facility_name: Hillsborough Juvenile Detention Center West

summary: PREA

raw_content:
PREA AUDIT: Auditor’s Summary Report
JUVENILE FACILITIES
Name of Facility: Hillsborough Girls Academy
Physical Address: 9506 E. Columbus Drive, Tampa, Florida 33619
Date report submitted: December 23, 2014
Auditor information: Flora Boyd
Address: 5 Rosemount Court, Blythewood, South Carolina 29016
Email: fbb4577@aol.com
Telephone number: 803-312-5199
Date of facility visit: July 18, 2014
Facility Information
Facility Mailing Address:
(if different from above) Same as Above
Telephone Number: 813-630-2900
The Facility is: Military County Federal
X Private for profit Municipal State
Private not for profit
Facility Type: Detention X Correction Other:
Name of PREA Compliance Manager: Shaurice Darling Title: Facility Administrator
813-630-2900
Email Address: shaurice.darling@g4s.com Telephone Number:
Agency Information
Name of Agency: G4S Youth Services, LLC
Governing Authority or Parent Agency: (if applicable)
G4S Youth Services, LLC
Physical Address: 6302 Benjamin Road, Suite 400,Tampa, Florida 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
Telephone Number: 813-514-6275 ext. 202
Email Address: jim.hill@us.g4s.com
Agency Wide PREA Coordinator:
Name: Bobbi Pohlman-Rogers Title: JJDA/PREA Director
Telephone Number: 954-818-5131
Email Address: bobbi.pohlman@us.g4s.com
1
AUDIT FINDINGS
NARRATIVE:
The Hillsborough Girls Academy (HGA) is located in Tampa, Florida and operated by G4S Youth
Services, LLC, under contract with the Florida Department of Juvenile Justice (FDJJ). HGA is an
18-bed, high and maximum risk program that serves high-risk female juvenile offenders, ages 13-
18 and maximum-risk female juvenile offenders, ages 14-21. The program utilizes gender specific,
cognitive-behavioral treatment and evidence-based programming. The average length of stay for
high-risk youth is between 9-12 months, while maximum-risk youth will stay between 18-36
months.
The facility has a total of 27 full-time positions, including a Facility Administrator, an Assistant
Facility Administrator, two mental health counselors, one case manager, one nurse, four
supervisors and ten direct care staff. HGA operates under the company’s “Girls 4 Success” model
which identifies signature strengths such as volunteer and family-focused services along with
therapeutic support, health and wellness, academic, and life skills services. Education is provided
by the Hillsborough County School District. HGA is accredited by the Commission on
Accreditation of Rehabilitation Facilities.
HGA provides Mental Health Overlay Services, individual, family and group treatment that
includes anger management, coping skills, depression management, ego development, self-
concept, family issues, impulse control, life and social skills, female issues, substance abuse and
addiction, trauma, and domestic violence.
DESCRIPTION OF FACILITY CHARACTERISTICS:
HGA consists of a single building with an administrative area, a multi-purpose area, and
educational classrooms, a kitchen and two separate housing units. One housing units has 12 single
rooms and the other has 13 single rooms. Shower and toilet stalls have curtains to help ensure
residents’ privacy. The facility has a video monitoring system 24 hours with 18 cameras.
SUMMARY OF AUDIT FINDINGS:
The notification of the on-site audit was posted six weeks prior to the first date of the on-site audit.
The posting of the notices was verified by photographs received electronically from the PREA
Compliance Manager. The photographs indicated notices were posted in various locations
throughout the facility including the housing unit and administrative areas. The Pre-Audit
Questionnaire, policies and supporting documentation were received on June 17, 2014. The Pre-
Audit Questionnaire, policies and some documents were uploaded to a UBS flash drive. The review
revealed the documents were provided for each standard in a manner that was easy to navigate. I
provided the PREA Compliance Manager a listing of noted concerns and additional documents
needed and she took steps to ensure that available documentation was provided during the on-site
visit. Specific corrective actions taken to address some of the deficiencies are summarized in this
report under the related standard.
PREA AUDIT: AUDITOR’S FINAL REPORT 2
The on-site audit was conducted July 16, 2014. After meeting with one of the Facility
Administrator, residents lead me on a complete tour of the facility. During the tour, youth were
observed to be under constant supervision of staff while involved in school and other activities. The
housing dorms were clean and orderly. Observation of housing units revealed bathroom shower and
toilet stalls have curtains for residents’ privacy.
During the on-site visit, 10 staff including direct care staff from all three shifts were interviewed.
Overall, the interviews revealed staff are knowledgeable of PREA standards and were able to
articulate their responsibilities. Five of the facility’s 10 residents were also interviewed. Residents
were well informed of their right to be free from sexual abuse and harassment and how to report
sexual abuse and harassment. Policies and secondary documentation were presented in a well-
organized fashion in a binder which contained a section for each standard.
A corrective action plan was developed, with input from the FDJJ PREA Coordinator, and provided
to the facility’s Compliance Manager on July 21, 2014, to specify the minimum remedial steps to be
taken to comply with PREA standards. The FDJJ PREA Coordinator provided documentation of
corrective action that was taken by FDJJ to comply with the standards as indicated in the auditor’s
comment section under the related standard. Remaining non-compliance issues were addressed
within the 180-day corrective action period as indicated in the auditor’s comment section
throughout this report.
Number of standards exceeded: 0
Number of standards met: 39
Number of standards not met: 0
Number of standards Not Applicable: 2
PREA AUDIT: AUDITOR’S FINAL REPORT 3
Standard 115.311-Zero Tolerance of Sexual Abuse and Sexual Harassment; PREA
Coordinator
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA Facility Operating Procedure (FOP) 10-25 mandates a zero-tolerance of sexual
abuse and sexual harassment and outlines how the facility carries out its approach to
preventing, detecting and responding to sexual abuse and sexual harassment. The policy
includes definitions of prohibited behaviors and sanctions for those found to have participated
in prohibited behaviors. The policy also provides strategies and responses for reducing and
preventing sexual abuse and harassment.
HGA is a residential juvenile treatment facility operated by G4S Youth Services. G4S
employs an agency-wide PREA Coordinator who is in an upper-level management position
within the agency. The PREA Coordinator interview revealed she has sufficient time and
authority to develop, implement and oversee the agency’s efforts to comply with PREA
standards in all G4S operated facilities. The Facility Administrator serves as the PREA
Compliance Manager and indicated during an interview that she has sufficient time to oversee
the facility’s PREA compliance efforts and to perform his other duties.
Standard 115.312- Contracting 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)
X Does Not Apply
Auditor Comments:
G4S does not contract with other entities for the confinement of residents.
Standard 115.313- Supervision and Monitoring
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
PREA AUDIT: AUDITOR’S FINAL REPORT 4
Auditor Comments:
HGA PREA FOP 10-25 requires the facility to develop, implement and document an
approved staffing plan. Although the staffing plan was not provided during my initial review,
it was provided during the on-site visit. The staffing plan mandates a 1:6 staff to resident ratio
during waking hours or a 1:12 staff to resident ratio during sleeping hours. The staffing plan
is based upon the agency’s contractual agreement with FDJJ and an operating capacity of 18
residents. The policy requires the facility to document deviations from the staffing plan on
the Shift Report or in the logbook however there have been no deviations from the plan.
Documentation of the annual review of the staffing plan dated June 4, 2014 was reviewed
and found to be in compliance with all elements contained in (d)-1 of this standard.
HGA utilizes video monitoring combined with direct staff supervision to protect residents
from sexual abuse and sexual harassment. Documentation of log entries were provided as
evidence that unannounced rounds are conducted by intermediate and upper level staff on all
shifts throughout the facility.
Standard 115.315- Limits to Cross-Gender Viewing and Searches
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 prohibits cross-gender strip searches, or pat down searches of youth,
except in exigent circumstances. 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. The policy 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 a
body cavity. All body cavity searches must be conducted by trained medical personnel in an
emergency room setting. Program staff are not authorized to conduct body cavity searches of
residents. During the past 12 months, there were no cross-gender strip or body cavity
searches and no cross-gender pat-down searches.
HGA PREA FOP 10-25 states the facility must ensure residents are allowed to shower,
perform bodily functions and change clothing without staff of the opposite sex viewing their
bodies.
HGA PREA FOP 10-25 requires opposite sex staff, volunteers and contractors entering
housing units to announce themselves. Resident interviews verified this is done on a consistent
bases.
HGA Policy 8-14 prohibits the search of transgender or intersex residents for the sole purpose
of determining the resident’s genital status. Staff interviews verified compliance.
PREA AUDIT: AUDITOR’S FINAL REPORT 5
Standard 115.316- Residents with Disabilities and Residents Who are Limited English
Proficient
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires the Compliance Manager to ensure that residents with
disabilities or who are limited English proficient are provided meaningful access to all
aspects of the facility’s efforts to prevent, protect and respond to sexual abuse and
harassment. This policy also states the facility prohibits the use of resident interpreter,
resident readers or any kind of resident assistants except when a delay in obtaining
interpreters services could jeopardies a resident’s safety. Resident and staff interviews
verified the facility does not use resident assistants and there were no instances of resident
interpreter or readers being used in the past 12 months however there is no documentation of
how services would be provided, if needed. During the corrective action period, Policy 9-2
Classification and Orientation, was revised to include how PREA education for residents
with disabilities will be provided in a format they can understand.
HGA PREA FOP 10-25 requires staff to provide PREA education in a format assessable to
all residents including those who may be limited English proficient, deaf, visually impaired
or otherwise with a disability, as well as to residents who have limited reading skills.
Samples of education material was provided.
Standard 115.317- Hiring and Promotion Decisions
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 and G4S Policy 3-16 requires criminal background screening for
new hires however the policies do not specifically require consulting with the child abuse
registry before hiring or enlisting services of any contractor who has contact with residents.
The FDJJ PREA Coordinator provided documentation that Florida State law does not allow
FDJJ to contact the abuse registry for the purpose of screening applicants.
Documentation of criminal background checks and that questions regarding past conduct
were asked and responded to during the interview process was reviewed and found to be in
compliance with the standard. G4S Policy 3-16 requires criminal background checks to be
conducted every five years. Applicants are required to sign acknowledging material
omission regarding misconduct, or false information is grounds for termination.
PREA AUDIT: AUDITOR’S FINAL REPORT 6
Standard 115.318- Upgrades to Facilities and Technology
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA’s housing and common areas are monitored 24 hours a day with 18 cameras. The
recent annual staffing plan assessment indicated several cameras needed to be repaired
however staff coverage allows for direct supervision in those areas.
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)
X Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires staff to report allegations of sexual abuse to local law
enforcement, the Florida Central Abuse Hotline and FDJJ’s Central Communication Center
(CCC). HGA does not have a Memorandum of Understanding (MOU) or documented
attempts to obtain a MOU with local law enforcement. During the corrective action period,
the Facility Administrator sent a letter to the Hillsborough County Sheriff’s Department
along with the DJJ PREA Compliance Form advising investigating agencies to follow the
DJJ Inspector General Directive 3-05 (uniform evidence protocol that maximizes the
potential for obtaining usable physical evidence for criminal prosecution) when investigating
sexual abuse allegations at the facility.
An unsigned agreement between G4S and the Crisis Center of Tampa Bay for victims’
advocacy services and forensic examinations for five of its facilities in Pasco County was
provided for my review. The agreement did not address the requirement for SANE or SAFE
medical examiners to conduct forensic examinations nor was there any other documentation
of attempts to obtain this agreement. HGA PREA FOP does not address forensic exams are
offered without costs to the victim. During the corrective action period a signed MOU with
the Crisis Center of Tampa Bay for victim’s advocacy services was provided and Policy 7-30
was revised to state that forensic exams are offered at no cost to the victim. Documentation
was also viewed verifying that forensic exams will be conducted by a SANE certified
medical examiner.
PREA AUDIT: AUDITOR’S FINAL REPORT 7
Standard 115.322- Policies to Ensure Referrals of Allegations for Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP requires the immediate referral of all sexual abuse allegations to local law
enforcement, the Florida Abuse Hotline and CCC. In the past 12 months, HGA had one
allegation of sexual abuse which was promptly reported as required by policy. The facility did
not receive any allegations that occurred at another facility. Interviews with the Facility
Administrator and other staff verified their knowledge of the policy’s requirements.
FDJJ’s website includes a PREA section which includes investigative responsibilities for
conducting investigations of allegations of sexual abuse in facilities.
Standard 115.331- Employees Training
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
G4S Policy Chapter 5, the training curriculum, staff training records and staff interviews
indicates staff receive PREA training during initial training and annually during refresher
training. The training curriculum provided was consistent with the elements of the standard
except for numbers 6 and 11 and it was not specifically tailored to the unique needs of staff
working with a female resident population in a juvenile confinement/treatment setting. During the
corrective action period, documentation was provided of staff training which included the
common reactions of sexual abuse and harassment of juvenile victims and relevant laws
regarding the applicable age of consent.
All employees and contractors are trained as new hires regardless of their previous
experience. Employees training records were reviewed and staff interviews verified staff
comprehension of their responsibilities relating to PREA standards.
Standard 115.332- Volunteer and Contractor Training
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
PREA AUDIT: AUDITOR’S FINAL REPORT 8
Does Not Meet Standard (requires corrective action)
Auditor Comments:
G4S Policy 3-48 states that prospective volunteers and interns are directed by Human
Resources to JFJ Ministries to coordinate the application process and orientation training.
A review of volunteer records revealed completed criminal background screenings and
training records indicating topics covered during orientation. Training documents are signed
by the volunteer/intern and the trainer. An interview with a volunteer revealed he is
knowledgeable concerning his responsibilities relative to PREA and the agency’s zero
tolerance policy regarding sexual abuse and harassment.
Contractors who have contact with residents are required to have the same training as
employees.
Standard 115.333- Resident Education
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires that during intake residents are provided with information
on the facility’s zero tolerance policy regarding sexual misconduct and how to report sexual
abuse and sexual harassment. The 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.
Documentation of resident’s signatures were reviewed and confirmed during resident
interviews. All residents interviewed stated they received this information the same day
they arrived at the facility and periodically thereafter.
There was no documentation of education in formats accessible to all residents including
those who are limited English proficient, deaf, visually impaired or otherwise disabled, as
well as to residents who have limited reading skills. During the corrective action period,
Policy 9-2 Classification and Orientation, was revised to include how PREA education for
residents with disabilities will be provided in a format they can understand.
Resident interviews revealed they have limited to no knowledge of the victims’ advocacy
service; however, during the corrective action period documentation of residents’ education
was provided. Residents were provided information about the services offered by Crisis
Center of Tampa and how to access the services.
Standard 115.334- Specialized Training: Investigation
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
PREA AUDIT: AUDITOR’S FINAL REPORT 9
standard for the relevant review period)
x Does Not Apply
Auditor comments:
Local law enforcement and the Florida Department of Children and Families conduct
criminal investigations into allegations of sexual abuse. HGA does not conduct any
investigations.
Standard 115.335- Specialized Training: Medical and Mental Health Care
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Certificates of Completion documented that the nurse successfully completed the National
Institute of Corrections on-line course titled, PREA: Medical Health Care for Sexual Assault
Victims in a Confinement Setting. The facility’s PREA FOP 10-25 references G4S Policy
Chapter 5 and FDJJ Policy 1919 which requires specialized training for medical and mental
health staff.
Staff interviews verified that medical staff does not conduct forensic examinations.
Standard 115.341- Obtaining information from Residents
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP requires staff to complete the FDJJ’s Vulnerability to Victimization and
Sexually Aggressive Behavior (VSAB) form. Documentation and resident interviews
revealed that risk screenings are being conducted. Completed VSAB forms are maintained in
residents’ treatment files. The screening for vulnerability to sexual victimization and sexual
aggressive behavior instrument 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)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
PREA AUDIT: AUDITOR’S FINAL REPORT 10
Auditor Comments:
HGA 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. The
instrument is scored prior to housing placement. Residents who score vulnerable to
victimization or sexually aggressive are included in the alert system, and referred for further
assessments. Residents who are identified or disclose prior sexual victims are referred to the
medical and mental health professionals within 14 days. An interview with the PREA
Compliance Manager confirmed that information from the VSAB is shared on a “need to
know” basis.
HGA Policy 8-14 precludes lesbian, gay, bi-sexual, transgender and intersex residents from
being placed in a particular housing area and states that LGBTI identification or status is not
an indicator of likelihood of being sexually abusive. Transgender or intersex resident’s own
view with respect to his/her safety will be given serious consideration. Staff interviews also
verified compliance with this standard.
Standard 115. 351- Resident Reporting
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA 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 residents are to be provided with the Abuse hotline number
which is provided at intake, included in the resident handbook and posted throughout the
facility.
HGA 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, calling the Florida Abuse Hotline, the Florida Council against Sexual
Violence Rape Crisis Hotline, or the Crisis Center of Tampa Bay Florida Referral Line. The
abuse hotline number is included in the resident handbook. Interviews with staff verified that
they would accept and document reports made verbally, in writing, anonymously, and from
third parties.
The facility does not provide at least one way for residents to report abuse or harassment to a
public or private entity or office that is not part of the agency and that is able to receive and
immediately forward resident reports of abuse and harassment to agency officials allowing
the resident to remain anonymous upon request. Residents must ask to use the phone which
will not allow them to remain anonymous and may not provide them with unimpeded access.
PREA AUDIT: AUDITOR’S FINAL REPORT 11
During the corrective action period, FOP 8-3 was revised to require staff to allow residents to
use a telephone to call the hotline upon request, without having to obtain staff permission and
that mandates staff not to question residents about the reason for the call, staff are to dial the
hotline number and hand the phone to the youth and remain at a distance that allows the
youth to privately report; and documentation was provided of staff training and resident
education on the implementation of these procedures and documentation of staff and resident
training on the implementation of the procedures was provided.
Standard 115. 352- Exhaustion of Administrative Remedies
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA Policy 8-4 states there is 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.
Standard 115. 353- Resident Access to Outside 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)
X Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 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.
An unsigned agreement with Crisis Center of Tampa Bay was provided however there is no
documentation of attempts to obtain the services required in this standard. During the
corrective action period, a signed MOU with Crisis Center of Tampa Bay was provided along
with documentation that residents were provided information about the services and how to
access the services.
Attorneys and other legal representatives are provided with reasonable and private access
upon request. Residents may call their parents/legal guardians and receive visits from them
on the weekends.
PREA AUDIT: AUDITOR’S FINAL REPORT 12
Standard 115. 354- Third Party Reporting
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ’s website provides the public with information regarding third-party reporting of
sexual abuse or sexual harassment on behalf of a resident. Resident interviews revealed their
awareness of reporting sexual abuse or sexual harassment to others outside of the facility
including their parents/legal guardians.
Standard 115. 361- Staff and Agency Reporting Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
All HGA staff are mandated reporters and are required by PREA FOP 10-25 to immediately
report any knowledge, suspicion or information they receive regarding sexual abuse and
harassment, retaliation against residents or staff who report any incidents or any staff neglect
or violation of responsibilities that may have contributed to an incident or retaliation. Random
staff interviews also helped to verify the facility’s compliance with this standard.
An interview with the nurse confirmed her responsibility to inform residents 18 years old of
her duty to report and limitations of confidentiality.
Standard 115. 362- Agency Protection Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP10-25 requires staff to take immediate action to protect a resident when he is
identified as being subject to substantial risk of imminent sexual abuse. There were no
residents identified as being at risk for sexual abuse in the past 12 months, as revealed in
interviews with the Facility Administrator and random staff.
PREA AUDIT: AUDITOR’S FINAL REPORT 13
Standard 115. 363- Reporting to other Confinement Facilities
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ Policy requires the Facility Administrator to notify the head of another facility within 72
hours upon receiving an allegation that a resident was sexually abused while confined at
another facility however this requirement is not addressed in HGA PREA FOP 10-25 or in the
Abuse Neglect Policy 8-3. During the corrective action period, the PREA FOP was revised to
be in compliance with this standard.
During the past 12 months, there were no allegations received that a resident was abused
while confined to another facility nor were there allegations of sexual abuse received by HGA
from other facilities.
Standard 115. 364- Staff First Responder Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires staff to take specific steps to respond to a report of sexual
abuse including; separating the alleged victim from the abuser; preserving any crime scene
within a period of time that still allows for the collection of physical evidence; request the
alleged victim not take any action that could destroy physical evidence; and ensure that the
alleged abuser does not take any action to destroy physical evidence, if the abuse took place
within a time period that still allows for the collection of physical evidence.
There were three allegations of sexual abuse during the past 12 months. A review of the
incident reports and follow-up documentation indicated the policy was followed in
compliance with this standard. Random staff interviews revealed considerable knowledge of
actions to be taken upon learning that a resident was sexually abused.
Standard 115. 365- Coordinated Response
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
PREA AUDIT: AUDITOR’S FINAL REPORT 14
Auditor Comments:
HGA PREA FOP 10-25 describes specific actions to be taken by staff in response to an
incident of sexual abuse however a written plan to coordinate actions among staff first
responders, medical, and facility leadership was not available. During the corrective action
period, the facility’s coordinated staff response plan was provided.
Interviews with the Facility Administrator and other staff revealed that they are
knowledgeable of their duties in response to an allegation of sexual abuse.
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)
X Non-Applicable Standard
Auditor Comments:
G4S is not a collective bargaining agency therefore this standard is not applicable.
Standard 115. 367- Agency Protection against Retaliation
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires the protection of residents and staff who have reported
sexual abuse or harassment or who have cooperated in a sexual abuse or sexual harassment
investigation. The monitoring will take place for a period of 90 days or longer, as needed.
The Facility Administrator is responsible for monitoring retaliation. There were no incidents
of retaliation in the past 12 months.
Standard 115. 368- Post-Allegation Protective Custody
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
PREA AUDIT: AUDITOR’S FINAL REPORT 15
Auditor Comments:
HGA would only restrict a resident to her single room as a last measure to keep a resident
who alleged sexual abuse safe and then only until an alternative means for keeping the
resident safe can be arranged.
Standard 115. 371- Criminal and Administrative Agency Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP10-25 states that FDJJ does not conduct criminal investigations of residents’
allegations of sexual abuse. Local law enforcement and the Florida Department of Children
and Families handle criminal investigations. FDJJ’s Office of Inspector General (OIG)
reviews allegations to identify any misconduct by staff related to FDJJ regulatory guidance.
There were three investigations of alleged resident sexual abuse at HGA during past 12
months. Each allegation was reported and investigated however none were founded.
Standard 115. 372- Evidentiary Standards for Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA does not conduct administrative investigations. All allegations of abuse are reported to
CCC.
Standard 115. 373- Reporting to Residents
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
PREA AUDIT: AUDITOR’S FINAL REPORT 16
Auditor Comments:
HGA PREA FOP 10-25 states that at the conclusion of any law enforcement investigation
where a sexual abuse incident has been reported, the victim or victim’s parents or legal
guardians should be notified that the investigation is concluded, either by the investigating
law enforcement agency or through a victim service agency officer or representative. At the
conclusion of the OIG administrative investigation, the victim’s parents or legal guardians
will be notified by receipt of a final administrative investigative report”.
During the corrective action period, the PREA FOP was revised to require that notifications
to victims be documented.
Standard 115. 376- Disciplinary for Staff
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 mandates staff disciplinary sanctions up to and including termination
for violating agency’s sexual abuse or sexual harassment policies. The policy also mandates
the violation be reported to local law enforcement. No employees have been terminated in the
past 12 months for violation of the facility’s sexual abuse or harassment policies.
Standard 115. 377- Corrective Action for Contractors and volunteers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires that 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. Documentation of the specific language that they be
reported to relevant licensing bodies or that they be prohibited from contact with youth was
not included. During the corrective action period, Policy 10-22 Volunteers was revised to
comply with this standard.
There were no reports of any allegations of sexual abuse or harassment by contractors or
volunteers in the past 12 months, therefore no reports to law enforcement or licensing bodies
and no remedial measures were taken.
PREA AUDIT: AUDITOR’S FINAL REPORT 17
Standard 115. 378- Disciplinary sanctions for Residents
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
As a treatment facility, HGA Policy 8-1 and the resident handbook outlines how the facility’s
behavior motivation program is designed to foster compliance with program rules and teach
youth alternative pro-social methods dealing with problems utilizing rewards and a
progressive discipline.
Standard 115. 381- Medical and Mental screening; History of Sexual Abuse
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP requires residents who disclose a history of sexual abuse or who disclose
previously perpetrating sexual abuse to be referred for medical and mental health screening
services within 24 hours of the screening. Staff interviews verified compliance with this
standard and documentation demonstrating the immediate notification of the medical and
mental health staff was provided.
Standard 115. 382- Access to Emergency Medical and Mental Health Services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25 requires timely and unimpeded access to emergency medical
treatment, crisis intervention services and victim advocacy services. The resident victim
would be transported to a local hospital for a forensic examination at no cost to the victim.
Medical staff are required to document the response and timeliness of emergency medical
treatment and follow-up. Documentation of emergency and follow-up treatment was
provided for the one incident of sexual abuse that occurred during the past 12 months.
PREA AUDIT: AUDITOR’S FINAL REPORT 18
Standard 115. 383- Ongoing Medical and Mental Health Care for Sexual Abuse Victims and
Abusers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP requires that a medical and mental health evaluation and treatment, as
determined by medical/mental health staff, be offered to resident victims of sexual abuse.
Standard 115. 386- Sexual Abuse Incident Reviews
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
HGA PREA FOP 10-25, mandates that the facility shall create a Review Team with specific
staff consistent with those outlined in section (c) of the standard. 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. 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.
Standard 115. 387- Data Collection
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ has developed a standardized instrument with definitions to collect accurate, uniform
data for every allegation of sexual assault. The instrument includes the data necessary to
answer all questions from the most recent version of the Survey of Sexual violence
conducted by the Department of Justice. HGA PREA FOP requires CCC to collect all data
relating to PREA. A review of the annual report revealed it was completed according to this
standard.
PREA AUDIT: AUDITOR’S FINAL REPORT 19
Standard 115. 388- Data Review for Corrective Action
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ’s annual report for fiscal year 2013-2014 indicates 32 PREA related allegations
reported by detention centers and residential facilities throughout the agency. The FDJJ
PREA Coordinator reviews data to improve the effectiveness of its prevention, protection and
response policies, practices and training. The annual report is made available to the public on
FDJJ’s website.
Standard 115. 389- Data Storage, Publication, and Destruction
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor comments:
HGA PREA FOP 10-25 directs that the facility shall ensure records are maintained and the
Facility Administrator ensures requests for additional information from the FDJJ PREA
Coordinator are responded to in a timely manner. The G4S Agency Head Designee interview
verified that G4S maintains an incident report tracking system and G4S facilities provide
data to FDJJ though CCC and FDJJ publishes the annual report on its website. 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 is maintained
for at least 10 years after the date of the initial collection.
AUDITOR CERTIFICATION:
The auditor certifies that the contents of the report are accurate to the best of her knowledge
and no conflict of interest exists with respect to her ability to conduct an audit of the agency
under review.
Auditor’s Signature Date: December 23, 2014
PREA AUDIT: AUDITOR’S FINAL REPORT 20

report_type: PREA

program_name_raw: hillsborough girls academy


state: FL

summary: PREA

raw_content:
PREA AUDIT: AUDITOR’S SUMMARY REPORT
JUVENILE FACILITIES
Name of Facility: Hillsborough Regional Juvenile Detention Center
Physical Address: 3948 W. Martin Luther King Jr. Blvd, Tampa, FL 33614
Date report submitted: December 31, 2014
Auditor information Dan McGehee
Address PO Box 595 White Rock, SC 29177
Email: mc72fsud@aol.com
Telephonenumber: 803-331-0264
Date of facility visit August 13-14, 2014
Facility Information
Facility Mailing Address:
(if different from above)
Telephone Number: 813-871-7650
The Facility is: Military County Federal
Private for profit Municipal State
Private not for profit
Facility Type: Detention Correction Other:
Name of PREA Compliance Manager: Fernando Crespo Title: Superintendent
Email Address: Fernando.crespo@djj.state.fl.us Telephone Number: 813-871-7650
Agency Information
Name of Agency: Florida Department of Juvenile Justice
Governing Authority or
Parent Agency: Florida
Department of Juvenile
Justice
Physical Address: 2737 Centerview Drive, Tallahassee, FL 32399
Mailing Address: (if
different from above)
Telephone Number: 850-717-2533
Agency Chief Executive Officer
Name: Christy Daly Title: Interim Secretary
Telephone
Email Address: Christy.Daly@djj.state.fl.us
Number: 850-413-7313
Agency Wide PREA Coordinator
Name: Gene McMahon Title: PREA coordinator
Telephone
Email Address: gene.mcmahon@djj.state.fl.us
Number: 850-171-2533
AUDIT FINDINGS
Program Description:
Hillsborough Regional Juvenile Detention Center (HRJDC) located in Tampa, Florida, is a 92 bed,
hardware secure facility that serves male and female juveniles detained by various circuit court(s).
HRJDC is operated by the Florida Department of Juvenile Justice (FDJJ) and serves Hillsborough County
area youth who are detained pending adjudication, disposition or placement in a commitment facility.
The average length of stay for residents is approximately 21 days.
The facility employs 75 full-time staff. The management team consists of a superintendent, one assistant
superintendent, three shift commanders, and four supervisors. Medical staff are contracted through Maxim
Healthcare Services and mental health services are provided by Camelot Community Care. The Florida
Department of Education provides funding to the Hillsborough County School Board to provide residents
with academic educational services. Facility staff provides direct supervision of youth in a safe, secure and
humane environment.
Hillsborough West Regional Juvenile Detention Center provides comprehensive mental health and
substance abuse services to all detained youth, as well as education and healthcare. Various mental health
services and groups are offered to youth throughout their confinement. The center has a full-time licensed
clinical social worker (LCSW) serving as the designated mental health authority (DMHA) responsible for
the overall coordination, implementation and supervision of all mental health and substance abuse services
provided at the center. Mental health and substance abuse services are provided seven days per week by a
LCSW and a non-licensed Master’s level clinician. They also have two other licensed mental health
counselors (LMHC) who fill in. The DMHA also provides face-to-face clinical supervision with
directions, instructions, and recommendations to the one non-licensed clinician. There are no substance
abuse-specific positions at the center. They currently employ one part-time licensed psychiatrist.
FACILITY DESCRIPTION:
The facility appears to have been constructed in the 1980s of concrete and concrete block construction. It is
located adjacent to a residential program for juveniles, both of which are next to the athletic stadiums for
baseball (George Steinbrenner) and football (Raymond James Stadium). The facility is high custody with
controlled entrance and egress for both staff and contractors. A metal detector and wand are used at the
pedestrian entrance. There is a small control center to control entrances and monitor the 56 cameras.
Cameras may also be accessed and viewed in the Superintendent and Assistant Superintendent’s offices.
Staff have identified additional blind spots in the facility and in areas where youth could be present and
have labeled them “red check areas”—off limits for youth. The auditor suggested that perhaps mirrors
could be installed to assist in improving sight lines.
There are three living units for males and one for females. Some youth are single room assigned and some
males are assigned to two and three-bed rooms. Youth are screened for placement based on results from
VSAB—Victimization and Sexually Aggressive Behavior screening tool. Rooms are equipped with toilets,
but no sinks. Sinks are located adjacent to communal showers. Youth are locked in rooms at night with
documented ten-minute checks.
The facility also contains a medical area, cafeteria, dayrooms, and classrooms. All are accessible by central
hallway. Living units have their own outside recreation spaces. There is a laundry area where staff wash
clothing and linens for the youth.
Summary of Audit Findings:
The posting of the audit notice was not completed by staff as required. Therefore, the auditor allowed a
new audit notice to be posted during the audit asking for correspondence by Sept 3, 2014 from anyone who
wanted to submit comments regarding PREA.
The PREA audit of the HWJDC was conducted on August 13 and 14, 2014, by Dan McGehee, certified
PREA auditor. An entrance briefing was held in the conference room with the Superintendent, Assistant
Superintendent and the PREA assistant. Mr. McGehee reviewed the audit time table and process and
thanked the staff for working with him on becoming PREA compliant.
A tour of the facility was then completed. The auditor examined the showers and inquired about the
shower process for both boys and girls. There were no shower curtains or screens for privacy for girls, and
boys showered as many as 3 at one time in communal showers. Staff stood in the doorway to supervise
residents, and they are always the same gender as the ones being supervised.
Following the tour, the auditor worked in the conference room on reviewing documentation to determine
standards compliance. In the afternoon, the auditor conducted interviews with seven staff.
On the second day, the auditor interviewed six residents, at least one from each living unit. Interviews with
residents revealed answers that were inconsistent for the PREA questions. The intake process recently
began showing a PREA video as a part of the process in addition to giving written PREA information.
Over time, this should help provide a better understanding of PREA and its requirements. All of the
residents knew their rights and how to report abuse. Staff interviews also revealed an understanding of
PREA. They also understood first responder duties, maintaining a crime scene, and how to report abuse.
All staff, both contract and state, have completed PREA training. The balance of the second morning was
spent completing the documentation review.
In early afternoon, the auditor conducted an exit briefing with the Superintendent, Assistant Superintendent,
and PREA assistant. He reviewed those standards in non-compliance and reviewed again the process for
completing the PREA process.
Standards Findings:
Number of standards exceeded: 0
Number of standards met: 40
Number of standards not met: 0
Number of standards Not Applicable: 1
Standard 115.311: Zero 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)
Auditor Comments:
HRJDC PREA Facility Operating Procedure (FOP) mandates zero-tolerance of sexual abuse and sexual
harassment and outlines how the facility carries out its approach to preventing, detecting and responding to
sexual abuse and sexual harassment. The policy includes definitions of prohibited behaviors and sanctions for
those found to have participated in prohibited behaviors. The policy also provides strategies and responses for
reducing and preventing sexual abuse and harassment.
HRJDC is a juvenile detention facility governed and operated by the FDJJ which employs an agency-wide
PREA Coordinator who is in an upper-level management position within the agency. The PREA
Coordinator interview revealed he has sufficient time and authority to develop, implement and oversee the
agency’s efforts to comply with PREA standards in all operated and contracted facilities. The facility’s
Superintendent serves as the PREA Compliance Manager who also utilizes the services of a designated
juvenile correctional officer.
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)
Auditor Comments:
FDJJ has approximately 50 contracts with providers for the confinement of juveniles in residential facilities
throughout the State. A signed contract review revealed provider’s agreement to comply with all requirements
and standards of the Prison Rape Elimination Act 28 CFR Part 115 as outlined in FDJJ Policy 1919. All
contracts were renewed in the past 12 months to include the requirement to comply with PREA standards.
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)
AUDITOR’S COMMENTS
Although HRJDC PREA FOP required the facility to develop, implement and document an approved staffing
plan. There is no mandate in policy for a 1:8 staff to resident ratio during waking hours or a 1:16 staff to
resident ratio during sleeping hours. The staffing plan is based upon the facility’s capacity of 92 residents.
HRJDC PREA FOP requires the facility to document deviations from the staffing plan on the Shift Report.
However, there have been no deviations from the plan.
Documentation of the annual review of the staffing plan dated July 10, 2014 was reviewed and found in
compliance with all elements contained in (d)-1 of this standard.
HRJDC utilizes video monitoring combined with direct staff supervision to protect residents from sexual abuse
and sexual harassment. Intermediate and upper level staff conduct unannounced rounds and these are
documented in the log book as well as on the shift reports.
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)
Auditor Comments:
HRJDC PREA FOP prohibits cross-gender strip searches, or pat down searches of youth, except in exigent
circumstances. However HRJDC Admission policy FOP does not prohibit cross-gender pat searches. The
corrective action plan should require the revision of the FOP to be consistent with this standard and the
PREA FOP.
The prohibition of cross-gender visual body cavity searches is not addressed in PREA FOP; however, the policy
revision should be required in the corrective action plan.
HRJDC PREA FOP states the facility must be configured to allow residents to shower; perform bodily functions
and change clothing without staff of the opposite sex viewing their bodies. Staff and resident interviews confirm
there is no cross-gender viewing; however, the open shower stalls with no partitions or shower curtains allow
residents to be viewed naked by same sex staff and other residents while taking showers. Some male residents
stated they keep their boxers on while showering to avoid exposure. The corrective action plan should require
that partitions and/or shower curtains be installed to eliminate the possibility of voyeurism by staff and/or
residents.
FDJJ Policy 1919 PREA requires opposite sex staff, volunteers and contractors entering housing units to announce
their presence. Resident interviews verified this is done consistently.
HRJDC PREA FOP prohibits the search of a transgender or intersex resident solely for the purpose of
determining the resident’s genital status and staff interviews verified compliance.
As of December 19, 2014, the corrective action taken is satisfactory to meet the standard.
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 standard for
the relevant review period)
□
Does NOT meet Standard (requires corrective action)
Auditor Comments:
HRJDC PREA FOP requires accommodations be made to ensure residents with disabilities or who are limited
English proficient are provided meaningful access to all aspects of the facility’s efforts to prevent, protect and
respond to sexual abuse and harassment. This policy also states the facility prohibits the use of resident
interpreter, resident readers or any kind of resident assistants except when a delay in obtaining interpreters
services could jeopardize a resident’s safety. Resident and staff interviews verified the facility does not use
resident assistants and there were no instances of resident interpreter or readers being used in the past 12
months.
HRJDC PREA FOP describes how interpreters or other services needed to assist residents with disabilities or
residents who may be limited English proficient will be provided by an active contract with Optimal Phone
Interpreters.
HRJDC PREA FOP requires staff to provide PREA education in a format assessable to all residents including
those who may be limited English proficient, deaf, visually impaired or otherwise with a disability, as well as
to residents who have limited reading skills.
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)
Auditor Comments:
Initial review of HRJDC PREA FOP revealed the policy did not specifically require consulting with the child
abuse registry before hiring or enlisting services of any contractor who has contact with residents. The PREA
Coordinator provided documentation that Florida State law does not allow FDJJ to contact the abuse registry
for the purpose of screening applicants.
A review of staff files revealed documented criminal background checks and that questions regarding past
conduct were asked and responded to during the interview process. Additionally, contract providers, who have
contact with residents, had documented criminal background checks. HRJDC PREA FOP requires criminal
background checks to be conducted every five years.
Applicants are required to sign acknowledging material omission regarding misconduct, or false information
is grounds for termination. Additionally, the HR director supplied a written statement which she signed that
all employees have successfully passed the background check. Also provided was the same for contract
nurses, mental health, and teachers.
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)
Auditor Comments:
HRJDC has not acquired any new facilities or updated surveillance technology since August 20, 2012. The video
monitoring system was assessed during the annual review of the staffing plan to determine if upgrades were
needed to enhance the facility’s ability to protect youth from sexual abuse. Staff has identified other blind spots
which exist and have implemented a “red check” sign policy where juveniles are not allowed in these spots. The
auditor suggested that staff consider installing mirrors in these areas to improve sight lines.
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)
Auditor Comments:
HRJDC PREA FOP requires staff to report allegations of sexual abuse to local law enforcement (the
Tampa Police Department) for criminal investigations and to the Florida Central Abuse Hotline and
FDJJ’s Central Communication Center (CCC). HRJDC has attempted to negotiate an MOU with
the Tampa Police Department.
HRJDC is in the process of obtaining an MOU with the Tampa Rape Crisis Center for victims’
advocacy services. The auditor also requested that either an MOU or a statement of services
provided be negotiated with St. Joseph’s Hospital.
As of December 18, 2014, the corrective action taken is satisfactory to meet the standard.
Standard 115.322: Policies to ensure referrals of allegations for 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)
Auditor Comments:
HRJDC PREA FOP requires the immediate referral of all sexual abuse allegations to local law enforcement, the
Florida Abuse Hotline and CCC. In the past 12 months, HRJDC has had no allegations of sexual abuse and has
not received any allegations that occurred at another facility. Interviews with staff verified their knowledge of
the policy’s requirements.
FDJJ’s website includes a PREA section which includes investigative responsibilities for conducting
investigations of allegations of sexual abuse.
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)
Auditor Comments:
HRJDC PREA FOP, the training curriculum, staff training records and staff interviews indicated staff receive
PREA training during initial training and annually during refresher training. The training uses “Skill Pro” and
requires competency based testing at its conclusion. Specific topics as outlined in the policy and the curriculum
are consistent with this standard’s requirements and are tailored to the facility’s resident population. All
employees are trained as new hires regardless of their previous experience. Employees’ training records were
reviewed and staff interviews verified staff comprehension of their responsibilities relating to PREA standards.
Additionally, a chart was reviewed indicating that all staff had received PREA training including a recently
transferred employee from another state institution.
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)
Auditor Comments:
HRJDC PREA FOP requires volunteers and contracted providers who have contact with residents to be trained
on their responsibilities on sexual misconduct prevention, detection, reporting and responding to sexual abuse,
assault or sexual harassment. Documentation provided by the volunteer coordinator for the facility revealed
both the training packet and the documentation of training for volunteers approved for the facility. Further,
contractors in medical, mental health and education signed that they had all received required training which
was further verified in staff interviews.
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)
Auditor Comments:
HRJDC PREA FOP requires residents to receive comprehensive education regarding the facility’s zero
tolerance policy and how to report sexual abuse and sexual harassment. Intake staff explains the PREA handout
to residents and residents sign verifying they received the information. Documentation of residents’ signatures
were reviewed and confirmed during resident interviews. All residents interviewed stated they received this
information within their first week. Beginning July 27, 2014 the facility began showing a PREA video as part
of the intake process to present PREA information to residents in addition to written hand-outs.
Resident interviews revealed a spectrum of answers to PREA questions. However, all residents interviewed
knew their PREA rights and how to report abuse. The auditor suggested to staff that they consider how they are
presenting the information to residents and also consider its repetition for better understanding.
Interviews with the PREA assistant revealed that she had posted the information for community agencies
although there was no negotiated MOU. In interviews, residents indicated knowledge of these agencies and
services as well as how to access them.
As of December 18, 2014, the corrective action taken is satisfactory to meet the standard.
Standard 115.334: Specialized training: 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)
Auditor comments:
The Tampa Police Department and the Florida Department of Children and Families conduct criminal
investigations into allegations of sexual abuse. HRJDC does not conduct any investigations.
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)
Auditor Comments:
HRJDC PREA FOP requires PREA training for all employees and specialized training for medical and mental
health staff. The facility did not present documentation of specialized training for medical and mental health staff
as staff interviews verified it had not been conducted. The corrective action plan requires documentation of
the nurses’ participation in specialized PREA training for medical and mental health staff. The nurses do
not conduct forensic examinations.
As of December 18, 2014, the corrective action taken is satisfactory to meet the standard.
Standard 115.341: Screening for risk of victimization and abusiveness
□
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)
Auditor Comments:
HRJDC PREA FOP requires staff to complete the FDJJ’s Vulnerability to Victimization and Sexually
Aggressive Behavior (VSAB) form if youth arrive from the Juvenile Assessment Center without a completed
form. Documentation and resident interviews revealed that risk screenings were being conducted; however,
Intake staff and resident interviews indicated residents were not asked whether they identify with being gay, bi-
sexual, transgender or intersex.
Completed VSAB forms are maintained in residents’ medical files.
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)
Auditor Comments:
HRJDC PREA FOP requires victimization screening information to be used to determine a resident’s room
assignment and the room’s proximity to direct care staff to ensure resident’s safety. The facility also utilizes the
Classification Alerts to ensure that staff working directly with residents are advised if the resident is identified as
being at risk for victimization or posing a risk.
HRJDC PREA FOP precludes lesbian, gay, bi-sexual, transgender and intersex residents from being placed in
a particular module and states that LGBTI identification or status is not an indicator of likelihood of being
sexually abusive. Transgender or intersex resident’s own view with respect to his/her safety will be given
serious consideration. Staff interviews also verified compliance with this standard. Transgender and intersex
residents are given the opportunity to shower separately from other youth.
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)
Auditor Comments:
HRJDC PREA FOP provides multiple ways for residents to privately report sexual abuse, sexual harassment,
retaliation and staff neglect including telling a staff member and calling Florida Abuse Hotline. The FOP further
states the facility is exempt from this standard because it does not have administrative procedures in place for
residents to report allegations of sexual abuse and sexual harassment through the grievance procedure while
FDJJ Policy 1919 PREA allows for the use of the grievance process to report allegations of sexual abuse and
sexual harassment.
The corrective action plan should include both the revising of the FOP and the installation of locked
grievances boxes in each living unit for residents’ use.
PREA FOP requires youth to have one way of reporting sexual abuse and sexual harassment to a public or
private entity or office that is not a part of the agency. Residents may call the Florida Abuse Hotline. Signs are
posted throughout the facility with the hotline number. Staff dial the number and then insure that the youth has
privacy in conducting the call.
As of December 18, 2014, the corrective action taken is satisfactory to meet the standard.
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)
Auditor Comments:
HRJDC PREA FOP states the facility is exempt from this standard because it does not have administrative
procedures in place for residents to report allegations of sexual abuse and sexual harassment through the
grievance procedure while FDJJ Policy 1919 PREA allows for the use of the grievance process to report
allegations of sexual abuse and sexual harassment.
The corrective action plan should include both the revising of the FOP and the installation of locked
grievances boxes in each living unit for residents’ use.
As of December 18, 2014, the corrective action taken is satisfactory to meet the standard.
Standard 115.353: Resident access to outside confidential support 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)
Auditor Comments:
HRJDC PREA FOP ensures residents are provided access to outside confidential support services. The facility
is in the process of obtaining a signed MOU with the Tampa Rape Crisis Center which was verified by email
correspondence. The MOU needs to be completed.
Signs containing the outside services hotline number and basic information about the service were posted
throughout the facility. The corrective action plan should include documentation of resident education
regarding services offered by the victims’ advocacy organization and the inclusion of information during
intake orientation.
Attorneys and other legal representatives are provided with reasonable and private access upon request.
Residents may call their parents/legal guardians and receive visits from them twice a week.
As of December 18, 2014, the corrective action taken is satisfactory to meet the standard.
Standard 115.354: Third-party 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)
Auditor Comments:
FDJJ’s website provides the public with information regarding third-party reporting of sexual abuse or sexual
harassment on behalf of a resident. Resident interviews revealed their awareness of reporting sexual abuse or
sexual harassment to others outside of the facility including their parents/legal guardians.
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)
Auditor Comments
All HRJDC staff are mandated reporters and are required by PREA FOP and FDJJ Policy 1919 to immediately
report any knowledge, suspicion or information they receive regarding sexual abuse and harassment, retaliation
against residents or staff who report any incidents or any staff neglect or violation of responsibilities that may have
contributed to an incident or retaliation. Random staff interviews also helped to verify the facility’s compliance
with this standard.
Standard 115.362: Agency protection 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)
Auditor Comments:
HRJDC PREA FOP requires staff to take immediate action to protect a resident when he/she is identified as
being subject to substantial risk of imminent sexual abuse. There was one transgender identified in the screening
process currently at the facility, and treated in accordance with policy.
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)
Auditor Comments:
HRJDC PREA FOP requires the Superintendent to notify the head of another facility within 72 hours upon
receiving an allegation that a resident was sexually abused while confined at another facility. During the past 12
months, there were no allegations received that a resident was abused while confined to another facility nor were
there allegations of sexual abuse received by HRJDC from other facilities.
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)
Auditor Comments:
HRJDC PREA FOP requires staff to take specific steps to respond to a report of sexual abuse including: separating the
alleged victim from the abuser; preserving any crime scene within a period of time that still allows for the collection of
physical evidence; request the alleged victim not take any action that could destroy physical evidence; and ensure that the
alleged abuser does not take any action to destroy physical evidence, if the abuse took place within a time period that still
allows for the collection of physical evidence. There was one allegation of sexual abuse during the past 12 months. Random
staff interviews revealed considerable knowledge of actions to be taken upon learning that a resident was sexually abused.
Standard 115.365: Coordinated response
□
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)
Auditor Comments:
HRJDC PREA FOP requires the development of a written plan to coordinate actions taken in response to an incident of
sexual assault among staff first responders, medical, and facility leadership. A review of the plan revealed that it covered the
requirements of the standard.
Interviews with staff revealed that they are knowledgeable of their duties in response to an allegation of sexual abuse.
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
Auditor Comments:
FDJJ is not a collective bargaining agency therefore this standard is not applicable.
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)
Auditor Comments:
FDJJ Policy 1919 PREA requires the protection of residents and staff who have reported sexual abuse or harassment or who
have cooperated in a sexual abuse or sexual harassment investigation. The monitoring will take place for a period of 90 days or
longer, as needed. The Superintendent is responsible for monitoring retaliation. There were no incidents of retaliation in the
past 12 months.
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)
Auditor Comments:
HRJDC would only restrict a resident to his/her single room as a last measure to keep safe a resident who alleged
sexual abuse and then only until an alternative means for keeping the resident safe can be arranged.
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)
Auditor Comments:
HRJDC PREA FOP states that FDJJ does not conduct criminal investigations of residents’ allegations of sexual abuse. Local
law enforcement (Tampa Police Department) and the Florida Department of Children and Families handle criminal
investigations. FDJJ’s Office of Inspector General (OIG) reviews allegations to identify any misconduct by staff related to
FDJJ regulatory guidance.
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)
Auditor Comments:
HRJDC PREA FOP states the facility shall impose no standard higher than a preponderance of the evidence in determining
whether allegations of misconduct by staff are substantiated.
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)
Auditor Comments:
There were no criminal or administrative investigations during the past 12 months. Therefore, no notices have been sent to
residents. HRJDC PREA FOP requires the Superintendent to notify residents who alleged sexual abuse when the facility
learns that the alleged abuser has been indicted on charges or convicted on a charge related to sexual abuse within the facility.
The OIG will notify residents whether the allegation has been determined to be substantiated, unsubstantiated or unfounded.
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 standard for the relevant
review period)
□
Does NOT meet Standard (requires corrective action)
Auditor Comments:
HRJDC PREA FOP mandates staff disciplinary sanctions up to and including termination for violating agency’s sexual abuse
or sexual harassment policies. The policy also mandates the violation be reported to local law enforcement. No employees
have been terminated or disciplined in the past 12 months for violation of the facility’s sexual abuse or 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)
Auditor Comments:
HRJDC PREA FOP requires volunteers and contractors in violation of the facility’s policies and procedures regarding
sexual abuse and harassment of residents to be reported to local law enforcement and to relevant licensing bodies unless
the activity was clearly not criminal. There have been no allegations of volunteers or contractors sexual abuse or sexual
harassment reported in the past 12 months.
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)
Auditor Comments:
HRJDC PREA FOP states that residents may receive disciplinary sanctions following an administrative finding or a
criminal investigation that resident engaged in youth-on-youth sexual abuse and sanctions shall be commensurate with
the nature and circumstances of the sexual abuse, the resident’s disciplinary history, and the sanctions imposed for
comparable offenses by other residents with similar histories. There were no administrative or criminal findings of guilt
for resident-on-resident sexual abuse in the past 12 months.
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)
Auditor Comments:
HRJDC PREA FOP requires residents who disclose a history of sexual abuse or who disclose previously perpetrating
sexual abuse to be referred for medical and mental health screening services within 24 hours of the screening. Staff
interviews 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)
Auditor Comments:
HRJDC PREA FOP requires timely and unimpeded access to emergency medical treatment, crisis intervention
services and victim advocacy services. The resident victim would be transported to a local hospital for a
forensic examination at no cost to the victim. Medical staff are required to document the response and
timeliness of emergency medical treatment and follow-up. There have been no victims of sexual abuse in the
past 12 months.
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)
Auditor Comments:
HRJDC PREA FOP requires that a medical and mental health evaluation and treatment, as determined by
medical/mental health staff, be offered to resident victims of sexual abuse. There have been no sexual assault
victims in the past 12 months; however, if services are needed, procedures are in place as verified during staff
interviews.
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)
Auditor Comments:
HRJDC PREA FOP requires the Superintendent to schedule a sexual assault incident review team meeting
within 30 days of the conclusion of each investigation. The policy mandates review team participation to
include regional office staff, Assistant Superintendent, facility supervisor, medical and mental health
staff, and OIG staff, if OIG investigated the incident, The FDJJ PREA Coordinator will prepare a report of
the review team’s findings and submit the report to the Assistant Secretary for Detention Services,
regional office staff and the facility’s Superintendent. There were no criminal or administrative
investigations of sexual abuse in the past 12 months.
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)
Auditor Comments:
DJJ has developed a standardized instrument with definitions to collect accurate uniform data for every allegation of sexual
assault. The instrument includes the data necessary to answer all questions from the most recent version of the Survey of
Sexual violence conducted by the Department of Justice. HRJDC PREA FOP requires CCC to collect all data relating to PREA.
A review of the annual report revealed it was completed according to this standard.
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)
Auditor Comments:
FDJJ’s annual report for fiscal year 2013-2014 indicates 32 PREA related allegations reported by detention centers and
residential facilities throughout the agency; however, there were no PREA related incidents indicated for HRJDC. The
FDJJ PREA Coordinator reviews data to improve the effectiveness of its prevention, protection and response policies,
practices and training. The annual report is made available to the public on FDJJ’s 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)
Auditor comments:
HRJDC PREA FOP requires that sexual abuse and sexual harassment data to be collected and securely retained for 10
years in accordance with the State of Florida’s records retention schedule. The annual report is made available to the
public on FDJJ’s website.
Any questions about PREA standards, required documentation or process please refer to the PREA Resource Center
website under Juvenile Standards.
AUDITOR CERTIFICATION:
The auditor certifies that the contents of the report are accurate to the best of his/her knowledge and
no conflict of interest exists with respect to his or her ability to conduct an audit of the agency under
review.
December 31, 2014
Auditor Signature Date

source: DJJ

program_name_raw: hillsborough juvenile detention center west