointed out by staff. The video monitoring system was assessed during the annual review of the
staffing plan. The interview with the Facility Administrator and according to the Pre-Audit
Questionnaire confirmed compliance with this standard.
RESPONSIVE PLANNING
Standard 115.321: Evidence protocol and forensic medical examinations
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.321 (a)
▪ If the agency is responsible for investigating allegations of sexual abuse, does the agency follow
a uniform evidence protocol that maximizes the potential for obtaining usable physical evidence
for administrative proceedings and criminal prosecutions? (N/A if the agency/facility is not
responsible for conducting any form of criminal OR administrative sexual abuse investigations.)
☐ Yes ☐ No ☒NA
115.321 (b)
▪ Is this protocol developmentally appropriate for youth where applicable? (N/A if the
agency/facility is not responsible for conducting any form of criminal OR administrative sexual
abuse investigations.) ☐ Yes ☐ No ☒ NA
▪ Is this protocol, as appropriate, adapted from or otherwise based on the most recent edition of
the U.S. Department of Justice’s Office on Violence Against Women publication, “A National
PREA Audit Report – v7 Page 43 of 125 West Palm Beach Youth Academy
Protocol for Sexual Assault Medical Forensic Examinations, Adults/Adolescents,” or similarly
comprehensive and authoritative protocols developed after 2011? (N/A if the agency/facility is
not responsible for conducting any form of criminal OR administrative sexual abuse
investigations.) ☐ Yes ☐ No ☒ NA
115.321 (c)
▪ Does the agency offer all residents who experience sexual abuse access to forensic medical
examinations, whether on-site or at an outside facility, without financial cost, where evidentiarily
or medically appropriate? ☒ Yes ☐ No
▪ Are such examinations performed by Sexual Assault Forensic Examiners (SAFEs) or Sexual
Assault Nurse Examiners (SANEs) where possible? ☒ Yes ☐ No
▪ If SAFEs or SANEs cannot be made available, is the examination performed by other qualified
medical practitioners (they must have been specifically trained to conduct sexual assault
forensic exams)? ☒ Yes ☐ No
▪ Has the agency documented its efforts to provide SAFEs or SANEs? ☒ Yes ☐ No
115.321 (d)
▪ Does the agency attempt to make available to the victim a victim advocate from a rape crisis
center? ☒ Yes ☐ No
▪ If a rape crisis center is not available to provide victim advocate services, does the agency
make available to provide these services a qualified staff member from a community-based
organization, or a qualified agency staff member? (N/A if the agency always makes a victim
advocate from a rape crisis center available to victims.) ☐ Yes ☐ No ☒ NA
▪ Has the agency documented its efforts to secure services from rape crisis centers?
☒ Yes ☐ No
115.321 (e)
▪ As requested by the victim, does the victim advocate, qualified agency staff member, or
qualified community-based organization staff member accompany and support the victim
through the forensic medical examination process and investigatory interviews? ☒ Yes ☐ No
▪ As requested by the victim, does this person provide emotional support, crisis intervention,
information, and referrals? ☒ Yes ☐ No
115.321 (f)
▪ If the agency itself is not responsible for investigating allegations of sexual abuse, has the
agency requested that the investigating agency follow the requirements of paragraphs (a)
through (e) of this section? (N/A if the agency/facility is responsible for conducting criminal AND
administrative sexual abuse investigations.) ☒ Yes ☐ No ☐ NA
115.321 (g)
PREA Audit Report – v7 Page 44 of 125 West Palm Beach Youth Academy
▪ Auditor is not required to audit this provision.
115.321 (h)
▪ If the agency uses a qualified agency staff member or a qualified community-based staff
member for the purposes of this section, has the individual been screened for appropriateness
to serve in this role and received education concerning sexual assault and forensic examination
issues in general? (N/A if agency always makes a victim advocate from a rape crisis center
available to victims.) ☐ Yes ☐ No ☒ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919 PREA - Forensic Medical Exams and MOU
FDJJ Policy 1919 PREA - Investigative Protocols
Forensic medical Examinations
IG Compliance Form-directive 3-05
IG Directive 4-03 IG request to Law Enforcement Officers to follow uniform evidence protocols.
Investigative protocol
PREA-Advocacy poster
IG request to LEO to follow uniform evidence protocols
MOU agreement with Palm Beach County Victim Services Center(SART)
115.321 (a): The Inspector General has published and sent out to law enforcement staff that would
investigate criminal allegation of sexual abuse a request that they follow uniform evidence and
investigative protocol.
115.321 (b): and (F): To the extent the agency is responsible for investigating allegations of sexual
abuse, the agency shall follow a uniform evidence protocol that maximizes the potential for obtaining
PREA Audit Report – v7 Page 45 of 125 West Palm Beach Youth Academy
usable physical evidence for administrative proceedings and criminal prosecutions. (b) The protocol
shall be developmentally appropriate for youth and as appropriate, shall be adapted from or otherwise
based on the most recent edition of the U.S. Department of Justice’s Office on Violence Against
Women publication, “A National Protocol for Sexual Assault Medical Forensic Examinations,
Adults/Adolescents,” or similarly comprehensive and authoritative protocols developed after 2011.
Policy and FOP provides for the uniform FDJJ Protocols to be followed. The Protocol is outlined
regarding appropriateness for youth and adults. The FDJJ Protocol, developed by related professionals,
addresses but is not limited to interviewing; evidence collection; victim services; notifications; and
prosecution of sexual assault cases. The agency-based investigators conduct administrative
investigations and the Palm County Sheriff’s Office investigate sexual abuse allegations that are
criminal in nature. Staff interviews confirmed an understanding of the facility’s protocol for obtaining
usable physical evidence if a resident alleges sexual abuse and knowledge of the entities responsible
for conducting investigations.
115.321 (c): The agency shall offer all residents who experience sexual abuse access to forensic
medical examinations whether on-site or at an outside facility, without financial cost, where
evidentiary or medically appropriate. Such examinations shall be performed by Sexual Assault Forensic
Examiners (SAFEs) or Sexual Assault Nurse Examiners (SANEs) where possible. If SAFEs or SANEs cannot
be made available, the examination can be performed by other qualified medical practitioners. The
agency shall document its efforts to provide SAFEs or SANEs. The facility does have a MOU with Palm
Beach County Victim Services SART Center. Which includes Saint Mary Medical Center for SANEs. The
medical center staff interviewed by telephone verified that the hospital had SANE staff on duty and
had a working relationship with the county’s Victim Services SART program.
115.321 (d): The facility does have a MOU with Palm Beach County Victim Services SART Center. that
includes Saint Mary Medical Center as part of the victim advocacy services. This MOU includes
advocacy services and emotional support services. The Victim’s center director was contacted and
provided a review of the program and services available to residents at Palm Beach County Victim
Services at no cost to the resident. The Advocacy program was familiar with the Palm Beach Regional
Juvenile Detention Center program. She verbally provided qualification of advocacy staff at the
program and the services they provide to residents. The facility utilizes Safe Nurse at Saint Mary
Medical Center. The medical center staff interviewed by telephone verified that the hospital had SANE
staff on duty and had a working relationship with Victim Services SART Center. A qualitied victim
advocate would accompany a resident for a SANEs and during the law enforcement investigations. The
advocate program would continue to offer emotional support, crisis intervention and referrals. The
center has full time clinical therapist that would also provide crisis intervention as requested by the
victim and as part of the resident treatment plan.
115.321 (g) The facility has a MOU with a Rape Crisis center. Compliance was determined through the
review of MOU with Palm Beach County Victim Services and interviews with staff from the OIG office.
Reviews of policies also contributed to the finding of compliance. Interviews with Mental Health
Provider, Medical Administrator, the Victim’s center staff, and with OIG investigator also provided
compliance with this standard.
PREA Audit Report – v7 Page 46 of 125 West Palm Beach Youth Academy
Standard 115.322: Policies to ensure referrals of allegations for
investigations
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.322 (a)
▪ Does the agency ensure an administrative or criminal investigation is completed for all
allegations of sexual abuse? ☒ Yes ☐ No
▪ Does the agency ensure an administrative or criminal investigation is completed for all
allegations of sexual harassment? ☒ Yes ☐ No
115.322 (b)
▪ Does the agency have a Policy and practice in place to ensure that allegations of sexual abuse
or sexual harassment are referred for investigation to an agency with the legal authority to
conduct criminal investigations, unless the allegation does not involve potentially criminal
behavior? ☒Yes ☐ No
▪ Has the agency published such Policy on its website or, if it does not have one, made the Policy
available through other means? ☒ Yes ☐ No
▪ Does the agency document all such referrals? ☒ Yes ☐ No
115.322 (c)
▪ If a separate entity is responsible for conducting criminal investigations, does the Policy
describe the responsibilities of both the agency and the investigating entity? (N/A if the
agency/facility is responsible for criminal investigations. See 115.321(a).) ☒ Yes ☐ No ☐
NA
115.322 (d)
▪ Auditor is not required to audit this provision.
115.322 (e)
▪ Auditor is not required to audit this provision.
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
PREA Audit Report – v7 Page 47 of 125 West Palm Beach Youth Academy
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ 1919 - Investigative Protocols
IG request to LEO to follow uniform evidence protocols
IG Compliance Form-directive
IG request to Law Enforcement Officers to follow uniform evidence protocols.
PAQ
115.322 (a & b) : FDJJ 1919 - Investigative Protocols and IG compliance directive requires allegations of
sexual abuse or sexual harassment be referred to an agency with the legal authority to conduct
criminal investigations unless the allegation does not involve criminal behavior. Staff including the
facility administrator and residents indicated that any allegations that are received by residents, staff,
volunteers, or contractors would be “Hot Line” by the person with the most information, when
possible, to the Central Control Center within two (2) hours of being made aware of an allegation of
sexual abuse or sexual harassment. This information can be found on FDJJ website. There were two
allegation of sexual abuse that were reported by residents in the last 12 months. All reports were
forward to CCC within 2 hours and documented.
115.322 (c): FDJJ 1919 - Investigative Protocols mandates that staff will secure the scene, not let the
victim or predator change clothing, brush teeth, use the restroom or shower. The facility will assist the
investigator in making available video and other material as requested. The IG office will report to the
facility and assist the law enforcement if the allegation is criminal in nature and conduct the
investigation if the incident is not criminal in nature.
Compliance was verified by reviewing policies, procedures, agency website and interviews with agency
designee, facility administrator, Investigator from OIG, staff, and residents.
TRAINING AND EDUCATION
Standard 115.331: Employee training
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.331 (a)
▪ Does the agency train all employees who may have contact with residents on its zero-tolerance
Policy for sexual abuse and sexual harassment? ☒ Yes ☐ No
PREA Audit Report – v7 Page 48 of 125 West Palm Beach Youth Academy
▪ Does the agency train all employees who may have contact with residents on how to fulfill their
responsibilities under agency sexual abuse and sexual harassment prevention, detection,
reporting, and response policies and procedures? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on residents’ right to
be free from sexual abuse and sexual harassment? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on the right of
residents and employees to be free from retaliation for reporting sexual abuse and sexual
harassment? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on the dynamics of
sexual abuse and sexual harassment in juvenile facilities? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on the common
reactions of juvenile victims of sexual abuse and sexual harassment? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on how to detect and
respond to signs of threatened and actual sexual abuse and how to distinguish between
consensual sexual contact and sexual abuse between residents? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on how to avoid
inappropriate relationships with residents? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on how to
communicate effectively and professionally with residents, including lesbian, gay, bisexual,
transgender, intersex, or gender nonconforming residents? ☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on how to comply
with relevant laws related to mandatory reporting of sexual abuse to outside authorities?
☒ Yes ☐ No
▪ Does the agency train all employees who may have contact with residents on relevant laws
regarding the applicable age of consent? ☒ Yes ☐ No
115.331 (b)
▪ Is such training tailored to the unique needs and attributes of residents of juvenile facilities?
☒ Yes ☐ No
▪ Is such training tailored to the gender of the residents at the employee’s facility? ☒ Yes ☐
No
▪ Have employees received additional training if reassigned from a facility that houses only male
residents to a facility that houses only female residents, or vice versa? ☒ Yes ☐ No
115.331 (c)
PREA Audit Report – v7 Page 49 of 125 West Palm Beach Youth Academy
▪ Have all current employees who may have contact with residents received such training?
☒ Yes ☐ No
▪ Does the agency provide each employee with refresher training every two years to ensure that
all employees know the agency’s current sexual abuse and sexual harassment policies and
procedures? ☒ Yes ☐ No
▪ In years in which an employee does not receive refresher training, does the agency provide
refresher information on current sexual abuse and sexual harassment policies? ☒ Yes ☐ No
115.331 (d)
▪ Does the agency document, through employee signature or electronic verification, that
employees understand the training they have received? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919 PREA - Staff Training
Acknowledgement form
PREA SkillPro training curriculum
PREA training 2020
PREA training 2021
115.331 (a): The agency Policy addresses PREA related training for staff. All interviewed staff members
were familiar with the PREA information regarding primary components of preventing, detecting and
responding to sexual abuse or sexual harassment. PREA training is provided to staff, as indicated by a
review of Policy and training documents. The documents and staff interviews support refresher
training is also conducted and is documented. The direct care staff interviewed and the PREA
PREA Audit Report – v7 Page 50 of 125 West Palm Beach Youth Academy
Compliance Manager reported the training is provided as required. All direct care staff members
interviewed, and document review verified the general topics below were included in the training:
1. The center Zero Tolerance Policy for sexual abuse and sexual harassment.
2. How to fulfill their responsibilities under the center sexual abuse and sexual harassment prevention,
detection, reporting, and response policies and procedures.
3. Residents’ right to be free from sexual abuse and sexual harassment.
4. The right of residents and employees to be free from retaliation for reporting sexual abuse and
sexual harassment.
5. The dynamics of sexual abuse and sexual harassment juvenile facilities.
6. The common reactions of juvenile victims of sexual abuse and sexual harassment.
7. How to detect and respond to signs of threatened and actual sexual abuse and how to distinguish
between consensual sexual contact and sexual abuse between residents.
8. How to avoid inappropriate relationships with residents.
9. How to communicate effectively and professionally with residents, including lesbian, gay, bisexual,
transgender, intersex, or gender nonconforming residents.
10. How to comply with relevant laws related to mandatory reporting of sexual abuse to outside
authorities; and 11. Relevant laws regarding the applicable age of consent.
115.331 (b): Such training shall be tailored to the unique needs and attributes of residents of juvenile
facilities and to the gender of the residents at the employee’s facility. The employee shall receive
additional training if the employee is reassigned from a facility that houses only male residents to a
facility that houses only female residents, or vice versa. The facility houses males and the training
considers the needs of the population as determined by a review of training curricula and interviews
with random staff. The Policy state the training shall be tailored to the needs and attributes to the
population served.
115.331 (c): The agency provide each employee with refresher each to ensure that all employees
know the agency’s current sexual abuse and sexual harassment policies and procedures. In recent
years the yearly in services added a video on on conducting cross gender or persons frisk searches (pat
down). All staff are required to complete this training. Training roster and training records were
reviewed and documented this training. The agency Policy and FOP addresses PREA related training for
staff. All interviewed staff members were familiar with the PREA information regarding primary
components of preventing, detecting and responding to sexual abuse or sexual harassment.
115.331 (d): The agency document training, through employee signature or electronic verification that
employees understand the training they have received. The Policy and FOP provides all training be
documented. Staff members sign training rosters and training acknowledgement statements. A
checklist is utilized for orientation training for all new employees and contains the elements of PREA
training. The facility provided the Auditor with several examples for verification of the training
occurring and the training was verified through staff interviews. PREA training is provided to staff, as
indicated by a review of Policy and training documents. The documents and staff interviews support
refresher training is also conducted and is documented. The direct care staff interviewed and the PREA
Compliance Manager reported the training is provided as required. All direct care staff members
interviewed, and document review verified the general topics below were included in the training: At
the facility, it was evident through documentation, interviews, and observation of the day-today
PREA Audit Report – v7 Page 51 of 125 West Palm Beach Youth Academy
operations the staff is trained continually about the PREA standards during shift briefings, monthly
staff meetings, and the completion of various on-line and instructor led trainings.
Compliance was determined by reviewing preservice and in service training curriculum and a review of
the training records of 10 staff including medical, mental health, direct care, facility administrator
indicated staff have received the training. An interview with random staff also confirmed that they
received the training and refresher training as mandated by Policy .
Standard 115.332: Volunteer and contractor training
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.332 (a)
▪ Has the agency ensured that all volunteers and contractors who have contact with residents
have been trained on their responsibilities under the agency’s sexual abuse and sexual
harassment prevention, detection, and response policies and procedures? ☒ Yes ☐ No
115.332 (b)
▪ Have all volunteers and contractors who have contact with residents been notified of the
agency’s zero-tolerance Policy regarding sexual abuse and sexual harassment and informed
how to report such incidents (the level and type of training provided to volunteers and
contractors shall be based on the services they provide and level of contact they have with
residents)? ☒ Yes ☐ No
115.332 (c)
▪ Does the agency maintain documentation confirming that volunteers and contractors
understand the training they have received? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
PREA Audit Report – v7 Page 52 of 125 West Palm Beach Youth Academy
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ 1919 - Volunteer and contractor Training
PREA Volunteer Training
115.332 (a): Contracting staff under the same training as full time staff that have contact with
residents. Volunteer staff must attend the volunteer training program that includes their
responsibilities under the agency’s sexual abuse and sexual harassment prevention, detection, and
response policies and procedures. At the present time the facility does not have any contractor or
volunteers.
115.332 (b): The level and type of training provided to volunteers and contractors shall be based on
the services they provide and level of contact they have with residents, but all volunteers and
contractors who have contact with residents shall be notified of the agency’s zero-tolerance Policy
regarding sexual abuse and sexual harassment and informed how to report such incidents.
115.332 (c): The agency shall maintain documentation confirming that volunteers and contractors
understand the training they have received. The PREA Notification document contains the information
reviewed with the contractor and volunteer. The document also serves as the training
acknowledgement statement containing the signature of the participant and the date, confirming their
understanding of the PREA information. The review of training curriculum revealed volunteers and
contract providers are given a downloaded version of the SkillPro on-line PREA training, asked to read
it and given the opportunity to ask questions prior to signing acknowledging they understand the
contents of the documents regarding PREA.
At the time of the audit the facility did not have any volunteer or contracting staff. The facility
administrator indicated the facility is going to start the training, background checks and contracting
and volunteer program in the near future. The facility utilizes the Palm Beach School District for
educational services. However, in class education was discontinued during the pandemic. The facility
has been conducting online education programming; however plans are to begin in person training in
the near future. A review of the training curriculum and interviews with personnel staff and PREA
compliance manager confirm that the facility has all of the required policies, procedures, training and
staff to implement a volunteer and contract program.
Standard 115.333: Resident education
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.333 (a)
▪ During intake, do residents receive information explaining the agency’s zero-tolerance Policy
regarding sexual abuse and sexual harassment? ☒ Yes ☐ No
▪ During intake, do residents receive information explaining how to report incidents or suspicions
of sexual abuse or sexual harassment? ☒ Yes ☐ No
PREA Audit Report – v7 Page 53 of 125 West Palm Beach Youth Academy
▪ Is this information presented in an age-appropriate fashion? ☒ Yes ☐ No
115.333 (b)
▪ Within 10 days of intake, does the agency provide age-appropriate comprehensive education to
residents either in person or through video regarding: Their rights to be free from sexual abuse
and sexual harassment? ☒ Yes ☐ No
▪ Within 10 days of intake, does the agency provide age-appropriate comprehensive education to
residents either in person or through video regarding: Their rights to be free from retaliation for
reporting such incidents? ☒Yes ☐ No
▪ Within 10 days of intake, does the agency provide age-appropriate comprehensive education to
residents either in person or through video regarding: Agency policies and procedures for
responding to such incidents? ☒Yes ☐ No
115.333 (c)
▪ Have all residents received the comprehensive education referenced in 115.333(b)?
☒ Yes ☐ No
▪ Do residents receive education upon transfer to a different facility to the extent that the policies
and procedures of the resident’s new facility differ from those of the previous facility?
☒ Yes ☐ No
115.333 (d)
▪ Does the agency provide resident education in formats accessible to all residents including
those who: Are limited English proficient? ☒ Yes ☐ No
▪ Does the agency provide resident education in formats accessible to all residents including
those who: Are deaf? ☒ Yes ☐ No
▪ Does the agency provide resident education in formats accessible to all residents including
those who: Are visually impaired? ☒ Yes ☐ No
▪ Does the agency provide resident education in formats accessible to all residents including
those who: Are otherwise disabled? ☒ Yes ☐ No
▪ Does the agency provide resident education in formats accessible to all residents including
those who: Have limited reading skills? ☒ Yes ☐ No
115.333 (e)
▪ Does the agency maintain documentation of resident participation in these education sessions?
☒ Yes ☐ No
115.333 (f)
PREA Audit Report – v7 Page 54 of 125 West Palm Beach Youth Academy
▪ In addition to providing such education, does the agency ensure that key information is
continuously and readily available or visible to residents through posters, resident handbooks,
or other written formats? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
PREA Posters
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
PREA Safety Brochure (PREA)
Acknowledgement Statements
Resident File Reviews
PAQ
115.333 (a): During the intake process, residents shall receive information explaining, in an age
appropriate fashion, the agency’s zero tolerance Policy regarding sexual abuse and sexual harassment
and how to report incidents or suspicions of sexual abuse or sexual harassment. This information is
provided by the staff that conduct the intake with resident. It is usually a case manager; however it can
be a therapist if a case manager is not available.
115.333 (b): Within 10 days of intake, the agency shall provide comprehensive age-appropriate
education to residents either in person or through video regarding their rights to be free from sexual
abuse and sexual harassment and to be free from retaliation for reporting such incidents, and
regarding agency policies and procedures for responding to such incidents. Also during the
comprehensive training the trainer goes over the PREA safety brochure and has a question and answer
session with new residents.
115.333 (c): FDJJ Policy 1919 requires that residents receive such education within 10 days of arrival at
the facility and shall receive education upon transfer to a different facility to the extent that the
policies and procedures of the resident’s new facility differ from those of the previous facility.
PREA Audit Report – v7 Page 55 of 125 West Palm Beach Youth Academy
115.333 (d): The agency shall provide resident education in formats accessible to all residents,
including those who are limited English proficient, deaf, visually impaired, or otherwise disabled, as
well as to residents who have limited reading skills. The facility has the capability to provide the PREA
education in formats accessible to all residents including those who may be hearing impaired; Deaf;
have intellectual, psychiatric and speech disabilities; low vision; blind; limited reading, limited English
proficient, and based on the individual need of the resident. Documentation was reviewed of a MOU
between the facility and Palm Beach County Board of Education for the provision of accommodations
and supportive services for residents in the aforementioned areas. Posted PREA information is in
English and Spanish accessible to residents, staff, contractors, volunteers, and visitors. The facility also
has a MOU with Language Line Solutions for interpreting and translating services. Staff interviews
confirmed residents are not used as translators or readers for other residents. The facility staff
indicated that the clinical supervisor, medical staff, education lead teacher and operations manager
would work with the community resources to provide education to residents regardless of his
limitations or disabilities.
115.333 (e): The agency shall maintain documentation of resident participation in these education
sessions. A sample of signed acknowledgement statements were reviewed which supported the
residents’ involvement in PREA education sessions. The residents were aware of PREA information,
including their rights regarding PREA, how to report allegations and that they would not be punished
for reporting allegations of sexual abuse or sexual harassment. The Intake staff was interviewed
regarding PREA education for residents. She ensures residents’ receipt of the information, including
the resident signing the acknowledgement form. A review of ten resident files confirmed they
acknowledged the received a PREA orientation during intake and a comprehensive training within 10
days of arrival at the facility.
115.333 (f): In addition to providing such education, the agency shall ensure that key information is
continuously and readily available or visible to residents through posters, resident handbooks, or other
written formats. The PREA education materials provide residents information on how to report
allegations of sexual harassment and sexual abuse. A brochure is provided to each resident to
eliminate incidents of sexual abuse and sexual harassment. The brochure provides educational
information regarding sexual abuse and victims. The residents revealed they can report allegations of
sexual abuse or sexual harassment by telling a staff member or telling a family. There were PREA
educational documentation noted throughout the facility including the lobby, visitation and living
units.
Compliance was determined by review of the agency policies, training curriculum, poster, and resident
files and by interviews with staff and resident.
Standard 115.334: Specialized training: Investigations
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.334 (a)
▪ In addition to the general training provided to all employees pursuant to §115.331, does the
agency ensure that, to the extent the agency itself conducts sexual abuse investigations, its
investigators have received training in conducting such investigations in confinement settings?
PREA Audit Report – v7 Page 56 of 125 West Palm Beach Youth Academy
(N/A if the agency does not conduct any form of administrative or criminal sexual abuse
investigations. See 115.321(a).)
☐ Yes ☐ No ☒ NA
115.334 (b)
▪ Does this specialized training include techniques for interviewing juvenile sexual abuse victims?
(N/A if the agency does not conduct any form of administrative or criminal sexual abuse
investigations. See 115.321(a).) ☐ Yes ☐ No ☒ NA
▪ Does this specialized training include proper use of Miranda and Garrity warnings? (N/A if the
agency does not conduct any form of administrative or criminal sexual abuse investigations.
See 115.321(a).) ☐ Yes ☐ No ☒ NA
▪ Does this specialized training include sexual abuse evidence collection in confinement settings?
(N/A if the agency does not conduct any form of administrative or criminal sexual abuse
investigations. See 115.321(a).) ☐ Yes ☐ No ☒NA
▪ Does this specialized training include the criteria and evidence required to substantiate a case
for administrative action or prosecution referral? (N/A if the agency does not conduct any form
of administrative or criminal sexual abuse investigations. See 115.321(a).)
☐ Yes ☐ No ☒ NA
115.334 (c)
▪ Does the agency maintain documentation that agency investigators have completed the
required specialized training in conducting sexual abuse investigations? (N/A if the agency does
not conduct any form of administrative or criminal sexual abuse investigations. See 115.321(a).)
☐ Yes ☐ No ☒ NA
115.334 (d)
▪ Auditor is not required to audit this provision.
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
PREA Audit Report – v7 Page 57 of 125 West Palm Beach Youth Academy
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Agency Policy FDJJ 1919, Prison Rape Elimination Act (PREA)
Inspector General Directive
Training Curriculum
PREA Compliance Form
Chief of Investigations Interview
115.334 (a): FDJJ Policy 1919 PREA provides for investigations of allegations of sexual abuse that are
criminal in nature to be conducted by the Palm County Sheriff’s Office. The Policy and FOP provides for
the investigators to be trained.
115.334 (b): In addition to the general training provided to all employees pursuant to §115.331, the
agency shall ensure that, to the extent the agency itself conducts sexual abuse investigations, its
investigators have received training in conducting such investigations in confinement settings.
Provision (b): Specialized training shall include techniques for interviewing juvenile sexual abuse
victims, proper use of Miranda and Garrity warnings, sexual abuse evidence collection in confinement
settings, and the criteria and evidence required to substantiate a case for administrative action or
prosecution referral.
115.334 (c): FDJJ Policy 1919 PREA states local law enforcement agencies, and the Florida Department
of Children and Families Services conduct criminal investigations into allegations of sexual abuse. FDJJ’s
Office of Inspector General (OIG) conducts administrative and management reviews, separate and
apart from any criminal investigation. The Policy further states the OIG staff will be trained on the
policies and procedures for the Department policies and procedures related to handling of sexual
misconduct incidents and reports. The chief of investigation maintains all of the training files for OIG
investigators.
Compliance was determined by review of the training curriculum in past audits, interviews with the
chief of investigation and the facility administrator.
Standard 115.335: Specialized training: Medical and mental health care
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.335 (a)
▪ Does the agency ensure that all full- and part-time medical and mental health care practitioners
who work regularly in its facilities have been trained in: How to detect and assess signs of
sexual abuse and sexual harassment? (N/A if the agency does not have any full- or part-time
medical or mental health care practitioners who work regularly in its facilities.)
☒ Yes ☐ No ☐ NA
▪ Does the agency ensure that all full- and part-time medical and mental health care practitioners
who work regularly in its facilities have been trained in: How to preserve physical evidence of
PREA Audit Report – v7 Page 58 of 125 West Palm Beach Youth Academy
sexual abuse? (N/A if the agency does not have any full- or part-time medical or mental health
care practitioners who work regularly in its facilities.) ☒Yes ☐ No ☐ NA
▪ Does the agency ensure that all full- and part-time medical and mental health care practitioners
who work regularly in its facilities have been trained in: How to respond effectively and
professionally to juvenile victims of sexual abuse and sexual harassment? (N/A if the agency
does not have any full- or part-time medical or mental health care practitioners who work
regularly in its facilities.) ☒ Yes ☐ No ☐ NA
▪ Does the agency ensure that all full- and part-time medical and mental health care practitioners
who work regularly in its facilities have been trained in: How and to whom to report allegations
or suspicions of sexual abuse and sexual harassment? (N/A if the agency does not have any
full- or part-time medical or mental health care practitioners who work regularly in its facilities.)
☒ Yes ☐ No ☐ NA
115.335 (b)
▪ If medical staff employed by the agency conduct forensic examinations, do such medical staff
receive appropriate training to conduct such examinations? (N/A if agency medical staff at the
facility do not conduct forensic exams or the agency does not employ medical staff.)
☒ Yes ☐ No ☐ NA
115.335 (c)
▪ Does the agency maintain documentation that medical and mental health practitioners have
received the training referenced in this standard either from the agency or elsewhere? (N/A if
the agency does not have any full- or part-time medical or mental health care practitioners who
work regularly in its facilities.) ☒ Yes ☐ No ☐ NA
115.335 (d)
▪ Do medical and mental health care practitioners employed by the agency also receive training
mandated for employees by §115.331? (N/A if the agency does not have any full- or part-time
medical or mental health care practitioners who work regularly in its facilities.)
☒Yes ☐ No ☐ NA
▪ Do medical and mental health care practitioners contracted by or volunteering for the agency
also receive training mandated for contractors and volunteers by §115.332? (N/A if the agency
does not have any full- or part-time medical or mental health care practitioners contracted by or
volunteering for the agency.) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
PREA Audit Report – v7 Page 59 of 125 West Palm Beach Youth Academy
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ 1919 - Specialized Training Medical-MH
PREA-Mental Health and Mental Professionals_ Module 2
PREA-Mental Health and Medical Professionals Module 1
PREA-Mental Health and Medical Professionals-Module 3
115.335 (a): FDJJ Policy 1919 provide medical and mental health staff members receive the regular
PREA training and the specialized training available online through the SkillPro training system
provided by FDJJ. The facility utilizes a private vendor to provide medical and mental health services.
By contract agreement, all contracting medical and mental health staff attend the training module
provided by the Department of Juvenile Justice. Documentation review confirmed both medical and
mental health staff completed the initial required training and Specialized Training. The center is a
therapeutic environment and is staffed with licensed mental health staff. The mental health staff
attend three DJJ medical/mental health modules and attend continuing education program for
licensing. The clinical supervisor provides sexual abuse awareness training as part of the staffing plan
and part of the mental health providers have received sexual abuse awareness as part of their
continuing education program. In addition to the Zero Tolerance Policy , all full- and part-time medical
and mental health care practitioners will be trained in the following: 1. How to detect and assess signs
of sexual abuse and sexual harassment. 2. How to preserve physical evidence of sexual abuse. 3. How
to respond effectively and professionally to juvenile victims of sexual abuse and sexual harassment. 4.
How and to whom to report allegations or suspicions of sexual abuse and sexual harassment. 5.
Medical and mental health practitioners are required by mandatory reporting laws to report sexual
abuse. 6. Medical and mental health practitioners shall inform residents at the initiation of services of
their duty to report and the limitations of confidentiality regarding sexual abuse.
115.335 (b): Forensic medical examinations are not conducted by the facility medical staff or mental
health staff.
115.335 (c): The facility provided training records indicated that medical and mental health staff had
attended medical specialized training. The agency utilizes a training program titled Skill Pro which
includes modules for generalized training and specialized training. Part of the program requires staff
to log on using their pass code to confirm their identity and signed an acknowledgement of the
training.
115.335 (d): The mental health and medical staff completed the general and refresher training
provided for all staff members.
PREA Audit Report – v7 Page 60 of 125 West Palm Beach Youth Academy
A review of the training curriculum, sign in rosters and interview with medical and mental health staff
confirmed that the staff have received specialized training and generalized training as required by
standards and have additional training that exceeds the expectations of the standards.
SCREENING FOR RISK OF SEXUAL VICTIMIZATION
AND ABUSIVENESS
Standard 115.341: Screening for risk of victimization and abusiveness
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.341 (a):
▪ Within 72 hours of the resident’s arrival at the facility, does the agency obtain and use
information about each resident’s personal history and behavior to reduce risk of sexual abuse
by or upon a resident? ☒ Yes ☐ No
▪ Does the agency also obtain this information periodically throughout a resident’s confinement?
☒ Yes ☐ No
115.341 (b)
▪ Are all PREA screening assessments conducted using an objective screening instrument?
☒ Yes ☐ No
115.341 (c)
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (1) Prior sexual victimization or abusiveness? ☒Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (2) Any gender nonconforming appearance or manner or
identification as lesbian, gay, bisexual, transgender, or intersex, and whether the resident may
therefore be vulnerable to sexual abuse? ☒ Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (3) Current charges and offense history? ☒ Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (4) Age? ☒ Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (5) Level of emotional and cognitive development? ☒Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (6) Physical size and stature? ☒ Yes ☐ No
PREA Audit Report – v7 Page 61 of 125 West Palm Beach Youth Academy
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (7) Mental illness or mental disabilities? ☒ Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (8) Intellectual or developmental disabilities? ☒Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (9) Physical disabilities? ☒ Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (10) The residents’ own perception of vulnerability? ☒ Yes ☐ No
▪ During these PREA screening assessments, at a minimum, does the agency attempt to
ascertain information about: (11) Any other specific information about individual residents that
may indicate heightened needs for supervision, additional safety precautions, or separation from
certain other residents? ☒ Yes ☐ No
115.341 (d)
▪ Is this information ascertained through conversations with the resident during the intake process
and medical mental health screenings? ☒ Yes ☐ No
▪ Is this information ascertained during classification assessments? ☒ Yes ☐ No
▪ Is this information ascertained by reviewing court records, case files, facility behavioral records,
and other relevant documentation from the resident’s files? ☒ Yes ☐ No
115.341 (e)
▪ Has the agency implemented appropriate controls on the dissemination within the facility of
responses to questions asked pursuant to this standard in order to ensure that sensitive
information is not exploited to the resident’s detriment by staff or other residents? ☒ Yes ☐
No
Auditor Overall Compliance Determination
☒
Exceeds Standard (Substantially exceeds requirement of standards)
☐
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
PREA Audit Report – v7 Page 62 of 125 West Palm Beach Youth Academy
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ 1919 - Screening (VSAB)
Screening procedures
Vulnerability for Victimization and Sexual Aggressive Behavior (VSAB)
Sample AVAB
Suicide Risk Screening Instrument sample
115.341 (a) and (b): The Florida Department of Juvenile Justice has developed a seamless system to
provide youth in the State a Florida the best possible program to succeed. Policies require all residents
to be assessed during intake screening and upon transfer to another facility for their risk of being
sexually abused by other residents or sexually abusive toward other residents. Prior to be placed in a
detention center or specialized treatment center resident go through the Juvenile Assessment Center
(JAC). During the assessment center resident a screened utilizing the Florida victimization and sexual
behavior screening instrument. When the resident arrives at the detention center and transfer to
program, they are again interviewed utilizing the VSAB instrument. While at the assessment center the
resident will also be given the MAYSI 2 and a suicide risk assessment that is utilizes in conjunction with
the VSAB in determining the risk level of the resident which is then utilized by the classification or
clinical staff to determine the best housing and placement for the resident.
Periodically throughout the resident’s confinement information is obtained about the residents'
personal history and behavior to reduce the risk of sexual abuse by or upon a resident. Information is
gathered through staff conversations with the resident, information provided by the probation
department, and/or family member, and incident reports written by the staff. This information will be
placed in the resident’s file and relayed to the facility administrator and team leader on duty. If
warranted, the supervisor will notify the Facility Administrator to determine if further action is
necessary. If residents indicate they have a history of sexual victimization the facility will enter a
Hotline report and notify the resident’s clinical supervisor and case manager.
According to the clinical director, a licensed mental health staff conducts a rescreening with the
resident prior to the treatment team meeting which occurs within 25 to 30 days after arrival at the
facility. This rescreening is conducted in a private office and only the outcomes of victim or predator is
shared with the treatment team members. Any issues of victimization are part of the therapist
treatment as deemed appropriate. All other protocol including notification of sexual abuse as a minor
would be followed by the clinical director.
115.341 (c): VSAB screening include mental, physical, or developmental disabilities, age, physical build,
prior incarcerations, criminal history (violent and non-violent), prior convictions for sex offenses
against an adult or child, prior acts of sexual abuse, prior convictions for violent offenses, history of
prior institutional violence or sexual abuse, prior sexual victimization, perception of vulnerability, and if
the resident is or is perceived to be (LGBTQI) or gender nonconforming.
PREA Audit Report – v7 Page 63 of 125 West Palm Beach Youth Academy
115.341 (d): FDJJ Policy 1919 PREA - Screening mandates that all residents will be interviewed using an
objective screening instrument for risk of victimization potential vulnerabilities or sexual abusiveness
tendencies to act out with sexually aggressive predatory behavior within seventy two (72) hours.
Screening staff interviewed indicated staff review the residents court records, MAYSI 2 report, suicide
screening reports, family information and any other documents that are provide to them at the time of
intake by the JAC. The screening staff utilizes the screening instrument during the initial intake process
that includes and conversation with the resident in a private setting. The screening staff indicated they
introduce the screening instrument to the resident by explaining the purpose of the questions and
acknowledges to the residents that that the know they just had the same questions, but it is important
in order to make sure they are safe and get the most out of the stay at the center. After the initial
screening or prior to the screening the medical staff interviews the residents and conduct a medical
screening. The nurse indicated she talks about sexual transmitted diseases and residents perception of
vulnerability. The clinical staff then interview all residents prior to determining which therapist is best
suited to work with the resident and also reviews the VSAB and if they have history of victimization,
the therapist utilizes this time to offer additional support and sets us a time to meet with the resident
within 72 hours to interview them about victimization. At that same time the therapist explains their
duty to report and offers to assist resident in making a report to CCC.
115.341 (e): Sensitive information obtained will not be exploited to the resident’s detriment by staff or
other residents. All staff will follow appropriate confidentiality when dealing with sensitive
information. Information obtained will only be used to make housing, bed, program, and education
assignments with the goal to keep all residents safe and free from sexual abuse and to reduce the risk
of victimization.
Based on the review of the agency Policy and procedures, observations and information obtained
through staff and resident interviews, and review of 10 resident files, the facility has demonstrated
exceed compliance with this standard.
Standard 115.342: Use of screening information
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.342 (a)
▪ Does the agency use all of the information obtained pursuant to § 115.341 and subsequently,
with the goal of keeping all residents safe and free from sexual abuse, to make: Housing
Assignments? ☒ Yes ☐ No
▪ Does the agency use all of the information obtained pursuant to § 115.341 and subsequently,
with the goal of keeping all residents safe and free from sexual abuse, to make: Bed
assignments? ☒ Yes ☐ No
▪ Does the agency use all of the information obtained pursuant to § 115.341 and subsequently,
with the goal of keeping all residents safe and free from sexual abuse, to make: Work
Assignments? ☒ Yes ☐ No
PREA Audit Report – v7 Page 64 of 125 West Palm Beach Youth Academy
▪ Does the agency use all of the information obtained pursuant to § 115.341 and subsequently,
with the goal of keeping all residents safe and free from sexual abuse, to make: Education
Assignments? ☒ Yes ☐ No
▪ Does the agency use all of the information obtained pursuant to § 115.341 and subsequently,
with the goal of keeping all residents safe and free from sexual abuse, to make: Program
Assignments? ☐ Yes ☐ No
115.342 (b)
▪ Are residents isolated from others only as a last resort when less restrictive measures are
inadequate to keep them and other residents safe, and then only until an alternative means of
keeping all residents safe can be arranged? (N/A if the facility never places residents in isolation
for any reason.) ☒ Yes ☐ No ☐ NA
▪ During any period of isolation, does the agency always refrain from denying residents daily
large-muscle exercise? (N/A if the facility never places residents in isolation for any reason.)
☒ Yes ☐ No ☐ NA
▪ During any period of isolation, does the agency always refrain from denying residents any
legally required educational programming or special education services? (N/A if the facility
never places residents in isolation for any reason.) ☒ Yes ☐ No ☐ NA
▪ Do residents in isolation receive daily visits from a medical or mental health care clinician? (N/A
if the facility never places residents in isolation for any reason.) ☒ Yes ☐ No ☐ NA
▪ Do residents in isolation also have access to other programs and work opportunities to the
extent possible? (N/A if the facility never places residents in isolation for any reason.)
☒ Yes ☐ No ☐ NA
115.342 (c)
▪ Does the agency always refrain from placing lesbian, gay, and bisexual (LGB) residents in
particular housing, bed, or other assignments solely on the basis of such identification or status?
☒ Yes ☐ No
▪ Does the agency always refrain from placing transgender residents in particular housing, bed, or
other assignments solely on the basis of such identification or status? ☒ Yes ☐ No
▪ Does the agency always refrain from placing intersex residents in particular housing, bed, or
other assignments solely on the basis of such identification or status? ☒ Yes ☐ No
▪ Does the agency always refrain from considering lesbian, gay, bisexual, transgender, or
intersex (LGBTI) identification or status as an indicator or likelihood of being sexually abusive?
☒ Yes ☐ No
115.342 (d)
▪ When deciding whether to assign a transgender or intersex resident to a facility for male or
female residents, does the agency consider, on a case-by-case basis, whether a placement
PREA Audit Report – v7 Page 65 of 125 West Palm Beach Youth Academy
would ensure the resident’s health and safety, and whether a placement would present
management or security problems (NOTE: if an agency by Policy or practice assigns residents
to a male or female facility on the basis of anatomy alone, that agency is not in compliance with
this standard)? ☒ Yes ☐ No
▪ When making housing or other program assignments for transgender or intersex residents,
does the agency consider, on a case-by-case basis, whether a placement would ensure the
resident’s health and safety, and whether a placement would present management or security
problems? ☒ Yes ☐ No
115.342 (e)
▪ Are placement and programming assignments for each transgender or intersex resident
reassessed at least twice each year to review any threats to safety experienced by the resident?
☒ Yes ☐ No
115.342 (f)
▪ Are each transgender or intersex resident’s own views with respect to his or her own safety
given serious consideration when making facility and housing placement decisions and
programming assignments? ☒ Yes ☐ No
115.342 (g)
▪ Are transgender and intersex residents given the opportunity to shower separately from other
residents? ☒ Yes ☐ No
115.342 (h)
▪ If a resident is isolated pursuant to provision (b) of this section, does the facility clearly
document: The basis for the facility’s concern for the resident’s safety? (N/A if the facility never
places residents in isolation for any reason.) ☒ Yes ☐ No ☐ NA
▪ If a resident is isolated pursuant to provision (b) of this section, does the facility clearly
document: The reason why no alternative means of separation can be arranged? (N/A if the
facility never places residents in isolation for any reason.) ☒ Yes ☐ No ☐ NA
115.342 (i):
▪ In the case of each resident who is isolated as a last resort when less restrictive measures are
inadequate to keep them and other residents safe, does the facility afford a review to determine
whether there is a continuing need for separation from the general population EVERY 30
DAYS? (N/A if the facility never places residents in isolation for any reason.)
☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
PREA Audit Report – v7 Page 66 of 125 West Palm Beach Youth Academy
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Suicide Risk Screening Instrument
VSAB skillpro training
Screening information
FDJJ POLICY - Placement of Youth
115.342 (a): All information obtained upon intake and periodically throughout the residents’
confinement will be used to make housing, bed, program, and education assignments with the goal of
keeping all residents safe and free from sexual abuse.
115.342 (b): Residents may be isolated from others only as a last resort when less restrictive measures
are inadequate to keep them and other residents safe, and then only until an alternative means of
keeping all resident’s safe can be arranged. During any period of isolation, agencies shall not deny
residents daily large-muscle exercise and any legally required educational programming or special
education services. Residents in isolation shall receive daily visits from a medical or mental health care
clinician. Residents shall also have access to other programs and work opportunities to the extent
possible. The medical and clinical director indicated during interview that they see the resident prior to
and throughout his time in isolation. Both indicated they see the resident at least daily; however it is
usually several time a day. WPBYA is a drug treatment center, and each resident has a therapist.
Placement in isolation does not exclude the resident from participation in groups or therapist daily
meetings.
115.342 (c): FDJJ Policy - Placement of Youth precludes lesbian, gay, bi-sexual, transgender, and
intersex residents from being placed in a particular housing unit and states LGBTI identification or
status is not an indicator of likelihood of being sexually abusive. Transgender or intersex resident’s own
view with respect to his/her safety will be given serious consideration. The PREA Compliance
Manager’s interview also verified compliance with this standard. During the site tour, there were no
rooms observed to be reserved for transgender or intersex residents. A staff interview and
observations revealed there is no special housing based on how a resident identifies.
115.342 (d): In deciding whether to assign a transgender or intersex resident to a facility for male or
female residents, and in making other housing and programming assignments, the agency shall
PREA Audit Report – v7 Page 67 of 125 West Palm Beach Youth Academy
consider on a case-by-case basis whether a placement would ensure the resident’s health and safety,
and whether the placement would present management or security problems. The Policy also provides
that housing and program assignments for transgender or intersex residents would be made on a case-
by-case basis and these residents would not be placed a special housing which was evident from staff
interviews. There were no transgender or intersex residents in the facility during the onsite visit. The
clinical director confirmed the facility would consider on a case-by-case basis whether a placement
would ensure the resident’s health and safety, and whether the placement would present
management or security problems. In interviews with the administrative team, the staff indicated that
a resident’s sexual status was one of several considerations for housing and programming resident.
Since it is a treatment program with groups of four to eight, the center stratifies the groups based on
size, maturity, age and would also utilizes the resident preference, sexual orientation, and perception
in placing youth with different therapist.
115.342 (e): Placement and programming assignments for each transgender or intersex resident shall
be reassessed at least twice each year to review any threats to safety experienced by the resident. The
Policy states placement and programming assignments for each transgender or intersex resident shall
be reassessed at least twice each year. This function would be done to review any threats to safety
experienced by the resident and the Intake staff is aware of the requirement. The Clinical Director
confirmed each transgender or intersex resident would be reassessed at least twice each year to
review any threats to safety experienced by the resident by Policy, however in reality, residents are
reassessed on an ongoing basis. Based on the review of the Pre-audit Questionnaire and interview with
the Intake staff, the evidence shows the facility follows this provision of the standard.
115.342 (f): A transgender or intersex resident’s own views with respect to his or her own safety shall
be given serious consideration. The resident’s concern for his own safety is taken into account through
the administration of the Vulnerability Assessment and this applies to every resident. The residents
confirmed in the interviews, they are asked about their safety concerns. A review of the PREA
Education & Screening Log demonstrated the additional documentation of the screening assessments
and re-assessments completed for each resident. The staff interviews revealed staff members are
aware of the Policy which requires the provision of the standard to be followed.
115.342 (g): Policy mandates that transgender and intersex residents shall be given the opportunity to
shower separately from other residents. All staff interviewed were aware of that requirement,
however most staff indicated that all residents are required to shower by themselves.
115.342 (h): If a resident is isolated pursuant to paragraph (b) of this section, the facility shall clearly
document: (1) The basis for the facility’s concern for the resident’s safety; and (2) The reason why no
alternative means of separation can be arranged. The Policy states if a resident is isolated pursuant to
part (B.2.) of this section, the facility shall document a. The basis for the facility’s concern for the
resident’s safety; and b. The reason why no alternative means of separation can be arranged. No
residents at risk of sexual victimization were placed in isolation in the 12 months preceding the audit.
Interviews with the Facility Administrator and PREA Compliance Manager confirmed the facility has not
used isolation for this purpose. The Isolation/separation would be documented according to the
provisions of the Policy and standard.
PREA Audit Report – v7 Page 68 of 125 West Palm Beach Youth Academy
115.342 (i): Policy mandate that every 30 days, the facility shall afford each resident described in
paragraph (h) of this section a review to determine whether there is a continuing need for separation
from the general population. The Policy states every thirty (30) days, staff shall afford each resident
described in provision (b) of this section a review to determine whether there is a continuing need for
separation from the general population. No residents at risk of sexual victimization were placed in
isolation in the 12 months preceding the audit. Interviews with the Facility Administrator and PREA
Compliance Manager confirmed the facility has not used isolation for this purpose.
Based on review of the agency Policy and interviews with agency director, PREA coordinator, PREA
compliance manager, facility administrator, clinical director and random staff, the facility is in full
compliance of this standard.
REPORTING
Standard 115.351: Resident reporting
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.351 (a)
▪ Does the agency provide multiple internal ways for residents to privately report: Sexual abuse
and sexual harassment? ☒ Yes ☐ No
▪ Does the agency provide multiple internal ways for residents to privately report: Retaliation by
other residents or staff for reporting sexual abuse and sexual harassment? ☒ Yes ☐ No
▪ Does the agency provide multiple internal ways for residents to privately report: Staff neglect or
violation of responsibilities that may have contributed to such incidents? ☒ Yes ☐ No
115.351 (b)
▪ Does the agency also provide at least one way for residents to report sexual abuse or sexual
harassment to a public or private entity or office that is not part of the agency? ☒ Yes ☐ No
▪ Is that private entity or office able to receive and immediately forward resident reports of sexual
abuse and sexual harassment to agency officials? ☒ Yes ☐ No
▪ Does that private entity or office allow the resident to remain anonymous upon request?
☒ Yes ☐ No
▪ Are residents detained solely for civil immigration purposes provided information on how to
contact relevant consular officials and relevant officials at the Department of Homeland Security
to report sexual abuse or harassment? (N/A if the facility never houses residents detained solely
for civil immigration purposes.) ☐ Yes ☐ No ☒ NA
115.351 (c)
PREA Audit Report – v7 Page 69 of 125 West Palm Beach Youth Academy
▪ Do staff members accept reports of sexual abuse and sexual harassment made verbally, in
writing, anonymously, and from third parties? ☒ Yes ☐ No
▪ Do staff members promptly document any verbal reports of sexual abuse and sexual
harassment? ☒ Yes ☐ No
115.351 (d)
▪ Does the facility provide residents with access to tools necessary to make a written report?
☒ Yes ☐ No
▪ Does the agency provide a method for staff to privately report sexual abuse and sexual
harassment of residents? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
CCC Florida Administrative code 63
FDJJ 1919 PREA - Youth reporting
General Counsel - PREA immigration status
Palm Beach Youth Academy Grievance Form
Multilingual Posters
Resident Reporting Poster
Safety Brochure
Third Party Reporting Forms
Medical Request Form
MOU, Victim Services SART Center
WPBYA FOP 1.03 Incident Reporting
115.351 (a) T The above policies, MOUs and External reporting mechanism identifies the multiple internal ways
for residents to report sexual abuse and harassment incidents, retaliation, staff neglect or violation of
responsibilities that may have contributed to such incidents. Included are Reporting registry hotline,
PREA Audit Report – v7 Page 70 of 125 West Palm Beach Youth Academy
confidential access through Victim Advocacy program to receive and forward reports of sexual abuse and sexual
harassment to FDJJ officials, allowing residents to remain anonymous upon request. Also, the policies identified
the resident’s accessibility to filing a grievance, communication (telephone, visitation, and correspondence) with
their attorney and/or parent/guardian, staff providing access to the hotline without asking the resident the
purpose of the call, the staff requirement of mandatory reporting and completing an incident report. The
department has provided a method for staff to privately report sexual abuse and sexual harassment of
residents.
West Palm Beach Youth Academy provides multiple internal ways for residents to privately report sexual abuse
and sexual harassment, retaliation and staff neglect including telling a trusted staff member or filling out a PREA
Reporting form and placing it in a secure drop box. Random resident interviews confirmed their knowledge of
this procedure. Resident safety brochures, and how to report posters addresses this standard and provides for
multiple internal ways a resident may report allegations abuse and sexual harassment, including how he/she can
privately report sexual abuse and sexual harassment; retaliation for reporting; and staff neglect or violations of
responsibilities that may have contributed to such. Residents may report allegations of sexual abuse or sexual
harassment by telephone through the 24-hour hotline of an agency not a part of the facility as confirmed by
resident interviews, posters, staff, MOU, and posted phone instructions. Direct care staff interviews revealed
residents may use the telephone, located on each unit, to privately report sexual abuse and sexual harassment.
The victims’ advocacy service, Victim Service SART Center was contacted to determine the scope of services
provided. The residents also identified internal ways a resident may report such as completing a PREA/grievance
form; talking to a trusted staff member; completing a Medical Request Form; or tell an outside person or family
member. There are designated locked boxes and forms on the living units for depositing the written grievance
forms. If a resident uses a grievance form to report allegations of sexual abuse or sexual harassment, he/she just
needs to place his/her name on the form, check the appropriate space and place it in the grievance box. The
resident receives a Safety Brochure which provides PREA related information, including how to report
allegations of sexual abuse. Posters are located in the living units and other areas visible to residents, staff,
contractors and visitors. Residents revealed they have contact with someone who does not work at the facility
such as a family member or other person they could report abuse to if needed. Staff members receive
information on how to report allegations of sexual abuse or sexual harassment through policies and procedures,
training, and staff meetings. The telephones in the housing units are in good working order. There is a telephone
in the muti purpose room that was not working at the time of the audit. The facility administrator was to contact
the contractor that installed the new system to determine if the phone could be placed back online. It is one of
several telephones that residents can utilize to make a call that were checked and found to be in good working
order, so it does not constitute a corrective action plan. However, it needs to be placed online.
115.351 (b): The agency shall also provide at least one way for residents to report abuse or harassment to a
public or private entity or office that is not part of the agency and that is able to receive and immediately
forward resident reports of sexual abuse and sexual harassment to agency officials, allowing the resident to
remain anonymous upon request. Residents may call the Florida Abuse Hotline or call the victims’ advocate
hotline. Residents may request to use a telephone with some degree of privacy to call the hotline without having
to obtain staff permission and that mandates staff not to question residents about the reason for the call. A
resident can request writing materials to write and send a letter to one of these sources. Random residents
interviewed were aware of the abuse hotline and were able to articulate how they could gain access. Residents
may use of the emergency telephone located on each unit. Signs are posted explaining how to access Victim
Service Center and contains nonemergency numbers for agencies, including the Sheriff’s Office. The resident is
also instructed on the signage to dial 911 for emergencies. Direct care staff revealed staff could use the
emergency phone to report allegations of abuse. Allegations of sexual abuse have not been reported during this
audit period. The facility does not detain residents solely for civil immigration purposes.
PREA Audit Report – v7 Page 71 of 125 West Palm Beach Youth Academy
115.351 (c): Staff shall accept reports made verbally, in writing, anonymously, and from third parties and shall
promptly document any verbal reports. The staff interviews confirmed the methods available to residents for
reporting allegations of sexual abuse and sexual harassment. Staff members are required to accept third-party
reports and to document verbal reports. All residents interviewed revealed they are familiar with the provisions
of the standard. The resident interviews demonstrated their familiarity with the various ways they may report
either in person, in writing, by phone, completing a PREA/grievance or Medical Request Form, or through a
third-party. The residents were aware third-party reports could be made and that reports can be made
anonymously. Staff members interviewed were aware of their duty to receive and document third-party reports.
115.351 (d): The facility shall provide residents with access to tools necessary to make a written report. Writing
materials are readily available for residents to complete the accessible forms. Prior to the site visit pictures were
sent to the Auditor showing the reporting forms such as PREA/Grievance forms and Medical Request Forms and
the accessibility of writing utensils. During the site visit and while on the site review, the Auditor observed the
accessibility of writing utensils to the residents. Staff may privately report sexual abuse and sexual harassment
of residents to their local law enforcement, state reporting agency, facility administrator or the PREA compliance
manager. Staff must report sexual abuse and sexual harassment immediately to the Facility Administrator and
must immediately notify the Child Registry hotline and Central Communication Center. Staff and Facility
Administrator confirmed that staff may report directly to the facility administrator, and he will coordinate with
the staff to call the Child Abuse registry Hotline. However, it is the responsibility of the staff that receive or
witness this action to assist the resident in making the call or for making the call to the hotline and CCC.
Compliance was determined by review of posters, Policy, and interview with staff, and residents.
Standard 115.352: Exhaustion of administrative remedies
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.352 (a)
▪ Is the agency exempt from this standard? NOTE: The agency is exempt ONLY if it does not
have administrative procedures to address resident grievances regarding sexual abuse. This
does not mean the agency is exempt simply because a resident does not have to or is not
ordinarily expected to submit a grievance to report sexual abuse. This means that as a matter of
explicit Policy, the agency does not have an administrative remedies process to address sexual
abuse. ☒ Yes ☐ No
115.352 (b)
▪ Does the agency permit residents to submit a grievance regarding an allegation of sexual abuse
without any type of time limits? (The agency may apply otherwise-applicable time limits to any
portion of a grievance that does not allege an incident of sexual abuse.) (N/A if agency is
exempt from this standard.) ☒ Yes ☐ No ☐ NA
▪ Does the agency always refrain from requiring a resident to use any informal grievance process,
or to otherwise attempt to resolve with staff, an alleged incident of sexual abuse? (N/A if agency
is exempt from this standard.) ☒ Yes ☐ No ☐ NA
115.352 (c)
PREA Audit Report – v7 Page 72 of 125 West Palm Beach Youth Academy
▪ Does the agency ensure that: A resident who alleges sexual abuse may submit a grievance
without submitting it to a staff member who is the subject of the complaint? (N/A if agency is
exempt from this standard.) ☒ Yes ☐ No ☐ NA
▪ Does the agency ensure that: Such grievance is not referred to a staff member who is the
subject of the complaint? (N/A if agency is exempt from this standard.) ☒Yes ☐ No ☐ NA
115.352 (d)
▪ Does the agency issue a final agency decision on the merits of any portion of a grievance
alleging sexual abuse within 90 days of the initial filing of the grievance? (Computation of the
90-day time period does not include time consumed by residents in preparing any administrative
appeal.) (N/A if agency is exempt from this standard.) ☐ Yes ☐ No ☒NA
▪ If the agency determines that the 90-day timeframe is insufficient to make an appropriate
decision and claims an extension of time [the maximum allowable extension of time to respond
is 70 days per 115.352(d)(3)], does the agency notify the resident in writing of any such
extension and provide a date by which a decision will be made? (N/A if agency is exempt from
this standard.) ☐ Yes ☐ No ☒NA
▪ At any level of the administrative process, including the final level, if the resident does not
receive a response within the time allotted for reply, including any properly noticed extension,
may a resident consider the absence of a response to be a denial at that level? (N/A if agency is
exempt from this standard.) ☐ Yes ☐ No ☒ NA
115.352 (e)
▪ Are third parties, including fellow residents, staff members, family members, attorneys, and
outside advocates, permitted to assist residents in filing requests for administrative remedies
relating to allegations of sexual abuse? (N/A if agency is exempt from this standard.)
☐ Yes ☐ No ☒ NA
▪ Are those third parties also permitted to file such requests on behalf of residents? (If a third
party, other than a parent or legal guardian, files such a request on behalf of a resident, the
facility may require as a condition of processing the request that the alleged victim agree to
have the request filed on his or her behalf, and may also require the alleged victim to personally
pursue any subsequent steps in the administrative remedy process.) (N/A if agency is exempt
from this standard.) ☒ Yes ☐ No ☐ NA
▪ If the resident declines to have the request processed on his or her behalf, does the agency
document the resident’s decision? (N/A if agency is exempt from this standard.)
☒ Yes ☐ No ☐ NA
▪ Is a parent or legal guardian of a juvenile allowed to file a grievance regarding allegations of
sexual abuse, including appeals, on behalf of such juvenile? (N/A if agency is exempt from this
standard.) ☐Yes ☐ No ☒ NA
▪ If a parent or legal guardian of a juvenile files a grievance (or an appeal) on behalf of a juvenile
regarding allegations of sexual abuse, is it the case that those grievances are not conditioned
PREA Audit Report – v7 Page 73 of 125 West Palm Beach Youth Academy
upon the juvenile agreeing to have the request filed on his or her behalf? (N/A if agency is
exempt from this standard.) ☐ Yes ☐ No ☒NA
115.352 (f)
▪ Has the agency established procedures for the filing of an emergency grievance alleging that a
resident is subject to a substantial risk of imminent sexual abuse? (N/A if agency is exempt from
this standard.) ☒ Yes ☐ No ☐ NA
▪ After receiving an emergency grievance alleging a resident is subject to a substantial risk of
imminent sexual abuse, does the agency immediately forward the grievance (or any portion
thereof that alleges the substantial risk of imminent sexual abuse) to a level of review at which
immediate corrective action may be taken? (N/A if agency is exempt from this standard.).
☒ Yes ☐ No ☐ NA
▪ After receiving an emergency grievance described above, does the agency provide an initial
response within 48 hours? (N/A if agency is exempt from this standard.) ☒ Yes ☐ No ☐ NA
▪ After receiving an emergency grievance described above, does the agency issue a final agency
decision within 5 calendar days? (N/A if agency is exempt from this standard.)
☒ Yes ☐ No ☐ NA
▪ Does the initial response and final agency decision document the agency’s determination
whether the resident is in substantial risk of imminent sexual abuse? (N/A if agency is exempt
from this standard.) ☒ Yes ☐ No ☐ NA
▪ Does the initial response document the agency’s action(s) taken in response to the emergency
grievance? (N/A if agency is exempt from this standard.) ☒ Yes ☐ No ☐ NA
▪ Does the agency’s final decision document the agency’s action(s) taken in response to the
emergency grievance? (N/A if agency is exempt from this standard.) ☒ Yes ☐ No ☐ NA
115.352 (g)
▪ If the agency disciplines a resident for filing a grievance related to alleged sexual abuse, does it
do so ONLY where the agency demonstrates that the resident filed the grievance in bad faith?
(N/A if agency is exempt from this standard.) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
PREA Audit Report – v7 Page 74 of 125 West Palm Beach Youth Academy
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
Inspector General statement
Resident Brochure
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
WPBYA FOP 1.03 Incident Reporting
FDJJ Grievance Procedure allows a resident to submit a grievance regarding an allegation of sexual
abuse with the following stipulations:
There is no time limit for reporting allegations.
Third parties, including fellow residents, staff members, family members, attorneys, and outside
advocates, may assist residents in filing requests for administrative remedies relating to allegations of
sexual abuse,
Permitted to file such requests on behalf of residents.
Allows the facility to request the alleged victim to agree to third party grievances alleging sexual abuse.
If a resident decline to have the request processed, the facility will document the residents’ decision.
Prohibits the requirement a resident must first use an informal grievance process, or to otherwise
attempt to resolve with staff, when reporting an allegation of sexual abuse.
Allows a resident to submit a grievance without submitting to a staff member who is the subject of the
complaint and prohibits the agency from referring the grievance to a staff member who is the subject
of the complaint.
Requires a final agency decision within ninety (90) days on any portion of a grievance that alleges
sexual abuse, and that the ninety (90) days shall not include time consumed by residents preparing any
administrative appeal
Allows the department to claim an extension of time to respond to a grievance up to seventy (70) days,
with notification to the resident.
Establishes an emergency grievance for a resident subject to a substantial risk of imminent sexual
abuse, including an initial response within 24 hours and a final response within five (5) days on the
determination of at substantial risk of imminent sexual abuse.
Prohibits the discipline of a resident for filing a grievance related to sexual abuse only where the
agency demonstrates the resident filed the grievance in bad faith.
The Policy describes the orientation residents receive explaining how to use the grievance process to
report allegations of abuse. Residents may place a written grievance or complaint in the grievance box
located in living/multi-purpose area of the facility. Residents are not required to utilize an informal
process for reporting allegations of sexual abuse or sexual harassment nor are they required to submit
it to the staff member involved in the allegation. The Juvenile Facility administrator will review the
complaint immediately and advise the resident of the outcome or status of the investigation. The
PREA Audit Report – v7 Page 75 of 125 West Palm Beach Youth Academy
policies and procedures describe an unimpeded process and allow for other individuals to assist a
resident in filing a grievance or to file grievances themselves on behalf of residents. The facility’s
protocol indicated when a resident submits a grievance relating to sexual abuse or sexual harassment
or sexual misconduct staff will immediately report the alleged details of the allegation directly to their
supervisor and Juvenile Facility Administrator and CCC within 2 hours of receiving the report. A
grievance regarding a PREA allegation is not processed as a grievance but is forwarded to the OIG for
an investigation.
There were no grievances filed involving PREA related issues during the past 12 months. There were no
grievances alleging sexual abuse that involved an extension due to the final decision not being reached
within 90 days. Additionally, there were no grievances alleging sexual abuse filed by residents in which
the resident declined third-party assistance
The agency provides grievance as one method of reporting an allegation of sexual abuse, sexual
harassment or child neglect. The agency has a formal grievance system for other concerns. When a
resident files a grievance he can do so utilizing the grievance system which is described above.
However, the resident will be advised that the facility administrator will forward the grievance to CCC
within 2 hours. Compliance was determined by review of Policy and grievance logs, as well as an
interview with the PREA compliance manager, residents, and OIG.
Standard 115.353: Resident access to outside confidential support services
and legal representation
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.353 (a)
▪ Does the facility provide residents with access to outside victim advocates for emotional support
services related to sexual abuse by providing, posting, or otherwise making accessible mailing
addresses and telephone numbers, including toll-free hotline numbers where available, of local,
State, or national victim advocacy or rape crisis organizations? ☒ Yes ☐ No
▪ Does the facility provide persons detained solely for civil immigration purposes mailing
addresses and telephone numbers, including toll-free hotline numbers where available of local,
State, or national immigrant services agencies? (N/A if the facility never has persons detained
solely for civil immigration purposes.) ☐ Yes ☐ No ☒ NA
▪ Does the facility enable reasonable communication between residents and these organizations
and agencies, in as confidential a manner as possible? ☒Yes ☐ No
115.353 (b)
▪ Does the facility inform residents, prior to giving them access, of the extent to which such
communications will be monitored and the extent to which reports of abuse will be forwarded to
authorities in accordance with mandatory reporting laws? ☒ Yes ☐ No
115.353 (c)
PREA Audit Report – v7 Page 76 of 125 West Palm Beach Youth Academy
▪ Does the agency maintain or attempt to enter into memoranda of understanding or other
agreements with community service providers that are able to provide residents with confidential
emotional support services related to sexual abuse? ☒ Yes ☐ No
▪ Does the agency maintain copies of agreements or documentation showing attempts to enter
into such agreements? ☒ Yes ☐ No
115.353 (d)
▪ Does the facility provide residents with reasonable and confidential access to their attorneys or
other legal representation? ☒ Yes ☐ No
▪ Does the facility provide residents with reasonable access to parents or legal guardians?
☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Posted Information
PREA Notification/Acknowledgement Form
PREA Brochure (Safety Pamphlet)
MOU, Palm Beach County Victim Services
WPBYA FOP 1.03 Incident Reporting
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
115.353 (a): Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA) mandates the facility shall
provide residents with access to outside victim advocates for emotional support services related to
sexual abuse, by providing, posting, or otherwise making accessible mailing addresses and telephone
numbers, including toll free hotline numbers where available, of local, State, or national victim
advocacy or rape crisis organizations, and, for persons detained solely for civil immigration purposes,
PREA Audit Report – v7 Page 77 of 125 West Palm Beach Youth Academy
immigrant services agencies. The facility shall enable reasonable communication between residents
and these organizations and agencies, in as confidential a manner as possible. WPBYA FOP PREA
ensures residents are provided access to outside confidential support services. The facility has
established an MOU with the West Palm Beach Victim Services which provide emotional support,
counselling; follow-up support; and referral for treatment after release or transfer to another facility.
Signs containing the Victim Service hotline number and basic information about the service were
observed throughout the facility. Contact information for advocacy services is a part of the PREA
education sessions and is also provided to each resident in the PREA brochure. Documentation of the
session is placed in each resident’s file. The hotline telephone was observed in each living unit and the
contact information for services from the agencies was posted. The telephone number was tested and
deemed in working order. Information is also provided through signs and posters in various parts of
the facility including each living unit. Interviews with the Victim Services staff indicated they have not
received any call from the faciity. The staff indicated they provide brochures and pre pandemic were
touring the facility. The staff indicated that besides providing victim advocacy, they provide a
telephone number that will allow the resident to talk to a trained counselor for emotional support.
They would also make arrangements to visit with the victim or have the victim brought to them or
another location if allowed by the facility. They have MOU with serval juvenile programs and have in
the pass been allowed to meet with the resident and their family to provide emotional support.
115.353 (b): The facility shall inform residents, prior to giving them access, of the extent to which such
communications will be monitored and the extent to which reports of abuse will be forwarded to
authorities in accordance with mandatory reporting laws. The FOP addresses confidentiality of the
advocacy support services. The resident receives information regarding the limitations of
confidentiality during the intake process. An acknowledgement statement specific to the review of the
reporting and advocacy services contains information regarding the advocacy services to be provided
by The Victim Service Center. When contacted by phone the center’s staff explained they always tell
the caller that the telephone calls or confidential however, they have a responsibility to report
allegation of child abuse or child neglect.
115.353 (c): The agency shall maintain or attempt to enter into memoranda of understanding or other
agreements with community service providers that are able to provide residents with confidential
emotional support services related to sexual abuse. The agency shall maintain copies of agreements or
documentation showing attempts to enter into such agreements. The FOP states the resident may use
the phone, located on each living unit, and push the appropriate number to gain access and speak with
a victim advocate. The agency is identified on the signage along with directions for reporting
allegations or requesting advocacy services. The Facility Administrator confirmed the availability and
accessibility of outside confidential support services to residents.
115.353 (d): The facility shall also provide residents with reasonable and confidential access to their
attorneys or other legal representation and reasonable access to parents or legal guardians. The
interview’s confirmed residents have access to attorneys and court workers and reasonable access to
their parents/legal guardians. The site tour revealed areas where residents could meet privately with a
legal representative and the visitation area for visits with family members. All residents interviewed
stated family could visit and they provided the days and times of visitation and for phone calls.
Residents interviewed confirmed the facility would allow them to see or talk with their lawyer, another
PREA Audit Report – v7 Page 78 of 125 West Palm Beach Youth Academy
lawyer or a court representative privately. Residents interviewed confirmed the facility would allow
them to see and talk with their parents or someone else, such as a legal guardian. Visitors to the facility
are informed of PREA. The Facility Administrator confirmed the facility provides residents with
reasonable and confidential access to their attorneys or court representatives and reasonable access to
parents or legal.
Compliance was determined by review of center visitation rules, policies, and memorandums, poster
located throughout the facility and interview with Staff of the West Palm Beach Victim’s Services,
faciity administrator and random staff and residents.
Standard 115.354: Third-party reporting
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.354 (a)
▪ Has the agency established a method to receive third-party reports of sexual abuse and sexual
harassment? ☒ Yes ☐ No
▪ Has the agency distributed publicly information on how to report sexual abuse and sexual
harassment on behalf of a resident? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
FDJJ 1919 PREA
WPBYA FOP 1.03 Incident Reporting
Third Party Reporting Forms
Report Posters
FDJJ Website
PREA Audit Report – v7 Page 79 of 125 West Palm Beach Youth Academy
115.354 (a): DJJ shall provide youth with reasonable and confidential access to their attorneys or other
legal representation and reasonable access to parent(s) or legal guardian(s) in accordance with DJJ
Policy. Third Party Reporting process, instructs staff to accept third party reports from any source,
provides information for anyone who sees or suspects sexual abuse, sexual harassment, or
victimization of any kind to report it promptly through. FDJJ websites provides the public with
information regarding third-party reporting of sexual abuse or sexual harassment on behalf of a
resident. Additionally, the staff provides the parent/guardian with a packet containing varied forms,
victim advocate services and third-party reporting information. There are two (2) separate reporting
options for the receipt of third-party reports of sexual abuse or sexual harassment. Third Party Posters
include how to contact the CCC for reporting allegation of sexual abuse, sexual harassment or
retaliation for making reports. Reporting Posters were in the visitation room and the main lobby of the
facility.
Compliance was determined by reviewing the DJJ website and interviews with random staff and
residents as well as review of policies and posters.
OFFICIAL RESPONSE FOLLOWING A RESIDENT REPORT
Standard 115.361: Staff and agency reporting duties
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.361 (a)
▪ Does the agency require all staff to report immediately and according to agency Policy any
knowledge, suspicion, or information regarding an incident of sexual abuse or sexual
harassment that occurred in a facility, whether or not it is part of the agency? ☒ Yes ☐ No
▪ Does the agency require all staff to report immediately and according to agency Policy any
knowledge, suspicion, or information regarding retaliation against residents or staff who
reported an incident of sexual abuse or sexual harassment? ☒Yes ☐ No
▪ Does the agency require all staff to report immediately and according to agency Policy any
knowledge, suspicion, or information regarding any staff neglect or violation of responsibilities
that may have contributed to an incident of sexual abuse or sexual harassment or retaliation?
☒ Yes ☐ No
115.361 (b)
▪ Does the agency require all staff to comply with any applicable mandatory child abuse reporting
laws? ☒ Yes ☐ No
115.361 (c)
▪ Apart from reporting to designated supervisors or officials and designated State or local services
agencies, are staff prohibited from revealing any information related to a sexual abuse report to
anyone other than to the extent necessary, as specified in agency Policy, to make treatment,
investigation, and other security and management decisions? ☒ Yes ☐ No
PREA Audit Report – v7 Page 80 of 125 West Palm Beach Youth Academy
115.361 (d)
▪ Are medical and mental health practitioners required to report sexual abuse to designated
supervisors and officials pursuant to paragraph (a) of this section as well as to the designated State
or local services agency where required by mandatory reporting laws? ☒ Yes ☐ No
▪ Are medical and mental health practitioners required to inform residents of their duty to report, and
the limitations of confidentiality, at the initiation of services? ☒ Yes ☐ No
115.361 (e)
▪ Upon receiving any allegation of sexual abuse, does the facility head or his or her designee
promptly report the allegation to the appropriate office? ☒ Yes ☐ No
▪ Upon receiving any allegation of sexual abuse, does the facility head or his or her designee
promptly report the allegation to the alleged victim’s parents or legal guardians unless the facility
has official documentation showing the parents or legal guardians should not be notified?
☒ Yes ☐ No
▪ If an alleged victim is under the guardianship of the child welfare system, does the facility head
or his or her designee promptly report the allegation to the alleged victim’s caseworker instead
of the parents or legal guardians? ☒ Yes ☐ No
▪ If a juvenile court retains jurisdiction over the alleged victim, does the facility head or designee
also report the allegation to the juvenile’s attorney or other legal representative of record within
14 days of receiving the allegation? ☒Yes ☐ No
115.361 (f)
▪ Does the facility report all allegations of sexual abuse and sexual harassment, including third-
party and anonymous reports, to the facility’s designated investigators? ☒Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
PREA Audit Report – v7 Page 81 of 125 West Palm Beach Youth Academy
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
WPBYA FOP 1.03 Incident Reporting
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
FDJJ Staff PREA Education and Training
Florida Administrative Code Rule 63F-11
PREA/Grievance Forms
Multilingual Posters
115.361 (a) (b): FDJJ Policy - Reporting Allegations, Florida Administrative Code Rule 63F-11
and FDJJ Staff training mandates that all employees, volunteers, interns, and contractors shall
immediately report to their supervisor any knowledge, suspicion, or information regarding an incident
of sexual abuse or sexual harassment that occurred in the facility, retaliation against residents or staff
who reported such an incident, and any staff neglect or violation of responsibilities that may have
contributed to an incident or retaliation. This mandated is not exclusive of incidents that involve non-
agency staff such as visitors. Upon receiving any allegation of sexual abuse, facility administrator
promptly reports allegations to the Agency’s Central Control Center(CCC). Medical and Mental Health
staff interviewed confirmed their responsibility to inform residents under 18 years old of their duty to
report and limitations of confidentiality.
115.361 (c): DJJ Policy mandates and interviews with random staff confirmed that persons making the
reports of any incidents that would occur in the facility and they are prohibited from sharing
information with anyone who is not part of the investigation or reporting process.
115.361 (d): Medical and Mental Health staff interviewed confirmed their responsibility to inform
residents under 18 years old of their duty to report and limitations of confidentiality during the intake
process.
115.361 (e): The CCC will make appropriate notification to senior DJJ management who will make
notification to management overseeing the facility where the alleged abuse occurred. Policies require
the Executive Director to notify the alleged victim’s parents or legal guardians. If the resident is under
the Department of Children and Families (DCF) custody, the DCF Case Worker will be notified and if
applicable, the attorney of record will be notified of the allegation within 14 days of receipt of the
allegation.
115.361 (f): FDJJ POLICY - Reporting Allegations and FDJJ Staff training mandates that all employees,
volunteers, interns, and contractors shall immediately report to their supervisor any knowledge,
suspicion, or information regarding an incident of sexual abuse or sexual harassment that occurred in
the facility, retaliation against residents or staff who reported such an incident, and any staff neglect or
violation of responsibilities that may have contributed to an incident or retaliation. Policy and training
also requires reporting any third party reports of sexual abuse, sexual harassment, staff neglect and
retaliation. Upon receiving any allegation of sexual abuse, the facility promptly reports allegations to
PREA Audit Report – v7 Page 82 of 125 West Palm Beach Youth Academy
the Agency’s Central Control Center(CCC). Policy mandates that these allegations or reported within 2
hours of being notified. Medical and Mental Health staff interviewed confirmed their responsibility to
inform residents under 18 years old of their duty to report and limitations of confidentiality.
Compliance was determined by review of policies, training module, and interviews with direct care
staff and first responders that are not direct care staff, the facility administrator, and the agency head
designee and the PREA coordinator.
Standard 115.362: Agency protection duties
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.362 (a)
▪ When the agency learns that a resident is subject to a substantial risk of imminent sexual
abuse, does it take immediate action to protect the resident? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Inspector General Directive
Vulnerability Assessments
Facility Operating Procedures (FOP) PREA
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
115.362 (a): Facility Policy and FDJJ Policy require staff to protect the residents through immediately
implementing protective measures. Interviews with the residents revealed their concerns about their
own safety are discussed during the intake process and during the administration of Screening
assessments. Policies requires that if the resident alleges, they are at substantial risk of imminent
sexual abuse, staff will take immediate steps to ensure the safety of the resident. The direct care staff
will take steps to separate the alleged victim from the alleged perpetrator and notify the staff with
PREA Audit Report – v7 Page 83 of 125 West Palm Beach Youth Academy
highest authority at the facility and the assistant facility administrator, or facility director. These staff
will then determine the best options to protect the victim. The staff will then follow the mandatory
reporting steps. All staff interviewed indicated their primary duty was to protect the residents housed
at the facility and would take immediate action to protect a resident that make and allegation of
imminent danger regardless of the whether it was sexual abuse, gang related, or resident own actions.
There have been no instances where residents were at imminent danger of sexual abuse.
Compliance was determined by review of policies and interviews with direct care staff, non-direct care
staff, and the facility administrator.
Standard 115.363: Reporting to other confinement facilities
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.363 (a)
▪ Upon receiving an allegation that a resident was sexually abused while confined at another
facility, does the head of the facility that received the allegation notify the head of the facility or
appropriate office of the agency where the alleged abuse occurred? ☒ Yes ☐ No
▪ Does the head of the facility that received the allegation also notify the appropriate investigative
agency? ☒ Yes ☐ No
115.363 (b)
▪ Is such notification provided as soon as possible, but no later than 72 hours after receiving the
allegation? ☒ Yes ☐ No
115.363 (c)
▪ Does the agency document that it has provided such notification? ☒Yes ☐ No
115.363 (d)
▪ Does the facility head or agency office that receives such notification ensure that the allegation
is investigated in accordance with these standards? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
PREA Audit Report – v7 Page 84 of 125 West Palm Beach Youth Academy
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ POLICY - Reporting to other facilities
PAQ
115.363: Upon receiving an allegation that a resident was sexually abused while confined at another
facility, the head of the facility that received the allegation shall notify the head of the facility or
appropriate office of the agency where the alleged abuse occurred and shall also notify the
appropriate investigative agency. The notification will be made no later than 72 hours and shall be
documented. Based on OIG standards all reports are called into the CCC within 2 hours of being made
aware of an allegation. The facility head or agency office that receives such notification shall ensure
that the allegation is investigated in accordance with these standards. If any allegation is made, the
notifications and documentation of the notifications would be made according to facility Policy.
During the past 12 months, there were no allegations received a resident was abused while confined to
another facility nor were there allegations of sexual abuse received by West Palm Beach Youth
Academy from other facilities.
Compliance was determined by review of policies, training module, and interviews with intake staff,
the facility administrator, and the agency head designee and the PREA coordinator.
Standard 115.364: Staff first responder duties
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.364 (a)
▪ Upon learning of an allegation that a resident was sexually abused, is the first security staff
member to respond to the report required to: Separate the alleged victim and abuser?
☒ Yes ☐ No
▪ Upon learning of an allegation that a resident was sexually abused, is the first security staff
member to respond to the report required to: Preserve and protect any crime scene until
appropriate steps can be taken to collect any evidence? ☒Yes ☐ No
▪ Upon learning of an allegation that a resident was sexually abused, is the first security staff
member to respond to the report required to: Request that the alleged victim not take any
actions that could destroy physical evidence, including, as appropriate, washing, brushing teeth,
changing clothes, urinating, defecating, smoking, drinking, or eating, if the abuse occurred
within a time period that still allows for the collection of physical evidence? ☒ Yes ☐ No
PREA Audit Report – v7 Page 85 of 125 West Palm Beach Youth Academy
▪ Upon learning of an allegation that a resident was sexually abused, is the first security staff
member to respond to the report required to: Ensure that the alleged abuser does not take any
actions that could destroy physical evidence, including, as appropriate, washing, brushing teeth,
changing clothes, urinating, defecating, smoking, drinking, or eating, if the abuse occurred
within a time period that still allows for the collection of physical evidence? ☒Yes ☐ No
115.364 (b)
▪ If the first staff responder is not a security staff member, is the responder required to request
that the alleged victim not take any actions that could destroy physical evidence, and then notify
security staff? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy - Responding to Allegations
Investigation procedures from OIG
PAQ
115.364 (a): Upon learning of an allegation that a resident was sexually abused, the first staff member
to respond to the report shall be required to:
• Separate the alleged victim and abuser;
• Preserve and protect any crime scene until appropriate steps can be taken to collect any
evidence;
• If the abuse occurred within a time period that still allows for the collection of physical
evidence, request that the alleged victim not take any actions that could destroy physical
evidence, including, as appropriate, washing, brushing teeth, changing clothes, urinating,
defecating, smoking, drinking, or eating; and
• If the abuse occurred within a time period that still allows for the collection of physical
evidence, ensure that the alleged abuser does not take any actions that could destroy physical
PREA Audit Report – v7 Page 86 of 125 West Palm Beach Youth Academy
evidence, including, as appropriate, washing, brushing teeth, changing clothes, urinating,
defecating, smoking, drinking, or eating
115.364 (b): If the first staff responder is not a security staff member, the responder shall be required
to request that the alleged victim not take any actions that could destroy physical evidence, and then
notify security staff. Random staff interviews revealed considerable knowledge of actions to be taken
upon learning a resident alleges being sexually abused.
Staff interviewed confirmed they knew their obligations when a resident makes an allegation or they
suspect an incident of sexual abuse has occurred.
Compliance was determined by a review of center training plan, first responder flow chart and
interviews with all staff including the maintenance staff that does not deal directly with resident.
Standard 115.365: Coordinated response
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.365 (a)
▪ Has the facility developed a written institutional plan to coordinate actions among staff first
responders, medical and mental health practitioners, investigators, and facility leadership taken
in response to an incident of sexual abuse? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Coordinated Response Plan
115.365 (a): FDJJ Coordinated Response includes a written plan to coordinate actions of employee first
responders, medical and mental health practitioners, investigators, and facility leadership in response
PREA Audit Report – v7 Page 87 of 125 West Palm Beach Youth Academy
to an incident of sexual abuse. FDJJ has a system in place providing the staff with clear actions to be
taken by staff including contacting administrative staff, medical and mental health staff, OIG and law
enforcement, victim advocate services, & parent/guardian and several other individuals. Staff
members are directed to follow the steps outlined and to utilize the checklist in addressing the
situation. There was no allegation of sexual abuse that included staff on residents. Compliance was
determined by review of the Coordinated Response of an Allegations of Sexual Abuse and interviews
with random staff, nurse, shift supervisors, PREA compliance managers and PREA coordinator.
Standard 115.366: Preservation of ability to protect residents from contact
with abusers
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.366 (a)
▪ Are both the agency and any other governmental entities responsible for collective bargaining
on the agency’s behalf prohibited from entering into or renewing any collective bargaining
agreement or other agreement that limits the agency’s ability to remove alleged staff sexual
abusers from contact with any residents pending the outcome of an investigation or of a
determination of whether and to what extent discipline is warranted? ☒ Yes ☐ No
115.366 (b)
▪ Auditor is not required to audit this provision.
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
28 C.F.R. 115.366 of the Federal Prison Rape Elimination Standard (PREA)
PREA Audit Report – v7 Page 88 of 125 West Palm Beach Youth Academy
115.366 (a): Pursuant to 28 C.F.R. 115.366 of the Federal Prison Rape Elimination Standard (PREA), the
Florida Department of Juvenile Justice (FDJJ) does not engage in the collective bargaining process
regarding any violation of departmental Policy regarding PREA. FDJJ does not allow an entity to restrict
the department’s ability to terminate an employee or remove a staff who allegedly abuses or harasses
youth from having contact with residents pending the outcome of an investigation or a determination
of whether and to what extent to discipline is warranted. Interviews with the FDJJ Commissioner and
PREA Coordinator determined the facility meets the requirements of the standard.
Standard 115.367: Agency protection against retaliation
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.367 (a)
▪ Has the agency established a Policy to protect all residents and staff who report sexual abuse
or sexual harassment or cooperate with sexual abuse or sexual harassment investigations from
retaliation by other residents or staff? ☒Yes ☐ No
▪ Has the agency designated which staff members or departments are charged with monitoring
retaliation? ☒ Yes ☐ No
115.367 (b)
▪ Does the agency employ multiple protection measures, such as housing changes or transfers
for resident victims or abusers, removal of alleged staff or resident abusers from contact with
victims, and emotional support services, for residents or staff who fear retaliation for reporting
sexual abuse or sexual harassment or for cooperating with investigations,? ☒ Yes ☐ No
115.367 (c)
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor: The conduct
and treatment of residents or staff who reported the sexual abuse to see if there are changes
that may suggest possible retaliation by residents or staff? ☒ Yes ☐ No
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor: The conduct
and treatment of residents who were reported to have suffered sexual abuse to see if there are
changes that may suggest possible retaliation by residents or staff? ☒ Yes ☐ No
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency: Act promptly to remedy
any such retaliation? ☒ Yes ☐ No
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor: Any resident
disciplinary reports? ☒ Yes ☐ No
PREA Audit Report – v7 Page 89 of 125 West Palm Beach Youth Academy
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor: Resident
housing changes? ☒ Yes ☐ No
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor: Resident
program changes? ☒ Yes ☐ No
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor: Negative
performance reviews of staff? ☒ Yes ☐ No
▪ Except in instances where the agency determines that a report of sexual abuse is unfounded,
for at least 90 days following a report of sexual abuse, does the agency monitor:
Reassignments of staff? ☒ Yes ☐ No
▪ Does the agency continue such monitoring beyond 90 days if the initial monitoring indicates a
continuing need? ☒ Yes ☐ No
115.367 (d)
▪ In the case of residents, does such monitoring also include periodic status checks?
☒ Yes ☐ No
115.367 (e)
▪ If any other individual who cooperates with an investigation expresses a fear of retaliation, does
the agency take appropriate measures to protect that individual against retaliation?
☒ Yes ☐ No
115.367 (f)
▪ Auditor is not required to audit this provision.
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
PREA Audit Report – v7 Page 90 of 125 West Palm Beach Youth Academy
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919- Protection against Retaliation
WPB Youth Academy Retaliation Form
WPBYA Policy 5.23 - protection against retaliation
115.367 (a): Facility and FDJJ policies establishes for protection or resident against retaliation and staff
for reports of sexual abuse or harassment or cooperation with investigations. Allegations of retaliation
shall be immediately reported to the site supervisor or designee. In instances where the supervisor is
believed to be involved in the retaliation, the employee shall notify the supervisor or designee at the
next appropriate supervisory level. For 90 calendar days, or longer based on continuing need, following
a report of sexual abuse, the PREA Compliance Manager( Assistant Director) shall monitor the conduct
or treatment of any individual, youth or employee, who were involved in a reported incident, and shall
act promptly to remedy any such retaliation. Monitoring steps include reviewing group, or facility
assignments, reviewing youth progress reports, periodic status checks with the youth, and
performance reviews or reassignments of employees involved in the initial report or investigation.
During the last 12 months there no allegation of sexual abuse that was monitored for retaliation.
Vivant (Sequel Youth and Family Services) has developed a company form for all facilities managed by
the cooperation to document retaliation monitoring.
115.367 (b): The agency shall employ multiple protection measures, such as housing changes or
transfers for resident victims or abusers, removal of alleged staff or resident abusers from contact with
victims, and emotional support services for residents or staff who fear retaliation for reporting sexual
abuse or sexual harassment or for cooperating with investigations. The Policy identifies measures to
protect staff and residents including the following: a. Initiating housing changes or transfers for
resident victims or abusers; b. Removing alleged staff or resident abusers from contact with victims;
and c. Providing emotional support services. The interview confirmed the facility would protect
residents and staff from retaliation for sexual abuse and sexual harassment allegations. Protective
measures would include housing changes, transfers, removing alleged abusers, and emotional support
services. The PREA Compliance Manager identified protective measures that are aligned with the
standard, including separating the alleged abuser from the alleged victim.
115.367 (c): For at least 90 days following a report of sexual abuse, the agency shall monitor the
conduct or treatment of residents or staff who reported the sexual abuse and of residents who were
reported to have suffered sexual abuse to see if there are changes that may suggest possible
retaliation by residents or staff and shall act promptly to remedy any such retaliation. Items the agency
should monitor include any resident disciplinary reports, housing, or program changes, or negative
performance reviews or reassignments of staff. The agency shall continue such monitoring beyond 90
days if the initial monitoring indicates a continuing need. FDJJ Policy 1919 PREA requires the
monitoring of items identified in this provision of the standard. The PREA Compliance Manager
explained during the interview how he would discharge those duties, including monitoring the items
identified in the standard and whether a resident filed a grievance alleging sexual abuse or sexual
harassment. Retaliation monitoring would occur for 90 days to see if there are any changes that may
suggest possible retaliation by residents or staff, and shall act promptly to remedy any such retaliation,
PREA Audit Report – v7 Page 91 of 125 West Palm Beach Youth Academy
according to Policy. The monitoring will continue beyond ninety (90) days if the initial monitoring
indicates a continuing need. There have been no incidents of retaliation during the 12 months
preceding the audit.
115.367 (d): In the case of residents, such monitoring shall also include periodic status checks. The
PREA Compliance Manager indicated status checks would be initiated with staff and residents. The FOP
states periodic status will occur. The Retaliation Status Checklist would be used to document the status
checks as well as the Retaliation Monitoring Checklist to document the ongoing motoring and use of
the Retaliation Status Checklist.
115.367 (e): If any other individual who cooperates with an investigation expresses a fear of
retaliation, the facility shall take appropriate measures to protect that individual against retaliation.
The FOP states if any other individual who cooperates with an investigation expresses the occurrence
retaliation from another resident or staff member, WPBYA shall take appropriate measures to protect
that individual against retaliation.
The assistant facility administrator (PREA compliance manager) indicated he would visit the resident
whenever an allegation is lodged by residents or third party immediately and discuss his role to
monitor for retaliation. The clinical supervisor indicated that therapist would also monitor for
retaliation. The facility administrator indicated he would monitor staff that report and cooperated with
any investigations. There have been no monitoring at the facility in the last 12 months. There was one
allegation of sexual abuse that did not indicate resident, date, or area of the incident. It was
determined to be unsubstantiated, and monitor did not occur since the allegation claims it happened
over two years before the audit. There was one allegation of staff and resident sexual abuse/ sexual
improper conduct that was unfounded.
Compliance was determined by review of the polices, the monitoring check list and interviews with the
retaliation monitor, facility administrator and Agency PREA coordinator.
Standard 115.368: Post-allegation protective custody
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.368 (a)
▪ Is any and all use of segregated housing to protect a resident who is alleged to have suffered
sexual abuse subject to the requirements of § 115.342? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
PREA Audit Report – v7 Page 92 of 125 West Palm Beach Youth Academy
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919 PREA
Statement of Fact
WPBYA Policy 5.23
115.368 (a) Policy 5.23 addresses this standard regarding placing residents in isolation who have
alleged to have suffered sexual abuse. According to Policy, a resident would only be placed in isolation
as a last resort if less restrictive measures are inadequate and only until alternative placement could be
found. Interviews the assistant facility director, and mental health director stated they would develop
a plan to protect the resident. If no other alternative is available, the resident could be moved to a
facility to protect the resident. During any period of isolation residents shall not be denied large-
muscle exercise, educational programming, special education services and other programs to the
extent possible. Residents in isolation would receive daily visits from a medical or mental health care
clinician. If a resident who alleges to have suffered sexual abuse is held in isolation, the facility affords
each such resident a review every 30 days to determine whether there is continuing need for
separation from the general population. The facility has no historical record of ever utilizing
segregation or isolation of a resident at MYA to protect residents from others due to a threat and
allegation of sexual abuse or sexual harassment. Compliance was determined by review of Policy
interviews with Facility Director and Assistant Director.
INVESTIGATIONS
Standard 115.371: Criminal and administrative agency investigations
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.371 (a)
▪ When the agency conducts its own investigations into allegations of sexual abuse and sexual
harassment, does it do so promptly, thoroughly, and objectively? [N/A if the agency/facility is not
responsible for conducting any form of criminal OR administrative sexual abuse investigations.
See 115.321(a).] ☒ Yes ☐ No ☐ NA
▪ Does the agency conduct such investigations for all allegations, including third party and
anonymous reports? [N/A if the agency/facility is not responsible for conducting any form of
PREA Audit Report – v7 Page 93 of 125 West Palm Beach Youth Academy
criminal OR administrative sexual abuse investigations. See 115.321(a).]
☒ Yes ☐ No ☐ NA
115.371 (b)
▪ Where sexual abuse is alleged, does the agency use investigators who have received
specialized training in sexual abuse investigations involving juvenile victims as required by
115.334? ☒ Yes ☐ No
115.371 (c)
▪ Do investigators gather and preserve direct and circumstantial evidence, including any available
physical and DNA evidence and any available electronic monitoring data? ☒ Yes ☐ No
▪ Do investigators interview alleged victims, suspected perpetrators, and witnesses?
☒ Yes ☐ No
▪ Do investigators review prior reports and complaints of sexual abuse involving the suspected
perpetrator? ☒ Yes ☐ No
115.371 (d)
▪ Does the agency always refrain from terminating an investigation solely because the source of
the allegation recants the allegation? ☒ Yes ☐ No
115.371 (e)
▪ When the quality of evidence appears to support criminal prosecution, does the agency conduct
compelled interviews only after consulting with prosecutors as to whether compelled interviews
may be an obstacle for subsequent criminal prosecution? ☒ Yes ☐ No
115.371 (f)
▪ Do agency investigators assess the credibility of an alleged victim, suspect, or witness on an
individual basis and not on the basis of that individual’s status as resident or staff?
☒ Yes ☐ No
▪ Does the agency investigate allegations of sexual abuse without requiring a resident who
alleges sexual abuse to submit to a polygraph examination or other truth-telling device as a
condition for proceeding? ☒ Yes ☐ No
115.371 (g)
▪ Do administrative investigations include an effort to determine whether staff actions or failures to
act contributed to the abuse? ☒ Yes ☐ No
PREA Audit Report – v7 Page 94 of 125 West Palm Beach Youth Academy
▪ Are administrative investigations documented in written reports that include a description of the
physical evidence and testimonial evidence, the reasoning behind credibility assessments, and
investigative facts and findings? ☒ Yes ☐ No
115.371 (h)
▪ Are criminal investigations documented in a written report that contains a thorough description
of the physical, testimonial, and documentary evidence and attaches copies of all documentary
evidence where feasible? ☒ Yes ☐ No
115.371 (i)
▪ Are all substantiated allegations of conduct that appears to be criminal referred for prosecution?
☒ Yes ☐ No
115.371 (j)
▪ Does the agency retain all written reports referenced in 115.371(g) and (h) for as long as the
alleged abuser is incarcerated or employed by the agency, plus five years unless the abuse was
committed by a juvenile resident and applicable law requires a shorter period of retention?
☒ Yes ☐ No
115.371 (k)
▪ Does the agency ensure that the departure of an alleged abuser or victim from the employment
or control of the agency does not provide a basis for terminating an investigation?
☒ Yes ☐ No
115.371 (l)
▪ Auditor is not required to audit this provision.
115.371 (m)
▪ When an outside agency investigates sexual abuse, does the facility cooperate with outside
investigators and endeavor to remain informed about the progress of the investigation? (N/A if
an outside agency does not conduct administrative or criminal sexual abuse investigations. See
115.321(a).) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
PREA Audit Report – v7 Page 95 of 125 West Palm Beach Youth Academy
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ POLICY – Investigations
Investigation procedures from OIG
Investigative Notifications
FDJJ Website
115.371 (a): FDJJ Policy establishes the agency Policy that all allegations of sexual abuse or sexual
harassment will be investigated. Florida Department of Juvenile Justice does not conduct their own
investigations of sexual abuse and harassment. The Office of the Inspector General conduct
administrative investigations and criminal investigations are conducted by local law enforcement.
Sustained allegations as a result of a criminal investigation will be referred for prosecution. The Florida
Department of Children and Families are also called when there is an allegation of sexual abuse. When
the OIG office refers and investigation back to DJJ the report will be conducted promptly, thoroughly,
and objectively for all allegations, including third party and anonymous reports
115.371 (b): Where sexual abuse is alleged, the agency shall use investigators who have received
special training in sexual abuse investigations involving juvenile victims pursuant to § 115.334.
115.371 (c): Investigators shall gather and preserve direct and circumstantial evidence, including any
available physical and DNA evidence and any available electronic monitoring data; shall interview
alleged victims, suspected perpetrators, and witnesses; and shall review prior complaints and reports
of sexual abuse involving the suspected perpetrator.
115.371 (d): The agency shall not terminate an investigation solely because the source of the allegation
recants the allegation.
115.371 (e): When the quality of evidence appears to support criminal prosecution, the agency shall
conduct compelled interviews only after consulting with prosecutors as to whether compelled
interviews may be an obstacle for subsequent criminal prosecution.
115.371 (f): The credibility of an alleged victim, suspect, or witness shall be assessed on an individual
basis and shall not be determined by the person’s status as resident or staff. No agency shall require a
resident who alleges sexual abuse to submit to a polygraph examination or other truth-telling device as
a condition for proceeding with the investigation of such an allegation.
115.371 (g): Administrative investigations shall include an effort to determine whether staff actions or
failures to act contributed to the abuse; and shall be documented in written reports that include a
PREA Audit Report – v7 Page 96 of 125 West Palm Beach Youth Academy
description of the physical and testimonial evidence, the reasoning behind credibility assessments, and
investigative facts and findings.
115.371 (h): Criminal investigations shall be documented in a written report that contains a thorough
description of physical, testimonial, and documentary evidence and attaches copies of all documentary
evidence where feasible.
115.371 (i): Substantiated allegations of conduct that appears to be criminal shall be referred for
prosecution.
115.371 (j): The agency shall retain all written reports referenced in paragraphs (g) and (h) of this
section for as long as the alleged abuser is incarcerated or employed by the agency, plus five years,
unless the abuse was committed by a juvenile resident and applicable law requires a shorter period of
retention.
115.371 (k): Provision (k): The departure of the alleged abuser or victim from the employment or
control of the facility or agency shall not provide a basis for terminating an investigation.
115.371 (l): Any State entity or Department of Justice component that conducts such investigations
shall do so pursuant to the above requirements.
115.371 (m): When outside agencies investigate sexual abuse, the facility shall cooperate with outside
investigators and shall endeavor to remain informed about the progress of the investigation. WPBYA
FOP PREA states FDJJ does not conduct criminal investigations of residents’ allegations of sexual abuse.
The Palm Beach County Sheriff’s Office and the Florida Department of Children and Families Services
handle criminal investigations. FDJJ’s Office of Inspector General (OIG) reviews allegations to identify
any misconduct by staff related to FDJJ regulatory guidance. The Policy also states the agency does not
terminate an investigation solely because the source of the allegation recants the allegation. The
agency retains all written reports of investigations pertaining to administrative and criminal
investigations. There have been no substantiated allegations of sexual abuse since the last PREA audit.
The interviews confirmed what the practice will be in accordance with the Policy, FOP, and standard.
During the last 12 months there were two allegations of staff on residents sexual abuse. Both were
referred to Local law enforcement of investigations. One allegation was investigated by the local law
enforcement and determined unfounded. One was review by local law enforcement and declined to
investigate based on the minimum information in the allegation. Both were administratively
investigated by OIG. One was determined to be unfounded, and one was unsubstantiated. The Florida
Department of Children and Families (DCF) reviewed and investigated both case and determined them
to be unfounded. A review of the administrative investigation was thorough, prompt and included was
there any obstacles or needs for additional staff or cameras noted during the investigations.
Compliance was determined by review of the two investigations, interviews with the chief of
investigation for OIG, PREA coordinator and facility administrator.
PREA Audit Report – v7 Page 97 of 125 West Palm Beach Youth Academy
Standard 115.372: Evidentiary standard for administrative investigations
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.372 (a)
▪ Is it true that the agency does not impose a standard higher than a preponderance of the
evidence in determining whether allegations of sexual abuse or sexual harassment are
substantiated? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
FDJJ Policy 1919 – Investigations
FDJJ Office of the Inspector General and criminal investigations conducts administrative investigations.
The investigator may make a finding of Substantiated, Not Substantiated, Unfounded, or Pending
Further Investigation. The finding will be made using the standard of proof of the preponderance of
the evidence (51 % of the evidence).
Compliance of the standard was determined by reviewing the Policy, investigative report and interview
with the agency PREA coordinator and investigator from Office of Inspector General.
Standard 115.373: Reporting to residents
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.373 (a)
PREA Audit Report – v7 Page 98 of 125 West Palm Beach Youth Academy
▪ Following an investigation into a resident’s allegation that he or she suffered sexual abuse in an
agency facility, does the agency inform the resident as to whether the allegation has been
determined to be substantiated, unsubstantiated, or unfounded? ☒ Yes ☐ No
115.373 (b)
▪ If the agency did not conduct the investigation into a resident’s allegation of sexual abuse in the
agency’s facility, does the agency request the relevant information from the investigative agency
in order to inform the resident? (N/A if the agency/facility is responsible for conducting
administrative and criminal investigations.) ☒ Yes ☐ No ☐ NA
115.373 (c)
▪ Following a resident’s allegation that a staff member has committed sexual abuse against the
resident, unless the agency has determined that the allegation is unfounded, or unless the
resident has been released from custody, does the agency subsequently inform the resident
whenever: The staff member is no longer posted within the resident’s unit? ☒ Yes ☐ No
▪ Following a resident’s allegation that a staff member has committed sexual abuse against the
resident, unless the agency has determined that the allegation is unfounded, or unless the
resident has been released from custody, does the agency subsequently inform the resident
whenever: The staff member is no longer employed at the facility? ☒ Yes ☐ No
▪ Following a resident’s allegation that a staff member has committed sexual abuse against the
resident, unless the agency has determined that the allegation is unfounded, or unless the
resident has been released from custody, does the agency subsequently inform the resident
whenever: The agency learns that the staff member has been indicted on a charge related to
sexual abuse in the facility? ☒ Yes ☐ No
▪ Following a resident’s allegation that a staff member has committed sexual abuse against the
resident, unless the agency has determined that the allegation is unfounded, or unless the
resident has been released from custody, does the agency subsequently inform the resident
whenever: The agency learns that the staff member has been convicted on a charge related to
sexual abuse within the facility? ☒ Yes ☐ No
115.373 (d)
▪ Following a resident’s allegation that he or she has been sexually abused by another resident,
does the agency subsequently inform the alleged victim whenever: The agency learns that the
alleged abuser has been indicted on a charge related to sexual abuse within the facility?
☒ Yes ☐ No
▪ Following a resident’s allegation that he or she has been sexually abused by another resident,
does the agency subsequently inform the alleged victim whenever: The agency learns that the
alleged abuser has been convicted on a charge related to sexual abuse within the facility?
☒ Yes ☐ No
115.373 (e)
▪ Does the agency document all such notifications or attempted notifications? ☒ Yes ☐ No
PREA Audit Report – v7 Page 99 of 125 West Palm Beach Youth Academy
115.373 (f)
▪ Auditor is not required to audit this provision.
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
FDJJ Policy 1919 – Investigations
WPBYA Policy 1.03 Incident Reporting
115.373 (a): FDJJ Policy 1919 – Investigations mandates FDJJ Policy 1919 PREA at the conclusion of any law
enforcement investigation into sexual abuse, the victim or the victim’s parent(s) or legal guardian(s) shall be
notified the investigation has concluded. The Statewide PREA Coordinator will send a letter notifying
residents/parents /legal guardian of charges and of the outcome of the investigation including the identification
of the investigative entity and state the findings.
115.373 (b): FDJJ Policy mandates that If the agency did not conduct the investigation, it shall request the
relevant information from the investigative agency in order to inform the resident. The Statewide PREA
Coordinator will send a letter notifying residents/parents /legal guardian of charges and of the outcome of the
investigation including the identification of the investigative entity and state the findings.
115.373 (c): FDJJ Policy requires following a resident’s allegation that a staff member has committed sexual
abuse against the resident, the agency shall subsequently inform the resident (unless the agency has
determined that the allegation is unfounded) whenever: (1) The staff member is no longer posted within the
resident’s unit; (2) The staff member is no longer employed at the facility; (3) The agency learns that the staff
member has been indicted on a charge related to sexual abuse within the facility; or (4) The agency learns that
the staff member has been convicted on a charge related to sexual abuse within the facility.
115.373 (d): Following a resident’s allegation that he or she has been sexually abused by another resident, the
agency shall subsequently inform the alleged victim whenever: (1) The agency learns that the alleged abuser has
been indicted on a charge related to sexual abuse within the facility; or (2) The agency learns that the alleged
abuser has been convicted on a charge related to sexual abuse within the facility.
PREA Audit Report – v7 Page 100 of 125 West Palm Beach Youth Academy
115.373 (e): Policy requires All such notifications or attempted notifications shall be documented. The Statewide
PREA Coordinator will send a letter notifying residents/parents /legal guardian of charges and of the outcome of
the investigation including the identification of the investigative entity and state the findings.
Based on the investigative reports, review of Policy and interviews with PREA compliance manager and PREA
coordinator for FDJJ it was determined that the agency is in compliance with this standard.
DISCIPLINE
Standard 115.376: Disciplinary sanctions for staff
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.376 (a)
▪ Are staff subject to disciplinary sanctions up to and including termination for violating agency
sexual abuse or sexual harassment policies? ☒ Yes ☐ No
115.376 (b)
▪ Is termination the presumptive disciplinary sanction for staff who have engaged in sexual
abuse? ☒ Yes ☐ No
115.376 (c)
▪ Are disciplinary sanctions for violations of agency policies relating to sexual abuse or sexual
harassment (other than actually engaging in sexual abuse) commensurate with the nature and
circumstances of the acts committed, the staff member’s disciplinary history, and the sanctions
imposed for comparable offenses by other staff with similar histories? ☒ Yes ☐ No
115.376 (d)
▪ Are all terminations for violations of agency sexual abuse or sexual harassment policies, or
resignations by staff who would have been terminated if not for their resignation, reported to:
Law enforcement agencies (unless the activity was clearly not criminal)? ☒ Yes ☐ No
▪ Are all terminations for violations of agency sexual abuse or sexual harassment policies, or
resignations by staff who would have been terminated if not for their resignation, reported to:
Relevant licensing bodies? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
PREA Audit Report – v7 Page 101 of 125 West Palm Beach Youth Academy
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
Facility Operating Procedures
Statement of Fact
115.376 (a): Staff is subjected to disciplinary sanctions up to and including termination for violating
agency sexual abuse or sexual harassment policies.
115.376 (b): According to local Policy and interview with facility administrator all allegations of sexual
abuse shall be immediately investigated. Upon the conclusion of the investigation, if staff is
determined that they were involved in sexual abuse of a resident, that staff will be terminated
immediately, and the investigation will be forwarded to law enforcement for further review and
charges.
115.376 (c): Disciplinary sanctions for violations of agency policies relating to sexual abuse and
harassment other than engaging in sexual abuse will be commensurate with the nature and
circumstances of the acts committed. However, most likely any degree of sexual abuse and
harassment will be met with termination of the staff member.
115.376 (d): All staff members who are terminated and or resign in lieu of termination due to
violations of the sexual abuse and sexual harassment Policy shall be reported to law enforcement.
Staff who resign because they would have been terminated, are reported to the local law enforcement
unless the activities were not clearly criminal.
There have been no adverse action taken against staff for violation of sexual abuse, sexual harassment,
child neglect or violation of PREA standards during the last 12 months. Compliance was determined by
review of the agency Policy, interview with PREA coordinator and facility administrator.
Standard 115.377: Corrective action for contractors and volunteers
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.377 (a)
PREA Audit Report – v7 Page 102 of 125 West Palm Beach Youth Academy
▪ Is any contractor or volunteer who engages in sexual abuse prohibited from contact with
residents? ☒ Yes ☐ No
▪ Is any contractor or volunteer who engages in sexual abuse reported to: Law enforcement
agencies (unless the activity was clearly not criminal)? ☒ Yes ☐ No
▪ Is any contractor or volunteer who engages in sexual abuse reported to: Relevant licensing
bodies? ☒ Yes ☐ No
115.377 (b)
▪ In the case of any other violation of agency sexual abuse or sexual harassment policies by a
contractor or volunteer, does the facility take appropriate remedial measures, and consider
whether to prohibit further contact with residents? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ POLICY 1919 – Disciplinary sanctions for Staff
WPBYA Policy 5.23 – corrective action for contractors and volunteers
PAQ
115.377 (a) Facility Policy 5.23 and FDJJ POLICY 1919 provide any contractor or volunteer who engages
in sexual abuse is prohibited from contact with residents. The Policies also provide for contractors and
volunteers who engage in sexual abuse to be reported to law enforcement and to relevant licensing
bodies.
115.377 (b) The documentation and interviews with the Staff Development Coordinator, Assistant
Facility Administrator and a contractor revealed the provision of information to volunteers and
contractors that sexual misconduct with a resident is strictly prohibited. In the case of any other
violation of agency sexual abuse or sexual harassment policies by a contractor or volunteer, the facility
PREA Audit Report – v7 Page 103 of 125 West Palm Beach Youth Academy
will take appropriate remedial measures, and consider whether to prohibit further contact with
residents, however, would most likely prohibit them from further contact with residents.
At the present time the facility does not have any contractor or volunteers. Compliance was
determined by training curriculum, contractor and volunteer applications and interviews with the PREA
compliance manager and Facility Administrator.
Standard 115.378: Interventions and disciplinary sanctions for residents
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.378 (a)
▪ Following an administrative finding that a resident engaged in resident-on-resident sexual
abuse, or following a criminal finding of guilt for resident-on-resident sexual abuse, may
residents be subject to disciplinary sanctions only pursuant to a formal disciplinary process?
☒ Yes ☐ No
115.378 (b)
▪ Are disciplinary sanctions commensurate with the nature and circumstances of the abuse
committed, the resident’s disciplinary history, and the sanctions imposed for comparable
offenses by other residents with similar histories? ☒ Yes ☐ No
▪ In the event a disciplinary sanction results in the isolation of a resident, does the agency ensure
the resident is not denied daily large-muscle exercise? ☒ Yes ☐ No
▪ In the event a disciplinary sanction results in the isolation of a resident, does the agency ensure
the resident is not denied access to any legally required educational programming or special
education services? ☒ Yes ☐ No
▪ In the event a disciplinary sanction results in the isolation of a resident, does the agency ensure
the resident receives daily visits from a medical or mental health care clinician? ☒ Yes ☐ No
▪ In the event a disciplinary sanction results in the isolation of a resident, does the resident also
have access to other programs and work opportunities to the extent possible? ☒ Yes ☐ No
115.378 (c)
▪ When determining what types of sanction, if any, should be imposed, does the disciplinary
process consider whether a resident’s mental disabilities or mental illness contributed to his or
her behavior? ☒ Yes ☐ No
115.378 (d)
▪ If the facility offers therapy, counseling, or other interventions designed to address and correct
underlying reasons or motivations for the abuse, does the facility consider whether to offer the
offending resident participation in such interventions? ☒ Yes ☐ No
PREA Audit Report – v7 Page 104 of 125 West Palm Beach Youth Academy
▪ If the agency requires participation in such interventions as a condition of access to any
rewards-based behavior management system or other behavior-based incentives, does it
always refrain from requiring such participation as a condition to accessing general
programming or education? ☒ Yes ☐ No
115.378 (e)
▪ Does the agency discipline a resident for sexual contact with staff only upon a finding that the
staff member did not consent to such contact? ☒ Yes ☐ No
115.378 (f)
▪ For the purpose of disciplinary action does a report of sexual abuse made in good faith based
upon a reasonable belief that the alleged conduct occurred NOT constitute falsely reporting an
incident or lying, even if an investigation does not establish evidence sufficient to substantiate
the allegation? ☒ Yes ☐ No
115.378 (g)
▪ If the agency prohibits all sexual activity between residents, does the agency always refrain
from considering non-coercive sexual activity between residents to be sexual abuse? (N/A if the
agency does not prohibit all sexual activity between residents.) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Agency Policy (FDJJ 1919), Prison Rape Elimination Act (PREA)
Facility Operating Procedures (FOP) PREA
Florida Administrative Rule
PREA posters
PREA Audit Report – v7 Page 105 of 125 West Palm Beach Youth Academy
115.378 (a): A resident may be subject to disciplinary sanctions only pursuant to a formal disciplinary
process following an administrative finding that the resident engaged in resident-on-resident sexual
abuse or following a criminal finding of guilt for resident-on-resident sexual abuse. FDJJ Policy 1919
PREA and WPBYA FOP PREA require an administrative process for dealing with violations of resident-
on-resident sexual abuse. The Facility Administrator’s interview confirms the formal disciplinary
process however residents may also be referred to law enforcement for charges regarding resident-on-
resident sexual abuse. Sexual activity between residents is prohibited and court or administrative
processes and sanctions occur after a determination the sexual activity was coerced. Residents will be
disciplined for sexual contact with staff only when it has been determined the staff member did not
consent to the sexual contact. FDJJ Policy 1919 PREA provide anyone reporting in good faith will not
receive any repercussions. The policies and interview with the mental health staff confirms counseling
or other interventions will be offered to address and correct the underlying reasons or motivations for
abuse when the resident remains in or returns to the facility after a sexual abuse incident. The
interview also revealed any type interventions or treatment services provided are not as a condition
for the resident to access participation in the behavior management system, education services, or
other programs. The interview with the Clinical Director and Facility Administrator revealed the
process regarding allegations of resident-on-resident abuse which can include the resident being
removed from the facility and placed in the detention center during the investigation by law
enforcement.
115.378 (b): Any disciplinary sanctions shall be commensurate with the nature and circumstances of
the abuse committed, the resident’s disciplinary history, and the sanctions imposed for comparable
offenses by other residents with similar histories. In the event a disciplinary sanction results in the
isolation of a resident, agencies shall not deny the resident daily large-muscle exercise or access to any
legally required educational programming or special education services. Residents in isolation shall
receive daily visits from a medical or mental health care clinician. Residents shall also have access to
other programs and work opportunities to the extent possible WPBYA provides that disciplinary
sanctions are commensurate with the nature and circumstances of the abuse committed, the
resident’s disciplinary history, and the sanctions imposed for comparable offenses by other residents
with similar histories. In the extreme event a disciplinary sanction results in the isolation of a resident,
WPBYA shall not deny the resident daily large-muscle exercise or access to any legally required
educational programming or special education services. Policy further provides for daily visits by
mental health and medical personnel. Residents shall also have access to other programs and work
opportunities to the extent possible and receive daily visits from medical and mental health staff.
115.378 (c): The disciplinary process shall consider whether a resident’s mental disabilities or mental
illness contributed to his or her behavior when determining what type of sanction, if any, should be
imposed. The WPBYA provides that the disciplinary process considers whether a resident’s mental
disabilities or mental illness contributed to his or her behavior when determining what type of
sanction, if any, should be imposed. This was confirmed by the interview with the Clinical Director.
115.378 (d): If the facility offers therapy, counseling, or other interventions designed to address and
correct underlying reasons or motivations for the abuse, the facility shall consider whether to offer the
offending resident participation in such interventions. The agency may require participation in such
interventions as a condition of access to any rewards-based behavior management system or other
PREA Audit Report – v7 Page 106 of 125 West Palm Beach Youth Academy
behavior-based incentives, but not as a condition to access to general programming or education.
WPBYA FOP provides the facility considers whether to offer the offending resident therapy, counseling,
or other interventions designed to address and correct underlying reasons or motivations for the abuse
participation. The facility may require participation in such interventions as a condition of access to
privileges, but not as a condition to access to general programming or education. While the facility
have licensed counselor, the facility does not have a sex offender program. The facility does have sex
offenders in the program; however it is designed to treat drug abuse and is not a sex offender
program.
115.378 (e): The agency may discipline a resident for sexual contact with staff only upon a finding that
the staff member did not consent to such contact.
115.378 (f): For the purpose of disciplinary action, a report of sexual abuse made in good faith based
upon a reasonable belief that the alleged conduct occurred shall not constitute falsely reporting an
incident or lying, even if an investigation does not establish evidence sufficient to substantiate the
allegation. The WPBYA FOP states a report of sexual abuse made in good faith based upon a
reasonable belief that the alleged conduct occurred shall not constitute falsely reporting an incident or
lying, even if an investigation does not establish evidence sufficient to substantiate the allegation.
115.378 (g): An agency may, in its discretion, prohibit all sexual activity between residents and may
discipline residents for such activity. An agency may not, however, deem such activity to constitute
sexual abuse if it determines that the activity is not coerced. WPBYA prohibits any sexual conduct
between residents. All such conduct is subject to disciplinary action. Court processes occur after
determination the sexual activity was coerced.
The Statement of Fact indicated during this audit period this facility has not had any incidents that
require intervention for residents having sexual conduct. Based on the review of the agency Policy and
procedures, observations and information obtained through the staff interview and review of
documentation, the facility has demonstrated compliance with this standard.
MEDICAL AND MENTAL CARE
Standard 115.381: Medical and mental health screenings; history of sexual
abuse
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.381 (a)
▪ If the screening pursuant to § 115.341 indicates that a resident has experienced prior sexual
victimization, whether it occurred in an institutional setting or in the community, do staff ensure
that the resident is offered a follow-up meeting with a medical or mental health practitioner
within 14 days of the intake screening? ☒Yes ☐ No
115.381 (b)
PREA Audit Report – v7 Page 107 of 125 West Palm Beach Youth Academy
▪ If the screening pursuant to § 115.341 indicates that a resident has previously perpetrated
sexual abuse, whether it occurred in an institutional setting or in the community, do staff ensure
that the resident is offered a follow-up meeting with a mental health practitioner within 14 days
of the intake screening? ☒ Yes ☐ No
115.381 (c)
▪ Is any information related to sexual victimization or abusiveness that occurred in an institutional
setting strictly limited to medical and mental health practitioners and other staff as necessary to
inform treatment plans and security management decisions, including housing, bed, work,
education, and program assignments, or as otherwise required by Federal, State, or local law?
☒ Yes ☐ No
115.381 (d)
▪ Do medical and mental health practitioners obtain informed consent from residents before
reporting information about prior sexual victimization that did not occur in an institutional setting,
unless the resident is under the age of 18? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ POLICY 1919 – MH and Medical Screening
WPBYA – Medical and Mental Health Screenings
Mental Health Referral form
Screening Instrument:
Florida Administrative Rule
PREA Audit Report – v7 Page 108 of 125 West Palm Beach Youth Academy
115.381 (a) If any of the intake screening forms indicates a resident has experienced prior sexual
victimization, whether it occurred in an institutional setting or in the community, the facility
administrator or other intake officer shall document the information on the Follow up Notification
Form. According to the Clinical Director all resident that arrive a WPBYA are seen by the clinical
director within 72 hours of arrival and the same question about victimization is discussed during their
initial Mental Health intake. However the screening staff document and forward a follow up
notification form.
115.381 (b) If any of the intake screening forms indicates a resident has previously perpetrated sexual
abuse, whether it occurred in an institutional setting or in the community, do staff ensure that the
resident is offered a follow-up meeting with a mental health practitioner within 14 days of the intake
screening. This same information is discussed with the clinical staff within 72 hours of intake. However
the screening staff document and forward a follow up notification form.
115.381 (c): Any information related to sexual victimization or abuse that occurred in an institutional
setting shall be strictly limited to medical and mental health practitioners and other staff, as necessary,
to develop treatment plans and security and management decisions, including housing, bedding,
education, and bedding, education, and program assignments, or as otherwise required by Federal,
State, or Local law.
115.381 (d): Medical and mental health staff is required to notify residents at the initiation of services
their duty to report, limitations of confidentiality, and must obtain informed consent from youth who
are 18 years old or older before reporting information about the resident’s prior sexual victimization
that did not occur in an institutional setting. Residents who report prior sexual victimization or disclose
prior incidents of perpetrating sexual abuse, either in an institution or in the community, are required
to be offered a follow-up with a medical or mental health practitioner within 14 days of
admission/screening.
Compliance was determined by review of the agency Policy and interviews with medical and mental
health staff.
Standard 115.382: Access to emergency medical and mental health
services
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.382 (a)
▪ Do resident victims of sexual abuse receive timely, unimpeded access to emergency medical
treatment and crisis intervention services, the nature and scope of which are determined by
medical and mental health practitioners according to their professional judgment? ☒ Yes ☐
No
115.382 (b)
PREA Audit Report – v7 Page 109 of 125 West Palm Beach Youth Academy
▪ If no qualified medical or mental health practitioners are on duty at the time a report of recent
sexual abuse is made, do staff first responders take preliminary steps to protect the victim
pursuant to § 115.362? ☒ Yes ☐ No
▪ Do staff first responders immediately notify the appropriate medical and mental health
practitioners? ☒Yes ☐ No
115.382 (c)
▪ Are resident victims of sexual abuse offered timely information about and timely access to
emergency contraception and sexually transmitted infections prophylaxis, in accordance with
professionally accepted standards of care, where medically appropriate? ☒ Yes ☐ No
115.382 (d)
▪ Are treatment services provided to the victim without financial cost and regardless of whether
the victim names the abuser or cooperates with any investigation arising out of the incident?
☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
Samples of Acknowledgement of PREA Education
FDJJ Policy 1919 – Access to Emergency Medical and MH
Resident medical treatment forms
MOU, Palm Beach County Victim Services
115.382 (a): FDJJ Policy 1919 PREA mandate youth victims of sexual abuse receive timely and
unimpeded access to onsite and offsite emergency medical treatment and crisis intervention services,
the nature and scope as determined by the judgement of medical and mental health professionals.
Medical and mental health staff interviews confirmed emergency medical care and crisis intervention
services will be provided by medical and mental health staff as required. Observations revealed
PREA Audit Report – v7 Page 110 of 125 West Palm Beach Youth Academy
medical and mental health staff members maintain secondary materials that document services to
residents and these staff are knowledgeable of what must occur in an incident of sexual abuse. It is
documented through policies and understood by the medical and mental health staff treatment
services will be provided at no cost to the victim, whether or not the victim cooperates with the
investigation.
Residents are provided access to an outside victim advocacy agency for services through a MOU with
the Palm Beach County Victim Services which includes but is not limited to emotional support and
accompaniment through the forensic examination and investigative interviews. The advocate will go to
the facility or the hospital to provide services. Review of medical files shows that medical and mental
health staff members maintain secondary materials and documentation of resident encounters. There
have been no allegations of sexual abuse during this audit period.
FDJJ Policy 1919 – Access to Emergency Medical and MH requires resident victims of sexual abuse are
offered timely information about and timely access to emergency contraception and sexually
transmitted disease prophylaxis, in accordance with professionally accepted standards of care, where
medically appropriate and unimpeded access to emergency medical treatment and crisis intervention
services. The medical staff have a protocol in place to assist in expediting a resident to the emergency
room with specific documentation for the direct care staff. The facility utilizes Local Hospital for
emergency medical treatment and the Palm Beach County Victims Services for advocacy services in
cases of sexual abuse.
115.382 (b): If no qualified medical or mental health practitioners are on duty at the time a report of
recent abuse is made, staff first responders shall take preliminary steps to protect the victim pursuant
to § 115.362 and shall immediately notify the appropriate medical and mental health practitioners. The
interviews with clinical staff revealed residents have unimpeded access to emergency services. The
coordinated response plan flow chart provide guidance to staff in protecting residents and for
contacting the appropriate staff regarding allegations or incidents of sexual abuse, including contacting
medical and mental health staff. The on-call medical list has the names of medical staff and their
emergency contact number. The full-time Nurse is generally on-call 24/7 as determined by the
interview. Interviews with staff from Palm Beach County Victim Services indicated there is an on call
SANE staff available 24/7 for forensic examinations. There is also a Victim Advocate on call 24/7 to
support a resident that has been sexually assaulted.
115.382 (c): Resident victims of sexual abuse while incarcerated shall be offered timely information
about and timely access to emergency contraception and sexually transmitted infections prophylaxis,
in accordance with professionally accepted standards of care, where medically appropriate. The FOP
and interviews confirmed processes and services are in place for a victim to receive timely access to
sexually transmitted infection prophylaxis, where medically appropriate. Additionally, follow-up
services as needed will be provided by the facility’s medical and mental health staff, according to the
interviews with clinical staff. The facility houses male only.
115.382 (d): FDJJ Policy 1919 – Access to Emergency Medical and MH mandates that treatment
services shall be provided to the victim without financial cost and regardless of whether the victim
names the abuser or cooperates with any investigation arising out of the incident. This was also
PREA Audit Report – v7 Page 111 of 125 West Palm Beach Youth Academy
confirmed through staff interviews. The staff at the Palm Beach Victim Services indicated there were
no costs associated with advocacy, emotional services, and mental health services.
Policy revealed emergency services will be provided by medical and mental health staff. The medical
and mental health staff interviews revealed they are knowledgeable of actions to take regarding an
incident of sexual abuse. It is documented through FDJJ Policy 1919 PREA and understood by the
medical and mental health staff that treatment services will be provided at no cost to the victim. Based
upon the review of policies, interview with the Medical, mental health staff and interviews with staff
from Palm Beach Victim Services the facility is compliant with this standard.
Standard 115.383: Ongoing medical and mental health care for sexual
abuse victims and abusers
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.383 (a)
▪ Does the facility offer medical and mental health evaluation and, as appropriate, treatment to all
residents who have been victimized by sexual abuse in any prison, jail, lockup, or juvenile
facility? ☒ Yes ☐ No
115.383 (b)
▪ Does the evaluation and treatment of such victims include, as appropriate, follow-up services,
treatment plans, and, when necessary, referrals for continued care following their transfer to, or
placement in, other facilities, or their release from custody? ☒ Yes ☐ No
115.383 (c)
▪ Does the facility provide such victims with medical and mental health services consistent with
the community level of care? ☒ Yes ☐ No
115.383 (d)
▪ Are resident victims of sexually abusive vaginal penetration while incarcerated offered
pregnancy tests? (N/A if “all-male” facility. Note: in “all-male” facilities, there may be residents
who identify as transgender men who may have female genitalia. Auditors should be sure to
know whether such individuals may be in the population and whether this provision may apply in
specific circumstances.) ☐ Yes ☐ No ☒ NA
115.383 (e)
▪ If pregnancy results from the conduct described in paragraph § 115.383(d), do such victims
receive timely and comprehensive information about and timely access to all lawful pregnancy-
related medical services? (N/A if “all-male” facility. Note: in “all-male” facilities, there may be
residents who identify as transgender men who may have female genitalia. Auditors should be
sure to know whether such individuals may be in the population and whether this provision may
apply in specific circumstances.) ☐ Yes ☐ No ☒NA
PREA Audit Report – v7 Page 112 of 125 West Palm Beach Youth Academy
115.383 (f)
▪ Are resident victims of sexual abuse while incarcerated offered tests for sexually transmitted
infections as medically appropriate? ☒ Yes ☐ No
115.383 (g)
▪ Are treatment services provided to the victim without financial cost and regardless of whether
the victim names the abuser or cooperates with any investigation arising out of the incident?
☒ Yes ☐ No
115.383 (h)
▪ Does the facility attempt to conduct a mental health evaluation of all known resident-on-resident
abusers within 60 days of learning of such abuse history and offer treatment when deemed
appropriate by mental health practitioners? ☒Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919 Prison Rape Elimination Act (PREA)
Florida Administrative Rule
115.383 (a): The facility shall offer medical and mental health evaluation and, as appropriate,
treatment to all residents who have been victimized by sexual abuse in any prison, jail, lockup, or
juvenile facility. WPBYA is a drug treatment center that includes mental health therapist. The clinical
Director indicated in interview that the facility would provide treatment as indicated as prior
victimization can be part of the treatment needed for recovering youth. The facility makes a referral to
mental health for anyone that provides information on prior victimization or past predator behavior in
order to comply with the standard. However, the clinical director indicated that all residents that go
through intake at the facility are seen by mental health within 72 hours.
PREA Audit Report – v7 Page 113 of 125 West Palm Beach Youth Academy
115.383 (b): FDJJ Policy 1919 Prison Rape Elimination Act includes a provision that the evaluation and
treatment of such victims shall include, as appropriate, follow-up services, treatment plans, and, when
necessary, referrals for continued care following their transfer to, or placement in, other facilities, or
their release from custody. Interviews with the clinical staff and observations confirmed on-going
medical and mental health care will be provided as appropriate and will include but not limited to
additional testing and medical services; medication management, if prescribed; individual counseling;
trauma group; and referrals as needed. Residents that are housed at WPBYC have a follow up plan
which includes mental health counseling as needed. The plan also includes the family in supporting the
resident. The West Palm Beach Victim services is part of the Florida Coalition of Victim Services and
would provide resident with support programs when released from the center.
115.383 (c): Based on interviews with the medical and mental health staff the facility shall provide
victims with medical and mental health services consistent with the community level of care.
115.383 (d): N/A
115.383 (e) N/A
115.383 (f) The Policy and interviews ensure that victims of sexual abuse will be provided tests for
sexually transmitted infections as medically appropriate. Testing would be done at the Victim Service
or local hospital and follow-up services may be done at the facility, as needed.
115.383 (g) All treatment services will be provided at no cost to the victim, according to DJJ policy and
staff interviews.
115.383 (h) FDJJ Policy provides for attempts to be made for a mental health practitioner to conduct a
mental health evaluation within 60 days on all known resident-on-resident abusers and offer
appropriate treatment by mental health staff. Services will include but not be limited to individual,
group and family counseling. Additionally, an evaluation or reassessment will be administered utilizing
the Vulnerability Assessment.
Based on a review of the PREA policies, and interviews with the Victim Support Services, clinical
director, medical staff, PREA coordinator and Facility Administrator the facility is in compliance with
this standard.
DATA COLLECTION AND REVIEW
Standard 115.386: Sexual abuse incident reviews
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.386 (a)
PREA Audit Report – v7 Page 114 of 125 West Palm Beach Youth Academy
▪ Does the facility conduct a sexual abuse incident review at the conclusion of every sexual abuse
investigation, including where the allegation has not been substantiated, unless the allegation
has been determined to be unfounded? ☒ Yes ☐ No
115.386 (b)
▪ Does such review ordinarily occur within 30 days of the conclusion of the investigation?
☒ Yes ☐ No
115.386 (c)
▪ Does the review team include upper-level management officials, with input from line
supervisors, investigators, and medical or mental health practitioners? ☒ Yes ☐ No
115.386 (d)
▪ Does the review team: Consider whether the allegation or investigation indicates a need to
change Policy or practice to better prevent, detect, or respond to sexual abuse? ☒ Yes ☐ No
▪ Does the review team: Consider whether the incident or allegation was motivated by race;
ethnicity; gender identity; lesbian, gay, bisexual, transgender, or intersex identification, status, or
perceived status; gang affiliation; or other group dynamics at the facility? ☒Yes ☐ No
▪ Does the review team: Examine the area in the facility where the incident allegedly occurred to
assess whether physical barriers in the area may enable abuse? ☒ Yes ☐ No
▪ Does the review team: Assess the adequacy of staffing levels in that area during different
shifts? ☒ Yes ☐ No
▪ Does the review team: Assess whether monitoring technology should be deployed or
augmented to supplement supervision by staff? ☒Yes ☐ No
▪ Does the review team: Prepare a report of its findings, including but not necessarily limited to
determinations made pursuant to §§ 115.386(d)(1) - (d)(5), and any recommendations for
improvement and submit such report to the facility head and PREA compliance manager?
☒ Yes ☐ No
115.386 (e)
▪ Does the facility implement the recommendations for improvement, or document its reasons for
not doing so? ☐ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
PREA Audit Report – v7 Page 115 of 125 West Palm Beach Youth Academy
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919 Prison Rape Elimination Act
Investigative Report Including IRT
115.386 (a): FDJJ Policy 1919 PREA require an incident review team meeting within 30 days of the
conclusion of each investigation unless the finding is unfounded. The policy mandates review team
participation to include the agency-wide PREA Coordinator, the facility’s PREA Compliance Manager,
regional office staff, facility supervisor, medical and mental health staff. The FDJJ’s PREA Coordinator
will prepare a report of the review team’s findings and submit the report to the Secretary for
Detention Services, regional office staff and the facility’s Facility Administrator. There were two
allegations of sexual abuse during the last 12 months. One was unfounded. One was unsubstantiated
and a review team reviewed the allegation.
The interview with the PREA Compliance Manager and a review of the form used to document the
incident review team’s findings indicate the team: consider whether the allegation or investigation
indicates a need to change policy or practice to better prevent, detect, or respond to sexual abuse
considers whether the incident or allegation was motivated by race; ethnicity; gender identity; lesbian,
gay, bisexual, transgender, or intersex identification, status, or perceived status; gang affiliation; or
other group dynamics at the facility; examine the area in the facility where the incident allegedly
occurred to assess whether physical barriers in the area may enable abuse; assess the adequacy of
staffing levels in that area during different shifts; assess whether monitoring technology should be
deployed or augmented to supplement supervision by staff.
115.386 (b): The Agency policy requires that the reviews occur within 30 days of the conclusion of the
investigation. There has been one allegation of sexual abuse, the PREA coordinator confirmed that the
incident review occurred within 30 days of the conclusion of the investigation. A review of the Incident
Review confirmed that the allegation was reviewed within 30 days of conclusion of the findings.
115.386 (c): The policy mandates review team participation to include the agency-wide PREA
Coordinator, the facility’s PREA Compliance Manager, regional office staff, facility supervisor, medical
and mental health staff. The FDJJ’s PREA Coordinator will prepare a report of the review team’s
findings and submit the report to the Secretary for Detention Services, regional office staff and the
facility’s Facility Administrator. This specific allegation was a report that a staff had sexual relationship
with an unknown resident, at a unknown time, in a unknow location on a unknow days over two years
PREA Audit Report – v7 Page 116 of 125 West Palm Beach Youth Academy
from the report. The incident review team included the facility administrator, assistant facility
administrator, Clinical director and shift supervisor.
115.386 (d): The committee reviewed the following:
1) Consider whether the allegation or investigation indicates a need to change policy or practice to
better prevent, detect, or respond to sexual abuse;
(2) Consider whether the incident or allegation was motivated by race; ethnicity; gender identity;
lesbian, gay, bisexual, transgender, or intersex identification, status, or perceived status; or, gang
affiliation; or was motivated or otherwise caused by other group dynamics at the facility;
(3) Examine the area in the facility where the incident allegedly occurred to assess whether physical
barriers in the area may enable abuse;
(4) Assess the adequacy of staffing levels in that area during different shifts;
(5) Assess whether monitoring technology should be deployed or augmented to supplement
supervision by staff; and
(6) Prepare a report of its findings, including but not necessarily limited to determinations made
pursuant to paragraphs (d)(1)-(d)(5) of this section, and any recommendations for improvement and
submit such report to the facility head and PREA Compliance Manager.
115.386 (e): The Policy outlines the requirements of the standard for the areas to be assessed by the
incident review team. The interview with the Facility Administrator, review documentation confirmed
the incident review team meeting are documented, including recommendations and the document
provided to the Facility Administrator. The interview with the Incident Review Team Member
confirmed the facility would prepare a report of its findings and any recommendations for
improvement when conducting a sexual abuse incident review. He confirmed the team would consider
all factors required by the standard. The latest incident team had no recommendations.
Compliance was determined by review of the Incident Review Team memorandum, Policy and
interviews with the incident review team members, facility administrator and PCM.
Standard 115.387: Data collection
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.387 (a)
▪ Does the agency collect accurate, uniform data for every allegation of sexual abuse at facilities
under its direct control using a standardized instrument and set of definitions? ☒ Yes ☐ No
115.387 (b)
▪ Does the agency aggregate the incident-based sexual abuse data at least annually?
☒ Yes ☐ No
115.387 (c)
PREA Audit Report – v7 Page 117 of 125 West Palm Beach Youth Academy
▪ Does the incident-based data include, at a minimum, the data necessary to answer all questions
from the most recent version of the Survey of Sexual Violence conducted by the Department of
Justice? ☒ Yes ☐ No
115.387 (d)
▪ Does the agency maintain, review, and collect data as needed from all available incident-based
documents, including reports, investigation files, and sexual abuse incident reviews?
☒ Yes ☐ No
115.387 (e)
▪ Does the agency also obtain incident-based and aggregated data from every private facility with
which it contracts for the confinement of its residents? (N/A if agency does not contract for the
confinement of its residents.) ☐ Yes ☐ No ☒NA
115.387 (f)
▪ Does the agency, upon request, provide all such data from the previous calendar year to the
Department of Justice no later than June 30? (N/A if DOJ has not requested agency data.)
☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ POLICY 1919 – Data Collection
FDJJ 2020 - Incident Operations Center
PREA FY 2017-18 Annual Report Final
PREA FY 2018-19 Annual Report
PREA FY 2019-20 Annual Report
CC Uniform Definitions
FDJJ Website
PREA Audit Report – v7 Page 118 of 125 West Palm Beach Youth Academy
115.387 (a): FDJJ POLICY 1919 and a review of reports confirm that FDJJ collects incident-based,
uniform data regarding allegations of sexual abuse at facilities under its direct control, including
contractors, using a standardized instrument and specific guidelines. The format used for FDJJ facilities
and contractors capture the information required to complete the most recent version of the Survey of
Sexual Violence conducted by the U. S. Department of Justice (DOJ).
Florida DJJ maintains and collects various types of identified data and related documents regarding
sexual abuse incidents. The facility collects and maintains data in accordance with directives by FDJJ
and FDJJ aggregates the sexual abuse data which culminates into an annual report. The agency
provides DOJ with data as requested.
115.387 (b): The facility collects and maintains data in accordance with directives by FDJJ and FDJJ
aggregates the sexual abuse data which culminates into an annual report. A standardized instrument
and specific guidelines and definitions are used to assist in identifying the data. The PREA compliance
manager shared a copy of the monthly report. FDJJ has a data base that captures all allegations of
sexual abuse or sexual harassment and tracks the investigations as soon as an allegation is sent to the
CCC.
115.387 (c): The format used for FDJJ facilities and contractors capture the information required to
complete the most recent version of the Survey of Sexual Violence conducted by the U. S. Department
of Justice (DOJ).
115.387 (d): The facility maintains and collects various types of identified data and related documents
regarding PREA. The facility collects and maintains data in accordance with Policy directives and FDJJ
and aggregates the data which culminates into an annual report. FDJJ also shall obtain incident-based
and aggregated data from every private facility with which it contracts for the confinement of its
residents.
115.387 (e): WPBYA is a private facility that does not contract with other facilities to house residents.
115.387 (f): WPBYA policy mandates that upon request, WPBYA shall provide all such data from the
previous calendar year to the Department of Justice no later than June 30. A request was not made for
the previous calendar year.
Compliance was determined by reviewing data collections for preceding three years, review of FDJJ
Policies and interview with the PREA coordinator, facility administrator and FDJJ agency head,
Standard 115.388: Data review for corrective action
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.388 (a)
▪ Does the agency review data collected and aggregated pursuant to § 115.387 in order to
assess and improve the effectiveness of its sexual abuse prevention, detection, and response
policies, practices, and training, including by: Identifying problem areas? ☒ Yes ☐ No
PREA Audit Report – v7 Page 119 of 125 West Palm Beach Youth Academy
▪ Does the agency review data collected and aggregated pursuant to § 115.387 in order to
assess and improve the effectiveness of its sexual abuse prevention, detection, and response
policies, practices, and training, including by: Taking corrective action on an ongoing basis?
☒Yes ☐ No
▪ Does the agency review data collected and aggregated pursuant to § 115.387 in order to
assess and improve the effectiveness of its sexual abuse prevention, detection, and response
policies, practices, and training, including by: Preparing an annual report of its findings and
corrective actions for each facility, as well as the agency as a whole? ☒ Yes ☐ No
115.388 (b)
▪ Does the agency’s annual report include a comparison of the current year’s data and corrective
actions with those from prior years and provide an assessment of the agency’s progress in
addressing sexual abuse ☒ Yes ☐ No
115.388 (c)
▪ Is the agency’s annual report approved by the agency head and made readily available to the
public through its website or, if it does not have one, through other means? ☒ Yes ☐ No
115.388 (d)
▪ Does the agency indicate the nature of the material redacted where it redacts specific material
from the reports when publication would present a clear and specific threat to the safety and
security of a facility? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed
for compliance with this standard.
FDJJ Policy 1919 Prison Rape Elimination Act (PREA)
Annual Reports
PREA Audit Report – v7 Page 120 of 125 West Palm Beach Youth Academy
WPBYA Policy 5.23 – Data Collection
115.388 (a): FDJJ Policy 1919 Prison Rape Elimination Act (PREA) policy recognizes the purpose of
conducting annual reports and annual PREA assessments are to review data collected and aggregated
pursuant to § 115.387 in order to assess and improve the effectiveness of its sexual abuse prevention,
detection, and response policies, practices, and training, including by: Identifying problem areas to
assess and improve the effectiveness of its sexual abuse prevention, detection, and response policies,
practices, and training, including by taking corrective action on an ongoing basis. Further to assess and
improve the effectiveness of its sexual abuse prevention, detection, and response policies, practices,
and training, including by preparing an annual report of its findings and corrective actions for each
facility, as well as the agency as a whole.
115.388 (b): A review of the annual reports for the last 4 years included a comparison of the current
year’s data and corrective actions with those from prior years and provide an assessment of the
agency’s progress in addressing sexual abuse.
115.388 (c): The annual report is reviewed by PREA coordinator, his supervisor and agency
administrative staff and signed by the Agency Head. Compliance was determined by the PREA policy
and website review.
115.388 (d): FDJJ policy 1919 indicates that all information that is placed on the website will not
include personal identifies The annual report has been reviewed and the report is accessible to the
public through the facility’s website. There are no personal identifiers on the annual report.
Compliance was determined by reviewing data collections for preceding three years and review of FDJJ
website.
Standard 115.389: Data storage, publication, and destruction
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.389 (a)
▪ Does the agency ensure that data collected pursuant to § 115.387 are securely retained?
☒ Yes ☐ No
115.389 (b)
▪ Does the agency make all aggregated sexual abuse data, from facilities under its direct control
and private facilities with which it contracts, readily available to the public at least annually
through its website or, if it does not have one, through other means? ☒ Yes ☐ No
115.389 (c)
▪ Does the agency remove all personal identifiers before making aggregated sexual abuse data
publicly available? ☒ Yes ☐ No
PREA Audit Report – v7 Page 121 of 125 West Palm Beach Youth Academy
115.389 (d)
▪ Does the agency maintain sexual abuse data collected pursuant to § 115.387 for at least 10
years after the date of the initial collection, unless Federal, State, or local law requires
otherwise? ☒ Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
The following polices, directives, memorandum and agency or facility supplements were reviewed for
compliance with this standard.
FDJJ Policy 1919 Prison Rape Elimination Act (PREA)
Annual Report
115.389 (a)(b): DJJ 909 Data Collection and Review requires that data be collected and securely retained for 10
years. The aggregated sexual abuse data was reviewed, and all personal identifiers are removed. The website
included State and privately operated facilities. Compliance was determined by review of the website and
interview with the agency PREA coordinator.
AUDITING AND CORRECTIVE ACTION
Standard 115.401: Frequency and scope of audits
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.401 (a)
▪ During the prior three-year audit period, did the agency ensure that each facility operated by the
agency, or by a private organization on behalf of the agency, was audited at least once? (Note:
The response here is purely informational. A "no" response does not impact overall compliance
with this standard.) ☒ Yes ☐ No
PREA Audit Report – v7 Page 122 of 125 West Palm Beach Youth Academy
115.401 (b)
▪ Is this the first year of the current audit cycle? (Note: a “no” response does not impact overall
compliance with this standard.) ☐ Yes ☒ No
▪ If this is the second year of the current audit cycle, did the agency ensure that at least one-third
of each facility type operated by the agency, or by a private organization on behalf of the
agency, was audited during the first year of the current audit cycle? (N/A if this is not the
second year of the current audit cycle.) ☐ Yes ☐ No ☒ NA
▪ If this is the third year of the current audit cycle, did the agency ensure that at least two-thirds of
each facility type operated by the agency, or by a private organization on behalf of the agency,
were audited during the first two years of the current audit cycle? (N/A if this is not the third year
of the current audit cycle.) ☒ Yes ☐ No ☐ NA
115.401 (h)
▪ Did the auditor have access to, and the ability to observe, all areas of the audited facility?
☒ Yes ☐ No
115.401 (i)
▪ Was the auditor permitted to request and receive copies of any relevant documents (including
electronically stored information)? ☒ Yes ☐ No
115.401 (m)
▪ Was the auditor permitted to conduct private interviews with residents? ☒ Yes ☐ No
115.401 (n)
▪ Were residents permitted to send confidential information or correspondence to the auditor in
the same manner as if they were communicating with legal counsel? ☒Yes ☐ No
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒ Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
PREA Audit Report – v7 Page 123 of 125 West Palm Beach Youth Academy
West Palm Beach Youth Academy meets the requirements of this standard based upon the following
evidence: Since August 20, 2013, FDJJ has ensured one-third of all operated detention centers and all
contracted residential facilities have been audited as evidenced by the Final Audit reports provided on
the Agency’s website. The Auditor was provided complete access to the facility and observed all areas
of the facility’s buildings and grounds. Additionally, all relevant documents were provided upon
request. The facility made space available for private staff and resident interviews. Residents were
provided information on the “Notice of the Auditor’s Onsite Visit” regarding how to send confidential
information to the Auditor. No correspondence was received by the Auditor.
Standard 115.403: Audit contents and findings
All Yes/No Questions Must Be Answered by the Auditor to Complete the Report
115.403 (f)
▪ The agency has published on its agency website, if it has one, or has otherwise made publicly
available, all Final Audit Reports. The review period is for prior audits completed during the past
three years PRECEDING THIS AGENCY AUDIT. The pendency of any agency appeal pursuant
to 28 C.F.R. § 115.405 does not excuse noncompliance with this provision. (N/A if there have
been no Final Audit Reports issued in the past three years, or in the case of single facility
agencies that there has never been a Final Audit Report issued.) ☒ Yes ☐ No ☐ NA
Auditor Overall Compliance Determination
☐
Exceeds Standard (Substantially exceeds requirement of standards)
☒
Meets Standard (Substantial compliance; complies in all material ways with the
standard for the relevant review period)
☐
Does Not Meet Standard (Requires Corrective Action)
Instructions for Overall Compliance Determination Narrative
The narrative below must include a comprehensive discussion of all the 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 does
not meet the standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
This is the third PREA audit for this facility. The previous audits were conducted in 6/23/2016 and
5/21/2019. Both audits were located on the agency website and were reviewed by the auditor.
AUDITOR CERTIFICATION
PREA Audit Report – v7 Page 124 of 125 West Palm Beach Youth Academy
I certify that:
☒ The contents of this report are accurate to the best of my knowledge.
☒ No conflict of interest exists with respect to my ability to conduct an audit of the
agency under review, and
☒ I have not included in the final report any personally identifiable information (PII)
about any resident or staff member, except where the names of administrative
personnel are specifically requested in the report template.
Auditor Instructions:
Type your full name in the text box below for Auditor Signature. This will function as your official
electronic signature. Auditors must deliver their final report to the PREA Resource Center as a
searchable PDF format to ensure accessibility to people with disabilities. Save this report document
into a PDF format prior to submission.1 Auditors are not permitted to submit audit reports that have
been scanned.2 See the PREA Auditor Handbook for a full discussion of audit report formatting
requirements.
Robert Manville March 9, 2022
Auditor Signature Date
1 See additional instructions here: https://support.office.com/en-us/article/Save-or-convert-to-PDF-d85416c5-7d77-4fd6-
a216-6f4bf7c7c110 .
2 See PREA Auditor Handbook, Version 1.0, August 2017; Pages 68-69.
PREA Audit Report – v7 Page 125 of 125 West Palm Beach Youth Academy

source: DJJ

pdf_url: https://www.djj.state.fl.us/content/download/299785/file/Florida_West Palm Beach Youth Academy_Year3Cycle3.pdf?version=1

program_name_raw: West Palm Beach Youth Academy

cycle: Year 3 Cycle 3