facility_name: Daytona Juvenile Residential Facility

summary: PREA

raw_content:
PREA AUDIT: AUDITOR’S SUMMARY REPORT
JUVENILE FACILITIES
Name of Facility: Daytona Juvenile Residential Facility
Physical Address: 1386 Indian Lake Road, Daytona Beach , Florida 32124
Date report submitted February 21, 2015
Auditor information : Lois Jenkins
Address P. O. Box 23905; Columbia, SC 29224
Email: lljenk2@bellsouth.net
Telephone number: 803-463-9554
Date of facility visit : January 20-21, 2015
Facility Information
Facility Mailing Address: Same as Above
(if different from above)
Telephone Number: 386-265-1932
The Facility is: Military County Federal
Pr ivate for profit Municipal State
Private not for profit
Facility Type: Detention C orrection Other:
Name of PREA Compliance Manager: Paul Brown Title: Facility Administrat or
Email Address: paul.brown@us.g4s.com Telephone Number: 386-265-1932 x25
Agency Information
Name of Agency: G4S Youth Services, LLC
Governing Authority or
G4S
Parent Agency: (if
applicable)
Physical Address: 6302 Benjamin Road, Suite 400; Tampa, FL 33634
Mailing Address: (if
different from above) Same as Above
Telephone Number: 813-514-6275
Agency Chief Executive Officer
Name: James C. Hill, Jr. Title: President
Email Address: jim.hill@us.g4s.com Telephone 813-514-6275, ext. 202
Number:
Agency Wide PREA Coordinator
Name: Bobbi Pohlman-Rogers Title: JJDPA/PREA Director
Telephone
Email Address: bobbi.pohlman@us.gus.com 954-818-5131
Number:
PREA AUDIT: AUDITOR’S SUMMARY REPORT 1
AUDIT FINDINGS
NARRATIVE:
Daytona Juvenile Residential Facility (DJRF) is a G4S Youth Services, LLC operated program located in
Daytona Beach Florida, Florida. Currently, the facility operates under contract with the Florida
Department of Juvenile Justice (FDJJ) and all residents are placed there by the FDJJ. The facility
operates as a 30 bed high-risk treatment program for adolescent male sex offenders between the ages of
13-18 with an average length of stay of 12 to 18 months.
DJRF employs a multi-disciplined staff to address the needs of youth placed there. Daily operational
oversight is provided by a full-time Facility Administrator and Assistant Facility Administrator, supported
by a Clinical Director and other clinical staff, Health Services Administrator and nurses, administrative
staff and a work force of direct care service providers focusing on treatment, safety, security, and order.
During the time of the on-site audit there were 33 staff employed at DJRF.
Staff reports that the core program at DJRF is a competency-based level system integrating behavioral
and clinical objectives, skill building and task completion and that staff at all levels are full participants in
an interdisciplinary treatment team approach to address the resident’s individualized needs, offer
guidance and assistance in goal completion, and monitor progress towards successful transition of the
resident to his family and the community. DJRF utilizes Thinking for a Change, Impact of Crime, and
Pathways curricula to direct the program’s treatment approach.
The facility provides all clothing and hygiene items and the on-site health care providers are available to
address the individual medical needs of each resident. Additionally, when assessed to be necessary,
residents may be taken off-site for medical attention.
Education and vocational services are provided through the Volusia County School District. The DJRF
school program offers English, Math, Science, Social Studies, and one elective course. Vocational
opportunities include the Microsoft Professional Career Certification.
DESCRIPTION OF FACILITY CHARACTERISTICS:
Daytona Juvenile Residential Facility is surrounded by a security perimeter fence. The complete facility
consists of three buildings referred to as Building One, Building Two and The Garage Building. Building
One includes staff offices, classrooms, a multipurpose room (also used for visitation), a kitchen, janitorial
closet, and bathroom facilities. Building Two is comprised primarily of two wings. One wing houses the
offices of the facility administrator, clinical, and medical staffs and medical examination room, as well as
a JSO classroom, a multipurpose day room, a kitchen, bathroom facilities, and janitorial closet. The other
wing of Building Two houses the master control surveillance area, resident sleeping rooms, and
bathroom/shower area. Within the living unit one resident is assigned per room. During the onsite audit
there were a total of 22 residents.
The Garage building is used for storage and maintenance staff work area.
There is adequate recreational space with the out-door recreation area located within the perimeter fence.
The facility has a total of 24 surveillance cameras in various locations both inside and outside of
buildings.
PREA AUDIT: AUDITOR’S SUMMARY REPORT 2
SUMMARY OF AUDIT FINDINGS:
The notification of the on-site audit was posted on December 9, 2014, six weeks prior to the first date of
the on-site audit. The posting of the notice was verified by photographs received electronically from the
Facility Administrator/PREA Compliance Manager. The photographs indicated notices were posted in
various locations throughout the facility including the housing unit and administrative areas.
A conference call was held with the G4S PREA Coordinator on December 31, 2014. The Pre-Audit
Questionnaire, policies and supporting documentation were uploaded to a flash drive and received via
Federal Express delivery from the DJRF PREA Compliance Manager on January 2, 2015. The
information received was well organized and easy to navigate. Upon review of the information, it was
noted that the Pre-Audit Questionnaire was not completed on the most recent version prompting a phone
call to the PREA Compliance Manager who submitted an updated Pre-Audit Questionnaire. A follow-up
call was placed on January 15, 2015 to discuss the Pre-Audit Questionnaire, discuss the on-site audit
process and additional documentation to be available for review during the on-site audit. An itinerary and
audit protocol was sent electronically to the PREA Compliance Manager.
The on-site audit was conducted January 20-21, 2015, and began with a brief meeting with the Facility
Administrator/PREA Compliance Manager, and then a meeting with the Facility Administrator and three
department heads to discuss the schedule for the day and documentation to be reviewed. After the
meeting we took a tour of the facility and observed all of the physical plant and grounds. I was
accompanied on the tour by the Facility Administrator and Assistant Facility Administrator. While
touring I observed that no resident was in the sleeping area. The residents were in school and under
supervision of teachers and security staff. I also observed that the audit notices were posted in various
locations in both buildings and posters in multiple languages were posted throughout the facility stating
the agency’s zero-tolerance for any form of sexual abuse or harassment with instructions on how to report
sexual abuse and harassment. Surveillance cameras are not located in the residents’ rooms or bathrooms
so the surveillance system does not show these areas, allowing residents to dress, shower and toilet in
private.
During the two-day on-site visit, 14 staff was interviewed, including workers from all three shifts. Staff
interviews revealed they have been trained on PREA Standards and understand their responsibilities and
duties to prevent, detect, and respond to sexual abuse and harassment. Ten random residents were
interviewed. The residents were informed of their right to be free from sexual abuse and harassment, and
retaliation, as well as how to report sexual abuse and harassment.
Finally, during the on-site audit process, all DJRF staff encountered was cooperative and responsive in
providing any requested documentation or audit needs. At the conclusion of the on-site audit, an exit
meeting was conducted with the Facility Administrator/PREA Compliance Manager.
A summary of audit findings are provided below.
Number of standards exceeded: 0
Number of standards met: 37
Number of standards not met: 0
Number of standards Not Applicable: 4
PREA AUDIT: AUDITOR’S SUMMARY REPORT 3
Standard 115.311 – Zero To tolerance of sexual abuse and sexual harassment.
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Daytona Juvenile Residential Facility (DJRF) Policy 10-25 dated September 22, 2014, conforms
to that of its contracting agency, Florida Department of Juvenile Justice, Policy 1919 revised
April 10, 2014. Page 3 of the DJRF policy has clearly written language mandating a zero
tolerance for all forms of sexual abuse and sexual harassment. Within the 10 page policy, the
agency’s approach to preventing detecting and responding to acts of sexual abuse and harassment
is outlined.
The agency, G4S, has a PREA Coordinator who oversees PREA compliance efforts for the
agency. Page 3 of policy 10-25 designates the DJRF Facility Administrator as the PREA
Compliance Manager and outlines the specific related duties. When interviewed, both the PREA
Coordinator and PREA Compliance Manager indicated they had authority and sufficient time to
manage PREA compliance related responsibilities.
Standard 115.312 - Contract with other entities for the confinement of residents.
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Not Applicable
DJRF is a G4S Youth Services, LLC program that operates under contract with the Florida
Department of Juvenile Justice (FDJJ) and does not contract with other entities for the
confinement of residents.
Standard 115.313 - Supervision and Monitoring
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF is a G4S Youth Services, LLC program and operates through contractual arrangement with
the Florida Department of Juvenile Justice (FDJJ). Policy 10-25 mandates that a Staffing Plan
Assessment be completed compliant with the requirements outlined in section (a) of this standard.
According to the most recent Staffing Plan Assessment and interview with the PREA Compliance
Manager, the facility maintains a minimum staffing ratio of 1:6 during resident waking hours and
1:10 during resident sleeping hours. The program utilizes a holdover schedule and no deviations
from the staffing plan during the past 12 months were found. There are no findings of inadequacies
PREA AUDIT: AUDITOR’S SUMMARY REPORT 4
from judicial, federal investigative agencies, nor internal or external oversight bodies; and there
were no documented deviations from the staffing plan.
The Staffing Plan Assessment and interviews with staff served to validate that in establishing and
maintaining the agreed upon ratios, consideration was given to needs of the residents to be served,
physical location and layout of the facility, as well as the location of available video surveillance
cameras. The Staffing Plan Assessment documents a total of 24 cameras and notes where they are
located. During the facility tour said cameras were observed.
DJRF Policy 10-25 mandates that Administrative Duty Officer (ADO) shall conduct unannounced
rounds on all shifts and that they be documented. The ADO at DRJF is upper or intermediate level
staff. Documentation of logs and video clips from the master surveillance system were provided
as documentation that unannounced rounds are occurring on all shifts.
Standard 115.315 - Limits to cross gender viewing and searches
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF policies 10-25, 10-3, and 8-14 outline all mandates in compliance with this standard.
Policy requires that only in exigent circumstances will cross-gender searches be conducted and
that any such search will be documented as to the reason for the search and why a same sex staff
was not available. DJRF Policy 10-3, states that strip searches must be conducted in a private
room with two staff members of the same sex as the resident. DJRF Policy 10-3 further states that
body cavity searches must be approved by the Facility Administrator or the Operations
Administrator only when it is strongly suspected that a youth has concealed contraband in the
body cavity. All body cavity searches must be conducted by trained medical personnel in an
emergency room setting. Program staff is not authorized to conduct a body cavity search of a
youth. During the past 12 months, there were no cross-gender strip and body cavity searches and
no cross-gender pat-down searches.
Policy prohibits searching or examining a transgender or intersex resident for the sole purpose of
determining the resident’s genital status.
Further, policy also mandates that residents have access to shower, perform bodily functions, and
change clothing without non-medical staff of the opposite gender viewing; and that staff of the
opposite sex shall announce their presence when entering resident housing facility or an area
where residents are likely to be showering or performing bodily functions or changing clothing.
Interviews with staff and residents verified that these practices are in place at DJRF.
DJRF provided documentation that security staff received training on how to conduct pat down
searches in a professional and respectful manner.
Standard 115.316 - Residents with disabilities and residents who are limited English proficient
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
PREA AUDIT: AUDITOR’S SUMMARY REPORT 5
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 requires the PREA Facility Compliance Manager to ensure residents with
disabilities and residents who are limited English proficient have an equal opportunity to
participate in or benefit from all aspects of the facility’s efforts to prevent, detect, and respond to
sexual abuse and harassment. The policy also states the facility will take steps to provide
interpreters who can interpret effectively, accurately, and impartially.
The policy prohibits the use of youth as interpreters, readers, or other assistant to perform such
functions except in limited circumstances where an extended delay in obtaining interpreters
services could jeopardize residents’ safety. The facility does not use resident assistants and there
were no instances of resident interpreter or readers being used in the past 12 months. Resident
and staff interviews validated compliance.
Policy 9-2, Classification and Orientation, provides further guidance for staff in meeting the
standard requirements.
Documentation for interpreter services and youth education materials was provided by the PREA
Compliance Manager.
Standard 115.317 - Hiring and promotion decisions
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Elements required by this standard are outlined in DJRF Policies 10-25 and 3-16 which conforms
to FDJJ Policy 1919, except for contacting the abuse registry for screening applicants.
Documentation that Florida law does not permit contacting the abuse registry for the purpose of
screening applicants was provided.
Persons desiring employment with DJRF completes the application packet; a portion of which is
sent from DJRF to the FDJJ Office of the Inspector General for background screening. Details of
the screening are described on the FDJJ’s website and include conducting two background
screenings; the Level II pre-employment screening and a 5-year re-screening. Upon request,
background screening is conducted on state and contract provider directors, owners, applicants,
employees, volunteers, mentors, and interns. The term contract provider includes grant recipient
employees, volunteers, mentors, and interns. Background screenings consist of a state and
national fingerprint check through the Florida Department of Law Enforcement and the Federal
Bureau of Investigations, and a demographic search of the Florida Clerk of the Courts. As a
criminal justice agency, the Department has access to juvenile, sealed, and expunged criminal
history information.
Interview with Human Resources (HR) staff confirmed that the policy is in practice for staff and
contractors. The auditor’s review of 10 of 33 current HR staff files validated at 100% that
criminal background records checks were completed, and applicants seeking employment are
asked about previous misconduct outlined in section (a) of this standard consistent with PREA
PREA AUDIT: AUDITOR’S SUMMARY REPORT 6
requirements and Florida Statutes. Of 10 files reviewed 5 met the five-year threshold for
rescreening and contained documentation validating the rescreens were completed in a timely
fashion.
DJRF has in place a process for contacting prior employers for information before hiring and
sharing information with employers.
FDJJ policy 1919 states that staff 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.
Standard 115.318 - Upgrades to facilities and technology
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Not Applicable
DJRF has not acquired any new facilities, or made any expansion or modification since August 20,
2012. DJRF has not installed or updated a video monitoring or surveillance system since August
20, 2012.
Standard 115.321- Evidence protocol and forensic medical examinations
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF does not conduct administrative or criminal sexual abuse investigations and by policy upon
learning of such an event DJRF staff must immediately make a report through the Florida
Department of Juvenile Justice (FDJJ) Central Communications Center (CCC) hotline. Policy
also mandates a call to local law enforcement and the Florida Department of Children and
Families Abuse Registry hotline. Criminal investigations are conducted by the Volusia County
Sheriff’s Office. The FDJJ has outlined for the local authorities how such investigations should
be conducted in compliance with the requirements outlined in sections (a) through (e) of this
standard.
Policy 7-30 states that all services for sexual assault allegation shall be provided at no cost to the
victim. Staff interviews validated that staff is aware of this policy. Documentation provided
revealed that DJRF has secured an agreement with the Florida Council Against Sexual Violence
for rape crisis services. Documentation was also provided for a Qualified MH professional
available when needed. There were no forensic medical examinations conducted in the past 12
months.
Standard 115. 322 - Policies to ensure referrals of allegations for investigations
PREA AUDIT: AUDITOR’S SUMMARY REPORT 7
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF policy 10.25 requires that any staff receiving a report of sexual misconduct or possible
sexual misconduct must ensure that it is immediately reported to their supervisor who shall ensure
that it is reported to local law enforcement if criminal in nature.
As stated in policy, the FDJJ does not conduct criminal investigations of youth-related sexual
misconduct reports. Local law enforcement agencies and the Department of Children and
Families handle such investigations. During the past 12 months, DJRF received five allegations
of youth on youth sexual abuse and all five were reported to the Volusia County Sheriff’s office
the Florida Department of Children and Families, and the FDJJ Office of the Inspector General,
CCC hotline for administrative investigation. At the time of the onsite audit, the investigations
were not yet finalized.
The FDJJ Policy 1919 describes the agency’s investigative responsibilities and duties for its
facilities and is published on the website.
Standard 115.331 - Employee training
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policies 10-25 and FDJJ Policy 1919 outline training requirements for staff that is
consistent with this standard. All newly hired employees are trained and the agency provides
PREA refresher trainings.
Review of employee staff training logs for PREA training with pre and post test results, 38 signed
staff training Acknowledgement Forms with post training scores, staff training curricula, and
other materials included as a part of PREA training, as well as staff interviews, all served to
validate that DJRF staff has been trained in compliance with this standard. The training
curriculum provided was consistent with the elements of 115.331(a).
Standard 115. 332 - Volunteer and contractor training
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy requires that all persons providing volunteer or contractor services at DJRF to be
PREA AUDIT: AUDITOR’S SUMMARY REPORT 8
trained on the agency’s zero-tolerance policy regarding sexual abuse and harassment and how to
report such incidents. Additional training provided to volunteers and contractors is based on the
service they provide and the level of contact they have with residents. Before volunteers can have
access to DJRF and provide services they must take the FDJJ PREA training, “A Course for
Volunteers” and upon completion, sign the form acknowledging that they have completed the
course and understand FDJJ PREA Policy 1919. This was verified through review of 25
acknowledgement forms (one dated 2011, one dated 2012, two dated 2013, twenty dated 2014, and
one dated 2015).
Contractors such as dentist, psychiatrist, and medical doctors sign the Acknowledgement of the
Prison Rape Elimination Act form declaring they have been informed and understand that DJRF
has a zero tolerance and that sexual contact of any kind is forbidden, the possible penalties for such
behaviors, and that they have a duty to report.
Documentation of 14 signed Teacher Acknowledgement of PREA training forms was provided.
Standard 115.333 - Resident education
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 requires that during intake all residents will be provided with information on
zero-tolerance regarding sexual misconduct including how to report sexual abuse and suspicion of
any sexual misconduct. Policy also requires that within 10 days of intake, all residents will be
provided with additional comprehensive training regarding their rights to be free from sexual
misconduct; their right to be free from retaliation for reporting; and the agency’s sexual
misconduct response policies and procedures.
As a part of the orientation, youth are given a resident handbook, and handouts with telephone
numbers for outside services including the Abuse hotline and acknowledge through signature that
they received the information and that they understand their right to be Safe from Sexual
Misconduct, Abuse and Harassment. Policy 9-2, Classification and Orientation, provides further
guidance for staff in meeting the standard requirements. Interviews with intake and clinical staff
verified that youth are provided with PREA required education when admitted to the facility.
Additionally, DJRF is a sex offender treatment program and staff reports PREA related topics are
constantly covered in multiple ways during a youth’s stay at the facility. Interviews with 10
random residents validated that they received education on PREA the same day they arrived at
the facility.
During the tour of the facility, posters in multiple languages outlining the sexual abuse zero
tolerance policy, duty to report, and instructions for reporting, were posted in various locations in
including the living units.
Youth Education handouts in multiple languages were provided to the auditor.
Standard 115.334 - Specialized training: Investigations
PREA AUDIT: AUDITOR’S SUMMARY REPORT 9
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Not Applicable
DJRF does not employ facility investigators. Criminal and administrative investigations are
referred to outside agencies.
Standard 115.335 - Specialized training: Medical and mental health care
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 and FDJJ Policy 1919 mandates medical and mental health care providers will
be subject to sexual abuse training similar to that of FDJJ employees as well as medical and mental
health specialized training consistent with the requirements of section (a) of this standard.
Staff interviews verified that DJRF medical staff does not conduct forensic examinations.
Documentation of electronic verification of completion of PREA sexual abuse training and
medical and mental health specialized training by all DJRF medical and mental health staff was
provided to the auditor.
Standard 115.341 – Obtaining Information from Residents
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 9-1 describes the process staff is to use for screening for Vulnerability to
Victimization and Sexual Aggressive Behavior (VSAB). Within 24 hours of a resident’s arrival
at the facility, trained staff meets with residents and complete the VSAB form. Information is
gathered from multiple sources to include parents, records from FDJJ, PDR reports, and
interviews with the youth. The instrument is scored prior to housing placement. Those residents
who score vulnerable to victimization or sexually aggressive are included in the alert system, and
referred for further assessments, as identified. Residents who are identified or report as prior
sexual victims are referred to the medical and mental health professionals within 14 days.
Interviews with the clinical director and PREA Compliance Manager confirmed that policy is in
practice and that information from the VSAB is disseminated on a “Need to Know” basis.
The screening for vulnerability to sexual victimization and sexual aggressive behavior instrument
PREA AUDIT: AUDITOR’S SUMMARY REPORT 10
met the 11 minimum required elements outlined in section (c) of the standard.
Standard 115. 342 – Placement of residents in housing, bed, program, education, and work
assignments
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy10-25 clearly states that the information gathered from screening for vulnerability to
sexual victimization and abusiveness shall be to guide treatment plans and security and
management decisions, including housing bed, work, education and program assignments.
Policy directs DJRF staff to maintain a continually updated internal alert system that keeps staff
alerted who are security or safety risks in multiple categories including sexual predator risks.
The resident housing at DJRF consists of one unit with single rooms. Isolation is prohibited.
DJRF Policies direct staff in the treatment of LGBTI residents consistent with those outlined in
sections (c) through (g) of this standard. There were no identified LGBTI residents in the
population at the time of the audit. Interviews with staff indicated they are aware of the policy
and would comply.
Standard 115. 351 - Resident Reporting
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 8.3.4 (B) Abuse and Neglect Reporting – states clearly that all youth shall have
unimpeded access to the Florida Abuse Hotline without interference or retaliation of any kind and
further outlines in detail that the Abuse hotline number is to be provided at intake. The number is
also, included in the resident handbook and posted throughout the facility.
DJRF provides instruction and multiple ways for residents to report sexual abuse and harassment
including telling a staff member, writing a grievance, asking to speak with the Facility
Administrator or a therapist, or calling the Florida Abuse Hotline. The abuse hotline number is
included in the resident handbook.
Staff and residents validated that they have access to the tools necessary to make a report. Also,
policy outlines procedures for staff to follow preventing them from denying a youth an abuse call,
delaying the call or listening in on the call. For security reasons staff may maintain sight
monitoring of the youth while the call is placed.
Interviews with staff validated that they would accept and document reports made verbally, in
PREA AUDIT: AUDITOR’S SUMMARY REPORT 11
writing, anonymously, and from third parties.
Standard 115.352 - Exhaustion of administrative remedies
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 8-4 outlines the administrative procedures for resident grievances regarding sexual
abuse or sexual harassment. The policy aligns nicely with this standard including no time limit for
a resident to file a grievance; and any grievance received that alleges a resident is substantially at
risk for imminent sexual abuse shall be immediately directed to the Facility Administrator, who
shall provide immediate response to the grievance.
During the past 12 months no sexual abuse grievance was filed. Interviews with residents
validated their knowledge of how to file a grievance for sexual abuse or harassment. During the
facility tour a locked grievance box was visible in the living unit.
Random resident interviews verified that they are aware of the procedures for filing an emergency
grievance.
Standard 115.353 - Resident access to outside confidential support services and legal representation
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy10-25, page 5 of 10 requires that residents shall have access to outside victim
advocates, the facility shall make accessible mailing addresses and telephone numbers, including
hotline numbers of victim advocacy or rape crisis organizations, and residents shall have
reasonable and confidential access to attorneys, parents or legal guardians.
Review of youth education materials including youth handbook, posters, brochures and handouts
verified that the information is made available to DJRF residents. Further, interviews with
residents and staff, suggest DJRF residents have been provided mailing addresses and telephone
numbers of local, state, or national victim advocacy or rape crisis organizations.
Documentation was provided verifying that DJRF has secured an agreement with the Florida
Council Against Sexual Violence for victim advocacy services.
DJRF does not detain residents solely for immigration purposes.
Standard 115.354 - Third-party reporting
Exceeds Standard (substantially exceeds requirement of standard)
PREA AUDIT: AUDITOR’S SUMMARY REPORT 12
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF is a FDJJ contracted facility and DJRF through the FDJJ website informs the public with
information regarding third-party reporting of sexual abuse and harassment on behalf of facility
residents. The FDJJ website also has a section dedicated to parents and among other information
includes this statement, “Abuse and neglect are serious issues that need to be handled with care.
In the event of an emergency abuse situation, ALWAYS call 911 FIRST and call the Florida
Abuse Hotline second at 1-800-962-2873. In a non-emergency situation, contact the Florida
Abuse Hotline via phone, fax, or web to receive assistance.” Complaints concerning the delivery
of services, safety, or security at a DJJ facility or program should be immediately reported to the
Central Communications Center. All other complaints can be reported to the Bureau of
Investigations. Incident/Complaint Hotline: (800) 355-2280. Complaints can also be: Faxed to
the Office of the Inspector General at (850) 414-7182;E-mailed to
OIG.Complaints@djj.state.fl.us; or Mailed to the: Department of Juvenile Justice, Office of the
Inspector General; 2737 Centerview Drive; Tallahassee, FL 32399-3100”
DJRF can receive third-party reports of sexual abuse and harassment through the Florida
Department of Children and Families Abuse hotline and the FDJJ Office of the Inspector General -
Central Communications Center hotline.
Interviews with residents revealed they are aware sexual abuse or harassment may be reported
through a third party.
Standard 115.361- Staff and agency reporting duties
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
The employees at DJRF are mandatory reporters and DJRF Policy 8-3 directs staff to immediately
report any abuse, knowledge, suspicion or information they receive regarding an incident of abuse
or harassment. Policy also directs staff to report any retaliation against residents or other staff
who reported an incident; and any staff neglect or violation of responsibilities that may have
contributed to an incident of abuse or retaliation. DJRF policies further direct staff in complying
with the elements outlined in sections (b) through (f) of this standard. Interviews with Health
Services Administrator, Facility Administrator/PREA Compliance Manager, and random selected
staff served to validate that the staff are aware of the policies and their duty to report. Staff
interviews also confirmed their knowledge of limits of liability and consents required. Review of
medical and mental health files verified documentation of applicable consent forms with resident
signatures.
Standard 115.362 - Agency protection duties
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
PREA AUDIT: AUDITOR’S SUMMARY REPORT 13
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 requires that when staff learns that a resident is subject to a substantial risk of
imminent sexual abuse it shall take immediate action to protect the resident from harm or further
threat. During the past 12 months no residents were identified to be of such risk. Interviews with
the Agency Head Designee, Facility Administrator/PREA Compliance Monitor and random
sample of staff validated that staff is aware of their mandate to immediately take steps necessary
to keep the resident safe.
Standard 115.363 - Reporting to other confinement facilities
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
During the past 12 months DJRF staff did not receive any reported allegations that a DJRF resident
was abused while confined at another facility. Likewise, DJRF did not receive any reports of
allegations of sexual abuse from other facilities that residents previously confined at DJRF were
sexually abused.
DJRF policy 10-25 requires that the Facility Administrator or designee shall notify the program
Administrator or Director upon receiving an allegation that a youth was sexually abused while
confined at that facility where the abuse occurred.
Standard 115.364 - Staff first responder duties
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 mandates in responding to sexual abuse that staff take specific steps consistent
with those outlined in sections (a) and (b) of this standard. These steps include identifying the
victim and perpetrator, keeping the victim safe and separate from the alleged perpetrator,
preserving any crime scene within a period that still allows for the collection of physical
evidence; requesting the alleged victim not take any action that could destroy physical evidence;
and ensuring the alleged abuser does not take any action to destroy physical evidence. DJRF
does not have investigators so beyond the steps already mentioned, staff are directed to report and
cooperate with the investigators when they arrive. Staff was able to articulate these duties and
responsibilities during interviews which indicated they have been trained and is aware of the
policies.
Standard 115.365 - Coordinated response
Exceeds Standard (substantially exceeds requirement of standard)
PREA AUDIT: AUDITOR’S SUMMARY REPORT 14
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
A Coordinated Response Plan specific to DJRF was provided to the auditor. The Plan outlines the
specific tasks to be completed by multiple people beginning with the 1st responder and ending with
the PREA Compliance Manager convening the Incident Review Team and final decisions.
Interview with the Facility Administrator/PREA Compliance Manager revealed knowledge of the
policy and responsibilities and duties of staff.
Standard 115.366 - Preservation of ability to protect residents from contact with abusers.
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Not Applicable
Daytona Juvenile Residential Facility does not participate in collective bargaining.
Standard 115.367 - Agency protection against retaliation
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policies 10-25 and 8-3 establish that residents and staff are to be protected from retaliation
for reporting sexual abuse or harassment and/or cooperating with investigations of sexual abuse
and harassment. The monitoring will take place for a period of at least 90 days and at each 30 day
interval the Facility Administrator/PREA Compliance manager will determine if retaliation is
occurring by reviewing such items as disciplinary reports, status checks, housing or program
changes, and negative performance reviews or staff reassignment. There were no incidents of
retaliation in the past 12 months reported.
Standard 115.368 - Post allegation protective custody
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF does not have isolation rooms or segregated housing. DJRF reports no resident alleging
sexual abuse was placed in isolation.
PREA AUDIT: AUDITOR’S SUMMARY REPORT 15
Standard 115.371 - Criminal and administrative agency investigations
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF does not employ facility investigators. All allegations of abuse are reported to the Florida
Department of Children and Families, the Volusia County Sheriff’s Office, and the FDJJ Office
of the Inspector General – Central Communications Center. DJRF reports one sustained
allegation of conduct appearing to be criminal that were referred for prosecution since August 20,
2012. The resident was 18 years old and was sent to a higher security level facility.
Standard 115.372 - Evidentiary standards for administrative investigations
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF does not conduct administrative investigations. All allegations of abuse are reported to
FDJJ Office of the Inspector General – Central Communications Center. Staff from the
Inspector General’s office conducts the administrative investigation and provides a report back to
DJRF.
Standard 115.373 - Reporting to residents
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 page 9 reads, “At the conclusion of any investigation where a sexual abuse
incident has been reported, the Facility Administrator shall notify the victim or victim’s parents
or legal guardians that the investigation is concluded.”
There were no investigations completed during the past 12 months and therefore no notifications
to victims, victim parents or legal guardians. During interview the PREA Compliance Manager
was knowledgeable of the reporting requirement.
Standard 115.376 - Disciplinary sanctions for staff
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
PREA AUDIT: AUDITOR’S SUMMARY REPORT 16
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
It is written in G4S DJRF Policy 10-25 that sexual activity between staff, volunteers or contracted
personnel and youth, as well as between youth is prohibited and subject to administrative and
criminal disciplinary sanctions. The policy also mandates that violations be reported to law
enforcement. The G4S Employee Handbook makes clear that employee sexual harassment is
prohibited and when an allegation is substantiated, disciplinary action up to and including
termination will be imposed.
During the past 12 months no staff from DJRF has been disciplined, terminated or resigned for
violating agency sexual abuse or harassment policies. Likewise, no DJRF staff has been reported
to law enforcement or licensing boards for violating agency sexual abuse and sexual harassment
policies.
Standard 115.377 - Corrective Action for contractors and volunteers
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-22 requires that like staff, volunteers and contracted personnel in violation of the
facility’s policies and procedures regarding sexual abuse and harassment of residents will be
reported to local law enforcement, unless the activity was clearly not criminal, and to relevant
licensing bodies.
DJRF reports not having any allegations of sexual abuse or harassment by contractors or
volunteers therefore no reports to law enforcement or licensing bodies and no remedial measures
were taken. Interviews with the Facility Administrator/PREA Compliance Manager revealed
knowledge of the remedial measures that would be taken.
Standard 115.378 - Disciplinary sanctions for residents
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF is designated as a sex offender treatment facility. During the past 12 months there has been
no administrative finding of resident-on-resident sexual abuse; and no criminal finding of guilt for
resident-on-resident sexual abuse at DJRF. No residents were placed in isolation. Interviews with
the Facility Administrator, medical, and mental health staff verified that residents are informed that
in the event of such findings charges could be filed. If, not prosecuted, then the Treatment Team
would make decision for any necessary treatment modification. Policy 8-1 provides guidance for
staff in holding youth accountable for their behaviors.
PREA AUDIT: AUDITOR’S SUMMARY REPORT 17
Standard 115.381 - Medical and mental health screenings; history of sexual abuse
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 requires that if during intake screening, health/mental health screening, or
health history, a resident discloses prior sexual victimization or perpetrated sexual abuse, whether
it occurred in a facility setting or in the community, staff shall ensure the youth is referred for
medical and mental health services within 14 day of the screening. Policy also mandates that
sensitive information shall be on a need-to-know basis and shall not be exploited to the resident’s
detriment by staff or other residents. Classification meetings that include medical and mental
health staff occur after intake on the same day that youth arrive at DJRF allowing for immediate
referrals for any necessary follow-up medical or mental health services. For youth 18 years or
older the Release of Information Authorization form is completed requiring the youth’s signature.
DJRF reports no resident disclosing prior victimization during their initial screening process.
Interviews with the medical and mental health staff and review of documentation in 12 MH files
and 12 medical files verified compliance with this standard.
Standard 115.382 - Access to emergency medical and mental health services
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 7-30 requires that residents who are victims of sexual assault shall have immediate
medical care. The Health Services Administrator verified that any sexual assault victim would
be provided unimpeded access to emergency medical treatment immediately and according to the
medical staff’s professional judgment; the victim would be offered timely information about
access to emergency contraception and sexually transmitted infection prophylaxis; and that the
services would be provided without cost to the victim. These services are documented in the
youth’s medical files. The one resident who reported sexual abuse still remaining in the program
verified when interviewed that he had a chance to see the nurse and he received mental health
treatment.
Standard 115.383 - Ongoing medical and mental health care for sexual abuse victims and abusers
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 7-30 mandates ongoing medical and mental health care for sexual abuse victims and
abusers to include mental health evaluations and services as appropriate and medical health care
PREA AUDIT: AUDITOR’S SUMMARY REPORT 18
services consistent with the community level of care. DJRF is an all-male residential facility.
Interviews with the Health Services Administrator and Clinical Director verified that there are
procedures in place compliant with the requirements of this standard.
Standard 115.386 - Sexual abuse incident reviews
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25, page 8 mandates that the facility shall conduct a sexual misconduct review at
the conclusion 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. The policy further mandates that the Review Team shall ordinarily conduct the
incident review within 30 days of the conclusion of every sexual misconduct investigation or
administrative review. Page 9 of the policy outlines the specifics of the Review Team’s duties the
same as those in section (d) of the standard; and directs that Review Team recommendation must
be implemented or justification provided for not implementing the recommendations. Review
Team meetings and findings are documented on the PREA Review Report. Interview with Facility
Administrator/PREA Compliance Manager verified that the facility is in compliance with this
standard.
Standard 115.387 - Data collection
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 directs that the facility shall ensure records are maintained and the Facility
Administrator shall ensure that requests for additional information from the FDJJ PREA
Coordinator are responded to in a timely manner. FDJJ Policy 1919 requires the Department to
collect uniform data in the Office of the Inspector General’s – Central Communications Center for
every allegation of sexual misconduct at its facilities, both state-operated and contracted providers.
Interview with the G4S Agency Head Designee verified that G4S maintains an Incident Report
(IR) Tracking system and that G4S facilities such as DJRF feed data to FDJJ and FDJJ publishes
the Annual Report.
Standard 115.388 Data review for corrective action
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
FDJJ Policy 1919 requires the PREA Coordinator to review data collected and aggregated in order
PREA AUDIT: AUDITOR’S SUMMARY REPORT 19
to assess and improve the effectiveness of the Department’s sexual misconduct prevention,
detection and response policies, practices, and training. Policy also requires that FDJJ will prepare
an annual report of sexual misconduct incidents, findings, and corrective actions for all facilities,
state and contracted, and the Department as a whole. The report includes a comparison of the
current years’ data and corrective actions with those from prior years. The report is made
available to the public through the FDJJ website.
Standard 115.389 Data storage, publication and destruction
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
DJRF Policy 10-25 directs that the facility shall ensure records are maintained and the Facility
Administrator shall ensure that requests for additional information from the FDJJ PREA
Coordinator are responded to in a timely manner. Interview with the G4S Agency Head Designee
verified that G4S maintains an Incident Report (IR) Tracking system and that G4S facilities such
as DJRF feed data to FDJJ and FDJJ publishes the Annual Report. FDJJ Policy 1919 established
that aggregated sexual abuse data be reviewed annually and placed on the facility’s website after
all personal identifiers are removed. All data collected will be maintained for at least 10 years
after the date of the initial collection.
AUDITORTOR CERTIFICATION:
The auditor certifies that the contents of the report are accurate to the best of his/her knowledge and
no conflict of interest exists with respect to his or her ability to conduct an audit of the agency under
review.
February 20, 2015
Auditor Signature Date
PREA AUDIT: AUDITOR’S SUMMARY REPORT 20

report_type: PREA