state: FL

facility_name: Britt Technical Youth Academy

summary: PREA - Year 1 Cycle 5

raw_content:
PREA Facility Audit Report: Final
Name of Facility: Britt Technical Youth Academy
Facility Type: Juvenile
Date Interim Report Submitted: NA
Date Final Report Submitted: 01/19/2026
Auditor Certification
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.
I have not included in the final report any personally identifiable information (PII)
about any inmate/resident/detainee or staff member, except where the names of
administrative personnel are specifically requested in the report template.
Auditor Full Name as Signed: Robert Manville Date of Signature: 01/19/2026
AUDITOR INFORMATION
Auditor name: Manville, Robert
Email: robertmanville9@gmail.com
Start Date of On- 01/05/2026
Site Audit:
End Date of On-Site 01/06/2026
Audit:
FACILITY INFORMATION
Facility name: Britt Technical Youth Academy
Facility physical 3001 26th Avenue South, St. Petersburg, Florida - 33712
address:
Facility mailing
address:
Primary Contact
Name: Janus Pierre
Email Address: jpierre@waynehalfway.com
Telephone Number: 7868620359
Superintendent/Director/Administrator
Name: Janus Pierre
Email Address: jpierre@waynehalfway.com
Telephone Number: 7868620359
Facility PREA Compliance Manager
Name: Janus Pierre
Email Address: Jpierre@waynehalfway.com
Telephone Number: 786-862-0359
Name: Amber Veaunt
Email Address: aveaunt@waynehalfway.com
Telephone Number: 352-428-7859
Name: Deziree Fulcher
Email Address: dfulcher@waynehalfway.com
Telephone Number: (941) 587-0063
Facility Health Service Administrator On-Site
Name: Leilani Huggins
Email Address: lhuggins@waynehalfway.com
Telephone Number: 216-240-2429
Facility Characteristics
Designed facility capacity: 24
Current population of facility: 23
Average daily population for the past 12 24
months:
Has the facility been over capacity at any No
point in the past 12 months?
What is the facility’s population Men/boys
designation?
Age range of population: 16-21
Facility security levels/resident custody Moderate-risk Residential
levels:
Number of staff currently employed at the 37
facility who may have contact with
residents:
Number of individual contractors who have 0
contact with residents, currently
authorized to enter the facility:
Number of volunteers who have contact 3
with residents, currently authorized to
enter the facility:
AGENCY INFORMATION
Name of agency: Wayne Halfway House, Inc.
Governing authority
or parent agency (if
applicable):
Physical Address: 106 Public Square South, Waynesboro, Tennessee - 38485
Mailing Address:
Telephone number:
Agency Chief Executive Officer Information:
Name:
Email Address:
Telephone Number:
Agency-Wide PREA Coordinator Information
Name: Kelly Banks Email Address: kbanks@waynehalfway.com
Facility AUDIT FINDINGS
Summary of Audit Findings
The OAS automatically populates the number and list of Standards exceeded, the number of
Standards met, and the number and list of Standards not met.
Auditor Note: In general, no standards should be found to be "Not Applicable" or "NA." A
compliance determination must be made for each standard. In rare instances where an auditor
determines that a standard is not applicable, the auditor should select "Meets Standard” and
include a comprehensive discussion as to why the standard is not applicable to the facility being
audited.
Number of standards exceeded:
5
• 115.311 - Zero tolerance of sexual
abuse and sexual harassment; PREA
coordinator
• 115.321 - Evidence protocol and
forensic medical examinations
• 115.335 - Specialized training: Medical
and mental health care
• 115.361 - Staff and agency reporting
duties
• 115.387 - Data collection
Number of standards met:
38
Number of standards not met:
0
POST-AUDIT REPORTING INFORMATION
Please note: Question numbers may not appear sequentially as some
questions are omitted from the report and used solely for internal
reporting purposes.
GENERAL AUDIT INFORMATION
On-site Audit Dates
1. Start date of the onsite portion of the 2026-01-05
audit:
2. End date of the onsite portion of the 2026-01-06
audit:
Outreach
10. Did you attempt to communicate Yes
with community-based organization(s)
or victim advocates who provide
No
services to this facility and/or who may
have insight into relevant conditions in
the facility?
a. Identify the community-based Crisis Center of Tampa Bay
organization(s) or victim advocates with
whom you communicated:
AUDITED FACILITY INFORMATION
14. Designated facility capacity: 24
15. Average daily population for the past 24
12 months:
16. Number of inmate/resident/detainee 1
housing units:
17. Does the facility ever hold youthful Yes
inmates or youthful/juvenile detainees?
No
Not Applicable for the facility type audited
(i.e., Community Confinement Facility or
Juvenile Facility)
Audited Facility Population Characteristics on Day One of the Onsite
Portion of the Audit
Inmates/Residents/Detainees Population Characteristics on Day One of the Onsite Portion
of the Audit
23. Enter the total number of inmates/ 16
residents/detainees in the facility as of
the first day of onsite portion of the
audit:
25. Enter the total number of inmates/ 0
residents/detainees with a physical
disability in the facility as of the first
day of the onsite portion of the audit:
26. Enter the total number of inmates/ 0
residents/detainees with a cognitive or
functional disability (including
intellectual disability, psychiatric
disability, or speech disability) in the
facility as of the first day of the onsite
portion of the audit:
27. Enter the total number of inmates/ 0
residents/detainees who are Blind or
have low vision (visually impaired) in the
facility as of the first day of the onsite
portion of the audit:
28. Enter the total number of inmates/ 0
residents/detainees who are Deaf or
hard-of-hearing in the facility as of the
first day of the onsite portion of the
audit:
29. Enter the total number of inmates/ 0
residents/detainees who are Limited
English Proficient (LEP) in the facility as
of the first day of the onsite portion of
the audit:
30. Enter the total number of inmates/ 0
residents/detainees who identify as
lesbian, gay, or bisexual in the facility as
of the first day of the onsite portion of
the audit:
31. Enter the total number of inmates/ 0
residents/detainees who identify as
transgender or intersex in the facility as
of the first day of the onsite portion of
the audit:
32. Enter the total number of inmates/ 0
residents/detainees who reported sexual
abuse in the facility as of the first day of
the onsite portion of the audit:
33. Enter the total number of inmates/ 0
residents/detainees who disclosed prior
sexual victimization during risk
screening in the facility as of the first
day of the onsite portion of the audit:
34. Enter the total number of inmates/ 0
residents/detainees who were ever
placed in segregated housing/isolation
for risk of sexual victimization in the
facility as of the first day of the onsite
portion of the audit:
35. Provide any additional comments No text provided.
regarding the population characteristics
of inmates/residents/detainees in the
facility as of the first day of the onsite
portion of the audit (e.g., groups not
tracked, issues with identifying certain
populations):
Staff, Volunteers, and Contractors Population Characteristics on Day One of the Onsite
Portion of the Audit
36. Enter the total number of STAFF, 37
including both full- and part-time staff,
employed by the facility as of the first
day of the onsite portion of the audit:
37. Enter the total number of 2
VOLUNTEERS assigned to the facility as
of the first day of the onsite portion of
the audit who have contact with
inmates/residents/detainees:
38. Enter the total number of 1
CONTRACTORS assigned to the facility as
of the first day of the onsite portion of
the audit who have contact with
inmates/residents/detainees:
39. Provide any additional comments No text provided.
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:
INTERVIEWS
Inmate/Resident/Detainee Interviews
Random Inmate/Resident/Detainee Interviews
40. Enter the total number of RANDOM 10
INMATES/RESIDENTS/DETAINEES who
were interviewed:
41. Select which characteristics you Age
considered when you selected RANDOM
INMATE/RESIDENT/DETAINEE Race
interviewees: (select all that apply)
Ethnicity (e.g., Hispanic, Non-Hispanic)
Length of time in the facility
Housing assignment
Gender
Other
None
42. How did you ensure your sample of I interview residents from housing assignment
RANDOM INMATE/RESIDENT/DETAINEE and program participation.
interviewees was geographically
diverse?
43. Were you able to conduct the Yes
minimum number of random inmate/
resident/detainee interviews?
No
44. Provide any additional comments No text provided.
regarding selecting or interviewing
random inmates/residents/detainees
(e.g., any populations you oversampled,
barriers to completing interviews,
barriers to ensuring representation):
Targeted Inmate/Resident/Detainee Interviews
45. Enter the total number of TARGETED 0
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. 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".
47. Enter the total number of interviews 0
conducted with inmates/residents/
detainees with a physical disability using
the "Disabled and Limited English
Proficient Inmates" protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. Facility Director, Facility PREA
information obtained from the PAQ; Compliance Manager. I also asked the staff
documentation reviewed onsite; and and the youth on the tour whether there were
discussions with staff and other inmates/ any disabled youth at the center. I observed
residents/detainees). the residents in the classroom, during meals,
and during interviews.
48. Enter the total number of interviews 0
conducted with inmates/residents/
detainees with a cognitive or functional
disability (including intellectual
disability, psychiatric disability, or
speech disability) using the "Disabled
and Limited English Proficient Inmates"
protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. Facility Director, Facility PREA
information obtained from the PAQ; Compliance Manager. I also asked the
documentation reviewed onsite; and education staff if any of the youth were in
discussions with staff and other inmates/ special education or had any learning
residents/detainees). disabilities. The teacher indicated that all but
two resident had their high school diploma or
GED. At the time of the tour, there were two
youth in her classroom. One interviewed
indicated he was preparing to take his GED
examination. The other youth indicated he
was completing his last module to get his high
school diploma.
49. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who are Blind or have low
vision (i.e., visually impaired) using the
"Disabled and Limited English Proficient
Inmates" protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. Facility Director, Facility PREA
information obtained from the PAQ; Compliance Manager. I also asked the staff
documentation reviewed onsite; and and the youth on the tour whether there were
discussions with staff and other inmates/ any youth who were low vision.
residents/detainees).
50. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who are Deaf or hard-of-
hearing using the "Disabled and Limited
English Proficient Inmates" protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. Facility Director, Facility PREA
information obtained from the PAQ; Compliance Manager. I also asked the staff
documentation reviewed onsite; and and the youth on the tour whether there were
discussions with staff and other inmates/ any residents that were hard of hearing.
residents/detainees).
51. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who are Limited English
Proficient (LEP) using the "Disabled and
Limited English Proficient Inmates"
protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. Facility Director, Facility PREA
information obtained from the PAQ; Compliance Manager. I spoke with each youth
documentation reviewed onsite; and at the center formally and informally. All of
discussions with staff and other inmates/ the residents spoke English. I asked the
residents/detainees). resident whether anyone in the day room
didn't speak English. All indicated they spoke
English.
52. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who identify as lesbian, gay,
or bisexual using the "Transgender and
Intersex Inmates; Gay, Lesbian, and
Bisexual Inmates" protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. mental health staff, facility
information obtained from the PAQ; director, and PREA compliance manager.
documentation reviewed onsite; and
discussions with staff and other inmates/
residents/detainees).
53. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who identify as transgender
or intersex using the "Transgender and
Intersex Inmates; Gay, Lesbian, and
Bisexual Inmates" protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. mental health staff, facility
information obtained from the PAQ; director, and PREA compliance manager.
documentation reviewed onsite; and
discussions with staff and other inmates/
residents/detainees).
54. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who reported sexual abuse in
this facility using the "Inmates who
Reported a Sexual Abuse" protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. mental health staff, facility
information obtained from the PAQ; director, and PREA compliance manager. I
documentation reviewed onsite; and reviewed the PAQ and the VSAB for each
discussions with staff and other inmates/ youth at the center and interviewed the
residents/detainees). medical staff. mental health staff, facility
director, and PREA compliance manager.
55. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who disclosed prior sexual
victimization during risk screening using
the "Inmates who Disclosed Sexual
Victimization during Risk Screening"
protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. mental health staff, facility
information obtained from the PAQ; director, and PREA compliance manager.
documentation reviewed onsite; and
discussions with staff and other inmates/
residents/detainees).
56. Enter the total number of interviews 0
conducted with inmates/residents/
detainees who are or were ever placed
in segregated housing/isolation for risk
of sexual victimization using the
"Inmates Placed in Segregated Housing
(for Risk of Sexual Victimization/Who
Allege to have Suffered Sexual Abuse)"
protocol:
a. Select why you were unable to Facility said there were "none here" during
conduct at least the minimum required the onsite portion of the audit and/or the
number of targeted inmates/residents/ facility was unable to provide a list of these
detainees in this category: inmates/residents/detainees.
The inmates/residents/detainees in this
targeted category declined to be interviewed.
b. Discuss your corroboration strategies I reviewed the PAQ and the VSAB for each
to determine if this population exists in youth at the center and interviewed the
the audited facility (e.g., based on medical staff. mental health staff, facility
information obtained from the PAQ; director, and PREA compliance manager. The
documentation reviewed onsite; and center does not have an area to separate
discussions with staff and other inmates/ youth, and the center director, agency head,
residents/detainees). and agency PREA coordinator all indicated
that Wayne's Halfway House does not permit
the use of segregation.
57. Provide any additional comments In conversation with the Florida PREA
regarding selecting or interviewing coordinator, a staff member in Central Office
targeted inmates/residents/detainees attempts to identify youth for this specialized
(e.g., any populations you oversampled, program. The program accepts youth who
barriers to completing interviews): have completed or are nearing completion of
their high school education. Youth are then
offered the opportunity to attend Britt
Technical College for six months to continue
their trade or education after they are
released from Florida DJJ.
Staff, Volunteer, and Contractor Interviews
Random Staff Interviews
58. Enter the total number of RANDOM 13
STAFF who were interviewed:
59. Select which characteristics you Length of tenure in the facility
considered when you selected RANDOM
STAFF interviewees: (select all that Shift assignment
apply)
Work assignment
Rank (or equivalent)
Other (e.g., gender, race, ethnicity,
languages spoken)
None
60. Were you able to conduct the Yes
minimum number of RANDOM STAFF
interviews?
No
61. Provide any additional comments No text provided.
regarding selecting or interviewing
random staff (e.g., any populations you
oversampled, barriers to completing
interviews, barriers to ensuring
representation):
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 information would satisfy multiple specialized staff interview requirements.
62. Enter the total number of staff in a 12
SPECIALIZED STAFF role who were
interviewed (excluding volunteers and
contractors):
63. Were you able to interview the Yes
Agency Head?
No
64. Were you able to interview the Yes
Warden/Facility Director/Superintendent
or their designee?
No
65. Were you able to interview the PREA Yes
Coordinator?
No
66. Were you able to interview the PREA Yes
Compliance Manager?
No
NA (NA if the agency is a single facility
agency or is otherwise not required to have a
PREA Compliance Manager per the Standards)
67. Select which SPECIALIZED STAFF Agency contract administrator
roles were interviewed as part of this
audit from the list below: (select all that Intermediate or higher-level facility staff
apply) 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)
Education and program staff who work with
youthful inmates (if applicable)
Medical staff
Mental health staff
Non-medical staff involved in cross-gender
strip or visual searches
Administrative (human resources) staff
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
If "Other," provide additional specialized I interviewed the Florida and Wayne's Halfway
staff roles interviewed: House agency head and PREA coordinator
68. Did you interview VOLUNTEERS who Yes
may have contact with inmates/
residents/detainees in this facility?
No
69. Did you interview CONTRACTORS Yes
who may have contact with inmates/
residents/detainees in this facility?
No
a. Enter the total number of 1
CONTRACTORS who were interviewed:
b. Select which specialized CONTRACTOR Security/detention
role(s) were interviewed as part of this
audit from the list below: (select all that Education/programming
apply)
Medical/dental
Food service
Maintenance/construction
Other
70. Provide any additional comments No text provided.
regarding selecting or interviewing
specialized staff.
SITE REVIEW AND DOCUMENTATION SAMPLING
Site Review
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: As you are conducting the site
review, you must document your tests of critical functions, important information gathered
through observations, and any issues identified with facility practices. The information you
collect through the site review is a crucial part of the evidence you will analyze as part of your
compliance determinations and will be needed to complete your audit report, including the Post-
Audit Reporting Information.
71. Did you have access to all areas of Yes
the facility?
No
Was the site review an active, inquiring process that included the following:
72. Observations of all facility practices Yes
in accordance with the site review
component of the audit instrument (e.g.,
No
signage, supervision practices, cross-
gender viewing and searches)?
73. Tests of all critical functions in the Yes
facility in accordance with the site
review component of the audit
No
instrument (e.g., risk screening process,
access to outside emotional support
services, interpretation services)?
74. Informal conversations with inmates/ Yes
residents/detainees during the site
review (encouraged, not required)?
No
75. Informal conversations with staff Yes
during the site review (encouraged, not
required)?
No
76. Provide any additional comments The Brit Technical Youth Academy is located in
regarding the site review (e.g., access to St. Petersburg, Florida, and is operated by
areas in the facility, observations, tests Wayne’s Halfway House Inc. Incorporated
of critical functions, or informal through a contract with the Florida
conversations). Department of Juvenile Justice (DJJ). It is a
24-bed residential program that serves male
juvenile offenders aged 17 to 20. The facility
has a substance abuse program, however it
main mission is to assist older youth in
transition back into daily life. Youth either
have that high school diploma, GED, or are
close to completion of one of these programs.
At the time of the audit, only two youth had
not completed these programs.
The Auditor was escorted on the site review of
the facility by the facility director.
The facility consists of a main building. There
are 2 module units outside the main building.
One is being utilized to provide education.
The other module unit is being refurbished.
There is a sign-in and search process for
visitors conducted upon entering the facility
at the main building. The site review included
observations of the youth and staff
interactions; a tour of buildings and grounds;
and informal interviews during staff
encounters.
There are 12 double-occupancy rooms in the
housing unit.
During the tour, staff members were observed
providing direct supervision and actively
engaging with the residents. Random staff,
specialized staff, and residents were
interviewed during the on-site audit. The
interviews of both staff and residents revealed
their general knowledge of PREA and the
related procedures. The staff members
interviewed were aware of the zero-tolerance
policy against sexual assault and sexual
harassment and understood their duties and
responsibilities regarding PREA. The residents
interviewed demonstrated their knowledge of
what PREA means and how to report sexual
assault and sexual harassment.
During the site review, the posted notices
were observed to be strategically placed and
accessible to residents, staff, visitors, and
contractors during this time period. The
notices contained the Auditor’s contact
information and information regarding the
confidentiality of information. No
correspondence was received during any
phase of the audit, and the facility has a
process in place to ensure that residents'
confidential communications are protected.
Verification of the postings was conducted
through pictures emailed to the Auditor,
observations during the comprehensive site
review, and interviews with residents and
staff.
There are signs posted throughout the facility
regarding PREA information and materials
that are available and accessible, containing
contact information of the assisting agencies
for reporting allegations and seeking help
regarding sexual abuse and sexual
harassment. The posted information includes
instructions on accessing assistance,
Grievance and Request to Speak Forms, and
safety information regarding sexual abuse
and sexual harassment. The Request to Speak
Form allows residents to request formally, in
writing, to speak with various staff members
at different levels of the organization.
Specifically, residents may ask to talk to the
center Director, Assistant Facility
Administrator, Clinical Director, Therapist, and
Case Management staff. Additionally, no staff
member can deny a resident’s use of a
telephone to access the Florida abuse
reporting hotlines or to request advocacy
services.
Signage was observed on doors indicating
that youth are not allowed in the room/area,
or are allowed only with staff supervision.
Observation of community bathrooms
revealed that shower stall openings have
shower curtains to provide residents with
privacy when showering. The shower
procedures are printed and posted at the
entrance of each bathroom. Also, residents
have appropriate toilet covers to ensure
privacy when using the toilet. Observation of
surveillance system monitors revealed that
cameras do not capture showers, toilets, or
the interiors of residents’ rooms.
The posted signage includes instructions for
accessing the 24/7 hotlines to report
allegations and request advocacy services for
the Crisis Center in Tramp Bay, Florida.
The Crisis Center of Tampa Bay was
contacted, and the auditor had several
conversations with its staff. The center and
BTYA were working to formalize an MOU for
the services they are currently providing.
Post-completion of the follow-up calls, the
center has signed an MOU with the Crisis
Center.
Residents participate in vocational and
educational programming provided by Britt
Technical College and in recreation activities.
During the audit, two residents were receiving
education from a module unit located next to
the main building. Five residents were out of
the building attending the Britt Technical
College. The auditor was allowed to speak
with the youth in the multipurpose room when
they were on the computer or playing video
games. All residents were engaged, knew
about PREA, and were happy to share their
knowledge with the auditor. All residents
indicated they were safe at this center.
Signage on doors indicated that youth are not
allowed in the room/area or are allowed
only with staff supervision.
Observation of community bathrooms
revealed that shower stall openings have
shower curtains to provide residents with
privacy when showering. The shower
procedures are printed and posted at the
entrance of each bathroom. There are two
hotlines available to residents—the
Department of Children and Family Services
and DJJ central communication center. The
auditor called all the above numbers from a
telephone that is in a common area. All
telephone calls were answered. The CCC
received a call to the facility administrator
with what would have been a case number.
The Child Abuse Hotline staff indicated they
would notify the local Department of Children
and Families and local law enforcement upon
receiving a call. Both parties indicated that
residents and family members can call the
hotline anonymously.
The auditor called the Crisis Center and was
connected to an emotional support staff
member.
Residents were observed interacting with staff
under staff’s direct supervision during dinner
time, leisure activities, and classroom
education activities. Residents were
interviewed during the tour and, additionally,
during the auditor’s recreation time when the
auditor went into the yard and talked
informally with the residents. All residents
reported feelingspok safe at the facility.
Residents knew the facility administrator and
indicated he speaks with them daily, including
most weekends.
Five staff members were spoken with during
the tour. Each was engaging with the auditor.
Several staff members are feeling. The DJJ
Central Communication Center has been at
the facility since it opened and has provided a
historical perspective on how the facility has
implemented PREA.
A review of logbooks and records revealed
documentation of safety and PREA rounds.
The Facility Administrator makes continuous
rounds throughout the center. Staff announce
their presence before entering a dormitory
housing residents of the opposite gender.
Florida DJJ has updated the comprehensive
video and has added an orientation video to
be shown to residents when they first come to
the center. The PAQ requires that centers
utilize the video. The center had a
comprehensive program that included
reviewing the handbook and poster with the
residents. A corrective action plan was
implemented, and all youth were shown the
video. The video has been incorporated into
the intake process. The center provided a
sign-in sheet of all residents, indicating they
had seen the video and understood the
information provided in the video
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.
77. In addition to the proof Yes
documentation selected by the agency
or facility and provided to you, did you
No
also conduct an auditor-selected
sampling of documentation?
78. Provide any additional comments The auditor identified the following personnel
regarding selecting additional file documents that were uploaded by the
documentation (e.g., any documentation center
you oversampled, barriers to selecting Three complete background checks
additional documentation, etc.). Three PREA questionnaires for new hires
Three PREA questionnaires for promotions DJJ
application for employment
Three child registry checks
Three NCIC verification
The auditor requested copies of specific
residents, including the following
8 PREA Vulnerability Screening, including any
reassessments
12 Orientation and comprehensive education
for the Residents
Sign-in sheet of all resident that were shown
the FDJJ videos
8 Staff Training Files
12 Unannounced rounds.
The center also uploaded some VSAB and
Resident training files
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.
79. Total number of SEXUAL ABUSE allegations and investigations overview during
the 12 months preceding the audit, by incident type:
# of allegations
# of
# of that had both
sexual # of criminal
administrative criminal and
abuse investigations
investigations administrative
allegations
investigations
Inmate- 0 0 0 0
on-
inmate
sexual
abuse
Staff- 0 0 0 0
on-
inmate
sexual
abuse
Total 0 0 0 0
80. Total number of SEXUAL HARASSMENT allegations and investigations overview
during the 12 months preceding the audit, by incident type:
# of allegations
# of sexual # of that had both
# of criminal
harassment administrative criminal and
investigations
allegations investigations administrative
investigations
Inmate-on- 0 0 0 0
inmate
sexual
harassment
Staff-on- 0 0 0 0
inmate
sexual
harassment
Total 0 0 0 0
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.
81. Criminal SEXUAL ABUSE investigation outcomes during the 12 months preceding
the audit:
Referred Indicted/
Convicted/
Ongoing for Court Case Acquitted
Adjudicated
Prosecution Filed
Inmate-on- 0 0 0 0 0
inmate sexual
abuse
Staff-on- 0 0 0 0 0
inmate sexual
abuse
Total 0 0 0 0 0
82. Administrative SEXUAL ABUSE investigation outcomes during the 12 months
preceding the audit:
Ongoing Unfounded Unsubstantiated Substantiated
Inmate-on-inmate 0 0 0 0
sexual abuse
Staff-on-inmate 0 0 0 0
sexual abuse
Total 0 0 0 0
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.
83. Criminal SEXUAL HARASSMENT investigation outcomes during the 12 months
preceding the audit:
Indicted/
Referred
Court Convicted/
Ongoing for Acquitted
Case Adjudicated
Prosecution
Filed
Inmate-on- 0 0 0 0 0
inmate sexual
harassment
Staff-on- 0 0 0 0 0
inmate sexual
harassment
Total 0 0 0 0 0
84. Administrative SEXUAL HARASSMENT investigation outcomes during the 12
months preceding the audit:
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
Sexual Abuse and Sexual Harassment Investigation Files Selected for
Review
Sexual Abuse Investigation Files Selected for Review
85. Enter the total number of SEXUAL 0
ABUSE investigation files reviewed/
sampled:
a. Explain why you were unable to The center became operational in August
review any sexual abuse investigation 2024. They have had no allegations of sexual
files: abuse or sexual harassment. This was
confirmed by review of the Florida 2024-2025
annual report, interviews with the Florida
PREA coordinator and the OIG Chief.
86. Did your selection of SEXUAL ABUSE Yes
investigation files include a cross-
section of criminal and/or administrative No
investigations by findings/outcomes?
NA (NA if you were unable to review any
sexual abuse investigation files)
Inmate-on-inmate sexual abuse investigation files
87. Enter the total number of INMATE- 0
ON-INMATE SEXUAL ABUSE investigation
files reviewed/sampled:
88. Did your sample of INMATE-ON- Yes
INMATE SEXUAL ABUSE investigation
files include criminal investigations? No
NA (NA if you were unable to review any
inmate-on-inmate sexual abuse investigation
files)
89. Did your sample of INMATE-ON- Yes
INMATE SEXUAL ABUSE investigation
files include administrative No
investigations?
NA (NA if you were unable to review any
inmate-on-inmate sexual abuse investigation
files)
Staff-on-inmate sexual abuse investigation files
90. Enter the total number of STAFF-ON- 0
INMATE SEXUAL ABUSE investigation
files reviewed/sampled:
91. Did your sample of STAFF-ON-INMATE Yes
SEXUAL ABUSE investigation files
include criminal investigations? No
NA (NA if you were unable to review any
staff-on-inmate sexual abuse investigation
files)
92. Did your sample of STAFF-ON-INMATE Yes
SEXUAL ABUSE investigation files
include administrative investigations? No
NA (NA if you were unable to review any
staff-on-inmate sexual abuse investigation
files)
Sexual Harassment Investigation Files Selected for Review
93. Enter the total number of SEXUAL 0
HARASSMENT investigation files
reviewed/sampled:
a. Explain why you were unable to The center became operational in August
review any sexual harassment 2024. They have had no allegations of sexual
investigation files: abuse or sexual harassment. This was
confirmed by review of the Florida 2024-2025
annual report, interviews with the Florida
PREA coordinator and the OIG Chief.
94. Did your selection of SEXUAL Yes
HARASSMENT investigation files include
a cross-section of criminal and/or No
administrative investigations by
findings/outcomes?
NA (NA if you were unable to review any
sexual harassment investigation files)
Inmate-on-inmate sexual harassment investigation files
95. Enter the total number of INMATE- 0
ON-INMATE SEXUAL HARASSMENT
investigation files reviewed/sampled:
96. Did your sample of INMATE-ON- Yes
INMATE SEXUAL HARASSMENT files
include criminal investigations? No
NA (NA if you were unable to review any
inmate-on-inmate sexual harassment
investigation files)
97. Did your sample of INMATE-ON- Yes
INMATE SEXUAL HARASSMENT
investigation files include administrative No
investigations?
NA (NA if you were unable to review any
inmate-on-inmate sexual harassment
investigation files)
Staff-on-inmate sexual harassment investigation files
98. Enter the total number of STAFF-ON- 0
INMATE SEXUAL HARASSMENT
investigation files reviewed/sampled:
99. Did your sample of STAFF-ON-INMATE Yes
SEXUAL HARASSMENT investigation files
include criminal investigations? No
NA (NA if you were unable to review any
staff-on-inmate sexual harassment
investigation files)
100. Did your sample of STAFF-ON- Yes
INMATE SEXUAL HARASSMENT
investigation files include administrative No
investigations?
NA (NA if you were unable to review any
staff-on-inmate sexual harassment
investigation files)
101. Provide any additional comments No text provided.
regarding selecting and reviewing
sexual abuse and sexual harassment
investigation files.
SUPPORT STAFF INFORMATION
DOJ-certified PREA Auditors Support Staff
102. Did you receive assistance from any Yes
DOJ-CERTIFIED PREA AUDITORS at any
point during this audit? REMEMBER: the
No
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.
Non-certified Support Staff
103. Did you receive assistance from any Yes
NON-CERTIFIED SUPPORT STAFF at any
point during this audit? REMEMBER: the
No
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.
AUDITING ARRANGEMENTS AND COMPENSATION
108. Who paid you to conduct this audit? The audited facility or its parent agency
My state/territory or county government
employer (if you audit as part of a consortium
or circular auditing arrangement, select this
option)
A third-party auditing entity (e.g.,
accreditation body, consulting firm)
Other
Identify the name of the third-party Correctional Management and
auditing entity Communications Group
Standards
Auditor Overall Determination Definitions
• Exceeds Standard
(Substantially exceeds requirement of standard)
• Meets Standard
(substantial compliance; complies in all material ways with the stand for the relevant
review period)
• Does Not Meet Standard
(requires corrective actions)
Auditor Discussion Instructions
Auditor discussion, including 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 standard. These recommendations must be included in the Final Report, accompanied by
information on specific corrective actions taken by the facility.
Zero tolerance of sexual abuse and sexual harassment; PREA
115.311
coordinator
Auditor Overall Determination: Exceeds Standard
Auditor Discussion
Evidence relied upon in deciding on compliance
FDJJ 1919 Procedure revisions Final 5.1.25.pdf
Wayne's Halfway House (WHH) Policy 2.02 Youth Orientation BTYA.doc
2.21 Educational Access Britt Technical Youth Academy BTYA
BTYA Org Chart.pdf
1.03 Provisions of an Abuse Free Environment BTYA.do
Employee Handbook.pdf
2.04 Classification Factors Procedures and Reassessment for Activities BTYA.
Wayne’s Halfway House (WHH) Org. Chart
Interview with
Agency Head PREA coordinator
PREA Compliance Manager, Facility Director
115.311 (a): The PAQ requires that an agency have a written policy mandating zero
tolerance toward all forms of sexual abuse and sexual harassment and outlining the
agency's approach to preventing, detecting, and responding to such conduct.
Wayne’s Halfway House is mandated to comply with Florida Department of Juvenile
Justice policies, procedures, and related forms.
The center provided the FDJJ Policy 1919 and WHH Policies, as well as organizational
charts.
Policy 1919 has a zero-tolerance policy for sexual abuse and sexual harassment.
This policy outlines the agency’s approach to preventing, detecting, and responding
to such conduct. This standard also requires the agency to employ or designate an
upper-level, agency-wide PREA coordinator with sufficient time and authority to
develop, implement, and oversee agency-wide efforts to comply with PREA
standards across all facilities.
The policy includes definitions of prohibited behaviors regarding sexual abuse and
sexual harassment, sanctions for those found to have participated in prohibited
behaviors, and a description of agency strategies and responses to reduce and
prevent sexual abuse and sexual harassment of residents.
All staff, volunteers, and contractors must complete training that includes the
Juvenile Detention Center Zero Policy Acknowledgement.
Policy mandates that 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. The policy outlines sanctions for those
found to have engaged in prohibited behaviors.
Policy 1919 establishes that the center, staff, residents, volunteers, contractors, or
visitors are committed to a zero-tolerance standard for incidents of sexual abuse
and sexual harassment. Residents with disabilities are afforded the same rights.
They will be provided with access to interpreters and materials to communicate with
residents with intellectual disabilities, including those with limited reading skills,
blindness, or 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
BTYA efforts to prevent, detect, and respond to sexual abuse and sexual
harassment.
WHH has developed and implemented policies to comply with PREA standards for
Juvenile Facilities. Polices include clearly defined definitions, and residents, staff,
contractor, and volunteer roles in preventing, detecting, and responding to sexual
abuse and sexual harassment.
115.311 (b)(c):
The PAQ requires that an agency employ or designate an upper-level, agency-wide
PREA coordinator with sufficient time and authority to develop, implement, and
oversee agency-wide efforts to comply with PREA standards across all facilities.
The PAQ requires that, where an agency operates more than one facility, each
facility shall designate a PREA compliance manager with sufficient time and
authority to coordinate the facility's efforts to comply with the PREA standards.
The facility provided an organizational chart and an interview with the PREA
coordinator and PREA Compliance Manager.
The Agency's organizational chart established that the PREA Coordinator reports to
the Executive VP of Administrative, Outpatient & Foster Services.
The interviewed Wayne's Halfway House PREA Coordinator stated that her
responsibility is to oversee PREA at all WHH Juvenile Facilities. She indicated that
quarterly meetings are held with the PREA Compliance Managers in the facilities.
According to the agency's organizational chart, the center’s director serves as the
PREA Compliance Manager and reports to the Chief Operational Officer.
In the interview, the compliance manager indicated he has sufficient time to do his
duties and can always rely on the district director and the agency PREA coordinator
for assistance.
Based on this analysis, the facility is substantially compliant with this provision,
and corrective action is not required.
115.312 Contracting with other entities for the confinement of residents
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations
PREA contract language
Copy of Residential Data Sheet_7.15.25.xlsx
BTYA contract
FDJJ 1919 Contract Compliance
Interview with
WHH Agency Head
WHH PREA coordinator
FDJJ PREA coordinator
Wayne's Halfway House does not contract with any other agencies to house clients.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.313 Supervision and monitoring
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations
FDJJ 1919 Contract Compliance
5.01 Youth Supervision BTYA 7.20.24.docx
Shower Procedures
5.04 Ten-Minute Checks BTYA 7.20.24.doc
Employee Handbook
3.18 Safety Planning Process for Youth BTYA.
BRITT STAFFING PLAN
Annual PREA Staffing Assessment 8/25/2025
313.313 (a)(c)€: The PAQ requires the agency shall ensure that each facility it
operates shall develop, implement, and document a staffing plan that provides for
adequate levels of staffing, and, where applicable, video monitoring, to protect
residents against sexual abuse. In calculating adequate staffing levels and
determining the need for video monitoring, facilities shall take into consideration:
(1) Generally accepted juvenile 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 unsubstantiated incidents of sexual abuse; and (11) Any other
relevant factors.
The PAQ requires that each secure juvenile facility maintain staff ratios of a
minimum of 1:8 during resident waking hours and 1:16 during resident sleeping
hours, except during limited and discrete exigent circumstances, which shall be fully
documented. Only security staff shall be included in these ratios. Any facility that,
as of the date of publication of this final rule, is not already obligated by law,
regulation, or judicial consent decree to maintain the staffing ratios outlined in this
paragraph shall have until October 1, 2017, to achieve compliance.
The PAQ requires that each secure facility implement 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. Such
policies and practices shall be implemented for both night and day shifts. Each
secure facility shall have a policy prohibiting staff from notifying other staff that
supervisory rounds are occurring, unless such an announcement is related to the
facility's legitimate operational functions.
The center provided the Staffing Plan and policies, including FDJJ policies 1919, 5.01,
and 3.18, and conducted interviews with the FDJJ PREA coordinator and facility
director.
FDJJ policy 1919 requires that staffing plans be established for each residential and
detention center facility. These plans provide for adequate levels of staffing, and,
where applicable, video monitoring, to protect youth against sexual misconduct. In
developing appropriate staffing plans and determining the need for video
monitoring for the facility, the following must be taken into consideration:
i. Generally accepted juvenile detention and residential practices;
ii. Any judicial findings of inadequacy; findings of inadequacy from Federal
investigative agencies or internal or external oversight bodies;
iii. All components of the facility’s physical plant (including “blind spots” or areas
where staff or youth may be isolated);
iv. The composition of the youth population;
v. The number and placement of supervisory staff;
vi. Institution programs occurring on a particular shift;
vii. Any applicable State or local laws, regulations, or standards;
viii. The prevalence of substantiated and unsubstantiated incidents of sexual
misconduct; and
ix. Any other relevant factors.
c. Any deviations from the staffing plan shall be fully documented.
At a minimum of once a year, each facility operated or contracted by the
Department, and in consultation with the Department’s PREA Statewide
Coordinator, shall assess, determine, and document whether adjustments are
needed to:
i. The staffing plan;
ii. Prevailing staffing patterns;
iii. The deployment of video monitoring systems and other monitoring
technologies; and
iv. The resources the facilities have available to commit to ensure adherence to
the staffing plan.
Intermediate-level or higher-level supervisors in Detention or Residential facilities,
as indicated on the facility table of organization, shall conduct and document
unannounced rounds. Unannounced rounds shall be performed more than once per
month on every shift to prevent, detect, respond to, and report sexual misconduct
allegations. These rounds shall be conducted during day and night shift hours.
Staff are prohibited from alerting other staff members that these supervisory rounds
are occurring unless such announcement is related to the legitimate operational
functions of the facility.
Policy 5.01: Britt Technical Youth Academy is a secure delinquent juvenile residential
program. Staffing shall be one staff member to eight youth (1:8) during awake hours
and one staff member to twelve youth (1:12) during non-awake hours. mandates
that Facilities develop, implement, and document an approved staffing report that
provides adequate levels of staffing and, where applicable, video monitoring to
protect youth from sexual abuse. Each time the staffing plan is not complied with,
the facility will document and justify all deviations.
The Facility Administrator and/or their designee shall track daily census information,
including, at a minimum, the total daily census count, new admissions, releases or
direct discharges, transfers, and youth temporarily away from the program.
Administrative staff may not be counted in the staff-to-youth ratio unless prior
written approval is obtained from either the Regional Director or the Assistant
Secretary. If Britt Technical Youth Academy anticipates a shortage, the Facility
Administrator will promptly contact the appropriate FL DJJ staff. Approval should not
be sought at the last minute; the Facility Administrator should review the personnel
list and staffing schedules regularly to anticipate any shortages. If approval is
granted, administrative staff may not perform any duties other than direct care and
must actively participate in sight and sound observation of the youth.
In the event of a staff shortage, the facility has a blue-dot system that identifies
staff responsible for holdovers. If necessary, the on-duty Shift Leader will remain on
until relief arrives. All employee telephone numbers will be readily available to the
Shift Supervisors in case additional staff need to be called in.
Administrators or their designees will conduct unannounced visits to verify staffing
and positioning. If a staff member becomes aware of an upcoming visit, they are
prohibited from disclosing it to any other staff member. It is imperative to the
fidelity of staffing monitoring that these rounds be unexpected.
The shift supervisors were interviewed as intermediate staff who conduct
unannounced rounds. They indicated that they conduct rounds on different shifts
each day, including weekends and holidays. These rounds are documented. They
indicated they don't tell staff when they arrive at the center or when they make
rounds. They indicated they vary the days and times.
According to the PAQ, the staffing plan is based on 24 residents.
Based on conversations with the PREA coordinator and the facility's PREA
compliance manager, it was clear that the facility reviews all areas of the center for
additional staffing or cameras, based on resident movement, to meet the
requirements of this standard. The direct care staff were observed throughout the
center during the tour.
The Auditor conducted a comprehensive facility tour of the administrative area,
education building, cottages, intake area, kitchen, and Medical Department.
Cameras were noted in all areas, including corridors except the bathrooms, showers,
and medical examination rooms. Additional cameras have been installed since the
last PREA audit.
The staffing plan provided by the facilities was the first plan under the contract for
the program, which became operational in August 2024.
During the on-site review, the auditor visited each classroom and each living unit.
The ratios were reviewed during the tour and exceeded the expectations of 1 to 8 in
each school. There were no residents in the living units during the tour.
Staff interviewed indicated that they are required to remain in their assigned area
until relieved. They noted that youth are never allowed to be left unsupervised.
Residents interviewed during the tour indicated they are not permitted to leave the
classroom unless a staff member accompanies them.
313.313(b):
The PAQ requires the agency to comply with the staffing plan except during limited
and discrete exigent circumstances and shall fully document deviations from the
plan during such circumstances.
The facility has had no deviations from the plan for the last 12 months.
The center provided an accountability statement that there had been no deviation
in the last 12 months.
The facility provided the facility annual assessment in August 2025. The evaluation
noted there were no deviations from the staffing plan in the previous 12 months.
The center’s director stated in an interview that the center consistently maintains or
exceeds the required ratio. He noted that, as a residential program, direct care staff
includes case managers, supervisory staff, and monitors.
During the facility tour, staff interviews revealed that the line staff and supervisory
staff collaborate as a team. They can call sergeant or other staff to provide
necessary coverage at the facility.
The staffing plan includes direct care staff, staff utilized for transportation, and
utility staff.
The interview with staff confirmed that assignments are based on activities at each
unit, which will affect the staffing plan. The facility director provided a daily roster
indicating the staffing used during the prior 24 hours.
During the tour of the center, the auditor noted that staff were always assigned to
the education area during the school day. On each occasion, there were 12 direct
care staff members located just outside the classrooms or inside the classrooms.
115.313 (d):
The PAQ requires, whenever necessary, but no less frequently than once each year,
for each facility the agency operates, in consultation with the PREA coordinator
required by § 115.311, the agency shall assess, determine, and document whether
adjustments are needed to: (1) The staffing plan established under paragraph (a) of
this section; (2) Prevailing staffing patterns; (3) The facility's deployment of video
monitoring systems and other monitoring technologies; and (3) The resources the
facility has available to commit to ensure adherence to the staffing plan.
The facility provided an annual assessment for August 2025. The center became
operational in August 2024.
The PREA Coordinator interviewed indicated that the evaluation will occur annually,
and a meeting will be held to discuss the staffing plan, necessary revisions,
technological adjustments (and how to consider PREA), and other areas that are
addressed during this meeting.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.315 Limits to cross-gender viewing and searches
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations
Female Announcements
Cross Gender Pat Search Training Video.
Cross Gender Training Sign-In Sheet.
5.09 Searches and Full Body Visual Searches BTYA 7.20.24.
FDJJ 1919 Procedure revisions Final 5.1.25
PAQ
Staff interviews Resident interviews
115.315 (a)(b)(c):
The PAQ requires that the facility not conduct cross-gender strip searches or cross-
gender visual body cavity searches (meaning a search of the anal or genital
opening) except in exigent circumstances or when performed by medical
practitioners.
Based on the PAQ and interviews with the center director and randomly selected
staff, the facility does not permit cross-gender pat-down searches of residents.
The facility shall document and justify all cross-gender strip searches, cross-gender
visual body cavity searches, and cross-gender pat-down searches.
Staff members of the opposite gender are prohibited from viewing residents while
showering, changing clothes, and performing bodily functions, except in exigent
circumstances or instances when the viewing is incidental to routine cell checks.
Staff members of the opposite gender must announce their presence when entering
a housing unit or any area where residents are likely to be showering, using the
restroom, or changing clothes.
The facility provided 5.09 Searches and Full Body Visual Searches, and the FDJJ
policy 1919.
Policy 5.09 requires that Frisk searches be completed by staff of the same sex as the
youth (male).
Full-body visual searches will be conducted in a private room/space.
· Two staff members shall conduct all full-body visual searches
· Staff searching shall be of the same sex as the youth being searched. When
two staff of the same gender are not available for a whole body visual search, the
search may be conducted by one staff member of the same gender, while a staff
member of the opposite gender is positioned to observe the staff member
searching, but cannot view the youth
· The reason for the search is explained to the youth as well as the process
throughout.
· The youth will arrange or remove some or all of their clothing in the presence
of staff.
· Direct Care staff will check all facial areas, ears, and hair.
· Direct Care staff will inspect youth clothing thoroughly.
· The Shift Supervisor on duty will complete an internal incident report and body
chart when applicable (i.e., self-inflicted injury).
A cavity search involves the examination of the youth’s body cavities, with the
exception of a visual inspection of the ears, nose, and mouth. Cavity exams may
only be performed by a trained medical professional in an emergency room setting.
They must be authorized by the Facility Administrator when there is a strong
suspicion of concealed contraband.
Policy 1919 indicates staff shall not search or physically examine a youth for the
sole purpose of determining the youth’s genital status. If the youth’s genital status
is unknown, it may be determined during conversation with the youth, by reviewing
medical records, other youth records, or, if necessary, by learning that information
as part of a broader medical examination conducted in private by a medical
practitioner.
Staff shall not conduct opposite sex strip searches or opposite sex frisk searches.
Youth must be allowed to shower, perform bodily functions, and change clothing
without nonmedical staff of the opposite sex viewing their breasts, buttocks, or
genitalia, except in exigent circumstances or when such viewing is incidental to
routine cell checks.
Youth considered to be vulnerable shall be allowed to shower separately from other
youth.
Staff of the opposite sex shall announce their presence when entering a youth
housing facility or an area where youth are likely to be showering, performing bodily
functions, or changing clothing.
Ten residents were interviewed. All indicated that a person of the other gender had
not searched them.
Thirteen staff were interviewed. Every member of staff attended the cross-gender
training and signed the training roster.
All staff interviewed indicated they had not searched a resident of the other gender
since working at the center.
During the center tour, the auditor spoke with staff and residents. All staff indicated
they don’t conduct pat searches or strip searches of residents of the other gender.
The residents engaged in a conversation during the on-site audit. They indicated
a female staff member had never searched them.
115.315 (c):
The PAQ requires the facility shall document and justify all cross-gender strip
searches, cross-gender visual body cavity searches, and cross-gender pat-down
searches.
Policy 5.09 mandates that the facility shall document and justify all cross-gender
strip searches, cross-gender visual body cavity searches, and cross-gender pat-
down searches.
According to the PAQ, there were no cross-gender searches during the last 12
months.
During the center tour, the auditor spoke with staff and residents. All staff indicated
they don’t conduct pat searches or strip searches of residents of the other gender.
The residents indicated they had never been searched by staff of the other gender.
115.315 (d):
The PAQ requires the facility to implement policies and 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. Such policies and procedures require staff of the opposite gender to
announce their presence when entering a resident housing unit. In facilities (such as
group homes) that do not contain discrete housing units, staff of the opposite
gender shall be required to announce their presence when entering an area where
residents are likely to be showering, performing bodily functions, or changing
clothing.
The facility provided policy 1919 and posters located throughout the facility.
Policy 1919 mandates that youth must be allowed to shower, perform bodily
functions, and change clothing without nonmedical staff of the opposite sex viewing
their breasts, buttocks, or genitalia, except in exigent circumstances or when such
viewing is incidental to routine cell checks.
Youth considered to be vulnerable shall be allowed to shower separately from other
youth.
Staff of the opposite sex shall announce their presence when entering a youth
housing facility or an area where youth are likely to be showering, performing bodily
functions, or changing clothing.
A tour of the center revealed that all areas used for resident housing have
necessary barriers, ensuring residents can shower without being seen by people of
the opposite gender and maintain privacy from other residents.
During the facility tour, the auditor noted that cameras were installed in all living
units, classrooms, the dining hall, and the administrative building. No cameras were
located in restrooms, showering areas, and dressing areas in the cottages.
The ten residents stated they are allowed to change clothes and shower in private.
All staff of the other gender always announce their presence when entering a
housing unit. Reminders are posted at the entrance of each housing unit.
115.315 (e):
The PAQ requires that the facility shall not search or physically examine a
transgender or intersex resident for the sole purpose of determining the resident's
genital status. If the resident's genital status is unknown, it may be determined
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.
The standard is no longer applicable.
115.315 (f):
The PAQ requires the agency shall train security staff in how to conduct cross
gender pat-down searches, and searches of transgender and intersex residents, in a
professional and respectful manner, and the
The standard is no longer applicable.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
Residents with disabilities and residents who are limited English
115.316
proficient
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations
FDJJ 1919 Disabilities
Florida - Poster 1 - CREOLE
Florida - Poster 1 - ENGLISH
Florida - Poster 1 - SPANISH
Florida - Poster 2 - CREOLE
Florida - Poster 2 - ENGLISH
Florida - Poster 2 - SPANISH
LLS-Onsite Brochure.
Britt Bi-Lingual Staff.
PREA contract language.
115.316 (a)(b)(c): The PAQ requires 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. An agency is not required to take
actions that it can demonstrate would result in a fundamental alteration in the
nature of a service, program, or activity, or in undue financial and administrative
burdens, as those terms are used in regulations promulgated under title II of the
Americans with Disabilities Act, 28 CFR 35.164.
The agency shall 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, including steps to
provide interpreters who can interpret effectively, accurately, and impartially, both
receptively and expressively, using any necessary specialized vocabulary.
The agency shall not rely 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.
The facility provided the FDJJ Policy 1919, the training curriculum, interpreter
contact information, and PREA Posters in English, Creole, and Spanish.
Policy 1919 mandates facilities must ensure all youth with disabilities (including, for
example, youth who are deaf or hard of hearing, those who are blind or have low
vision, or those who have intellectual developmental, psychiatric, or speech
disabilities), have an equal opportunity to participate in or benefit from all aspects
of the Department’s efforts to prevent, detect, and respond to sexual misconduct.
The facility must also ensure meaningful access to its efforts to prevent, detect, and
respond to sexual misconduct for youth who are limited-English proficient, including
steps to provide interpreters who can interpret effectively, accurately, and
impartially, both receptively and expressively, using any necessary specialized
vocabulary. The facility may not use youth as interpreters, readers, or other
assistance to perform such functions except in limited circumstances where an
extended delay in obtaining an effective interpreter/reader/assistant could
compromise the youths’ safety, the performance of the first responder duties, or the
investigation of the youth’s allegations.
Language assistance services will be available at no cost to youth with limited
English proficiency (LEP).
Staff are made aware of procedures to provide disabled residents equal opportunity
to participate and/or receive information related to the agency's zero-tolerance
policy on sexual abuse and sexual harassment in their Residents with Disabilities
and Residents Who are Limited English Proficient Training Material.
The interviewed agency head reported that the agency established procedures to
provide residents with disabilities and residents who are limited English proficient
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.
The center should take appropriate steps to ensure that youth with disabilities
and those with limited English proficiency have an equal opportunity to participate
in or benefit from all aspects of the Center’s efforts to prevent, detect, and respond
to sexual abuse and sexual harassment.
The training curriculum requires that staff not rely on youth interpreters, readers, or
other youth assistants, except in limited circumstances where an extended delay in
obtaining an effective interpreter could compromise the youth’s safety.
The thirteen staff members interviewed indicated they would use contracted staff or
one of the bilingual staff members. They would not use residents to report on behalf
of another resident.
During the on-site portion of the audit, the auditor observed materials in English,
Creole, and Spanish, and the intake area had additional resources for interpreters
and for residents with disabilities.
BTYA will ensure that all written materials provided to residents are in a format or
delivered through methods that facilitate effective communication with residents
with disabilities, including those with intellectual disabilities, limited reading skills,
or who are blind or have low vision. Facilities will not rely on residents, readers, or
other individuals being served.
Residents who are special education students receive an Individualized Education
Program meeting that includes parents, legal guardians, or child advocates.
Family members or friends of the youth may not serve as the sign language
interpreter unless specifically requested by that individual. Other youth may not be
used for translating. The facility has a contract for language services, including sign
language services. Staff would read all the required information for the facility
orientation and the comprehensive PREA training for residents who can’t read.
Whenever communication accommodation is needed, the facility program director is
responsible for arranging an interpreter or another auxiliary aid to ensure
reasonably prompt and effective communication with the youth.
The center provided an intake brochure available in English, Creole, and Spanish,
along with 10 other posters displayed throughout the center. The brochure and
posters were brightly colored and provided no means of reporting, how to protect
oneself from being abused, and the agency's zero tolerance for sexual abuse or
harassment.
At the time of the audit, there were no LEP residents and no cognitively disabled
residents.
Staff are made aware of procedures to provide disabled residents equal opportunity
to participate and/or receive information related to the agency's zero-tolerance
policy on sexual abuse and sexual harassment in their Residents with Disabilities
and Residents Who are Limited English Proficient Training Material.
The center has several posters that staff can use to call a translation service. The
center provided an invoice from interpretative services.
The auditor called Language Line and used the code to speak with a staff member
who was willing to connect the auditor with an interpreter.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.317 Hiring and promotion decisions
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations
FDJJ 1800 - Background screening and Hiring practice.
FDJJ 1919 Hiring and Promotions
1.01 Background Screening BTYA 7.20.24.
1.02 Five-Year Background Screening BTYA.
Affidavit of Good Moral Character.pdf
Criminal history PREA.
Human Resources Interview
115.317 (a)(b)(c)(d):
The PAQ requires The agency shall not hire or promote anyone who may have
contact with residents, and shall not enlist the services of any contractor who may
have contact with residents, who (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 the activity described in paragraph (a)(2) of this section.
The PAQ indicated that 100 employee background checks and 1 contracting
background check have been completed in the last 12 months.
The PAQ requires the agency 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 residents.
The PAQ requires before hiring new employees who may have contact with
residents, the agency shall: (1) Perform a criminal background records check; (2)
Consults any child abuse registry maintained by the State or locality in which the
employee would work; and (3) 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.
The PAQ requires the agency shall also perform a criminal background records
check, and consult applicable child abuse registries, before enlisting the services of
any contractor who may have contact with residents.
The center provided policy 18000, Background Investigation; policy 1919; and
background-check documents.
Policy 1800 provides
• Background screening and hiring practices shall be conducted to ensure all
Department employees, contract provider and grant recipient employees (including
owners, operators, and directors), volunteers, mentors, and interns with access to
youth or confidential youth records meet established statutory requirements of
Level 2 Screening Standards.
• The Department is cognizant of its status as a criminal justice agency and its
special responsibilities in dealing with the youth population and has determined that
it is appropriate to establish background screening and hiring requirements for all
Department employees and volunteers, as well as all contract provider owners,
operators, employees, and volunteers.
• All contract providers and Department employees will be screened in
accordance with Level 2 standards, as set forth in Chapter 435, Florida Statutes, as
a condition of initial employment and retention in those positions. Additionally, all
provider and Department employees will be re-screened every five (5) years of
continued employment.
• Employment background screening shall be completed prior to hiring an
employee or utilizing the services of a volunteer, mentor, or intern.
• An assessment shall be completed prior to the hiring of direct-care positions.
• Contract provider employment and volunteer background screenings will be
processed and housed in the Care Provider Background Screening Clearinghouse.
This database is owned and maintained by the Agency for Health Care
Administration (AHCA).
• The BSU will review and provide the results from the FDLE's Automated
Training Management System (ATMS) to the contract providers for screenings done
on potential or permanent employees.
• The Department does not hire, promote, or contract with anyone who:
i. 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);
ii. 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;
iii. Has been civilly or administratively adjudicated to have engaged in the
activity described in ii above.
• The Department shall ask all applicants and employees who may have
contact with youth about previous misconduct in written applications or interviews
for hiring or promotions, and in any interviews or written self-evaluations conducted
as part of the review of current employees.
• The Department shall consider any substantiated incidents of sexual
misconduct in determining whether to hire, promote, or contract with anyone.
• Employees being considered for promotion shall disclose any sexual
misconduct and material omission regarding such misconduct, or the provision of
materially false information shall be grounds for termination.
• Employees and volunteers will report any arrest, which includes 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. If an employee or volunteer fails to
report an arrest within 24 hours, they shall submit an explanation for the delay in
reporting. Failure to report an arrest in a timely manner may result in disciplinary
action, up to and including dismissal. Supervisors and/or Human Resources
personnel will report any new arrest or notice to appear to the Background
Screening Unit, which will determine whether the offense disqualifies the employee
or volunteer from continued service.
• Any person required to complete an assessment for direct-care positions, or
undergo background screening as a condition of employment or volunteering
services who refuses to cooperate in such screenings or refuses to submit the
information necessary to complete the screening process shall not be employed or
utilized as a volunteer until a background screening is completed and the outcome
of the screening states the person is eligible for employment. Any person who is
already employed or volunteering and becomes disqualified shall be dismissed.
115.317 (e):
The PAQ requires the agency shall 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.
The facility's policy 1919 states that centers shall conduct background checks or
alternative background checks on all staff, volunteers, interns, and contractors
every five (5) years. FDJJ utilized “Live Scan” for continuous background checks on
staff, contractors, or volunteers. This includes a background check by the sheriff’s
office. This was confirmed by reviewing the Live Scan background check for staff.
The facility had no one with five years of tenure.
The interviewed HR staff reported that the agency conducts all background checks
through the Criminal History Unit. The center is responsible for contacting the child
abuse registry. The child abuse registry will only advise that a person is not on the
registry.
115.317 (f):
The PAQ requires the agency shall also 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 and in any interviews or written self-evaluations conducted as part of
reviews of current employees. The agency shall also impose upon employees a
continuing affirmative duty to disclose any such misconduct.
The facility provided the PREA pre-employment questionnaire, promotions, and
annual evaluations.
During initial interviews, prospective employees, interns, and volunteers shall be
informed of the background check procedure. FDJJ shall require the following
background checks on all DJJ staff, and any applicant that is being considered for
employment or promotion with DJJ: 1. Criminal background or records check. 2.
Child abuse and neglect registry check. The agency asks applicants about any prior
misconduct described in paragraph (a) of this section in written applications or
during interviews for hiring or promotion. The facility does a yearly staff appraisal,
and sexual abuse or sexual harassment is part of that appraisal.
The center shall not hire or promote a staff member, or enlist the services of a
contractor, who may have contact with a resident, who:
a. Has engaged in sexual abuse in a prison, jail, lockup, community confinement
facility, juvenile facility, or other institution;
b. 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
c. Has been civilly or administratively adjudicated of having engaged or attempted
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.
115.317 (g):
The PAQ requires material omissions regarding such misconduct, or the provision of
materially false information, shall be grounds for termination.
The facility policy 1800 states that material omissions regarding such misconduct or
the provision of materially false information shall be grounds for termination.
Staff are required to sign the form affirming that they have a continued “affirmative
duty to disclose any of the above-mentioned misconduct.
115.317 (h):
The PAQ requires, 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 center provided 1919, which indicates that, unless prohibited by law or DJJ
Policies, the Department’s Office of Human Resources, in coordination with the
Office of Investigations and Office of Legal Services, will provide information on
substantiated allegations of sexual abuse or sexual harassment between a current
or former employee and a youth upon receiving a request from an institutional
employer.
According to interviews with human resources staff, the center would ask the
prospective candidate to sign a release statement and would then send the
requested information.
Based on the review of the documentation and the interview with the
Director and Human Resources staff, the facility is complying with all provisions of
this standard.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is
115.318 Upgrades to facilities and technologies
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations.
Updated video monitoring system
Interviews with
Agency head
Facility Director
115.318 (a)(b)
The PAQ requires that when designing or acquiring any new facility and in planning
any substantial expansion or modification of existing facilities, the agency shall
consider the effect of the design, acquisition, expansion, or modification upon the
agency's ability to protect residents from sexual abuse.
The PAQ requires that when installing or updating a video monitoring system,
electronic surveillance system, or other monitoring technology, the agency shall
consider how such technology may enhance the agency's ability to protect residents
from sexual abuse.
According to the facility, the center became operational in August 2024. Before
taking the youth, the Florida PREA coordinator, regional administrator, and WHH
staff reviewed the cameras and made some upgrades to the camera and monitoring
system.
A review of the camera and monitoring system was conducted during the tour of the
center and found to be in good working order. No blind spots were noted during the
tour.
A review of the annual assessment in August 2025 confirms the auditor's impression
of the camera and monitoring system.
Based on this analysis, the facility exceeds the compliance standard, and corrective
action is not required.
115.321 Evidence protocol and forensic medical examinations
Auditor Overall Determination: Exceeds Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations
FDJJ Policy 1919 PREA - Forensic Medical Exams
FDJJ Policy 1919 PREA - Investigative Protocols Forensic Medical Examinations
IG Compliance Form-directive 3-05
IG Directive 4-03
The OIG requested that Law Enforcement Officers follow uniform evidence protocols.
PREA Youth Posters
MOU Crisis Center of Tampa Bay
Britt Technical Youth Academy Coordinated Response Plan for PREA Allegations.
Interviews with
PREA Compliance Manager
Center Administrator
Staff of the Victim Advocate and Emotional Support
Chief of Investigations
FDJJ PREA Coordinator
115.321 (a)(b)(C):
The PAQ requires that, 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 usable physical evidence for administrative
proceedings and criminal prosecutions.
The PAQ requires that the protocol shall be developmentally appropriate for youth
and, as applicable, 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.
The PAQ requires that the agency shall offer all residents who experienced 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 center provides policy 1919, directives 3.05 and 4.03, and an MOU with the
Crisis Center of Tampa Bay.
Based on the auditor's review of the MOU, as requested by the victim, the victim
advocate shall accompany and support the victim through the forensic medical
examination and investigative interviews, and shall provide emotional support, crisis
intervention, information, and referrals. The agency always provides an advocate
from an advocacy center. It does not use agency staff to accompany and support
the victim during forensic medical examinations and investigative interviews.
Policy 1919 mandates that the OIG is responsible for conducting administrative and
criminal sexual abuse investigations, including youth-on-youth and staff-on-youth
sexual abuse. The investigations will follow the guidelines of a National Sexual
Abuse Protocol or similarly comprehensive and authoritative protocol.
In an interview with the staff of the Crisis Center of Tampa Bay, the center has a
SANE staff and victim advocates that are part of the forensic team when an
evaluation is requested.
OIG Directive 3.05 mandates that, Pursuant to Florida statute, the Office of
Inspector General is to report to the Florida Department of Law Enforcement or
other law enforcement agencies, as appropriate, whenever the Office of Inspector
General has reasonable grounds to believe that a crime has been committed.
Upon discovery of possible evidence of a criminal violation during the course of any
Investigation or when there are reasonable grounds to believe that a criminal
violation has occurred, the Inspector General or designee will notify the appropriate
law enforcement agency.
All notifications or referrals to law enforcement and/or the State Attorney's Office
will be documented in the office and/or in the Investigative file.
Policy 1919 requires that trained, qualified, and professional investigators from the
Office of Investigations conduct administrative and criminal investigations.
Employees shall fully cooperate with internal administrative investigations and
provide accurate reports of violations of law, policies, and/or conduct by youth and
staff.
Based on the PAQ, BTYA would utilize the St. Petersburg Police or the Pinellas
Sheriff’s Office to conduct criminal investigations.
Interviews with (13) random staff confirmed that all staff were trained in basic
evidence preservation protocols and are well-versed in their responsibilities.
Evidence would be protected and preserved until an investigator arrived, who would
then proceed to collect and process the evidence. These staff also understood that
investigations were conducted by the Office of Investigations' PREA Unit and could
name the supervising investigator as the primary point of contact. During the tour
of the center, staff were asked who conducted the investigations, and it was
reported that the investigative staff does so.
The director of the OIG indicated in an interview that the investigative unit is
notified whenever there is an allegation of sexual abuse or sexual harassment. They
contact the center and, based on the incident, will immediately have staff report to
the center to begin the investigation.
The agency has an MOU with the Crisis Center of Tampa Bay, which provides SAFE
evaluation, forensic interviews, and victim advocacy services.
According to the PAQ, the center has not sent a resident for SAFE or SANE in the last
12 months.
115.321 (d)(e):
The PAQ requires the agency shall attempt to make available to the victim a victim
advocate from a rape crisis center. If a rape crisis center is not available to provide
victim advocate services, the agency shall make these services available through a
qualified staff member from a community-based organization or a qualified agency
staff member. Agencies shall document efforts to secure services from rape crisis
centers. For this standard, a rape crisis center refers to an entity that provides
intervention and related assistance, such as the services specified in 42
U.S.C.14043g(b)(2)(C), to victims of sexual assault of all ages. The agency may
utilize a rape crisis center that is part of a governmental unit as long as the center is
not part of the criminal justice system (such as a law enforcement agency) and
offers a comparable level of confidentiality as a nongovernmental entity that
provides similar victim services.
As requested by the victim, the victim advocate, a qualified agency staff member,
or a qualified community-based organization staff member shall accompany and
support the victim through the forensic medical examination and investigatory
interviews and shall provide emotional support, crisis intervention, information, and
referrals.
The facility provided an MOU with the Crisis Center of Tampa Bay, which would
assign a victim advocate.
In an interview, the PREA compliance manager indicated that the MOU includes
advocacy, emotional support, SANE examinations, and an emotional support
hotline.
115.321 (f)
The PAQ requires, to the extent that the agency itself is not responsible for
investigating allegations of sexual abuse, the agency requests that the investigating
agency follow the requirements of paragraphs (a) through (e) of this section.
The Department does not conduct criminal investigations for youth-related sexual
abuse reports. Local Law enforcement and the Department of Children and Families
handle such investigations involving youth in Florida. The Department conducts
administrative investigations and management reviews, separate and apart from
criminal investigations. 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 usable physical evidence for administrative
proceedings and criminal prosecutions. (b) The protocol shall be developmentally
appropriate for youth and, as applicable, 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. Policy provides for the uniform Protocols to be followed. The Protocol
outlines the appropriateness for youth and adults. 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.
The OIG has issued a request to local law enforcement to utilize the National
Protocol for Sexual Assault Medical Forensic Examinations, Adults/Adolescents.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.322 Policies to ensure referrals of allegations for investigations
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determinations.
FDJJ Policy 1919 - Investigative Protocols
OIG Directive requests that Law Enforcement Officers follow uniform evidence
protocols.
FDJJ Website
Investigator Database
Interviews with
PREA Compliance Manager
Facility Director
Agency Head
OIG Chief of Investigations.
115.322 (a & b)
The PAQ requires the agency shall ensure that an administrative or criminal
investigation is completed for all allegations of sexual abuse and sexual
harassment.
The agency shall have in place a policy to ensure that allegations of sexual abuse
and/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. The agency shall publish such policy on its website or,
if it does not have one, make the policy available through other means. The agency
shall document all such referrals.
The center provided Policy 1919 FDJJ Website.
Policy 1919 mandates that all staff, volunteers, interns, and contractors having first
knowledge of an incident, or receiving a report of an alleged incident, will report in
compliance with conditions in this policy and the Prison Rape Elimination Act, if
applicable.
BTYA does not conduct criminal investigations for residents related to sexual abuse
reports. Local Law enforcement and the Department of Children and Families handle
such investigations involving youth in Florida. The OIG conducts administrative
investigations and management reviews, separate from criminal investigations. The
DJJ PREA Policy outlines how investigative responsibilities are handled for allegations
of sexual abuse and harassment and is available on the Florida DJJ website. This
information is available in both English and Spanish. Further, the agency has a
Policy that requires allegations of sexual abuse or sexual harassment to 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 claims that are received by
residents, staff, volunteers, or contractors would be reported to the “Hot Line” by
the person with the most information when possible. This information is
documented in the Investigative database maintained by the OIG office.
The OIG will ensure that all allegations of sexual abuse and sexual harassment on
DJJ property or in a community residential program, including third-party and
anonymous reports, are investigated.
Based on the PAQ during the last 12 months, no allegations of sexual abuse or
sexual harassment were or are being investigated.
The Florida Department of Juvenile Justice provides the information, which is
available at https://www.djj.state.fl.us/services/department-support-services/office-
of-inspector-general.
The auditor reviewed the website and confirmed that the information was located as
indicated in the PAQ.
115.322 (c): If a separate entity is responsible for conducting criminal
investigations, such publication shall describe the responsibilities of both the
agency and the investigating entity.
The interviewed agency head reported that when there is an allegation of sexual
abuse or sexual harassment, the person reporting the allegation will contact the
CCC Upon making that call, the investigator will assess the inquiry to determine if it
is PREA. Upon deciding that it is an allegation of sexual abuse or sexual harassment,
OIG will be notified and will conduct the investigation or assist local law
enforcement in investigating if it is criminal in nature. Upon completion of a
thorough investigation, an investigation summary along with recommendations is
made. The investigation process includes, but is not limited to, interviews, file
reviews, camera footage reviews, and evidence collection. The investigation process
uses the National Sexual Abuse Protocol guidelines.
Based on this analysis, the facility is substantially compliant with this provision, and
a corrective action plan is not required.
115.331 Employee training
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in deciding on compliance
FDJJ Policy 1919 PREA - Staff Training PREA Acknowledgement form
PREA Skill Pro training curriculum, Part one and Part
Britt PREA Part One Training Acknowledgement
Britt PREA Part Two Training Acknowledgement
Britt Menta Health Part Three Training Acknowledgement
Cross Gender Training Acknowledgement Form
115.331 (a):
The PAQ requires the agency shall train all employees who may have contact with
residents on:(1) Its zero-tolerance policy for sexual abuse and sexual
harassment;(2) How to fulfill their responsibilities under agency 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 in 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; and(10) How to comply with relevant laws
related to mandatory reporting of sexual abuse to outside authorities;(11) Relevant
laws regarding the applicable age of consent.
The center provides the Florida Department of Juvenile Justice Skill Pro modules 1,
2, 3, and 4, along with a statement of fact.
BTYA utilizes the Florida Department of Juvenile Justice Training Program and
augments training for the specialized components of the residents’ programs. 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, which is also conducted and documented. The direct care staff
interviewed, and the PREA Compliance Manager reported that the training is
provided as required. All staff members interviewed, and documentation reviewed
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's 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 in 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. The
training is extensive across each standard and its application.
115.331 (b):
The PAQ requires that 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 reassigned from
a facility housing only male residents to one housing only female residents, or vice
versa.
The center provided the training curriculum. The center only houses male
residents.
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. All
employees receive training that includes managing and communicating with female
residents. The facility houses female residents. The training considers the needs of
the population, as determined through a review of training curricula and interviews
with randomly selected staff. The agency training for all staff also includes working
with LGBTI youth in DJJ facilities. Additionally, the agency has developed training for
First Responder duties and responsibilities.
115.331 (c):
The PAQ requires that all current employees who have not received such training
shall be trained within one year of the effective date of the PREA standards, and the
agency shall 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. In years in which an employee does not
receive refresher training, the agency shall provide refresher information on current
sexual abuse and sexual harassment policies.
The agency provides a refresher each year to ensure all employees know the
agency’s current sexual abuse and sexual harassment policies and procedures. In
recent years, the yearly in-service training added a video
on conducting cross gender or person frisk searches (pat down). All staff are
required to complete this training. The training roster and records were reviewed
and documented for this training session for BTYA staff. Additional training is
provided at the facility for the on-site training staff. The review of the topic included
an additional refresher on most topics in the Skill Pro Curriculum. The
All interviewed staff members were familiar with the PREA information regarding
primary components of preventing, detecting, and responding to sexual abuse or
sexual harassment.
Interviews with non-direct care and contracting staff, and their files, confirmed that
all staff at BTYA receive the same training. Policy and procedure mandate that staff
be trained at least once per year. All staff indicated they were required to complete
preservice training before working with any residents.
Several stated they had to shadow staff for at least two weeks after receiving their
preservice training.
115.331 (d):
The PAQ requires the agency shall document, through employee signature or
electronic verification, that employees understand the training they have received.
The center provided documentation of training for all staff.
The agency documents training through employee signatures or electronic
verification to confirm that employees understand the training they have received.
The policy provides that 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 examples to verify that the training
occurred, 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 that refresher training is conducted and
documented. The direct care staff interviewed, and the PREA Compliance Manager
reported that the training is provided as required. All direct care staff members
interviewed, and documents reviewed verified the general topics below were
included in the training: At the facility, it was evident through documentation,
interviews, and observation of the day-to-day operations that the staff is trained
continually about the PREA standards during shift briefings, monthly staff meetings,
and the completion of various online and instructor-led trainings.
BTYA requires staff to complete PREA training annually and to attend an all-staff
meeting each month. Staff interviewed indicated that one administrator meets with
staff during staff briefings at least once a month to discuss PREA-related topics.
There are more than 10 posters on sexual safety located throughout the facility.
Staff indicated they are also trained in cross-gender pat searches, including
scenarios when staff are authorized to conduct them. Most indicated that such
searches would be only to protect the resident from extreme harm. There have been
no cross-gender searches by the center since it assumed operations.
BTYA manages a population of youth who have either completed the GED or a high
school diploma, or are expected to complete an education program within a month
of arriving at the center. The youth are then assigned to attend the Britt Technical
School for additional training and/or education.
Compliance was determined by reviewing the preservice and in-service training
curricula and staff training records. An interview with a randomly selected staff
member also confirmed that they had received the required training and refresher
training as mandated by policy. The interview included questions about the
specialized training programs. Staff demonstrated an understanding of working with
older male youth.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.332 Volunteer and contractor training
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in deciding on compliance
Volunteers and General Contractors Training
FDJJ Policy 1919 - Volunteer and contractor Training
FDJJ Policy 8.17 Volunteer/Contractor Information Sheet (PREA)
Visitors and Volunteers. Sign In Sheet
Contractor interview
115.332 (a):
The PAQ requires the agency shall ensure 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.
The center provided the DJJ Policy 1919 and 8.17
Both policies require that, prior to having contact with the residents, all volunteers
and contractors receive training on their responsibilities under the agency’s sexual
abuse and sexual harassment prevention, detention, and response policies and
procedures. The level and type of training provided shall be based on the services
they provide and the level of contact they have with residents. 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 be informed of
how to report such incidents.
115.332 (b):
The PAQ requires that the level and type of training provided to volunteers and
contractors shall be based on the services they provide and the 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.
Based on sign-in logs and interviews with contracting staff, 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 on
how to report such incidents.
One contracting teacher was interviewed. She articulated the training she had
received.
115.332 (c):
The PAQ requires the agency shall maintain documentation confirming that
volunteers and contractors understand the training they have received.
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
participant's signature and date, confirming their understanding of the PREA
information. Over the past year, 1 contractor and 3 volunteers have completed the
Volunteer and Contractor training.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.333 Resident education
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in deciding on compliance
FDJJ Policy 1919 - Youth Training
2.02 Youth Orientation BTYA
PREA acknowledgement form
Ten Different PREA Brochures (French Creole, Spanish, and English)
Youth education sign in
Youth training Education material Resident Files
Interview
Random Residents Intake Staff
PREA compliance manager
115.333 (a)(b)(c)
The PAQ requires that 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.
The PAQ requires that, 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.
The PAQ requires that current residents who have not received such education be
educated within one year of the effective date of the PREA standards 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.
The PAQ requires the agency to 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 those with limited reading skills.
The center provided Policy 1919, the resident handbook, the PREA brochure, and
Policy 2.02 Youth Orientation BTYA.
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 those with limited reading skills.
The agency maintains documentation of participation in the education program. In
addition to providing such education, the agency shall ensure that key information
is continuously and readily available to residents through posters, resident
handbooks, or other written materials.
The center conducts orientation and comprehensive training for all new residents
upon arrival at the facility, usually within 72 hours, covering all aspects of the
training requirements.
The intake staff indicated that they review the resident handbook, the PREA
brochure, and the Crisis Center of Tampa Bay poster.
A review of the handbook included 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. The handbook also included the youth's 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.
The PREA brochure included information on outside entity reporting; you have the
right to be safe at all times. No one has the right to ask you for sex or sexual favors.
You do not have the right to ask anyone for sex or sexual favors while in custody.
Any sexual contact between youth, or between youth and staff, is against the law.
Your report of sexual abuse will be shared only with people who need to know.
Residents receive information explaining the agency’s zero-tolerance policy in an
age-appropriate fashion, including how to report incidents or suspicions of sexual
abuse or sexual harassment in the following manner. The comprehensive education
is delivered in a format accessible to all residents, including those who are limited-
English proficient, deaf, visually impaired, or otherwise disabled, as well as those
with limited reading skills. The facility can provide PREA education in formats
accessible to all residents, including those who may be limited-English proficient,
deaf, visually impaired, or otherwise disabled, and those with limited reading skills.
According to documentation and interviews with the Facility Director and the
Assistant Facility Administrator, Britt Technical Class will assist with the provision of
services to disabled and limited-English-proficient residents. If the youth reports a
deficiency, or staff are aware of one, in any of these areas, they report the need for
an additional resource to the supervisor. The supervisor notifies the facility
administrator, who will contact the appropriate community resource services,
including the local board of education. 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.
The center provided a list of bilingual staff and a contract for interpretive services.
There were posted signs in the officer station and control room on how to access
interpretive services for all staff. The auditor called the interpretive services
program and spoke with a staff member from the service, who indicated she had
access to any language. The center has a four-digit code used to contact the
services. The four-digit code was printed on the posters with the interpretive
services phone number.
The practice used before the onsite audit was in line with the standards' mandates.
However, under the contract, the center is also required to provide training using
the Florida Department of Juvenile Justice video.
A corrective action plan was implemented. All residents at the center were shown
the FDJJ PREA orientation and comprehensive videos on the first day of the onsite
audit. The center has established training for intake staff, in which residents watch
the DJJ video before staff explain all sections of the resident handbook.
The center provided the auditor with a sign-in sheet listing all residents who had
received the PREA videos.
115.333 (e):
The PAQ requires the agency shall maintain documentation of resident participation
in these education sessions.
The agency shall maintain documentation of resident participation
in these education sessions. A sample of signed acknowledgement statements was
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. Staff
ensure residents receive the information, including the resident signing the
acknowledgement.
The center provided the auditor with acknowledgment sheets for nine residents,
indicating receipt of the handbook, orientation, and brochures.
The auditor requested five additional training sessions for the youth being
interviewed. Five of the residents scheduled for interviews acknowledged that their
acknowledgments had already been uploaded to the PAQ by the center.
In the last 12 months, 34 residents received comprehensive training as indicated in
the PAQ.
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.
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 with information on how to report allegations of sexual
harassment and sexual abuse. A safety guide is provided to each resident to
eliminate incidents of sexual abuse and sexual harassment. The guide includes
educational information regarding sexual abuse and victims in a cartoon format. The
residents revealed they can report allegations of sexual abuse or sexual harassment
by telling a staff member or a family member. PREA educational documentation was
noted throughout the facility, including the lobby, visitation, and living units.
The center provided 10 PREA Posters that were located throughout the center.
The posters included educational posters such as no means no, you have the right
to be free from sexual abuse and speak up. All posters were
All residents interviewed formally and informally during the tour, and subsequent
visits to the recreation area confirmed that the administrative staff talks to
them daily about PREA. They indicated that staff conducting rounds will ask them
questions about PREA.
Ten residents were interviewed. All residents interviewed reported receiving the
training on their first day at the facility. They were able to articulate that they were
aware of how to report allegations, that they have the right to be free from sexual
abuse or harassment, and they knew they would not face retaliation if they made a
report of allegations. The resident indicated they had watched the PREA video and
were asked to sign a statement confirming receipt of the training.
A corrective action plan was implemented during the on-site audit, requiring the
center to use the PREA video provided by the Florida Department of Juvenile
Justice.
Compliance was determined by completion of the corrective action plan, review of
the agency policies, training curriculum, posters, and resident files, and interviews
with staff and residents.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.334 Specialized training: Investigations
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making a compliance determination
FDJJ 1919 - Youth reporting
DJJ Website reporting screenshot.
CCC Florida Administrative Code 63F.
FDJJ 1919 - Reporting to Youth.
Prison Rape Elimination Act - OIG investigator training
Interviews
Chief of Investigation
115.334 (a)(b)(c):
The PAQ requires 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.
The PAQ requires specialized training that 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.
The PAQ requires the agency shall maintain documentation that agency
investigators have completed the required specialized training in conducting sexual
abuse investigations.
Britt Technical Youth Academy does not conduct any form of administrative or
criminal sexual abuse investigation.
According to an interview with the OIG Chief, all OIG investigators undergo
extensive training prior to conducting administrative investigations, which includes
the “Basic Investigation Training” requirement.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.335 Specialized training: Medical and mental health care
Auditor Overall Determination: Exceeds Standard
Auditor Discussion
Evidence relied upon in making a compliance determination
FDJJ Policy 1919 - Specialized Training Medical-MH Medical training Mental health
training
PREA-Mental Health and Medical Professionals Specialized training for medical and
mental health
PREA-Mental Health and Medical Professionals Skill Pro Medical/Mental Health
Modules
3.08 Specialized Treatment Services BTYA
3.03 Non-Licensed Mental Health and Substance Abuse Clinical Staff BTY
3.04 Mental Health and Substance Abuse Admission Screening BTYA
Designated Mental Health Clinical Authority BTYA.
PREA-Mental Health and Mental Professionals_ Module 2.pdf
PREA-Mental Health and Medical Professionals Module 1
.335 FDJJ 1919 Specialized MH and Medical Training.pdf
PREA-Mental Health and Medical Professionals-Module 4
115.335 (a):
The agency shall ensure that all full- and part-time medical and mental health care
practitioners who work regularly in its facilities have been trained in:(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; and(4) How and to
whom to report allegations or suspicions of sexual abuse and sexual harassment.
FDJJ Policy 1919 PREA - Specialized Training: Medical-MH. Medical and mental health
staff receive regular PREA training, and specialized PREA training is included in the
FDJJ Skill Pro training modules. 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):
If medical staff employed by the agency conduct forensic examinations, such
medical staff shall receive the appropriate training to conduct such examinations.
The facility's medical staff or mental health staff does not conduct forensic medical
examinations.
115.335 (c):
The agency shall maintain documentation that medical and mental health
practitioners have completed the training referenced in this standard, either
through the agency or elsewhere.
The facility's acknowledgment of training indicates that medical and mental health
staff have attended specialized medical training. Based on PAQ, 5 medical and
mental health staff members have received specialized training over the past 12
months.
115.335 (d):
Medical and mental health care practitioners shall also receive the training
mandated for employees under § 115.331 or for contractors and volunteers under §
115.332, depending upon the practitioner's status at the agency.
The mental health and medical staff completed the general and refresher training
provided for all staff members.
A review of the training curriculum, acknowledgement documentation, and
interviews with medical and mental health staff confirmed that staff have received
specialized and general training as required by standards, and have additional
training that exceeds those expectations. Staff assigned to this program receive
further training from the clinical director.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.341 Obtaining information from residents
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making a compliance determination
FDJJ 1919 Obtaining information from the youth VSAB.
3.04 Mental Health and Substance Abuse Admission Screening BTYA
Staff VSAB Training Resident File Review Mental Health File Review
Interviews
Staff responsible for Risk Screening
PREA coordinator
PREA compliance manager
PREA Coordinator
Random Residents
115.341 (a)(b)(c)
The PAQ requires within 72 hours of the resident's arrival at the facility and
periodically throughout a resident's confinement, the agency shall obtain and use
information about each resident's personal history and behavior to reduce the risk
of sexual abuse by or upon a resident.
Such assessments shall be conducted using an objective screening instrument.
The PAQ requires at a minimum, the agency shall attempt to ascertain information
about: (1) Prior sexual victimization or abusiveness; (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; (3)
Current charges and offense history; (4) Age; (5) Level of emotional and cognitive
development; (6) Physical size and stature; (7) Mental illness or mental
disabilities;(8) Intellectual or developmental disabilities; (9) Physical disabilities; (10)
The resident's own perception of vulnerability; and (11) Any other specific 12. Any
other specific information about individual detainees that may indicate heightened
needs for supervision, additional safety precautions, or separation from certain
other detainees.
The center provided policy 1919, VSAB, and policy 3.04.
Policy 1919 requires screening upon admission to a facility or transfer to another
facility) for risk of sexual abuse victimization or sexual abusiveness toward other
residents. The policy requires that residents be screened for risk of sexual
victimization or risk of sexually abusing other residents within 72 hours of their
intake.
Youth vulnerability assessments will be conducted and documented by generating
the VSAB. At a minimum, the report will attempt to ascertain information about the
following:
1. Prior sexual victimization or abusiveness.
2. Any gender nonconforming appearance or manner or identification as
lesbian, gay, bisexual, transgender, or intersex (LGBTI), and whether the resident
may therefore be vulnerable to sexual abuse;
3. Current charges and offense history;
4. Age;
5. Level of emotional and cognitive development;
6. Physical size and stature;
7. Mental illness or mental disabilities;
8. Intellectual or developmental disabilities;
9. Physical disabilities;
10. The youth’s perception of vulnerability; and
11. Any other specific information about the individual youth that may
indicate a heightened need for supervision, additional safety precautions, or
separation from certain other youths.
115.341 (d).
PAQ requires this information shall be ascertained through conversations with the
resident during the intake process and medical and mental health screenings;
during classification assessments; and by reviewing court records, case files, facility
behavioral records, and other relevant documentation from the resident's files.
Policy 1919 and in interview with the staff that conducts the initial screening
information, the resident’s information will be ascertained through conversations
with the youth during the intake process, The staff conducting the screening
indicated she reviews court records, case files, facility behavioral records, and other
relevant documentation from the resident's files and has a conversation with the
resident parents or legal guardian.
115.341 (e).
The agency shall implement 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.
Policy 1919 mandates the facility will control the dissemination of the youth’s
information by complying with all applicable disclosure requirements and Facility
PREA Compliance Manager. The dissemination of information ensures that sensitive
information is not exploited to the resident’s detriment by staff or other resident.
Residents interviewed confirmed when they first came to the facility; they were
asked questions; whether they have ever been sexually abused, whether they
identify with being gay, bisexual, or transgender, whether they have any disabilities,
and whether they think they might be in danger of sexual abuse at the facility. They
stated they were asked these questions the first day at the facility.
The Staff Responsible for Risk Screening confirmed she screens residents upon
admission to the facility or transfer from another facility for risk of sexual
abuse victimization or sexual abusiveness toward other residents. She stated she
screens residents for risk of sexual victimization or risk of sexually abusing other
residents within 72 hours of their intake. The information is obtained through
conversations with residents during intake, medical and mental health screenings,
and review of relevant court records.
The PREA coordinator interviewed indicated that the Screening Instrument is
considered protective information. The information is provided to the facility
management team members on a need-to-know basis.
The auditor reviewed the Screening of the 10 youth selected for interview.
Compliance with this standard was determined through a review of the screening
instrument, interviews with randomly selected staff, and interviews with the PREA
compliance manager and the facility director.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.342 Placement of residents
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Placement, Housing, etc.
FDJJ 1919 - Placement of Youth
VSAB form RC8050
VSAB SkillPro training
Healthcare Admission Screening and Rescreening Form BTYA.docx
4.07 Youth Orientation to Healthcare Services-Health Education BTYA
Interviews with:
Facility director
PREA Compliance Manager
Random Staff
Medical Mental Health
115.342 (a)(b):
The PAQ requires the agency shall use all information obtained pursuant to §
115.341 and subsequently to make housing, bed, program, education, and work
assignments for residents to keep all residents safe and free from sexual abuse.
The PAQ requires that 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 residents 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 facility provided policies 1919
Policy 1919 mandates that all information obtained shall be used to make housing,
bed, program, and work assignments for youth with the goal of keeping all youth
safe from sexual abuse. The facility makes individualized determinations about how
to ensure the safety of each youth. The PREA Compliance Manager and Staff
Responsible for Risk Screening confirmed the facility uses information from the risk
screening during intake to keep residents safe and free from sexual abuse and
sexual harassment by determining housing and programming assignments.
Based on interviews with the facility director, the center does not use isolation. The
center is a halfway house program that assigns residents to attend Britt Technical
College. If a resident requires separation to keep him safe, the center would have to
request immediate removal to a safe environment. The center has no isolation areas
or spaces that could be used to isolate the resident.
The interviewed PREA Coordinator reported that the facility does not have special
housing units for lesbian, gay, bisexual, transgender, or intersex residents. ALL
youth are placed in the same type of room/cell. They’re individual rooms, so there is
immediate separation for all.
The staff interviewed responsible for risk screening reported that the facility uses
the information from the risk screening during intake to keep residents safe and free
from sexual abuse and sexual harassment.
The facility director indicated that the center does not utilize isolation to house
youth who are subject to being victims or fear of being victimized.
115.342 (h)(i)
The PAQ requires that if a resident is isolated pursuant to paragraph (b) of this
section, the facility shall 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.
Policy 1919 requires 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 facility director indicated he would comply with the Florida Department of
Juvenile Justice Policy if the center were ever required to isolate a youth.
Policy mandates that, prior to segregating youth, the facility document the
following:
(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
In the last audit cycle, the center has not had a youth at risk of sexual victimization
who was placed in isolation.
If a resident at risk of sexual victimization is held in isolation, the facility affords
each such resident a review every 30 days to determine whether there is a
continuing need for separation from the general population.
According to interviews with the facility administrator, the facility would place
residents under one-on-one supervision until the risk was resolved. They would not
be isolated in a room or housing unit.
Compliance with this standard was determined through a review of the screening
instrument, interviews with randomly selected staff, and interviews with the PREA
compliance manager and the facility director.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.351 Resident reporting
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
Agency Policy FDJJ 1919 Youth Reporting
FS 39.201 Mandatory Reporting.
DJJ Website reporting screenshot.PNG
CCC Florida Administrative code 63F.pdf
General Counsel - PREA immigration status.
PREA Florida Statute, Child abuse reporting, et al.
Resident Handbook
Help Request Forms Posted Information
2020 Florida Statutes Title V Chapter 39 Proceedings related to Children.
Interviews
Random Resident
Facility Director
PREA Compliance Manager
115.351 (a)
The PAQ requires the agency shall provide multiple internal ways for residents to
privately report sexual abuse and sexual harassment, retaliation by other residents
or staff for reporting sexual abuse and sexual harassment, and staff neglect or
violation of responsibilities that may have contributed to such incidents.
The center provided Policy 1919, the resident handbook, numerous posters for
reporting, and FS 39.201, Mandatory Reporting.
The FDJJ and center, through the handbook, PREA brochure, and numerous posters,
identified 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
DFCS Child Abuse Hotline: (800) 962-2873.
Report to any staff, volunteer, contractor, or medical or mental health staff.
Submit a grievance or sick call slip.
Report to the PREA Coordinator or PREA Compliance Manager.
If you are over 18, reports can be made to DJJ’s Central Communications Center
(800)355-2280
Also, the policies identified the residents’ 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
report sexual abuse and sexual harassment of residents privately. Florida Law
explicitly mandates reporting of sexual abuse and sexual harassment. It also
establishes a State Child Abuse Hotline under the supervision of the Department of
Children Services. The reporting of child abuse, abandonment, or neglect is codified
in 2020 Florida Statutes Title V Chapter 39-“39.201” Mandatory reports of child
abuse, abandonment, or neglect; mandatory reports of death; central abuse
hotline.— (1)(a) Any person who knows, or has reasonable cause to suspect, that a
child is abused, abandoned, or neglected by a parent, legal custodian, caregiver, or
other person responsible for the child’s welfare, as defined in this chapter, or that a
child is in need of supervision and care and has no parent, legal custodian, or
responsible adult relative immediately known and available to provide supervision
and care shall report such knowledge or suspicion to the department in the manner
prescribed in subsection (2). (b) Any person who knows, or who has reasonable
cause to suspect, that a child is abused by an adult other than a parent, legal
custodian, caregiver, or other person responsible for the child’s welfare, as defined
in this chapter, shall report such knowledge or suspicion to the department in the
manner prescribed in subsection
(2). (c) Any person who knows, or has reasonable cause to suspect, that a child is
the victim of childhood sexual abuse or the victim of a known or suspected juvenile
sexual offender, as defined in this chapter, shall report such knowledge or suspicion
to the department in the manner prescribed in subsection (2). (d) Reporters in the
following occupation categories are required to provide their names to the hotline
staff: 1. Physician, osteopathic physician, medical examiner, chiropractic physician,
nurse, or hospital personnel engaged in the admission, examination, care, or
treatment of persons; 2. Health or mental health professional other than one listed
in subparagraph 1.; 3. Practitioner who relies solely on spiritual means for healing;
4. School teacher or other school official or personnel; 5. Social worker, day care
center worker, or other professional childcare, foster care, residential, or
institutional worker; 6. Law enforcement officer; or 7. Judge.” Talk to, call, or send a
letter or note to any of the following: A staff member you trust. Program
Administrator, your attorney, advocate your parents or guardians Child Abuse
Hotline, Central Communication Center telephone reporting. Residents have the
right to privately report sexual assault, abuse, harassment, or retaliation by other
residents or staff for reporting sexual abuse and sexual harassment. If staff neglect
or violate responsibilities that may have contributed to such incidents, the Resident
can request that Direct Care Staff, Volunteer, Intern, Supervisor, PREA Compliance
Manager, and Facility Administrator call CCC and the Sexual Abuse Registry (DCF).
These programs were called using the telephone available to residents and were
used to test the telephone. In each case, the auditor was able to make a report to
the program. CCC indicated they would report to OIG and the Department of
Children and Family Services if the youth were under 18. The facility administrator
indicated that OIG would notify his office and the Alachua Sheriff’s Office if the
allegation were criminal in nature. The center has a multipurpose room at its center.
The center has a telephone located in the multipurpose area and a small office with
a telephone that residents can utilize to make a report of sexual abuse or sexual
harassment. Staff would allow the residents to go into the office to make the call
and stay outside while the youth made the call.
115.351 (b):
The PAQ requires the agency also to 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 can receive and immediately forward resident reports of sexual
abuse and sexual harassment to agency officials, allowing the resident to remain
anonymous upon request. Residents detained solely for civil immigration purposes
shall be provided with information on how to contact relevant consular officials and
Department of Homeland Security officials.
The center provided the telephone number, address, and policy 1919. The
information was noted on posters, handbooks, and brochures provided to the
youth.
Policy 1919 mandates that 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 can 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 sexual abuse
hotline or the Central Communication Center Hotline. Residents may request to use
a telephone in some degree of privacy to call the hotline without obtaining staff
permission, and staff must not question residents about the reason for the call.
Writing materials are available for residents to complete Grievance, Sick Call
Request, and Speak Out forms, and to take notes. Each resident receives a Student
Handbook that includes information on reporting allegations, and residents are
informed about reporting methods during PREA education sessions.
The interviews, review of documents, and facility practices revealed that residents
are provided the tools to make written allegations of sexual abuse and sexual
harassment.
Residents interviewed were aware of the abuse hotline and could articulate how to
access it.
The auditor called the CCC and DFCS child abuse hotlines and spoke with a staff
member. CC indicated they would provide the center with a case number. DFCS
indicated they would notify the closest DFCS office or the local law enforcement.
115.351 (c):
The PAQ requires staff to accept reports made verbally, in writing, anonymously,
and from third parties and shall promptly document any verbal reports.
The center provides policy FS 39.201, Mandatory Reporting, and PREA, Florida
Statute, Child Abuse Reporting.
Policy and Florida law mandate that 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
stated they were familiar with the standard's provisions. The resident interviews
demonstrated their familiarity with the various ways they may report, including in
person, in writing, by phone, by completing a PREA/grievance or Medical Request
Form, or through a third party. The residents were aware that third-party reports
could be submitted and that they could be submitted anonymously. Staff members
interviewed were mindful of their duty to receive and document third-party reports.
115.351 (d):
The PAQ requires that the facility provide residents with access to the necessary
tools to make a written report.
The facility provides residents with the tools needed to prepare a written report.
Writing materials are readily available for residents to complete the accessible
forms. Before the site visit, pictures were sent to the auditor showing the reporting
forms, such as PREA/Grievance forms and Medical Request Forms, and the
availability of writing utensils. During the site visit and site review, the auditor
observed the availability of writing utensils for residents. Staff must report sexual
abuse and sexual harassment immediately to the Facility Director and must
immediately notify the State Sexual Abuse Registry Hotline. The Staff and Facility
Administrator confirmed that staff may report directly to the facility administrator,
who will coordinate with staff to call CCC (the sexual abuse registry), local law
enforcement, and the legal guardian.
The PREA compliance manager interviewed indicated that residents are provided
pencil, paper and stamp and access to the telephone to make reports of allegations
of sexual abuse or sexual harassment.
115.351 (e):
The PAQ requires the agency shall provide a method for staff to report sexual abuse
and sexual harassment of residents privately.
Staff may make anonymous reports of sexual abuse and sexual harassment of
residents to their local law enforcement, state reporting agency (CCC), Department
of Family and Children Hotline, PREA Coordinator, facility administrator, or the PREA
compliance manager.
Compliance was determined by reviewing posters and policies and by interviewing
staff; by calling CCC, the child abuse hotline, the Crisis Center hotline, and the FDJJ
PREA Coordinator.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.352 Exhaustion of administrative remedies
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Youth reporting
1.09 Grievance process BTYA 7.20.24.
Youth Handbook
Youth Grievances Forms
Florida Administrative Code Rule 63f-11 Central Communications Center (CCC)
Interviews
Florida Department of Juvenile Justice PREA coordinator
Facility Director
PREA Compliance Manager
15.252 (a):
The PAQ requires that an agency shall be exempt from this standard if it does not
have administrative procedures to address resident grievances regarding sexual
abuse.
The center PAQ states that any allegations of sexual misconduct are immediately
reported and converted to investigation that are outside the agency and are not
considered by the agency to be grievance. Youth are provided with the notice in the
youth handbook.
Resident may file a grievance regarding sexual abuse or sexual harassment.
However, the director will forward the grievance to the CCC within 2 hours of
receiving the grievance. The facility will not undertake investigations of the
grievance, however if it is an emergency grievance and the resident claims or
appears to be imminent danger or if the grievance claims staff member sexual
abuse, the facility director will take immediate steps to protect the resident, to
preserve the crime scene and remove the staff from the areas where the resident is
housed or place staff member on administrative leave pending investigation.
Instructions on how to file grievances are provided to residents in the resident
handbook and PREA posters. While the agency utilizes the Grievance system only
for residents to make allegations of sexual abuse or sexual harassment, the
grievance system does meet the standards for reporting non-Prevention of Sexual
Abuse and Trafficking (PREA related allegations.
Florida Administrative Code Rule 63f-11 Central Communications Center (CCC)
requires that any allegation of sexual misconduct or youth-on-youth sexual activity
be reported to the CCC. The person making the report shall provide basic
information such as the date and time of the incident, where the incident occurred,
the supervising staff, and who may be involved. The CCC will make appropriate
notifications to senior DJJ management, who will, in turn, make subsequent
notifications to management overseeing the facility where the alleged abuse
occurred. In addition to providing appropriate notification through Department
channels, staff should take no further action unless directed by law enforcement or
first responders. There is no time limit on when a youth may report an allegation of
sexual misconduct. Youth shall be provided multiple internal ways to privately report
sexual misconduct, retaliation by other youth or staff for reporting sexual
misconduct, and staff neglect or violation of responsibilities that may have
contributed to such incidents.
Compliance was determined based on an interview with the FDJJ PREA Compliance
Coordinator and information provided in the Pre-Audit Questionnaire. In the past 12
months, no emergency grievances alleging sexual abuse were filed.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
Resident access to outside confidential support services and legal
115.353
representation
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination.
DJJ Policy 1919 - Outside Support
Local Domestic Violence Centers
natl-abuse-hotline-English
natl-abuse-hotline-Spanish
BTYA Res Handbook
BTYA Res Handbook
US Citizenship and Immigration Services - English.
US Citizenship and Immigration Services - Spanish.
FDJJ 1919.
Britt Documentation Of Agreement.
Attempt to establish an MOU
Interview with Victim Advocate and Emotional Support Staff
Emails and telephone documentation
115.353 (a)(c):
The PAQ requires 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
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, immigrant services agencies. The facility shall enable
reasonable communication between residents and these organizations and
agencies, in as confidential a manner as possible.
The PAQ requires 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 facility provided Policy 1919, the Poster, the MOU, an Attempt to codify the
MOU, and Resident Handbook information on contacting the Crisis Center of Tampa
Bay.
Policy 1919 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, immigrant services agencies. The facility shall
enable reasonable communication between residents and these organizations and
agencies, in as confidential a manner as possible.
The center has attempted to codify an MOU with the Crisis Center of Tampa Bay. The
Crisis Center was interviewed by the auditor and indicated that they had provided
the center with a poster and telephone number for emotional support staff and had
agreed to provide these services to any person, including the youth house at BTYA.
The center and Crisis Center of Tampa Bay signed the MOU on 1/15/2026.
A review of the resident handbook included the Crisis Center's telephone number.
There is a poster throughout the center, particularly in the telephone area, with
contact information for the emotional support staff. The handbook stated that
support services are available from the victim advocate at the Crisis Center of
Tampa Bay and can be reached at (813) 964-1964.
The auditor called the number and reached a staff member who agreed to connect
me with an emotional support staff member.
Staff interviewed indicated that residents may use a private office telephone to
contact the Crisis Center.
The center also has a poster for the National Abuse Hotline in English and Spanish,
with residents' phone numbers to call for emotional support.
The center has a Poster with the U.S. Citizenship and Immigration Services
telephone number in English and Spanish posted throughout the center.
Ten residents at the center were interviewed. The residents who were interviewed
regarding the victim knew about the emotional support hotline. The residents
indicated that you only need to request a call; staff will allow you to use the private
office next to the housing unit, and you can call at any time.
All residents interviewed were aware of the Crisis Center and the poster displayed
throughout the center.
115.353 (b):
The PAQ requires the facility to inform residents, before 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.
Policy 1919 requires the center to inform residents, before 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 policy addresses the confidentiality of the advocacy support
services. The resident is informed of privacy limitations during the intake process.
When contacted by phone, the center’s staff explained that they always inform
callers that calls are confidential.
115.353 (d):
The PAQ requires 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 facility provided Policy 1919
Policy 1919 mandates that youth in Department of Juvenile Justice (DJJ) facilities/
programs shall have the right to uncensored, confidential contact with their legal
representative by telephone, in writing, or in person. Youth in DJJ facilities/programs
shall not be denied access to the courts. Youth shall be assured that seeking judicial
relief will not be met with reprisal or penalty from any agent of the Department.
These rights shall not be diminished or denied for disciplinary reasons. The center
will inform youth during the intake process that they will have reasonable,
confidential access to their attorneys and other legal counsel.
A youth’s attorney will have the right to meet with the youth at any reasonable
time. Except in unusual circumstances, the attorney requesting the meeting should
be encouraged to hold it at a time most convenient for the youth. All attorneys must
present their Bar card in addition to any other required identification at the time of
the visit.
The center provides residents with access to parents or legal guardians with phone
calls, 2 face-to-face visits each week, and 2 stamps for written communication via
mail. This information is located in the resident handbooks.
The interview’s confirmed residents have access to attorneys and court workers and
reasonable access to their parents/legal guardians.
Residents indicated they may call their parents twice a week and may make a
private call in an office if they need to speak with their parents/legal guardian about
legal or private matters. Residents indicated the center has Skype on one of the
computers that residents are allowed to use to visit with their parents, or parents
can come to the center every other week to see them.
According to an interview with the facility director, we ask the attorney to schedule
an appointment to see the youth or to set up a time to speak by phone or Zoom
with the attorneys. However, we will not turn a verified attorney away from seeing
his client.
The site tour identified areas where residents could meet privately with a legal
representative and the visitation area for family visits.
All residents interviewed stated that families could visit and provided the days and
times of those visits and phone calls. The resident indicated that staff dial the
number and then allow them to take the phone into their room to speak with their
attorney or parents.
The Facility director confirmed that the facility provides residents with reasonable,
confidential access to their attorneys or court representatives and to parents or
legal guardians. Residents can contact their attorney by requesting an attorney call.
Staff will expedite the call and allow the resident to call from a private office. The
director indicated that, before visiting the resident, they request that the attorney
schedule a time, as many of the residents are at the Britt Vocational College each
weekday.
The PREA compliance manager indicated that attorneys or residents can schedule
call times, and residents may use one of the phones in the common area or a
private office to speak with their attorney.
The PREA compliance manager indicated they handle the same process with
parents in an emergency or when the resident needs to speak with them about
private matters.
Residents interviewed, both formally and informally, while touring the facility,
indicated they were allowed to visit their families and to talk privately with their
parents or legal counsel.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.354 Third-party reporting
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence used in making a compliance determination.
PREA Brochure Posted Information
FDJJ Website
FDJJ Policy 1919 PREA- Third Party Reporting
Youth Handbook
Florida - Poster 1 - CREOLE
Florida - Poster 1 - ENGLISH
Florida - Poster 1 - SPANISH
3rd Party reporting. Poster
Florida - Poster 2 – English
Florida - Poster 1 - Spanish
Florida - Poster 1 - CREOLE
Interviews:
Random Staff
Random Residents
PREA Coordinator
115.354 (a)
The PAQ requires that the agency shall establish a method to receive third-party
reports of sexual abuse and sexual harassment and shall distribute publicly
information on how to report sexual abuse and sexual harassment on behalf of a
resident.
The agency provides multiple access for third-party reporting.
FDJJ websites provide the public with information regarding third-party reporting of
sexual abuse or sexual harassment on behalf of a resident.
The center had a poster on third-party reporting throughout the center.
The auditor called the Abuse Registry Hotline and the DJJ Central Communication
Center. Each agency accepted all and advised that they would notify the Florida
Department of Juvenile Justice, the local Department of Children and Family
Services, and the Office of Inspector General. Each indicated they would accept and
follow through with the notification, including if the call was anonymous.
Reporting Posters were posted in the visitation room during the audit and in the
facility's main lobby. The youth/family handbook contains the phone number and
the various ways for families to make notification of sexual abuse or sexual
harassment to FDJJ or to BTYA.
In interviews, staff indicated they would accept any third-party call, report the
information to the facility administrator, the Florida CCC, and the child abuse
hotline, and protect the youth immediately upon receiving such a call.
The chief investigator's interview indicated that any call from CCC would be
investigated, including third-party or anonymous calls.
The resident interviewed indicated they were aware that a family member could file
a report on their behalf.
Staff interviewed knew their role and most indicated they would immediately
implement the facility’s coordinated response plan. Residents were aware of the
option to inform a friend or family member, who could submit a third-party report.
Compliance was assessed through interviews with randomly selected staff and
residents and by reviewing policies and posters. All telephone numbers listed on the
poster were called and answered by agency staff.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.361 Staff and agency reporting duties
Auditor Overall Determination: Exceeds Standard
Auditor Discussion
Evidence relied upon in making the compliance determination.
FDJJ 1919 Staff and agency reporting
Florida Code 39 Section 201-2020
FDJJ Policy 1.12 Incident- CCC reporting
Staff Training
Interviews with
PREA Compliance Manager
Facility Director
Randomly Selected Staff
Medical and Mental Health Staff
115.361 (a) (b)(c)
The PAQ requires The agency shall require all staff to report immediately and
according to agency policy any knowledge, suspicion, or information they receive
regarding an incident of sexual abuse or sexual harassment that occurred in a
facility, whether or not it is part of the agency; 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.
The PAQ requires that the agency also require all staff to comply with any applicable
mandatory child abuse reporting laws.
The PAQ requires, apart from reporting to designated supervisors or officials and
designated State or local services agencies, staff shall be 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.
The facility provided policy 1919, 1.12, and yearly refresher training for staff.
Florida Administrative Code Rule 63F-11, Central Communications Center (CCC),
requires that any allegation of sexual misconduct or youth-on-youth sexual activity
be reported to the CCC. The person making the report shall provide basic
information such as the date and time of the incident, where the incident occurred,
the supervising staff, and who may be involved. The CCC will make appropriate
notification to senior DJJ management, who will, in turn, make subsequent
notification to management overseeing the facility where the alleged abuse
occurred. In addition to providing appropriate notification through Department
channels, staff should take no further action unless directed by law enforcement or
first responders.
Any staff, contractor(s), or volunteer(s) who receives a report of sexual misconduct
or possible sexual misconduct must ensure that it is reported to the Department of
Children and Families Florida Abuse Hotline, local law enforcement if criminal in
nature, and the CCC. Reports can be received verbally, in writing, anonymously, and
from third parties. All verbal reports shall be documented promptly and reported
accordingly. In addition to reporting to designated supervisors or officials and state
or local service agencies, staff are prohibited from disclosing any information related
to a sexual misconduct report to anyone, except as necessary to make treatment,
investigation, and other security and management decisions. While victims and
complainants may report anonymously, staff who follow up to report the allegations
shall not be afforded anonymous status.
The PREA compliance manager confirmed that the center operates in accordance
with policy mandates.
An interview with the facility Director confirmed that upon notification of a sexual
abuse allegation, he will notify the CCC within 2 hours. If the child is under 18, DFCS
will be notified. Additionally, the youth's parent or legal guardian will be notified in
accordance with DJJ policy. He further stated that if a juvenile court retains
jurisdiction over the victim, the allegation would be reported to the juvenile's
attorney or other legal representative of record
115.361 (d):
The PAQ requires (1) Medical and mental health practitioners shall be 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. (2) Such practitioners shall be
required to inform residents at the initiation of services of their duty to report and
the limitations of confidentiality.
Policy 1919 and 1.12 mandate that medical and mental health practitioners report
sexual misconduct to designated supervisors and Department officials, the CCC, law
enforcement if criminal in nature, and the Florida Abuse Hotline operated by the
Department of Children and Families (s.39.201, F.S.). Said practitioners must inform
residents at the initiation of services of their duty to report and the limitations of
confidentiality.
In interviews with medical and mental health staff, each was aware of their
reporting obligations to inform residents. Neither has received an allegation at the
center. Each also indicated that they are mandated reporters and advised their
duties to report to all residents upon admission to the center. Interviews with the
medical staff and mental health professionals confirmed their limitations of
confidentiality are explained before each assessment and session; as a mandatory
report, they are required to report any knowledge, suspicion, or information
regarding an incident of sexual abuse or sexual harassment to a designated
supervisor or official immediately upon learning of it
115.361 (e):
The PAQ requires 1) Upon receiving any allegation of sexual abuse, the facility head
or his or her designee shall promptly report the allegation to the appropriate agency
office and 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. (2) If the alleged victim is under guardianship of the child welfare system,
the report shall be made to the alleged victim's case worker instead of the parents
or legal guardians. (3) If a juvenile court retains jurisdiction over the alleged victim,
the facility head or designee shall also report the allegation to the juvenile's
attorney or other legal representative of record within 14 days of receiving the
allegation.
The facility provided interviews with the PREA Compliance Manager and facility
director and Child Abuse Reporting provides that upon receiving any allegation of
sexual abuse, the facility head or their designee shall promptly report the allegation
to the appropriate agency office and 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.
Upon receiving any allegation of sexual abuse, the facility director or his or her
designee shall promptly report the allegation to the appropriate agency office and
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.
If a juvenile court retains jurisdiction over the alleged victim, the facility director or
designee shall also report the allegation to the juvenile’s attorney or other legal
representative of record within 14 days of receiving the allegation.
The facility shall report all allegations of sexual abuse and sexual harassment,
including third-party and anonymous reports, to the facility’s designated
investigators.
The interviewed PREA compliance manager reported that when the facility receives
an allegation of sexual abuse call, they will call the Department of Family and
Children's Services hotline. Following the call, the reporting staff must prepare a
report. If a juvenile court retains jurisdiction over the victim, they are informed
within 24 hours of any allegations of sexual abuse.
The facility director reported that if there is an allegation of sexual abuse or sexual
harassment, the allegation is reported to them. Then he would report it via the
hotline for investigation.
115.361 (f):
The PAQ requires the facility shall report all allegations of sexual abuse and sexual
harassment, including third-party and anonymous reports, to the facility's
designated investigators.
The facility provided 1919, and staff training:
Staff training and policy mandates that all employees, volunteers, interns, and
contractors shall immediately report 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 to the shift supervisor, PCM or Administrator.
Policy and training also require reporting any third-party reports of sexual abuse,
sexual harassment, staff neglect, and retaliation.
The center has not had any allegations of sexual abuse or sexual harassment since
becoming operational in August 2024.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.362 Agency protection duties
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination.
FDJJ 1919 Imminent risk
FDJJ 1919 Protective custody
FDJJ 1919 Protection against retaliation
Interview
Agency Head
PREA Compliance Manager
Facility Administrator
Random Staff
PAQ
115.362 (a)
The PAQ requires when an agency learns that a resident is subject to a substantial
risk of imminent sexual abuse, it shall take immediate action to protect the
residents.
The center provided policies 1919 which require if staff learns that a youth is subject
to a substantial risk of imminent sexual misconduct, they shall take immediate
action to protect the youth from further harm or threat. Also, if staff learns a youth
poses a substantial risk of sexually abusing other youth in the facility, they shall
take immediate action to protect other youth from further harm or threat.
During the formal interviews with residents, the auditor asked each resident about
their feelings of safety at the center. All residents indicated they felt safe, and the
center's staff were available to address any concerns.
The interviewed random sample of staff reported that if they learn a resident is at
risk of imminent sexual abuse, they will separate the involved parties, move them
to a safe location, immediately contact the shift supervisor, and the facility director.
Such actions will be taken immediately.
The interviewed agency head reported that when a resident is subject to a
substantial risk of imminent sexual abuse, the center would immediately remove
the resident from the immediate danger/unsafe zone until less restrictive measures
can be found. We would make sure that the resident/victim is not in contact with
any perpetrator with whom the resident is at risk of imminent sexual abuse.
Staff are expected to respond immediately.
The interviewed facility director reported that when they learn that a resident is at
substantial risk of imminent sexual abuse, staff are trained to separate the residents
immediately. We may have to change cottages, monitor daily, and change
classrooms. Check for any additional red flags. Staff are expected to respond
immediately.
Based on the PAQ, there has been no incident where the agency or facility would
have taken action regarding a youth being subject to substantial risk of imminent
sexual abuse.
Compliance was determined by review of policies and interviews with direct care
staff, non-direct care staff, and the facility director.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.363 Reporting to other confinement facilities
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ Policy 1.12 Incident- CCC reporting
FDJJ Policy 1919 - Reporting to other facilities
PAQ
Interviews
Facility Director
Agency Head
115.363(a-d)
The PAQ requires that 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 the appropriate office of the agency
where the alleged abuse occurred and shall also notify the proper investigative
agency.
Such notification shall be provided as soon as possible, but no later than 72 hours
after receiving the allegation.
The agency shall document that it has provided such notification.
The facility head or agency office that receives such notification shall make sure
that the allegation is investigated in accordance with these standards.
Policy 1919 states that upon receiving an allegation that a youth was sexually
abused while confined at another facility, the head of the facility that received the
allegation shall notify the head of the facility where the alleged abuse occurred and
shall also notify the CCC, the Florida Abuse Hotline, and local law enforcement.
The facility will document that it has provided the required notification. The
document will be provided as soon as possible, but no later than 72 hours from
receipt of the allegation. The PREA Compliance Manager shall maintain
documentation of notification.
Policy 1.12 requires the center will notify the CCC office within 2 hours of notification
that a youth was sexually abused.
During the past 12 months, there were no allegations received that a resident was
abused while confined to another facility.
The agency head indicated in the interview that the center must immediately notify
the sending center and the OIG or local law enforcement to conduct the
investigation.
The facility director indicated that no notification has been received at the center.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.364 Staff first responder duties
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 First Responder Duties.pdf
Britt Technical Youth Academy Coordinated Response Plan for PREA Allegations.
Staff training
Random Staff interviews
Random non-direct care interviews
115.364 (a)(b):
The PAQ requires Upon learning of an allegation that a resident was sexually
abused, the first staff member to respond to the report shall be required to: (1)
Separate the alleged victim and abuser; (2) Preserve and protect any crime scene
until appropriate steps can be taken to collect any evidence; (3) 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 (4) 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
evidence, including, as appropriate, washing, brushing teeth, changing clothes,
urinating, defecating, smoking, drinking, or eating 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.
The PAQ requires that if the first staff responder is not a security staff member, the
responder shall request that the alleged victim not take any actions that could
destroy physical evidence and then notify security staff.
The facility provided policy, Britt Technical Youth Academy Sexual Abuse
Coordinated Response, and FDJJ 1919 First Responder Duties staff/contractor
training.
All center staff have been trained in direct supervision and can serve as direct care
staff at any time. All staff are also considered first responders.
Policy 1919 requires
Upon discovery of an incident defined as sexual abuse, staff members are
responsible for taking immediate actions to ensure the safety of the victim and
notifying appropriate law enforcement and medical personnel. These actions
include, but are not limited to, identifying and separating victim(s), suspect(s), and
making every attempt to preserve evidence. The first direct care staff member to
respond to the allegation will:
1. Take immediate action to protect and ensure that the victim is safe, and separate
the alleged victim and perpetrator;
2. Obtain basic information such as where the incident occurred and who may be
involved, but will not ask any other questions;
3. Preserve and protect the crime scene, if applicable, until appropriate steps can
be taken to collect any evidence;
4. If the abuse occurred within a time period that still allows for the collection of
physical evidence, request that the alleged victim and ensure that the abuser does
not take any actions that will destroy physical evidence, including washing, brushing
teeth, changing clothes, urinating, defecating, drinking, eating, etc., and
5. If the first staff responder is a non-direct care staff member, they are required to
ensure the victim is safe and instruct the victim and perpetrator not to take any
actions that will destroy physical evidence and then immediately notify direct care
staff.
a. Youth who are alleged victims of sexual abuse will be treated in a sensitive and
non-judgmental manner.
b. The agency prohibits the use of youth interpreters, youth readers, or other types
of youth assistance except in limited circumstances where an extended delay in
obtaining an effective interpreter could compromise the youth’s safety, the
performance of first-response duties under §115.364, or the investigation of the
youth’s allegations.
c. In secure facilities, staff will ensure that the garments/clothing worn by those
involved and the scenes where the alleged act(s) occurred are protected to ensure
that evidence is not further contaminated. This simply means securing any evidence
until law enforcement and/or the DJJ Office of Investigations arrive. Securing means
maintaining control over the evidence or scene and documenting any access to or
deviations from that evidence. Staff shall not move, touch, or alter the evidence in
any way. Staff should not discuss any facts of the incident with anyone except those
directly involved in the response or investigation. All of this information is reportable
to law enforcement and subsequent investigators.
It is essential that the garments/clothing worn by those involved and the scenes
where alleged act(s) occurred be protected to ensure that evidence is not further
contaminated. This simply means securing any evidence until law enforcement
arrives. Securing is defined as maintaining control over the evidence or scene and
documenting any access to or deviation from that evidence. Staff shall not move,
touch, or alter the evidence in any way. Staff shall not discuss any acts or incidents
with anyone except those directly involved in the response or investigation of the
incident. All of this information is reportable to law enforcement and subsequent
investigators.
Twelve staff were interviewed. Each of the staff members was able to articulate their
responses if a resident made an allegation of sexual abuse. Each of the staff
indicated they would separate the victim and abuser and request that the victim
and abuser not do anything to destroy any evidence.
One teacher was interviewed and was able to articulate their response, including
notifying the closest direct care staff.
Staff interviewed confirmed they knew their obligations when a resident makes an
allegation or they suspect an incident of sexual abuse has occurred.
Based on the PAQ and review of investigative files in the past 12 months, no
allegations that a resident was sexually abused were reported.
In the past 12 months, no allegations were reported to staff notified within a time
period that still allowed for the collection of physical evidence:
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.365 Coordinated response
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
Britt Technical Youth Academy Coordinated Response Plan for PREA Allegations.
FDJJ 1919 Coordinated Response.pdf
Interview with the facility director
115.365 (a)
The PAQ requires the facility shall develop a written institutional plan to coordinate
actions taken in response to an incident of sexual abuse, among staff first
responders, medical and mental health practitioners, investigators, and facility
leadership.
Policy 1919 establishes that each facility will develop a site-specific coordinated
response plan.
The interviewed facility director reported that the facilities coordinate response is
that initially direct care staff they are going to ensure safety with the victim,
separate involved parties, make sure that they are not tampering with the evidence
(no shower, change of clothes, leave site in tac), they will notify me and I
will contact the local sheriff’s office and making a hotline call. We would offer a
follow-up for emotional support services. We also provide residents with the
opportunity to have a community victim advocate offer support services. Staff are
trained on the plan each year.
This plan outlines the procedures and specific duties of the First Responders, Control
Room Operator, Medical Staff, Mental Health Staff, Administrative Duty Officer,
Investigator, and Facility Leadership. Additionally, the plan establishes and defines
the roles of the Sexual Abuse Coordinated Team Members.
Compliance was determined through a review of the Coordinated Response plan and
interviews with the facility director, Captain, Shift Supervisors, medical director,
mental health provider, and a randomly selected staff member.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
Preservation of ability to protect residents from contact with
115.366
abusers
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
Interview with Wanes Halfway House Agency Head
The PAQ requires that neither the agency nor any other governmental entity
responsible for collective bargaining on the agency's behalf shall enter into or renew
any collective bargaining agreement or other agreement that limits the agency's
ability to remove alleged staff sexual abusers from contact with residents pending
the outcome of an investigation or of a determination of whether and to what extent
discipline is warranted.
The center provided an interview with the agency head.
In interviews with the agency head, neither the agency nor any other governmental
entity responsible for collective bargaining on the agency's behalf shall enter into or
renew any collective bargaining agreement or other agreement that limits the
agency's ability to remove alleged staff sexual abusers from contact with residents
pending the outcome of an investigation or of a determination of whether and to
what extent discipline is warranted.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.367 Agency protection against retaliation
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Protection against retaliation.
Retaliation Log (blank)
Interviews with
Agency Head
Facility Director
Staff who conduct Retaliation Monitoring
15.367 (a):
The PAQ requires the agency shall establish 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 and
shall designate which staff members or departments are charged with monitoring
retaliation.
The facility provided policy 1919, retaliation sheets, and Retaliation monitoring staff.
Policy 1919 mandates Directors, Facility PREA Compliance Managers, and other
supervisors will take immediate steps to ensure that youth alleging sexual abuse
and sexual harassment, or staff reporting, are not victims of any form of retaliation.
After a resident reports alleged sexual abuse or sexual harassment, staff must
complete Retaliation Log Sheets on each resident involved in the retaliation
monitoring.
Monitoring for retaliation shall start immediately once an allegation of sexual abuse
or sexual harassment has been made. Monitoring shall last for at least 90 days.
Termination of monitoring can only occur prior to 90 days if the investigation has
determined that the allegation is unfounded or if the person (youth/staff) is no
longer at the site. Monitoring can continue beyond 90 days if there is reason to
believe retaliation or fear is an ongoing concern, or if there are any extenuating
circumstances.
The PREA Compliance Manager shall immediately begin monitoring for retaliation
upon receipt of an allegation.
When monitoring for retaliation, the following should be observed:
1. The conduct and treatment of a resident or staff member who reported the
sexual abuse and sexual harassment.
2. Resident disciplinary reports.
3. Housing.
4. Program changes.
5. Negative performance reviews; or
6. Reassignment of staff.
The center provided a memo that indicated that during the last 12 months, there
have been no allegations of sexual allegation of sexual abuse that are being
monitored for retaliation.
An interview with the Agency head indicated that the facility leadership will assess
the situation and speak to the youth regarding their safety. Additionally, the facility
has a PREA Compliance Manager who is responsible for monitoring for retaliation. If
necessary, we will change housing units, change facilities, remove alleged abusers,
and youth are offered follow-up with mental health or outside counseling services.
In interviews with the facility director, he indicated that the center would monitor
throughout the investigation. We would move residents to other cottages,
classrooms, and recreation periods. We would place staff on no-contact status. If we
expected retaliation we would request the OIG complete an investigation.
We can also place staff on no-contact status or administrative leave.
If an individual who cooperates with an investigation expresses fear of retaliation,
how does the agency take measures to protect that individual? We will monitor the
situation and remove any parties that are involved in inciting fear among staff or
youth. If the local staff are unable to conduct the monitoring, the agency PREA
Coordinator will conduct it. If retaliation occurs, it will be investigated.
The retaliation monitor indicated that he would meet with the staff and residents
and explain the retaliation monitoring process. I would review any expected
changes in the resident's routine, such as eating alone, being away from peers, staff
not actively involved with the youth, and disciplinary reports. I would also have
given the youth a chance to the emotional support staff at the Crisis Center and
asked for their input.
115.367 (b):
The PAQ requires the agency to 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 facility provided 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 facility director stated that he would meet with the youth as soon as the
incident was reported, ask them about their safety concerns, and make immediate
accommodations as needed to protect the resident and staff.
The interviewed staff charged with monitoring for retaliation reported that their role
in preventing retaliation against residents and staff who reported sexual abuse or
sexual harassment, or against those who cooperated with sexual abuse or sexual
harassment investigations, was to keep the victim and predator separate and let the
resident know of the supportive services available. If staff are involved, we would
place them on non-contact status or administrative leave.
When asked Do you initiate contact with residents who reported sexual abuse it was
reported that we would make contact and check in at least once a shift.
The retaliation monitors and PREA compliance manager indicated they would
provide resident housing changes or transfers for resident victims or abusers,
removal of alleged staff or resident abusers from contact with victims, and
emotional support services.
115.367 (c):
The PAQ requires that, 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.
It 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 facility provided monitoring instrument, which requires the facility to monitor
residents, beginning as soon as a resident or staff member makes an allegation of
sexual abuse or sexual harassment, and will continue for a minimum of 90 days.
Retaliation may continue beyond 90 days based on the investigation, the resident’s
safety, the resident's perception of safety, or staff concerns.
There have been no incidents of retaliation during the 12 months preceding the
audit.
115.367 (d):
The PAQ requires, in the case of residents, that such monitoring shall also include
periodic status checks.
The Retaliation monitor indicated status checks would be initiated with staff and
residents.
The facility director indicated he would see the youth at least once a week and see
how they are doing.
In interviews with the facility director and retaliation monitors, both indicated that
they see the youth at the center almost every day, usually five to ten times a day,
and conduct daily status checks with all youth. They also indicated that they are
required to document their monitoring.
115.367 (e):
The PAQ requires that if any other individual who cooperates with an investigation
expresses a fear of retaliation, the agency shall take appropriate measures to
protect that individual against retaliation.
The facility provided interviews with the agency head and facility administrator.
The agency head and facility director indicated that 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. Policy states
that if any other individual who cooperates with an investigation expresses the
occurrence of retaliation from another resident or staff member.
The facility director indicated he would monitor staff who report and/or cooperate
with any investigations. The retaliation monitor interviewed indicated they would
meet with the resident every week to ensure there is no retaliation for reporting
sexual abuse or sexual harassment.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.368 Post-allegation protective custody
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Protective custody.pdf
FDJJ 1919.pdf
Interviews
Facility Administrator
Medical and Mental Health Staff
115.368 (a):
The PAQ requires that any use of segregated housing to protect a resident who is
alleged to have suffered sexual abuse shall be subject to the requirements of §
115.342.
The center provided policies 1919. The center also provided an interview with the
facility director, stating that it has not used isolation during the last PREA cycle.
Policy 1919 states that youth may be isolated from others only as a last resort when
less-restrictive measures are inadequate to keep them and other youth safe, and
then only until an alternative means of keeping all youth safe can be arranged.
a. The facility shall clearly document the basis for the facility’s concern for the
youth’s safety and the reason no alternative means of separation can be arranged.
b. Youth in isolation shall not be denied large-muscle exercise and educational
programming.
c. Youth in isolation shall receive daily visits from medical and mental health
practitioners.
The facility director's interview confirmed compliance with this standard. According
to the facility director, there has been no time when a resident was separated or
isolated from other residents for an allegation of sexual abuse or harassment, or for
fear of being sexually abused. Britt Technical Academy is a half way program and
youth are housed here while they attend Britt Technical College.
We have no isolation room or any means of isolating a youth. We would have to
place resident on one on one supervision and request an immediately transfer to
the area RYDC until appropriate measure can be implemented.
The medical and mental health staff interviewed indicated that they visit any youth
placed in any isolated area as identified by the facility director.
During a tour of the center, no isolation rooms or areas were identified by staff,
youth, or administrators. A review of the investigation reports did not reveal any
youth who were segregated.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.371 Criminal and administrative agency investigations
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Investigations.pdf
Interviews
Facility Administrator
PRA Coordinator
OIG Chief of Investigator
115.371 (a):
The PAQ requires that when the agency conducts its own investigations into
allegations of sexual abuse and sexual harassment, it shall do so promptly,
thoroughly, and objectively for all allegations, including third-party and anonymous
reports.
FDJJ Policy 1919 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. The Department of Family
and Children conduct a separate investigation involving residents under the age of
18.
115.371 (b):
The PAQ requires that, 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.
The Office of Inspector General follows protocols in conducting administrative
investigations in FDJJ settings and the investigators receive training on the related
agency policies Florida Department of Juvenile Justice has requested the agencies
that conduct allegation of sexual abuse or sexual harassment follow the PREA
standards.
15.371 (c):
The PAQ requires that Investigators gather and preserve direct and circumstantial
evidence, including any available physical and DNA evidence and any available
electronic monitoring data; interview alleged victims, suspected perpetrators, and
witnesses; and review prior complaints and reports of sexual abuse involving the
suspected perpetrator.
The Office of Inspector General follows protocols in conducting administrative
investigations in FDJJ settings and the investigators receive training on the related
agency policies Florida Department of Juvenile Justice has requested the agencies
that conduct allegation of sexual abuse or sexual harassment follow the PREA
standards.
All staff interviewed were aware of their responsibility to secure the scene and not
allow victims or abusers to destroy the evidence.
The investigator gathers all surveillance documents, telephone calls recording if
available, conducts interviews with the resident victim, witnesses, staff on duty,
control room staff, and lastly the abuser.
115.371 (d):
The PAQ requires the agency not to terminate an investigation solely because the
source of the allegation recants the allegation
The agency shall not terminate an investigation solely because the source of the
allegation recants the allegation.
The Investigator’s supervisor confirmed that an investigation does not terminate if
the source of the allegation recants the allegation.
115.371 (e):
The PAQ requires 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.
Any criminal investigations are conducted by local law enforcement and would be
referred to appropriate jurisdiction for prosecution. Completed reports shall be
retained in the Office of the inspector general in accordance with the state retention
schedule. Interviews with Facility Administrator and investigator confirmed that the
present retention period is the agency retain all written reports referenced in
115.371 for as long as the alleged abuser is incarcerated or employed by the
agency, plus five years.
The Office of Investigation Supervisor confirmed that when he discovers evidence
that a prosecutable crime may have occurred, he will consult with a prosecutor to
determine whether the agency shall conduct compelled interviews.
115.371 (f):
The PAQ requires the credibility of an alleged victim, suspect, or witness who 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.
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):
The PAQ requires administrative investigations: (1) Shall include an effort to
determine whether staff actions or failures to act contributed to the abuse; and (2)
Shall be documented in written reports that include a description of the physical and
testimonial evidence, the reasoning behind credibility assessments, and
investigative facts and findings.
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 description of the physical and testimonial evidence,
the reasoning behind credibility assessments, and investigative facts and findings.
The investigator interviewed reported that the following efforts would be made
during the administrative investigation to determine whether staff actions or failures
to act contributed to sexual abuse.
115.371 (h):
The PAQ requires 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.
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.
The agency PREA coordinator provided an accountability statement. The center has
not received any allegations that were referred for prosecution in the last 12
months.
115.371 (i):
The PAQ requires that Substantiated allegations of conduct that appears to be
criminal shall be referred for prosecution.
(i): Substantiated allegations of conduct that appear to be criminal shall be referred
for prosecution.
115.371 (j):
The PAQ requires 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.
Policy 1919 states 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):
The PAQ requires the departure of the alleged abuser or victim from employment or
control of the facility or agency shall not provide a basis for terminating an
investigation.
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 (m):
The PAQ requires 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.
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. As part of the responsive planning staff are trained in protecting
the crimes scene and cooperating with investigative units.
All investigative files are maintained by the OIG office portal is password protected
and limited to staff that have access to this portal.
Compliance was determined by interviews with the Director and assistant director of
investigations, investigator, PREA coordinator, Agency Head, Agency website, and
facility superintendent. Compliance was also determined by review of 15
investigative files.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.372 Evidentiary standard for administrative investigations
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination.
FDJJ Policy 1919 – Investigations
FDJJ Office of the Inspector General conducts administrative investigations.
Interviews
Chief of Investigative Unit (OIG)
115.372
The PAQ requires the agency shall impose no standard higher than a preponderance
of the evidence in determining whether allegations of sexual abuse or sexual
harassment are substantiated.
The investigator may make a finding of Substantiated, Not Substantiated,
unfounded, or Pending Further Investigation. The findings will be made using the
standard of proof of the preponderance of the evidence (51 % of the evidence). The
Investigator must objectively review all evidence in favor of or contrary to the
finding. The investigator must objectively consider and balance the evidence in
favor of or contrary to the finding, and to support a finding of sexual abuse or
harassment by a preponderance of evidence. The investigator must be convinced
that the evidence in favor of the finding outweighs the evidence against the finding,
or is confident that the evidence, when taken as a whole, shows that it is more
probable than not that the alleged incident took place in this case.
Compliance with the standard was determined by reviewing the Policy, the
investigative report, and interviews with the agency PREA coordinator and
the investigator from the Office of Inspector General.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.373 Reporting to residents
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FLDJJ policy 1919 Resident Notification
Interviews with
Facility Administrator
OIG Chief
115.373 (a)(c)(d)(e):
The PAQ requires the following: Following an investigation into a resident's
allegation of sexual abuse suffered in an agency facility, the agency shall inform the
resident as to whether the allegation has been determined to be substantiated,
unsubstantiated, or unfounded.
All such notifications or attempted notifications shall be documented.
The facility provided Policy 1919, notification forms, and an interview with the
director of investigation and the facility director.
Investigator Training Curriculum: When an investigation into a youth's allegation of
sexual misconduct occurring in a facility is conducted, the facility shall inform the
victim or the victim's parent(s) or legal guardian(s) by letter whether the allegation
has been determined to be substantiated, unsubstantiated, or unfounded.
At the conclusion of an investigation, based on an interview with the Director of
Investigation, the OIG staff will inform the victim whether the allegation has been
substantiated, unsubstantiated, or unfounded.
Policy 1919 requires that all such notifications or attempted notifications be
documented.
The agency provides policy 1919, which states
Following an investigation into a youth’s allegation of sexual misconduct occurring
in a facility, the facility shall inform the victim or victim’s parent(s) or legal
guardian(s) by letter as to whether the allegation has been determined to be
substantiated, unsubstantiated, or unfounded.
a. Following a youth’s allegation that a staff member has committed sexual
abuse against the youth, the youth will be informed (unless the allegation is
unfounded) whenever:
i. The staff member is no longer posted within the youth’s unit.
ii. The staff member is no longer employed at the facility.
b. Following a youth’s allegation that he or she has been sexually abused by
another youth, the alleged victim will be informed whenever:
i. The agency learns that the alleged abuser has been indicted on a charge
related to sexual abuse within the facility.
ii. The agency learns that the alleged abuser has been convicted on a charge
related to sexual abuse within the facility.
a. All such notifications or attempted notifications shall be documented.
115.373 (b):
If the agency did not conduct the investigation, it shall request the relevant
information from the investigative agency in order to inform the residents.
In interview with the center director and PREA compliance manager, the center
would reach out to the investigative agency and request information needed to
make a notification to the youth and parent or legal guardian.
Based on the PAQ there were no allegations of sexual abuse or sexual harassment in
the last 12 months.
Based on a review of the policy and interviews with the investigator and facility
director, and a review of the investigation files, it was determined that the agency is
in compliance with this standard.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required
115.376 Disciplinary sanctions for staff
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
Employee Handbook
FDJJ 1919 Disciplinary sanctions.
Interview with Facility Administrator
115.376 (a)(b) (c) (d) :
The PAQ requires that staff be subjected to disciplinary sanctions up to and
including termination for violating agency sexual abuse or sexual harassment
policies.
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.
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.
The PAQ requires that 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, shall be reported to law enforcement
agencies, unless the activity was clearly not criminal, and to any relevant licensing
bodies.
The facility provided policy 1919 and the employee handbook.
The facility director indicated that upon the conclusion of the investigation, if staff
are determined to have been 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.
Policy 1919 states that DJJ has zero tolerance for any acts of sexual abuse, assault,
misconduct, or harassment. Sexual activity between staff and juveniles, volunteers,
or contract personnel and juveniles is prohibited and subject to administrative and
criminal disciplinary sanctions. Staff will be subject to disciplinary sanctions up to
and including termination and criminal prosecution for violating the agency’s sexual
abuse or sexual harassment policies. (See DJJ 3.80, Employee Progressive
Discipline.)
Failure to comply with the requirements of this policy and procedures may result in
disciplinary action, up to and including dismissal. All terminations for violations of
agency sexual abuse policy, or resignations by staff who would have been
terminated if not for their resignation, shall be reported to law enforcement
agencies, unless the activity was clearly not criminal.
Termination shall be the presumptive disciplinary sanction for staff who have
engaged in sexual abuse.
The PAQ indicated that no staff were disciplined for PREA-related allegations in the
last 12 months.
According to an interview with the facility administrator, all staff members who are
terminated 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.
Compliance was determined through a review of the agency policy and interviews
with the PREA facility director.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required
115.377 Corrective action for contractors and volunteers
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ Training for Volunteers & Contractors 5.1.25.pdf
Visitors and Volunteers.pdf
Britt Technical Youth Academy Coordinated Response Plan for PREA Allegations.
FDJJ 1919 Disciplinary sanctions.pdf
PAQ
Interview with Facility Director
115. 377 (a)(b)
The PAQ requires that any contractor or volunteer who engages in sexual abuse
shall be prohibited from contact with residents and shall be reported to law
enforcement unless the activity was clearly not criminal, and to relevant licensing
bodies.
The PAQ requires the facility to take appropriate remedial measures and consider
whether to prohibit further contact with residents in the case of any other violation
of agency sexual abuse or sexual harassment policies by a contractor or volunteer.
The facility provided volunteer and contract training, Policy 1919, and an interview
with the facility director.
Policy 1919 states Policy 1919 states DJJ has zero tolerance for any acts of sexual
abuse, assault, misconduct or harassment. Sexual activity between staff and
juveniles, volunteers or contract personnel and juveniles, and juvenile and juveniles
is prohibited and subject to administrative and criminal disciplinary sanctions. Staff
will be subject to disciplinary sanctions up to and including termination and criminal
prosecution for violating the agency’s sexual abuse or sexual harassment policies.
A volunteer's services may be postponed, curtailed, or terminated if the volunteer
has not provided services within 12 months, or if the volunteer's activity threatens
the order and security of the program or the volunteer's safety.
Policy 1919 requires that any contractor or volunteer who engages in sexual abuse
be prohibited from contact with youth and will be reported to law enforcement
agencies and relevant licensing bodies, unless the activity was clearly not criminal.
Based on an interview with the facility director, in the case of any other violation of
agency sexual abuse or sexual harassment policies by a contractor or volunteer, the
facility will take appropriate remedial measures. It shall consider whether to prohibit
further contact with the youth.
The facility provided interviews with the facility director and the PAQ.
In an interview with the facility director, he indicated that he has the authority
to take remedial measures to prohibit contractor of volunteer from entering the
centers In the case of any other violation of agency sexual abuse or sexual
harassment policies by a contractor or volunteer, the facility 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.
Based on the PAQ, there have been no PREA-related adverse actions involving
contractors or volunteers during the last 12 months.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.378 Interventions and disciplinary sanctions for residents
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Youth Disciplinary Action
BTYA Res Handbook
PAQ
Interview with
Facility Director
Mental Health Staff
115.378 (a) (b):
The PAQ requires that 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.
The PAQ requires that any disciplinary sanctions 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.
The facility provided policy 1919. Resident handbook, and mental health interviews.
Policy 1919 states that youth will receive appropriate interventions if they engage in
youth-on-youth sexual abuse. Decisions regarding which types of interventions to
use in particular cases, including treatment, counseling, education programs, or
disciplinary sanctions, will be made to promote improved behavior by the youth and
ensure the safety of other youth and staff.
OIG or local law enforcement will refer youth for criminal prosecution when
appropriate. The agency will discipline youth for sexual conduct with staff only upon
finding that the staff member did not consent to such contact.
BTYA facility director indicated that the center does not isolate youth as a
disciplinary sanction.
115.378 (c):
The PAQ requires 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 Facility Director stated that mental disability, or mental illness, is considered
when determining sanctions.
The mental health staff indicated she would be contacted prior to any disciplinary
action.
115.378 (d):
The PAQ requires that 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 provide 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
behavior-based incentives, but not as a condition of access to general programming
or education.
According to the mental health staff, the facility offers therapy, counseling, or other
interventions designed to address and correct the underlying reasons or motivations
for abuse. If the facility offers therapy, counseling, or other interventions designed
to address and correct the underlying reasons or motivations for abuse, it considers
whether to require the offending resident to participate in such interventions as a
condition of access to any rewards-based behavior management system or other
behavior-based incentives. Access to general programming or education is not
conditional on participation in such interventions. At the present time we don’t have
a staff trained in providing sexual abuse therapy and would have to outsource these
services.
115.378 (e):
The PAQ requires that 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.
Policy 1919 and State Law require 10.Section 985.701, Florida Statutes, makes
certain acts of sexual misconduct between a youth and staff person a felony. A
youth’s consent to sexual acts with a staff member is not a defense under this
subsection of the law.
In interviews with the PREA coordinator, youth would only be disciplined if staff
members did not consent to sexual abuse. However, staff would be disciplined
under the subsection of the law.
115.378 (f):
The PAQ requires 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.
Policy 1919 states that a report of sexual misconduct made in good faith based
upon a reasonable belief that the alleged conduct occurred shall not constitute
falsely reporting an incident, even if an investigation does not establish evidence
sufficient to substantiate the allegation.
Youth shall be advised that any person who knowingly and willfully makes a false
report to the Florida Abuse Hotline or counsels another to make a false report is
guilty of a third-degree felony in accordance with Chapter 39.205, Florida Statutes.
Anyone reporting in a good faith shall be immune from any civil or criminal liability.
115.378 (g):
The PAQ requires that 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.
The facility provided 1919, which indicates the center prohibits 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.
Residents interviewed indicated they were advised that they would be disciplined
for any sexual abuse, sexual harassment, or sexual misconduct. On the first day,
during their orientation, they arrived at the center. Most indicated that they are
reminded of their duties to hold one another accountable for maintaining a safe
environment for all residents.
Based on this analysis, the facility is substantially compliant with this provision and
a corrective action is not required.
115.381 Medical and mental health screenings; history of sexual abuse
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in make compliance determination
FDJJ 1919 MH and Medical
Consent to Disclose.
Interview with
Medical Staff
Mental Health Staff
115.381 (a)(b)(c)
The PAQ required 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, staff shall ensure that the resident is offered a follow
up meeting with a medical or mental health practitioner within 14 days of the intake
screening.
The PAQ requires 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, staff shall ensure that the resident is offered a follow
up meeting with a mental health practitioner within 14 days of the intake screening.
The PAQ requires any information related to sexual victimization or abusiveness that
occurred in an institutional setting that shall be strictly limited to medical and
mental health practitioners and other staff, as necessary, to inform treatment plans
and security and management decisions, including housing, bed, work, education,
and program assignments, or as otherwise required by Federal, State, or local law.
The facility provided Policies 1919 (Mental Health Screening), (Medical Screening),
Policy 1919 medical services staff and mental health practitioners will obtain
informed consent from youth before reporting information about prior sexual
victimization that did not occur in a facility setting, unless the youth is under the
age of 18.
If an intake 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, staff will ensure that the resident is offered a follow-up meeting/session
with a mental health or medical practitioner within 14 days of the intake screening.
The information collected during the medical and mental health screening is strictly
limited to informing security and to making management decisions regarding
treatment plans, housing, work, education, and program assignments.
The facility indicated on the PAQ that 100% of those who reported prior
victimization received follow-up services. Youth are screened by medical within two
hours of arrival during intake. An interview with the Medical Director and (2) mental
health counselors found that referrals to mental health for youth with a history of
sexual victimization are made within 72 hours, and the youth is seen within 14 days
after the referral.
The mental health staff indicated they interview every resident the day they arrive
at the center. Before the interview, they review the VSAB to determine if they have
been a victim of sexual abuse or exploitation.
115.381 (d):
The PAQ requires medical and mental health practitioners shall 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.
During intake, each youth signs the Consent to Disclose, which explains mandatory
reporting laws and the limitations of confidentiality.
The mental health staff interviewed indicated that they explain their duties to report
and explain their options if they are over 18. They also provide youth with the
opportunity to speak with the Crisis Center staff.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.382 Access to emergency medical and mental health services
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in make compliance determination
3.02 Licensed Mental Health and Substance Abuse Clinical Staff BTYA
3.05 Mental Health and Substance Abuse Assessment-Evaluation BTYA
3.04 Mental Health and Substance Abuse Admission Screening BTYA 1.30.25.
3.14 Mental Health Crisis Intervention Services BTYA
3.08 Specialized Treatment Services BTYA.docx
3.15 Crisis Assessments BTYA 1.31.25.docx
Documentation Of Agreement.pdf
FDJJ 1919 Placement of Youth.pdf
VSAB form RC8050.pdf
4.06 Healthcare Admission Screening and Rescreening Form BTYA.
Interview with Medical Staff Mental Health Staff
Crisis Center SANE
115.382 (a) (b)
The PAQ requires that 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.
The facility provided Policy 1919, 4.06, 3.15. 3.08, 3.14, 3.04, 3.05, 3.02, and
interviews with medical and mental health staff.
Policy 1919 indicates that the facility will offer medical and mental health evaluation
and appropriate treatment to all youth who have been victimized by sexual abuse
(inside or outside the facility). Victims of sexual abuse while confined in a secure
facility will be offered tests for sexually transmitted infections as medically
appropriate.
The facility will provide the required services or enter into an MOU with the nearest
Rape Crisis Center to ensure that youth receive them.
The facility will conduct a mental health evaluation of all known youth-on-youth
abusers within 72 hours of learning of such abuse history and offer treatment when
deemed appropriate by mental health practitioners.
Policy 3.14 includes that if the youth is an alleged victim in a PREA event, a Mental
Health and Substance Abuse Referral Summary must be submitted immediately for
a Crisis Assessment, and the youth will be offered ongoing mental health treatment
services consistent with the community level of care.
Youth Self-Referral: Youth must be permitted to request Mental Health and
Substance Abuse Crisis Intervention. Youth Self-Referrals are also documented on
the Mental Health/Substance Abuse Referral Summary Form (MHSA 014).
Policy 4.06 Healthcare Admission Screening and Rescreening Form BTYA requires
that if the youth is in need of immediate medical attention, ensure the youth is
transported to the local Emergency Room for treatment, or call 911 and notify the
Designated Health Authority.
When there is a report of a sexual assault from a youth to a staff member, or there
is suspicion of sexual assault, the staff member will immediately refer the youth to
the medical services staff. An initial evaluation and determination of the need for an
outside medical referral for further testing and evaluation will be performed.
1. Any allegation, suspicion, or report of a sexual assault that includes
penetration will be immediately referred for outside medical testing and evaluation.
2. The facility Director or Office of Investigations staff may independently
decide that a youth must be referred for outside medical testing and evaluation.
3. Facility/program or medical services staff members are strictly
prohibited from performing any forensic examinations or testing that may be used
as evidence against the youth (e.g., Sexual Assault Nurse Examiners [SANE]
examinations. DJJ 11.14.III.M). In addition, examinations of alleged perpetrators will
be performed by an outside medical provider.
4. The medical services staff or the investigating PREA Investigator will
contact the emergency room staff to request that the youth be evaluated for injuries
related to the alleged sexual assault, using the sexual assault kit and standard
The facility Director will ensure that victims of sexual abuse while confined shall be
offered timely information and access to emergency contraception and sexually
transmitted infections prophylaxis, in accordance with professionally accepted
standards of care, where medically appropriate.
An interview with the agency's medical staff confirmed that a resident who
experiences sexual abuse will be taken to Crisis Center for treatment. Interviews
with the facility Director, PREA Coordinator, and medical staff explained that an
advocate from the Crisis Center.
An interview with the Nurse Manager confirmed that youth would be offered timely
information access to sexually transmitted infection prophylaxis at the local
hospital. The facility will provide follow-up treatments as ordered by the physician.
These services will be provided in a timely and consistent manner, in accordance
with the professionally accepted standards of care.
No youth received emergency medical treatment for sexual abuse within the audit
cycle.
115.382 (c):
The PAQ requires that 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 facility provided an interview with medical staff and Crisis Center staff.
The medical staff indicated that the information about emergency contraception
and sexually transmitted infections prophylaxis is part of the SANE process, and any
child will have follow-up services as part of the SANE process. The same information
will be provided to victims during the follow-up meeting, the examination, and
the mental health follow-up.
Policy 1919 indicates victims of sexual abuse receive timely, unimpeded access to
emergency medical and crisis intervention services, including information about and
access to emergency contraception and sexually transmitted infection prophylaxis.
Medical staff and random staff indicated that the center would transport victims of
sexual abuse to the Crisis Center.
The center has posters regarding these victims and pregnancy services posted in
the center.
115.382 (d):
The PAQ requires that treatment services 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.
The facility provided 1919, which 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 confirmed through staff interviews.
Based on analysis, the facility is substantially compliant with this provision and
corrective action is not required.
Ongoing medical and mental health care for sexual abuse victims
115.383
and abusers
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Ongoing MH and medical.pdf
Consent to Disclose Interview with
Crisis Center of Tampa Bay
Medical Staff
Mental Health Staff
115.383 (a)(b):
The PAQ requires 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.
The PAQ requires 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.
The facility provided Policy 1919, as well as interviews with medical staff, mental
health staff, and Crisis Center staff.
Policy 1919 indicates the facility will offer medical and mental health evaluation
and appropriate treatment to all youth who have been victimized by sexual abuse
(inside or outside the facility). Victims of sexual abuse while confined in a secure
facility will be offered tests for sexually transmitted infections as medically
appropriate.
The facility will conduct a mental health evaluation of all known youth-on-
youth abusers within 72 hours of learning of such abuse history and offer treatment
when deemed appropriate by mental health practitioners.
The facility director indicated in the interview that the facility would provide
treatment, as prior victimization can be part of the treatment needed for recovering
youth. The facility makes a referral to mental health for anyone who provides
information on prior victimization or past predator behavior to comply with the
standard.
Residents receive a mental health and medical screening upon arrival at the center
and can request these services at any time.
The mental health staff indicated they see each resident upon arrival at the center
and at least once a month. They are usually seen each week. When the youth arrive
at the center, I do a mental health evaluation and develop a treatment plan when
appropriate.
The Crisis Center interview indicated that anyone who undergoes a SAFE/SANE
evaluation is scheduled to meet with the victim advocate for follow-up.
The Crisis Center provides ongoing mental health counseling services for residents
assigned from their geographic location and makes referrals to the Florida Coalition
against sexual Violence.
The facility provided the Facility 1919, which includes a provision that the evaluation
and treatment of such victims shall consist of, 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.
During intake, youth will receive written information on how to access medical,
mental health, and dental health services.
Health education on preventive medicine and strategies to support the
development of personal health care regimens will be provided to youth. Such
education shall include, but not be limited to, counseling during medical screening,
history & physical examinations, and orientation on personal hygiene and disease
control. It may consist of the benefits of regular exercise and proper nutrition. In
addition, when appropriate, health care personnel will assist youth /parents in
identifying community health care referrals, including chronic and convalescent
care, preventive maintenance, and emergency care.
Interviews with the director and residents confirmed on-going medical and mental
health care will be provided as appropriate and will include, but not be limited to,
additional testing and medical services; medication management, if prescribed;
individual counseling; trauma group; and referrals as needed.
115.383 (c):
The PAQ requires that the facility shall provide such victims with medical and mental
health services consistent with the community level of care. In the interview, the
medical and mental health staff indicated that the services provided to the youth
meet or exceed community standards.
115.383 (d-e):
The PAQ requires that resident victims of sexually abusive vaginal penetration while
incarcerated shall be offered pregnancy tests.
If pregnancy results from the conduct described in paragraph (d) of this section,
such victims shall receive timely and comprehensive information about and timely
access to all lawful pregnancy-related medical services.
The center provided that it is a male facility.
115.383 (f)
The PAQ requires that resident victims of sexual abuse while incarcerated be offered
tests for sexually transmitted infections as medically appropriate.
Policy states that “Ongoing medical and mental health care for sexual abuse victims
and abusers. The facility shall offer medical and mental health evaluations and
appropriate treatment in adherence to PREA Standards. As part of the intake
process, residents complete a medical screening that includes questions about
whether the resident is sexually active.
According to an interview with the nurse, all residents are advised of sexually
transmitted infections and are tested when they arrive at the center.
115.383 (g)
The PAQ requires 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.
The facility provided 1919 , which requires that treatment services be provided to
the victim at no cost, regardless of whether the victim names the abuser or
cooperates with any investigation arising from the incident. This was also confirmed
through staff interviews
115.383 (h)
The PAQ requires the facility shall 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.
Services will include, but not be limited to, individual, group, and family counseling.
Additionally, an evaluation or reassessment will be conducted using the Screening
Assessment.
The mental health staff interviewed indicated that all residents receive a mental
health screening when they arrive at the center, and all residents are rescreened
within 60 days of arrival at the center. Any resident who is known to have abused
another resident would be seen when they first arrived at the center, and as soon as
the mental health staff knows it.
Based on this analysis, the facility is substantially compliant with this provision and
corrective action is not required.
115.386 Sexual abuse incident reviews
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination.
FDJJ 1919 Incident Review
Interviews with
Incident Review Team
PREA Compliance Manager
Facility Director
Florida Department of Juvenile Justice PREA coordinator
115.386 (a)(b):
The PAQ requires the facility shall 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.
The PAQ requires that Such review shall ordinarily occur within 30 days of the
conclusion of the investigation.
The PAQ indicated there have been no incident review team meetings in the last 12
months.
The facility provided PREA Policy 1919 and an interview with the FDJJ PREA
coordinator.
Policy 1919 requires that the PREA Statewide Coordinator will conduct a sexual
misconduct incident review at the end of every sexual misconduct investigation or
administrative review, including those where the allegation has not been
substantiated, unless the allegation has been determined to be unfounded. Said
review shall ordinarily be conducted within 30 days of the conclusion of the
investigation. The review team shall include the PREA Facility Compliance Manager,
Department program area staff, upper-level management, with input from line
supervisors, including medical and mental health officials. The OIG may participate
when the OIG investigates the incident. If applicable, information regarding
administrative investigations resulting from a sexual misconduct incident shall be
included in such reviews, including the reasoning behind the credibility
assessments.
6. The review team shall:
a. Consider whether the allegation or investigation indicates a need to change
policy or practice to better prevent, detect, or respond to sexual misconduct;
b. Consider whether the incident or allegation was motivated by race, sex,
ethnicity, gang affiliation, or was motivated or otherwise caused by other group
dynamics at the facility.
c. Examine the area in the facility where the incident allegedly occurred to
assess whether physical barriers in the area may enable abuse;
d. Assess the adequacy of staffing levels in that area during different shifts;
e. Assess whether monitoring technology shall be deployed or augmented to
supplement supervision by staff; and
f. Prepare a report of its findings, including but not necessarily limited to items
a. through e. above, and any recommendations for improvement and submit such
report to the DJJ Regional Director for the appropriate branch (Residential or
Detention), the facility administrator, and the PREA Facility Compliance Manager.
7. Recommendations for improvement from the report shall be implemented, or
justification provided for not implementing said recommendations.
115.386 (c):
The PAQ requires the review team to include upper-level management officials, with
input from line supervisors, investigators, and medical or mental health
practitioners.
The Sexual Abuse Incident Report lists the staff who will participate in the meeting.
The list includes the FDJJ PREA coordinator, WHH state supervising staff, facility
director, assistant director, medical staff, mental health staff, and supervisory staff.
115.386 (d):
The PAQ requires the review team shall: (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.
The facility provided interviews with the Incident Review Team Member, the Facility
PREA compliance manager, the superintendent, and the agency head.
Each was asked whether they would review the following in accordance with the
PREA policy.
Consider whether the allegation or investigation indicates a need to change policy
or practice to better prevent, detect, or respond to sexual abuse.
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.
Examine the area in the facility where the incident allegedly occurred to assess
whether physical barriers in the area may enable abuse.
Assess staffing levels in that area across different shifts.
Assess whether monitoring technology should be deployed or augmented to
supplement supervision by staff; and
Prepare a report of its findings utilizing a critical incident review form. Implement
the recommendations for improvement.
Document implementation of recommendations or its reasons for not doing so.
115.386 (e):
The PAQ requires the facility shall implement recommendations for improvement or
shall document its reasons for not doing so.
Policy 1919 outlines the standard's requirements for the areas to be assessed by the
incident review team.
The interview with the facility director and a review of documentation confirmed
that the incident review team meeting is documented, including recommendations.
The interview with the Incident Review Team Member confirmed that the facility
prepared a report of its findings and recommendations for improvement following a
review of a sexual abuse incident.
The PREA compliance manager and facility director indicated that any
recommendations for the center will be completed as soon as possible.
Based on this analysis, the facility meets expectations with this provision, and
corrective action is not required.
115.387 Data collection
Auditor Overall Determination: Exceeds Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ 1919 Data Collection.pdf
FDJJ 2020 - Incident Operations Center.pdf
Florida Annual Report for fiscal year 2024-2025
WHH PREA 2023 PREA ANNUAL REPORT - Final
WHH PREA 2022 PREA ANNUAL REPORT - Final.
Interview with Wayne’s Halfway House PREA Coordinator
FDJJ PREA Coordinator
Facility PREA Compliance Manager
115.387(a)(b)
The PAQ requires the agency shall collect accurate, uniform data for every
allegation of sexual abuse at facilities under its direct control using a standardized
instrument and set of definitions.
The WHH is responsible for collecting accurate, uniform data for every allegation of
sexual abuse at facilities under the direct control, using a standardized instrument
and set of definitions. This information is uploaded to the WHH annual report and
forwarded to the Florida PREA Coordinator for inclusion in the FDJJ annual report.
The auditor reviewed the annual reports for WHH 2023 and 2022. The auditor also
reviewed the FDJJ annual Report for the 2024-2025 fiscal year.
The FDJJ annual report noted that Britt Technical Youth Academy had not had a PREA
allegation.
In interviews with the PREA compliance manager, it was stated that it uses a
standardized instrument to collect information, which is sent to the WHH and JDJJ
offices at least once a year.
The review included definitions and a standardized instrument for gathering the
information. The WHH information was found at https://www.tn.gov/content/dam/tn/
dcs/documents/juvenile-justice/prea/2023WHWHPREAAnnualReport.pdf.��
115.387 (c):
The PAQ requires that incident-based data collected include, at a minimum, the
information necessary to answer all questions in the most recent version of the
Department of Justice's Survey of Sexual Violence.
The Florida PREA coordinator and the WHH PREA coordinator indicated that all data
from the previous calendar year is provided to the Department of Justice as
requested each year.
115.387 (d):
The PAQ requires the agency shall maintain, review, and collect data as needed
from all available incident-based documents, including reports, investigation files,
and sexual abuse incident reviews.
The facility maintains and collects various types of PREA-related data and
documents. The facility collects and maintains data in accordance with WHH and
FDJJ policy and standards.
115.387 (e) (F):
The PAQ requires the agency to also obtain incident-based and aggregated data
from every private facility with which it contracts for the confinement of its
residents.
The PAQ requires that, upon request, the agency provide all such data from the
previous calendar year to the Department of Justice no later than June 30.
Policy 1919 requires the agency to collect accurate, uniform data on every
allegation of sexual abuse at facilities and community residential programs under its
control using a standardized Special Incident Report (SIR), in accordance with DJJ
8.5, Special Incident Reporting; DJJ 23.1; PREA; and Attachment K. The SIR process
includes, at a minimum, the data necessary to answer all questions from the most
recent version of the Survey of Sexual Violence (SSV) conducted by the Department
of Justice. The agency will maintain, review, and collect data from all available
incident-based documents, including reports, investigation files, and sexual abuse
incident reviews, as needed.
An interview with the FDJJ PREA Coordinator confirmed that the data is aggregated
annually and published in an annual report. He further confirmed that the SSV is
completed and submitted to the DOJ as requested.
The most recent Annual Report is for the 2022 reporting year and is consistent
with all requirements of this standard. The annual comparison report began in
FY2013 and has been produced consistently since.
Britt Technical Youth Academy began operations in August 2024, and its information
is not updated at the time of the onsite audit. Based on an interview with the center
director, the center has not had an allegation of sexual abuse or sexual harassment
since the center became operational.
115.387 (f):
Policy mandates that upon request, the center 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 in the prior calendar year.
The facility's PREA compliance manager indicated that he is required to submit an
annual report to the FDJJ and WHH PREA coordinator.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.388 Data review for corrective action
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
2023 WHH PREA ANNUAL REPORT - Final
2024-2024 FDJJ PREA ANNUAL REPORT - Final.
FDJJ Policy 2020 – Data Collection FDJJ Website PREA Reports.docx
Interview with
PREA Compliance Manager Agency Head
Facility Director
115.388 (a)(b):
The PAQ requires The agency shall 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: (1)
Identifying problem areas; (2) Taking corrective action on an ongoing basis; and (3)
Preparing an annual report of its findings and corrective actions for each facility, as
well as the agency as a whole.
Such a report shall include a comparison of the current year's data and corrective
actions with those from prior years and shall provide an assessment of the agency's
progress in addressing sexual abuse.
The FDJJ PREA coordinator provides a statistical review for the past four years and a
summary of the analysis of the comparison. In reviewing the documentation, the
FDJJ indicated that the analysis of aggregated data collected illustrates the agency’s
commitment to sexual safety in our facilities and its culture of zero tolerance.
The agency head indicated that the agency compares reports to review policies and
enhance training. BTYA has not been in operation long enough to make comparisons
with previous years.
The interviewed PREA Coordinator reported that the agency reviewed data collected
and aggregated, totaling 115.387, to assess and improve the effectiveness of its
sexual abuse prevention, detection, and response policies and training. It is
reviewed annually. The agency will take corrective action as needed. It was further
reported that the agency prepares an annual report of its findings.
The agency leadership reviews and approves the after-action plan after the
leadership review and sign-off on the final report.
In the reports, no specific identifying information is made available to the public
regarding who was involved in any particular matter.
FDJJ Policy 1919 – Data Collection recognizes the purpose of conducting annual
reports and annual PREA assessments are to review data collected and aggregated
pursuant to § 115.387 to assess and improve the effectiveness of its sexual abuse
prevention, detection, and response policies, practices, and training, including by:
Identifying problem areas to determine 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 and for the agency as a whole.
Wayne’s Halfway House's head indicated in the interview that Wayne’s Halfway
House meets monthly with all directors to review incident reports from the Wayne’s
Halfway House-operated center and to determine trends, policy violations, staffing
concerns, and the general outcomes of investigations. He indicated that they are
proactive in utilizing this as a learning experience for facility administrators and to
determine where Wayne’s Halfway House needs to send additional resources to
assist the centers in complying with PREA mandates.
The Wayne’s Halfway House PREA coordinator indicated that all centers have
monthly and quarterly calls to review all incidents at their centers and determine
whether additional resources, policy changes, training opportunities, or staff neglect
are needed.
115.388 (c):
The PAQ requires that the agency's report be approved by the agency head and
made readily available to the public through the agency's website or, if it does not
have one, through other means.
The annual report is reviewed by the PREA coordinator, his supervisor, and agency
leadership staff and signed by the Agency Head. It is then uploaded to the Florida
DJJ portal.
The WHH annual report is reviewed by the PREA coordinator, his supervisor, and
agency leadership staff, and signed by the Agency Head.
The WHH director approved a review of the 2023 annual report of operations, which
was then uploaded to the WHH website.
The Florida annual report for 2024-2025 was reviewed by the PREA coordinator, his
supervisor, and agency leadership staff, and signed by the Agency Head. It is then
uploaded to the Florida DJJ portal.
115.388 (d):
The PAQ requires that the agency may redact specific material from the reports
when publication would present a clear and specific threat to the safety and security
of a facility, but that it must indicate the nature of the material redacted.
Policy 23.1 - Data Collection states that all information posted on the website will
not include personal information.
The interviewed PREA Coordinator reported that redacting specific material from the
report would be permissible only if publication would present a clear and specific
threat to the facility's safety and security. We would indicate the nature of the
redaction.
Compliance was determined by reviewing data collected over the preceding three
years and the Florida Department of Juvenile Justice Website.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.389 Data storage, publication, and destruction
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ1316 Policy - Data storage
CCC Uniform Definitions.pdf
Florida Department of Juvenile Justice Data 1316 storage procedures
Management Procedures
115.389 (a)(b)(c)(d):
a. The PAQ requires the agency shall ensure that data collected pursuant to §
115.387 are securely retained.
b. The agency shall 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.
c. Before making aggregated sexual abuse data publicly available, the agency
removes all personal identifiers.
d The PAQ requires the agency to maintain sexual abuse data collected pursuant to
§115.387 for at least 10 years after the date of initial collection, unless federal,
state, or local law requires otherwise.
The facility provided the Policy 1316 Records Management, which states that the
Florida Department of Juvenile Justice is responsible for ensuring that incident-based
and aggregated data are securely retained for a minimum of 10 years.
The Florida Department of Juvenile Justice Procedure - Records and Information
Management Procedures requires that data be collected and securely retained for
10 years. The aggregated sexual abuse data was reviewed, and all personal
identifiers were removed. The website included State and privately operated
facilities.
At BTYA, screening instruments and investigative files are maintained in private
offices in locked cabinets. Medical and mental health files are also secure and are
not available to non-medical or mental health staff. All forums and computerized
databases are password-protected and have limited user access.
In interviews with the PREA compliance manager, she indicated that part of the
annual training is computer safety. Also included in the training and practiced by
administrative staff is keeping the cabinet locked and computers turned off when
not in use.
During the site review, all doors were secured, cabinets were locked, and computers
that were not in use were turned off. The staff indicated that the hard copies of
medical files are maintained in a locked cabinet in the medical file office and are not
available to any staff other than medical and mental health.
Compliance was determined through a review of the website, a tour of the center,
and an interview with the agency's PREA coordinator.
Based on this analysis, the facility is substantially compliant with this provision, and
corrective action is not required.
115.401 Frequency and scope of audits
Auditor Overall Determination: Meets Standard
Auditor Discussion
Evidence relied upon in making the compliance determination
FDJJ Policy 1919 PREA
https://www.djj.state.fl.us/partners-providers-staff/prison-rape-elimination-act-prea-
/completed-prea-audit-reports
Interview with
Facility Director
Agency Head
PREA coordinator
PREA Compliance Manager
115.401 (a)(b):
The PAQ requires during the three-year period starting on August 20, 2013. During
every three years thereafter, the agency shall ensure that each facility operated by
the agency, or by a private organization on behalf of the agency, is audited at least
once.
The agency shall ensure that at least one-third of each facility type operated by the
agency, or by a private organization on behalf of the agency, is audited.
The facility provided 1919, which requires all FDJJ facilities to be audited every three
years for compliance with the Prison Rape Elimination Act.
FDJJ Policy 1919 requires all DJJ facilities to be audited every 3 years to ensure
compliance with the Prison Rape Elimination Act. The initial PREA audit of Charles
Britt Youth Academy was conducted in 2015, 2018, and 2021 by Certified PREA
auditors. These audits were conducted by various private providers. The present
provider began operation in August 2024 after the center was reactivated and is
now the Britt Technical Youth Academy and is operated by Wayne’s Halfway House
Inc.
115.401 (h):
The PAQ requires the auditor shall have access to, and shall observe, all areas of the
audited facilities.
During the audit, I was allowed access to all areas of the center. I was permitted to
visit places throughout the facility during the official tour and to conduct
additional visits while interviewing and observing camera locations. There were no
limitations on interviewing staff or residents, and no obstacles in conducting tours
during waking and sleeping hours.
115.401 (i):
The PAQ requires that the auditor be permitted to request and receive copies of any
relevant documents (including electronically stored information).
I requested personnel files, resident files, training records, investigation files,
logbooks, and pertinent forms for use in the audit process. Each document was
provided on a timely basis.
115.401 (m):
The PAQ requires that the auditor be permitted to conduct private interviews with
residents.
I interviewed random on-duty staff for the first 24 hours of the audit and a random
sample of residents during the onsite audit. Interviews were conducted in a private
area of the facility.
115.401 (n):
The PAQ requires residents shall be permitted to send confidential information or
correspondence to the auditor in the same manner as if they were communicating
with legal counsel.
Postings were displayed throughout the facility with the name and address of the
PREA auditor. The auditor received no correspondence from residents. The
information was posted on November 24, 2025
The auditor interviewed the PREA Compliance Manager and asked if residents were
allowed to send mail to the auditor.
115.403 Audit contents and findings
Auditor Overall Determination: Meets Standard
Auditor Discussion
FDJJ Policy 1919 requires all DJJ facilities be audited every three years
for compliance with the Prison Rape Elimination Act
The initial PREA audit was operated by a private vendor as Charles Britt Youth
Academy and was conducted in 2015, 2018 and 2021 by a certified PREA auditor.
Each of these audits was located on the DJJ website.
At the present time, the center has been renamed, and the mission has been
modified to provide older youth an opportunity to attend Britt Technical College. The
present center is know at the Britt Technical Youth Academy and is operated by
Wayne's Halfway House Inc.
This is the fourth PREA audit for this facility. All reports were reviewed on the Florida
Department of Juvenile Justice Website. The website was found to be user-friendly
and was accessed by doing a Google search of Florida Department of Juvenile
Justice PREA audits.
Appendix: Provision Findings
115.311 Zero tolerance of sexual abuse and sexual harassment; PREA
(a) coordinator
Does the agency have a written policy mandating zero tolerance yes
toward all forms of sexual abuse and sexual harassment?
Does the written policy outline the agency’s approach to yes
preventing, detecting, and responding to sexual abuse and sexual
harassment?
115.311 Zero tolerance of sexual abuse and sexual harassment; PREA
(b) coordinator
Has the agency employed or designated an agency-wide PREA yes
Coordinator?
Is the PREA Coordinator position in the upper-level of the agency yes
hierarchy?
Does the PREA Coordinator have sufficient time and authority to yes
develop, implement, and oversee agency efforts to comply with
the PREA standards in all of its facilities?
115.311 Zero tolerance of sexual abuse and sexual harassment; PREA
(c) coordinator
If this agency operates more than one facility, has each facility yes
designated a PREA compliance manager? (N/A if agency operates
only one facility.)
Does the PREA compliance manager have sufficient time and yes
authority to coordinate the facility’s efforts to comply with the
PREA standards? (N/A if agency operates only one facility.)
115.312
Contracting with other entities for the confinement of residents
(a)
If this agency is public and it contracts for the confinement of its na
residents with private agencies or 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.)
115.312
Contracting with other entities for the confinement of residents
(b)
Does any new contract or contract renewal signed on or after na
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 OR the response to
115.312(a)-1 is "NO".)
115.313
Supervision and monitoring
(a)
Does the agency ensure that each facility has developed a staffing yes
plan that provides for adequate levels of staffing and, where
applicable, video monitoring, to protect residents against sexual
abuse?
Does the agency ensure that each facility has implemented a yes
staffing plan that provides for adequate levels of staffing and,
where applicable, video monitoring, to protect residents against
sexual abuse?
Does the agency ensure that each facility has documented a yes
staffing plan that provides for adequate levels of staffing and,
where applicable, video monitoring, to protect residents against
sexual abuse?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: The
prevalence of substantiated and unsubstantiated incidents of
sexual abuse?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring:
Generally accepted juvenile detention and correctional/secure
residential practices?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: Any
judicial findings of inadequacy?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: Any
findings of inadequacy from Federal investigative agencies?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: Any
findings of inadequacy from internal or external oversight bodies?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: All
components of the facility’s physical plant (including “blind-spots”
or areas where staff or residents may be isolated)?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: The
composition of the resident population?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: The
number and placement of supervisory staff?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring:
Institution programs occurring on a particular shift?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: Any
applicable State or local laws, regulations, or standards?
Does the agency ensure that each facility’s staffing plan takes into yes
consideration the 11 criteria below in calculating adequate
staffing levels and determining the need for video monitoring: Any
other relevant factors?
115.313
Supervision and monitoring
(b)
Does the agency comply with the staffing plan except during yes
limited and discrete exigent circumstances?
In circumstances where the staffing plan is not complied with, yes
does the facility fully document all deviations from the plan? (N/A
if no deviations from staffing plan.)
115.313
Supervision and monitoring
(c)
Does the facility maintain staff ratios of a minimum of 1:8 during yes
resident waking hours, except during limited and discrete exigent
circumstances? (N/A only until October 1, 2017.)
Does the facility maintain staff ratios of a minimum of 1:16 during yes
resident sleeping hours, except during limited and discrete
exigent circumstances? (N/A only until October 1, 2017.)
Does the facility fully document any limited and discrete exigent yes
circumstances during which the facility did not maintain staff
ratios? (N/A only until October 1, 2017.)
Does the facility ensure only security staff are included when yes
calculating these ratios? (N/A only until October 1, 2017.)
Is the facility obligated by law, regulation, or judicial consent yes
decree to maintain the staffing ratios set forth in this paragraph?
115.313
Supervision and monitoring
(d)
In the past 12 months, has the facility, in consultation with the yes
agency PREA Coordinator, assessed, determined, and documented
whether adjustments are needed to: The staffing plan established
pursuant to paragraph (a) of this section?
In the past 12 months, has the facility, in consultation with the yes
agency PREA Coordinator, assessed, determined, and documented
whether adjustments are needed to: Prevailing staffing patterns?
In the past 12 months, has the facility, in consultation with the yes
agency PREA Coordinator, assessed, determined, and documented
whether adjustments are needed to: The facility’s deployment of
video monitoring systems and other monitoring technologies?
In the past 12 months, has the facility, in consultation with the yes
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?
115.313
Supervision and monitoring
(e)
Has the facility implemented a policy and practice of having yes
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 )
Is this policy and practice implemented for night shifts as well as yes
day shifts? (N/A for non-secure facilities )
Does the facility have a policy prohibiting staff from alerting other yes
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 )
115.315
Limits to cross-gender viewing and searches
(a)
Does the facility always refrain from conducting any cross-gender yes
strip or cross-gender visual body cavity searches, except in
exigent circumstances or by medical practitioners?
115.315
Limits to cross-gender viewing and searches
(b)
Does the facility always refrain from conducting cross-gender pat- yes
down searches in non-exigent circumstances?
115.315
Limits to cross-gender viewing and searches
(c)
Does the facility document and justify all cross-gender strip yes
searches and cross-gender visual body cavity searches?
Does the facility document all cross-gender pat-down searches? yes
115.315
Limits to cross-gender viewing and searches
(d)
Does the facility implement policies and procedures that enable yes
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?
Does the facility require staff of the opposite gender to announce yes
their presence when entering a resident housing unit?
In facilities (such as group homes) that do not contain discrete yes
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)
115.315
Limits to cross-gender viewing and searches
(e)
This provision is no longer applicable to your compliance finding, na
please select N/A.
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.315
Limits to cross-gender viewing and searches
(f)
This provision is no longer applicable to your compliance finding, na
please select N/A.
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.316 Residents with disabilities and residents who are limited
(a) English proficient
Does the agency take appropriate steps to ensure that residents yes
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?
Does the agency take appropriate steps to ensure that residents yes
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?
Does the agency take appropriate steps to ensure that residents yes
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?
Does the agency take appropriate steps to ensure that residents yes
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?
Does the agency take appropriate steps to ensure that residents yes
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?
Does the agency take appropriate steps to ensure that residents yes
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.)
Do such steps include, when necessary, ensuring effective yes
communication with residents who are deaf or hard of hearing?
Do such steps include, when necessary, providing access to yes
interpreters who can interpret effectively, accurately, and
impartially, both receptively and expressively, using any
necessary specialized vocabulary?
Does the agency ensure that written materials are provided in yes
formats or through methods that ensure effective communication
with residents with disabilities including residents who: Have
intellectual disabilities?
Does the agency ensure that written materials are provided in yes
formats or through methods that ensure effective communication
with residents with disabilities including residents who: Have
limited reading skills?
Does the agency ensure that written materials are provided in yes
formats or through methods that ensure effective communication
with residents with disabilities including residents who: Who are
blind or have low vision?
115.316 Residents with disabilities and residents who are limited
(b) English proficient
Does the agency take reasonable steps to ensure meaningful yes
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?
Do these steps include providing interpreters who can interpret yes
effectively, accurately, and impartially, both receptively and
expressively, using any necessary specialized vocabulary?
115.316 Residents with disabilities and residents who are limited
(c) English proficient
Does the agency always refrain from relying on resident yes
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?
115.317
Hiring and promotion decisions
(a)
Does the agency prohibit the hiring or promotion of anyone who yes
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)?
Does the agency prohibit the hiring or promotion of anyone who yes
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?
Does the agency prohibit the hiring or promotion of anyone who yes
may have contact with residents who: Has been civilly or
administratively adjudicated to have engaged in the activity
described in the bullet immediately above?
Does the agency prohibit the enlistment of services of any yes
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)?
Does the agency prohibit the enlistment of services of any yes
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?
Does the agency prohibit the enlistment of services of any yes
contractor who may have contact with residents who: Has been
civilly or administratively adjudicated to have engaged in the
activity described in the two bullets immediately above?
115.317
Hiring and promotion decisions
(b)
Does the agency consider any incidents of sexual harassment in yes
determining whether to hire or promote anyone, or to enlist the
services of any contractor, who may have contact with residents?
115.317
Hiring and promotion decisions
(c)
Before hiring new employees who may have contact with yes
residents, does the agency: Perform a criminal background records
check?
Before hiring new employees who may have contact with yes
residents, does the agency: Consult any child abuse registry
maintained by the State or locality in which the employee would
work?
Before hiring new employees who may have contact with yes
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?
115.317
Hiring and promotion decisions
(d)
Does the agency perform a criminal background records check yes
before enlisting the services of any contractor who may have
contact with residents?
Does the agency consult applicable child abuse registries before yes
enlisting the services of any contractor who may have contact
with residents?
115.317
Hiring and promotion decisions
(e)
Does the agency either conduct criminal background records yes
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?
115.317
Hiring and promotion decisions
(f)
Does the agency ask all applicants and employees who may have yes
contact with residents directly about previous misconduct
described in paragraph (a) of this section in written applications or
interviews for hiring or promotions?
Does the agency ask all applicants and employees who may have yes
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?
Does the agency impose upon employees a continuing affirmative yes
duty to disclose any such misconduct?
115.317
Hiring and promotion decisions
(g)
Does the agency consider material omissions regarding such yes
misconduct, or the provision of materially false information,
grounds for termination?
115.317
Hiring and promotion decisions
(h)
Unless prohibited by law, does the agency provide information on yes
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.)
115.318
Upgrades to facilities and technologies
(a)
If the agency designed or acquired any new facility or planned any na
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.)
115.318
Upgrades to facilities and technologies
(b)
If the agency installed or updated a video monitoring system, yes
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.)
115.321
Evidence protocol and forensic medical examinations
(a)
If the agency is responsible for investigating allegations of sexual yes
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.)
115.321 Evidence protocol and forensic medical examinations
(b)
Is this protocol developmentally appropriate for youth? (N/A if the yes
agency/facility is not responsible for conducting any form of
criminal OR administrative sexual abuse investigations.)
Is this protocol, as appropriate, adapted from or otherwise based yes
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? (N/A if the agency/facility is not
responsible for conducting any form of criminal OR administrative
sexual abuse investigations. )
115.321
Evidence protocol and forensic medical examinations
(c)
Does the agency offer all residents who experience sexual abuse yes
access to forensic medical examinations, whether on-site or at an
outside facility, without financial cost, where evidentiarily or
medically appropriate?
Are such examinations performed by Sexual Assault Forensic yes
Examiners (SAFEs) or Sexual Assault Nurse Examiners (SANEs)
where possible?
If SAFEs or SANEs cannot be made available, is the examination yes
performed by other qualified medical practitioners (they must
have been specifically trained to conduct sexual assault forensic
exams)?
Has the agency documented its efforts to provide SAFEs or yes
SANEs?
115.321
Evidence protocol and forensic medical examinations
(d)
Does the agency attempt to make available to the victim a victim yes
advocate from a rape crisis center?
If a rape crisis center is not available to provide victim advocate yes
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?
Has the agency documented its efforts to secure services from yes
rape crisis centers?
115.321 Evidence protocol and forensic medical examinations
(e)
As requested by the victim, does the victim advocate, qualified yes
agency staff member, or qualified community-based organization
staff member accompany and support the victim through the
forensic medical examination process and investigatory
interviews?
As requested by the victim, does this person provide emotional yes
support, crisis intervention, information, and referrals?
115.321
Evidence protocol and forensic medical examinations
(f)
If the agency itself is not responsible for investigating allegations yes
of sexual abuse, has the agency requested that the investigating
entity follow the requirements of paragraphs (a) through (e) of this
section? (N/A if the agency is responsible for investigating
allegations of sexual abuse.)
115.321
Evidence protocol and forensic medical examinations
(h)
If the agency uses a qualified agency staff member or a qualified na
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? (Check N/A if agency
attempts to make a victim advocate from a rape crisis center
available to victims per 115.321(d) above.)
115.322
Policies to ensure referrals of allegations for investigations
(a)
Does the agency ensure an administrative or criminal yes
investigation is completed for all allegations of sexual abuse?
Does the agency ensure an administrative or criminal yes
investigation is completed for all allegations of sexual
harassment?
115.322
Policies to ensure referrals of allegations for investigations
(b)
Does the agency have a policy in place to ensure that allegations yes
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?
Has the agency published such policy on its website or, if it does yes
not have one, made the policy available through other means?
Does the agency document all such referrals? yes
115.322
Policies to ensure referrals of allegations for investigations
(c)
If a separate entity is responsible for conducting criminal na
investigations, does such publication 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))
115.331
Employee training
(a)
Does the agency train all employees who may have contact with yes
residents on: Its zero-tolerance policy for sexual abuse and sexual
harassment?
Does the agency train all employees who may have contact with yes
residents on: How to fulfill their responsibilities under agency
sexual abuse and sexual harassment prevention, detection,
reporting, and response policies and procedures?
Does the agency train all employees who may have contact with yes
residents on: Residents’ right to be free from sexual abuse and
sexual harassment
Does the agency train all employees who may have contact with yes
residents on: The right of residents and employees to be free from
retaliation for reporting sexual abuse and sexual harassment?
Does the agency train all employees who may have contact with yes
residents on: The dynamics of sexual abuse and sexual
harassment in juvenile facilities?
Does the agency train all employees who may have contact with yes
residents on: The common reactions of juvenile victims of sexual
abuse and sexual harassment?
Does the agency train all employees who may have contact with yes
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?
Does the agency train all employees who may have contact with yes
residents on: How to avoid inappropriate relationships with
residents?
The subsection of this provision is no longer applicable to your na
compliance finding, please select N/A.
Does the agency train all employees who may have contact with yes
residents on: How to comply with relevant laws related to
mandatory reporting of sexual abuse to outside authorities?
Does the agency train all employees who may have contact with yes
residents on: Relevant laws regarding the applicable age of
consent?
115.331
Employee training
(b)
Is such training tailored to the unique needs and attributes of yes
residents of juvenile facilities?
Is such training tailored to the gender of the residents at the yes
employee’s facility?
Have employees received additional training if reassigned from a yes
facility that houses only male residents to a facility that houses
only female residents, or vice versa?
115.331
Employee training
(c)
Have all current employees who may have contact with residents yes
received such training?
Does the agency provide each employee with refresher training yes
every two years to ensure that all employees know the agency’s
current sexual abuse and sexual harassment policies and
procedures?
In years in which an employee does not receive refresher training, yes
does the agency provide refresher information on current sexual
abuse and sexual harassment policies?
115.331
Employee training
(d)
Does the agency document, through employee signature or yes
electronic verification, that employees understand the training
they have received?
115.332
Volunteer and contractor training
(a)
Has the agency ensured that all volunteers and contractors who yes
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?
115.332
Volunteer and contractor training
(b)
Have all volunteers and contractors who have contact with yes
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)?
115.332
Volunteer and contractor training
(c)
Does the agency maintain documentation confirming that yes
volunteers and contractors understand the training they have
received?
115.333
Resident education
(a)
During intake, do residents receive information explaining the yes
agency’s zero-tolerance policy regarding sexual abuse and sexual
harassment?
During intake, do residents receive information explaining how to yes
report incidents or suspicions of sexual abuse or sexual
harassment?
Is this information presented in an age-appropriate fashion? yes
115.333
Resident education
(b)
Within 10 days of intake, does the agency provide age-appropriate yes
comprehensive education to residents either in person or through
video regarding: Their rights to be free from sexual abuse and
sexual harassment?
Within 10 days of intake, does the agency provide age-appropriate yes
comprehensive education to residents either in person or through
video regarding: Their rights to be free from retaliation for
reporting such incidents?
Within 10 days of intake, does the agency provide age-appropriate yes
comprehensive education to residents either in person or through
video regarding: Agency policies and procedures for responding to
such incidents?
115.333
Resident education
(c)
Have all residents received such education? yes
Do residents receive education upon transfer to a different facility yes
to the extent that the policies and procedures of the resident’s
new facility differ from those of the previous facility?
115.333
Resident education
(d)
Does the agency provide resident education in formats accessible yes
to all residents including those who: Are limited English proficient?
Does the agency provide resident education in formats accessible yes
to all residents including those who: Are deaf?
Does the agency provide resident education in formats accessible yes
to all residents including those who: Are visually impaired?
Does the agency provide resident education in formats accessible yes
to all residents including those who: Are otherwise disabled?
Does the agency provide resident education in formats accessible yes
to all residents including those who: Have limited reading skills?
115.333
Resident education
(e)
Does the agency maintain documentation of resident participation yes
in these education sessions?
115.333
Resident education
(f)
In addition to providing such education, does the agency ensure yes
that key information is continuously and readily available or visible
to residents through posters, resident handbooks, or other written
formats?
115.334
Specialized training: Investigations
(a)
In addition to the general training provided to all employees na
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? (N/A if the agency does
not conduct any form of administrative or criminal sexual abuse
investigations. See 115.321(a).)
115.334
Specialized training: Investigations
(b)
Does this specialized training include: Techniques for interviewing na
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).)
Does this specialized training include: Proper use of Miranda and na
Garrity warnings? (N/A if the agency does not conduct any form of
administrative or criminal sexual abuse investigations. See
115.321(a).)
Does this specialized training include: Sexual abuse evidence na
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).)
Does this specialized training include: The criteria and evidence na
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).)
115.334
Specialized training: Investigations
(c)
Does the agency maintain documentation that agency na
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).)
115.335
Specialized training: Medical and mental health care
(a)
Does the agency ensure that all full- and part-time medical and yes
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.)
Does the agency ensure that all full- and part-time medical and yes
mental health care practitioners who work regularly in its facilities
have been trained in: How to preserve physical evidence of 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.)
Does the agency ensure that all full- and part-time medical and yes
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.)
Does the agency ensure that all full- and part-time medical and yes
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.)
115.335
Specialized training: Medical and mental health care
(b)
If medical staff employed by the agency conduct forensic yes
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.)
115.335
Specialized training: Medical and mental health care
(c)
Does the agency maintain documentation that medical and yes
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.)
115.335
Specialized training: Medical and mental health care
(d)
Do medical and mental health care practitioners employed by the yes
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.)
Do medical and mental health care practitioners contracted by yes
and 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.)
115.341
Obtaining information from residents
(a)
Within 72 hours of the resident’s arrival at the facility, does the yes
agency obtain and use information about each resident’s personal
history and behavior to reduce risk of sexual abuse by or upon a
resident?
Does the agency also obtain this information periodically yes
throughout a resident’s confinement?
115.341
Obtaining information from residents
(b)
Are all PREA screening assessments conducted using an objective yes
screening instrument?
115.341
Obtaining information from residents
(c)
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Prior sexual
victimization or abusiveness?
The subsection of this provision is no longer applicable to your na
compliance finding, please select N/A.
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Current
charges and offense history?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Age?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Level of
emotional and cognitive development?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Physical size
and stature?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Mental illness
or mental disabilities?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Intellectual or
developmental disabilities?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Physical
disabilities?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: The resident’s
own perception of vulnerability?
During these PREA screening assessments, at a minimum, does yes
the agency attempt to ascertain information about: Any other
specific information about individual residents that may indicate
heightened needs for supervision, additional safety precautions, or
separation from certain other residents?
115.341
Obtaining information from residents
(d)
Is this information ascertained: Through conversations with the yes
resident during the intake process and medical mental health
screenings?
Is this information ascertained: During classification assessments? yes
Is this information ascertained: By reviewing court records, case yes
files, facility behavioral records, and other relevant documentation
from the resident’s files?
115.341
Obtaining information from residents
(e)
Has the agency implemented appropriate controls on the yes
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?
115.342
Placement of residents
(a)
Does the agency use all of the information obtained pursuant to § yes
115.341 and subsequently, with the goal of keeping all residents
safe and free from sexual abuse, to make: Housing Assignments?
Does the agency use all of the information obtained pursuant to § yes
115.341 and subsequently, with the goal of keeping all residents
safe and free from sexual abuse, to make: Bed assignments?
Does the agency use all of the information obtained pursuant to § yes
115.341 and subsequently, with the goal of keeping all residents
safe and free from sexual abuse, to make: Work Assignments?
Does the agency use all of the information obtained pursuant to § yes
115.341 and subsequently, with the goal of keeping all residents
safe and free from sexual abuse, to make: Education
Assignments?
Does the agency use all of the information obtained pursuant to § yes
115.341 and subsequently, with the goal of keeping all residents
safe and free from sexual abuse, to make: Program Assignments?
115.342
Placement of residents
(b)
Are residents isolated from others only as a last resort when less no
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?
During any period of isolation, does the agency always refrain yes
from denying residents daily large-muscle exercise?
During any period of isolation, does the agency always refrain yes
from denying residents any legally required educational
programming or special education services?
Do residents in isolation receive daily visits from a medical or yes
mental health care clinician?
Do residents also have access to other programs and work yes
opportunities to the extent possible?
115.342
Placement of residents
(c)
This provision is no longer applicable to your compliance finding, na
please select N/A.
This provision is no longer applicable to your compliance finding, na
please select N/A.
This provision is no longer applicable to your compliance finding, na
please select N/A.
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.342
Placement of residents
(d)
This provision is no longer applicable to your compliance finding, na
please select N/A.
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.342
Placement of residents
(e)
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.342
Placement of residents
(f)
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.342
Placement of residents
(g)
This provision is no longer applicable to your compliance finding, na
please select N/A.
115.342
Placement of residents
(h)
If a resident is isolated pursuant to paragraph (b) of this section, na
does the facility clearly document: The basis for the facility’s
concern for the resident’s safety? (N/A for h and i if facility doesn’t
use isolation?)
If a resident is isolated pursuant to paragraph (b) of this section, na
does the facility clearly document: The reason why no alternative
means of separation can be arranged? (N/A for h and i if facility
doesn’t use isolation?)
115.342
Placement of residents
(i)
In the case of each resident who is isolated as a last resort when yes
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?
115.351 Resident reporting
(a)
Does the agency provide multiple internal ways for residents to yes
privately report: Sexual abuse and sexual harassment?
Does the agency provide multiple internal ways for residents to yes
privately report: 2. Retaliation by other residents or staff for
reporting sexual abuse and sexual harassment?
Does the agency provide multiple internal ways for residents to yes
privately report: Staff neglect or violation of responsibilities that
may have contributed to such incidents?
115.351
Resident reporting
(b)
Does the agency also provide at least one way for residents to yes
report sexual abuse or sexual harassment to a public or private
entity or office that is not part of the agency?
Is that private entity or office able to receive and immediately yes
forward resident reports of sexual abuse and sexual harassment to
agency officials?
Does that private entity or office allow the resident to remain yes
anonymous upon request?
Are residents detained solely for civil immigration purposes yes
provided information on how to contact relevant consular officials
and relevant officials at the Department of Homeland Security to
report sexual abuse or harassment?
115.351
Resident reporting
(c)
Do staff members accept reports of sexual abuse and sexual yes
harassment made verbally, in writing, anonymously, and from
third parties?
Do staff members promptly document any verbal reports of sexual yes
abuse and sexual harassment?
115.351
Resident reporting
(d)
Does the facility provide residents with access to tools necessary yes
to make a written report?
115.351
Resident reporting
(e)
Does the agency provide a method for staff to privately report yes
sexual abuse and sexual harassment of residents?
115.352
Exhaustion of administrative remedies
(a)
Is the agency exempt from this standard? yes
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.
115.352
Exhaustion of administrative remedies
(b)
Does the agency permit residents to submit a grievance regarding na
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.)
Does the agency always refrain from requiring an resident to use na
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.)
115.352
Exhaustion of administrative remedies
(c)
Does the agency ensure that: A resident who alleges sexual abuse na
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.)
Does the agency ensure that: Such grievance is not referred to a na
staff member who is the subject of the complaint? (N/A if agency
is exempt from this standard.)
115.352
Exhaustion of administrative remedies
(d)
Does the agency issue a final agency decision on the merits of any na
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.)
If the agency determines that the 90 day timeframe is insufficient na
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.)
At any level of the administrative process, including the final level, na
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.)
115.352
Exhaustion of administrative remedies
(e)
Are third parties, including fellow residents, staff members, family na
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.)
Are those third parties also permitted to file such requests on na
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.)
If the resident declines to have the request processed on his or na
her behalf, does the agency document the resident’s decision?
(N/A if agency is exempt from this standard.)
Is a parent or legal guardian of a juvenile allowed to file a na
grievance regarding allegations of sexual abuse, including
appeals, on behalf of such juvenile? (N/A if agency is exempt from
this standard.)
If a parent or legal guardian of a juvenile files a grievance (or an na
appeal) on behalf of a juvenile regarding allegations of sexual
abuse, is it the case that those grievances are not conditioned
upon the juvenile agreeing to have the request filed on his or her
behalf? (N/A if agency is exempt from this standard.)
115.352 Exhaustion of administrative remedies
(f)
Has the agency established procedures for the filing of an na
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.)
After receiving an emergency grievance alleging a resident is na
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.)
After receiving an emergency grievance described above, does na
the agency provide an initial response within 48 hours? (N/A if
agency is exempt from this standard.)
After receiving an emergency grievance described above, does na
the agency issue a final agency decision within 5 calendar days?
(N/A if agency is exempt from this standard.)
Does the initial response and final agency decision document the na
agency’s determination whether the resident is in substantial risk
of imminent sexual abuse? (N/A if agency is exempt from this
standard.)
Does the initial response document the agency’s action(s) taken in na
response to the emergency grievance? (N/A if agency is exempt
from this standard.)
Does the agency’s final decision document the agency’s action(s) na
taken in response to the emergency grievance? (N/A if agency is
exempt from this standard.)
115.352
Exhaustion of administrative remedies
(g)
If the agency disciplines a resident for filing a grievance related to na
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.)
115.353 Resident access to outside confidential support services and
(a) legal representation
Does the facility provide residents with access to outside victim yes
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?
Does the facility provide persons detained solely for civil yes
immigration purposes mailing addresses and telephone numbers,
including toll-free hotline numbers where available of local, State,
or national immigrant services agencies?
Does the facility enable reasonable communication between yes
residents and these organizations and agencies, in as confidential
a manner as possible?
115.353 Resident access to outside confidential support services and
(b) legal representation
Does the facility inform residents, prior to giving them access, of yes
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?
115.353 Resident access to outside confidential support services and
(c) legal representation
Does the agency maintain or attempt to enter into memoranda of yes
understanding or other agreements with community service
providers that are able to provide residents with confidential
emotional support services related to sexual abuse?
Does the agency maintain copies of agreements or documentation yes
showing attempts to enter into such agreements?
115.353 Resident access to outside confidential support services and
(d) legal representation
Does the facility provide residents with reasonable and yes
confidential access to their attorneys or other legal
representation?
Does the facility provide residents with reasonable access to yes
parents or legal guardians?
115.354
Third-party reporting
(a)
Has the agency established a method to receive third-party yes
reports of sexual abuse and sexual harassment?
Has the agency distributed publicly information on how to report yes
sexual abuse and sexual harassment on behalf of a resident?
115.361
Staff and agency reporting duties
(a)
Does the agency require all staff to report immediately and yes
according to agency policy any knowledge, suspicion, or
information they receive regarding an incident of sexual abuse or
sexual harassment that occurred in a facility, whether or not it is
part of the agency?
Does the agency require all staff to report immediately and yes
according to agency policy any knowledge, suspicion, or
information they receive regarding retaliation against residents or
staff who reported an incident of sexual abuse or sexual
harassment?
Does the agency require all staff to report immediately and yes
according to agency policy any knowledge, suspicion, or
information they receive regarding any staff neglect or violation of
responsibilities that may have contributed to an incident of sexual
abuse or sexual harassment or retaliation?
115.361
Staff and agency reporting duties
(b)
Does the agency require all staff to comply with any applicable yes
mandatory child abuse reporting laws?
115.361
Staff and agency reporting duties
(c)
Apart from reporting to designated supervisors or officials and yes
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?
115.361
Staff and agency reporting duties
(d)
Are medical and mental health practitioners required to report yes
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?
Are medical and mental health practitioners required to inform yes
residents of their duty to report, and the limitations of
confidentiality, at the initiation of services?
115.361
Staff and agency reporting duties
(e)
Upon receiving any allegation of sexual abuse, does the facility yes
head or his or her designee promptly report the allegation to the
appropriate office?
Upon receiving any allegation of sexual abuse, does the facility yes
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?
If the alleged victim is under the guardianship of the child welfare yes
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? (N/A if the alleged victim is not
under the guardianship of the child welfare system.)
If a juvenile court retains jurisdiction over the alleged victim, does yes
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?
115.361
Staff and agency reporting duties
(f)
Does the facility report all allegations of sexual abuse and sexual yes
harassment, including third-party and anonymous reports, to the
facility’s designated investigators?
115.362
Agency protection duties
(a)
When the agency learns that a resident is subject to a substantial yes
risk of imminent sexual abuse, does it take immediate action to
protect the resident?
115.363
Reporting to other confinement facilities
(a)
Upon receiving an allegation that a resident was sexually abused yes
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?
Does the head of the facility that received the allegation also yes
notify the appropriate investigative agency?
115.363
Reporting to other confinement facilities
(b)
Is such notification provided as soon as possible, but no later than yes
72 hours after receiving the allegation?
115.363
Reporting to other confinement facilities
(c)
Does the agency document that it has provided such notification? yes
115.363
Reporting to other confinement facilities
(d)
Does the facility head or agency office that receives such yes
notification ensure that the allegation is investigated in
accordance with these standards?
115.364
Staff first responder duties
(a)
Upon learning of an allegation that a resident was sexually yes
abused, is the first security staff member to respond to the report
required to: Separate the alleged victim and abuser?
Upon learning of an allegation that a resident was sexually yes
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?
Upon learning of an allegation that a resident was sexually yes
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?
Upon learning of an allegation that a resident was sexually yes
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?
115.364
Staff first responder duties
(b)
If the first staff responder is not a security staff member, is the yes
responder required to request that the alleged victim not take any
actions that could destroy physical evidence, and then notify
security staff?
115.365
Coordinated response
(a)
Has the facility developed a written institutional plan to coordinate yes
actions among staff first responders, medical and mental health
practitioners, investigators, and facility leadership taken in
response to an incident of sexual abuse?
115.366 Preservation of ability to protect residents from contact with
(a) abusers
Are both the agency and any other governmental entities yes
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?
115.367
Agency protection against retaliation
(a)
Has the agency established a policy to protect all residents and yes
staff who report sexual abuse or sexual harassment or cooperate
with sexual abuse or sexual harassment investigations from
retaliation by other residents or staff?
Has the agency designated which staff members or departments yes
are charged with monitoring retaliation?
115.367
Agency protection against retaliation
(b)
Does the agency employ multiple protection measures for yes
residents or staff who fear retaliation for reporting sexual abuse or
sexual harassment or for cooperating with investigations, 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?
115.367
Agency protection against retaliation
(c)
Except in instances where the agency determines that a report of yes
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?
Except in instances where the agency determines that a report of yes
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?
Except in instances where the agency determines that a report of yes
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?
Except in instances where the agency determines that a report of yes
sexual abuse is unfounded, for at least 90 days following a report
of sexual abuse, does the agency: Monitor: Any resident
disciplinary reports?
Except in instances where the agency determines that a report of yes
sexual abuse is unfounded, for at least 90 days following a report
of sexual abuse, does the agency: Monitor: Resident housing
changes?
Except in instances where the agency determines that a report of yes
sexual abuse is unfounded, for at least 90 days following a report
of sexual abuse, does the agency: Monitor: Resident program
changes?
Except in instances where the agency determines that a report of yes
sexual abuse is unfounded, for at least 90 days following a report
of sexual abuse, does the agency: Monitor: Negative performance
reviews of staff?
Except in instances where the agency determines that a report of yes
sexual abuse is unfounded, for at least 90 days following a report
of sexual abuse, does the agency: Monitor: Reassignments of
staff?
Does the agency continue such monitoring beyond 90 days if the yes
initial monitoring indicates a continuing need?
115.367
Agency protection against retaliation
(d)
In the case of residents, does such monitoring also include yes
periodic status checks?
115.367
Agency protection against retaliation
(e)
If any other individual who cooperates with an investigation yes
expresses a fear of retaliation, does the agency take appropriate
measures to protect that individual against retaliation?
115.368
Post-allegation protective custody
(a)
Is any and all use of segregated housing to protect a resident who yes
is alleged to have suffered sexual abuse subject to the
requirements of § 115.342?
115.371
Criminal and administrative agency investigations
(a)
When the agency conducts its own investigations into allegations na
of sexual abuse and sexual harassment, does it do so promptly,
thoroughly, and objectively? (N/A if the agency does not conduct
any form of administrative or criminal investigations of sexual
abuse or harassment. See 115.321(a).)
Does the agency conduct such investigations for all allegations, na
including third party and anonymous reports? (N/A if the agency
does not conduct any form of administrative or criminal
investigations of sexual abuse or harassment. See 115.321(a).)
115.371
Criminal and administrative agency investigations
(b)
Where sexual abuse is alleged, does the agency use investigators yes
who have received specialized training in sexual abuse
investigations involving juvenile victims as required by 115.334?
115.371
Criminal and administrative agency investigations
(c)
Do investigators gather and preserve direct and circumstantial yes
evidence, including any available physical and DNA evidence and
any available electronic monitoring data?
Do investigators interview alleged victims, suspected yes
perpetrators, and witnesses?
Do investigators review prior reports and complaints of sexual yes
abuse involving the suspected perpetrator?
115.371
Criminal and administrative agency investigations
(d)
Does the agency always refrain from terminating an investigation yes
solely because the source of the allegation recants the allegation?
115.371
Criminal and administrative agency investigations
(e)
When the quality of evidence appears to support criminal yes
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?
115.371
Criminal and administrative agency investigations
(f)
Do agency investigators assess the credibility of an alleged victim, yes
suspect, or witness on an individual basis and not on the basis of
that individual’s status as resident or staff?
Does the agency investigate allegations of sexual abuse without yes
requiring a resident who alleges sexual abuse to submit to a
polygraph examination or other truth-telling device as a condition
for proceeding?
115.371
Criminal and administrative agency investigations
(g)
Do administrative investigations include an effort to determine yes
whether staff actions or failures to act contributed to the abuse?
Are administrative investigations documented in written reports yes
that include a description of the physical evidence and testimonial
evidence, the reasoning behind credibility assessments, and
investigative facts and findings?
115.371
Criminal and administrative agency investigations
(h)
Are criminal investigations documented in a written report that yes
contains a thorough description of the physical, testimonial, and
documentary evidence and attaches copies of all documentary
evidence where feasible?
115.371
Criminal and administrative agency investigations
(i)
Are all substantiated allegations of conduct that appears to be yes
criminal referred for prosecution?
115.371
Criminal and administrative agency investigations
(j)
Does the agency retain all written reports referenced in yes
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?
115.371
Criminal and administrative agency investigations
(k)
Does the agency ensure that the departure of an alleged abuser yes
or victim from the employment or control of the facility or agency
does not provide a basis for terminating an investigation?
115.371
Criminal and administrative agency investigations
(m)
When an outside entity investigates sexual abuse, does the facility yes
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).)
115.372
Evidentiary standard for administrative investigations
(a)
Is it true that the agency does not impose a standard higher than yes
a preponderance of the evidence in determining whether
allegations of sexual abuse or sexual harassment are
substantiated?
115.373
Reporting to residents
(a)
Following an investigation into a resident’s allegation of sexual yes
abuse suffered in the facility, does the agency inform the resident
as to whether the allegation has been determined to be
substantiated, unsubstantiated, or unfounded?
115.373
Reporting to residents
(b)
If the agency did not conduct the investigation into a resident’s yes
allegation of sexual abuse in an agency 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.)
115.373
Reporting to residents
(c)
Following a resident’s allegation that a staff member has yes
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?
Following a resident’s allegation that a staff member has yes
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?
Following a resident’s allegation that a staff member has yes
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?
Following a resident’s allegation that a staff member has yes
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?
115.373
Reporting to residents
(d)
Following a resident’s allegation that he or she has been sexually yes
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?
Following a resident’s allegation that he or she has been sexually yes
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?
115.373
Reporting to residents
(e)
Does the agency document all such notifications or attempted yes
notifications?
115.376
Disciplinary sanctions for staff
(a)
Are staff subject to disciplinary sanctions up to and including yes
termination for violating agency sexual abuse or sexual
harassment policies?
115.376
Disciplinary sanctions for staff
(b)
Is termination the presumptive disciplinary sanction for staff who yes
have engaged in sexual abuse?
115.376
Disciplinary sanctions for staff
(c)
Are disciplinary sanctions for violations of agency policies relating yes
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?
115.376
Disciplinary sanctions for staff
(d)
Are all terminations for violations of agency sexual abuse or yes
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?
Are all terminations for violations of agency sexual abuse or yes
sexual harassment policies, or resignations by staff who would
have been terminated if not for their resignation, reported to:
Relevant licensing bodies?
115.377
Corrective action for contractors and volunteers
(a)
Is any contractor or volunteer who engages in sexual abuse yes
prohibited from contact with residents?
Is any contractor or volunteer who engages in sexual abuse yes
reported to: Law enforcement agencies (unless the activity was
clearly not criminal)?
Is any contractor or volunteer who engages in sexual abuse yes
reported to: Relevant licensing bodies?
115.377
Corrective action for contractors and volunteers
(b)
In the case of any other violation of agency sexual abuse or sexual yes
harassment policies by a contractor or volunteer, does the facility
take appropriate remedial measures, and consider whether to
prohibit further contact with residents?
115.378
Interventions and disciplinary sanctions for residents
(a)
Following an administrative finding that a resident engaged in yes
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?
115.378
Interventions and disciplinary sanctions for residents
(b)
Are disciplinary sanctions commensurate with the nature and yes
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 yes
resident, does the agency ensure the resident is not denied daily
large-muscle exercise?
In the event a disciplinary sanction results in the isolation of a yes
resident, does the agency ensure the resident is not denied access
to any legally required educational programming or special
education services?
In the event a disciplinary sanction results in the isolation of a yes
resident, does the agency ensure the resident receives daily visits
from a medical or mental health care clinician?
In the event a disciplinary sanction results in the isolation of a yes
resident, does the resident also have access to other programs
and work opportunities to the extent possible?
115.378 Interventions and disciplinary sanctions for residents
(c)
When determining what types of sanction, if any, should be yes
imposed, does the disciplinary process consider whether a
resident’s mental disabilities or mental illness contributed to his or
her behavior?
115.378
Interventions and disciplinary sanctions for residents
(d)
If the facility offers therapy, counseling, or other interventions yes
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?
If the agency requires participation in such interventions as a yes
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?
115.378
Interventions and disciplinary sanctions for residents
(e)
Does the agency discipline a resident for sexual contact with staff no
only upon a finding that the staff member did not consent to such
contact?
115.378
Interventions and disciplinary sanctions for residents
(f)
For the purpose of disciplinary action, does a report of sexual yes
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?
115.378
Interventions and disciplinary sanctions for residents
(g)
Does the agency always refrain from considering non-coercive yes
sexual activity between residents to be sexual abuse? (N/A if the
agency does not prohibit all sexual activity between residents.)
115.381
Medical and mental health screenings; history of sexual abuse
(a)
If the screening pursuant to § 115.341 indicates that a resident yes
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?
115.381
Medical and mental health screenings; history of sexual abuse
(b)
If the screening pursuant to § 115.341 indicates that a resident yes
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?
115.381
Medical and mental health screenings; history of sexual abuse
(c)
Is any information related to sexual victimization or abusiveness yes
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?
115.381
Medical and mental health screenings; history of sexual abuse
(d)
Do medical and mental health practitioners obtain informed yes
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?
115.382
Access to emergency medical and mental health services
(a)
Do resident victims of sexual abuse receive timely, unimpeded yes
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?
115.382
Access to emergency medical and mental health services
(b)
If no qualified medical or mental health practitioners are on duty yes
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?
Do staff first responders immediately notify the appropriate yes
medical and mental health practitioners?
115.382
Access to emergency medical and mental health services
(c)
Are resident victims of sexual abuse offered timely information yes
about and timely access to emergency contraception and sexually
transmitted infections prophylaxis, in accordance with
professionally accepted standards of care, where medically
appropriate?
115.382
Access to emergency medical and mental health services
(d)
Are treatment services provided to the victim without financial yes
cost and regardless of whether the victim names the abuser or
cooperates with any investigation arising out of the incident?
115.383 Ongoing medical and mental health care for sexual abuse
(a) victims and abusers
Does the facility offer medical and mental health evaluation and, yes
as appropriate, treatment to all residents who have been
victimized by sexual abuse in any prison, jail, lockup, or juvenile
facility?
115.383 Ongoing medical and mental health care for sexual abuse
(b) victims and abusers
Does the evaluation and treatment of such victims include, as yes
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?
115.383 Ongoing medical and mental health care for sexual abuse
(c) victims and abusers
Does the facility provide such victims with medical and mental yes
health services consistent with the community level of care?
115.383 Ongoing medical and mental health care for sexual abuse
(d) victims and abusers
Are resident victims of sexually abusive vaginal penetration while na
incarcerated offered pregnancy tests? (N/A if all-male facility.)
115.383 Ongoing medical and mental health care for sexual abuse
(e) victims and abusers
If pregnancy results from the conduct described in paragraph § na
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.)
115.383 Ongoing medical and mental health care for sexual abuse
(f) victims and abusers
Are resident victims of sexual abuse while incarcerated offered yes
tests for sexually transmitted infections as medically appropriate?
115.383 Ongoing medical and mental health care for sexual abuse
(g) victims and abusers
Are treatment services provided to the victim without financial yes
cost and regardless of whether the victim names the abuser or
cooperates with any investigation arising out of the incident?
115.383 Ongoing medical and mental health care for sexual abuse
(h) victims and abusers
Does the facility attempt to conduct a mental health evaluation of yes
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?
115.386
Sexual abuse incident reviews
(a)
Does the facility conduct a sexual abuse incident review at the yes
conclusion of every sexual abuse investigation, including where
the allegation has not been substantiated, unless the allegation
has been determined to be unfounded?
115.386
Sexual abuse incident reviews
(b)
Does such review ordinarily occur within 30 days of the conclusion yes
of the investigation?
115.386
Sexual abuse incident reviews
(c)
Does the review team include upper-level management officials, yes
with input from line supervisors, investigators, and medical or
mental health practitioners?
115.386
Sexual abuse incident reviews
(d)
Does the review team: Consider whether the allegation or yes
investigation indicates a need to change policy or practice to
better prevent, detect, or respond to sexual abuse?
The subsection of this provision is no longer applicable to your na
compliance finding, please select N/A.
Does the review team: Examine the area in the facility where the yes
incident allegedly occurred to assess whether physical barriers in
the area may enable abuse?
Does the review team: Assess the adequacy of staffing levels in yes
that area during different shifts?
Does the review team: Assess whether monitoring technology yes
should be deployed or augmented to supplement supervision by
staff?
Does the review team: Prepare a report of its findings, including yes
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?
115.386
Sexual abuse incident reviews
(e)
Does the facility implement the recommendations for yes
improvement, or document its reasons for not doing so?
115.387
Data collection
(a)
Does the agency collect accurate, uniform data for every yes
allegation of sexual abuse at facilities under its direct control
using a standardized instrument and set of definitions?
115.387
Data collection
(b)
Does the agency aggregate the incident-based sexual abuse data yes
at least annually?
115.387
Data collection
(c)
Does the incident-based data include, at a minimum, the data yes
necessary to answer all questions from the most recent version of
the Survey of Sexual Violence conducted by the Department of
Justice?
115.387
Data collection
(d)
Does the agency maintain, review, and collect data as needed yes
from all available incident-based documents, including reports,
investigation files, and sexual abuse incident reviews?
115.387
Data collection
(e)
Does the agency also obtain incident-based and aggregated data yes
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.)
115.387
Data collection
(f)
Does the agency, upon request, provide all such data from the na
previous calendar year to the Department of Justice no later than
June 30? (N/A if DOJ has not requested agency data.)
115.388
Data review for corrective action
(a)
Does the agency review data collected and aggregated pursuant yes
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?
Does the agency review data collected and aggregated pursuant yes
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?
Does the agency review data collected and aggregated pursuant yes
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?
115.388
Data review for corrective action
(b)
Does the agency’s annual report include a comparison of the yes
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
Data review for corrective action
(c)
Is the agency’s annual report approved by the agency head and yes
made readily available to the public through its website or, if it
does not have one, through other means?
115.388
Data review for corrective action
(d)
Does the agency indicate the nature of the material redacted yes
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?
115.389
Data storage, publication, and destruction
(a)
Does the agency ensure that data collected pursuant to § 115.387 yes
are securely retained?
115.389
Data storage, publication, and destruction
(b)
Does the agency make all aggregated sexual abuse data, from yes
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?
115.389
Data storage, publication, and destruction
(c)
Does the agency remove all personal identifiers before making yes
aggregated sexual abuse data publicly available?
115.389
Data storage, publication, and destruction
(d)
Does the agency maintain sexual abuse data collected pursuant to yes
§ 115.387 for at least 10 years after the date of the initial
collection, unless Federal, State, or local law requires otherwise?
115.401
Frequency and scope of audits
(a)
During the prior three-year audit period, did the agency ensure yes
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.)
115.401
Frequency and scope of audits
(b)
Is this the first year of the current audit cycle? (Note: a “no” yes
response does not impact overall compliance with this standard.)
If this is the second year of the current audit cycle, did the agency na
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.)
If this is the third year of the current audit cycle, did the agency na
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.)
115.401
Frequency and scope of audits
(h)
Did the auditor have access to, and the ability to observe, all yes
areas of the audited facility?
115.401
Frequency and scope of audits
(i)
Was the auditor permitted to request and receive copies of any yes
relevant documents (including electronically stored information)?
115.401
Frequency and scope of audits
(m)
Was the auditor permitted to conduct private interviews with yes
inmates, residents, and detainees?
115.401
Frequency and scope of audits
(n)
Were inmates, residents, and detainees permitted to send yes
confidential information or correspondence to the auditor in the
same manner as if they were communicating with legal counsel?
115.403
Audit contents and findings
(f)
The agency has published on its agency website, if it has one, or yes
has otherwise made publicly available, all Final Audit Reports. The
review period is for prior audits completed during the past three
years PRECEDING THIS 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, there has never been a Final Audit Report
issued.)

source: DJJ

report_type: PREA

file_name: Florida_Britt Technical Youth Adademy_Year1Cycle5.pdf

program_name_raw: Britt Technical Youth Adademy

cycle: Year 1 Cycle 5