facility_name: Broward Youth Treatment Center

summary: PREA

raw_content:
PREA AUDIT: AUDITOR’S SUMMARY
REPORT JUVENILE FACILITIES
Name of Facility: Broward Girls Academy
Physical Address: 8301 South Palm Drive, Pembroke Pines, FL 33025
Date report submitted: October 23, 2015
Auditor information: Shirley L. Turner
Address: 3199 Kings Bay Circle, Decatur, GA 30034
Email: shirleyturner3199@comcast.net
Telephone number: 678-895-2829
Date of facility visit: October 5, 2015
Facility Information
Facility Mailing Address: 8301 South Palm Drive, Pembroke Pines, FL 33025
Telephone Number: (954) 322-6500
The Facility is: Military County Federal
X Private for profit Municipal State
Private not for profit
Facility Type: Detention Correction X Other: Residential
Name of PREA Compliance Manager: Pamela Rollins Title: Program Director
Email Address: pamela.rollins@youthservices.com Telephone Number:
(954) 322-6500
Agency Information
Name of Agency: Youth Services International
Governing Authority or Parent Agency: NA
Physical Address: 6000 Cattleridge Dr., Suite 200, Sarasota, FL 34232
Mailing Address: Same as Above
Telephone Number: (941) 953-9199
Agency Chief Executive Officer
Name: Jim Slattery Title: CEO/President
Telephone (941) 953-9199
Email Address: jim.slattery@youthservices.com
Number:
Agency Wide PREA Coordinator
Name: Jesse Williams Title: PREA Coordinator
Email Address: jesse.williams@youthservices.com Telephone (941) 953-9199
Number:
1
AUDIT FINDINGS
NARRATIVE:
The Broward Girls Academy is a 30-bed residential program for low and moderate risk girls, age 14-
19 years, who are committed to the Florida Department of Juvenile Justice (DJJ). The facility is
operated by Youth Services International, Incorporated (YSI). The girls admitted to the program are
assessed and classified as moderate risk with serious to severe mental disturbance. Program services
include mental health groups and individual and family counseling. Residents participate in Cannabis
Youth Treatment, Cognitive Behavioral Therapy, Dialectical Behavioral Therapy, and Trauma
Recovery and Empowerment for Adolescent Girls and Youth Women (G-TREM).
Cannabis Youth Treatment includes residents participating in two individual sessions using
Motivational Enhancement Therapy to address marijuana usage. Residents participate in 12 group
sessions addressing coping skills, meeting needs without marijuana and additional coping skills
topics. All residents with a substance abuse diagnosis participate in this group two times per week.
Cognitive Behavioral Therapy-Rational Living Therapy (RLT) groups are based on cognitive-
behavioral therapy and residents learn rational self-counseling. RLT groups are held twice a week
and address unhealthy thinking patterns, such as all or nothing thinking, overgeneralization and
mental filter. Dialectical Behavioral Therapy (DBT) groups address mood regulation through four
content areas: Mindfulness, Distress Tolerance, Emotional Regulation and Interpersonal
Effectiveness. G-TREM groups are held once a week and enhance key trauma recovery and coping
skills, decrease risk of re-victimization and strengthen girls’ overall functioning.
On-site medical services are provided by a full-time Registered Nurse in the position of Nurse
Manager and a contract physician who visits the facility weekly. Mental health staff includes the
Clinical Director, three Therapists, and a contract psychologist and contract psychiatrist who both
visit the facility once a week. Located within the mental health unit are two Case Managers and four
interns. Education/vocational services are provided on-site by Broward County Schools. Youth
Counselors provide direct care and supervision to residents during their movement throughout the
facility’s programs and services. Shift Supervisors provide effective oversight to the general
operations of each shift. Social services, recreation services and other activities are also provided.
DESCRIPTION OF FACILITY CHARACTERISTICS:
The program is housed in one main building which is separated to contain another juvenile residential
treatment program. The entrance lobby contains a reception area and space and seating for visitors.
A conference room is located in this area, beyond the lobby and is shared by the two programs. The
Broward Girls Academy is contained in one section of the building, consisting of a long hallway that
includes classrooms; control room; offices; storage; medical clinic; housing rooms; bathrooms; and a
dayroom. The dayroom space is also used for eating meals and snacks that are delivered from the
adjacent program.
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There are a total of eight rooms, four beds are in seven rooms and one room has two beds; all rooms
are attractively maintained. The bathrooms provide the residents with a reasonable amount of privacy
for changing clothes, using the toilet and taking showers. Isolation is not used at this facility. The
facility does have a room that is designated as the quiet room. It is accessorized to reflect the state of
a tranquil environment and is located in a section that includes administrative and treatment staff
members’ offices. The residents maintain an outside flower garden, under the supervision of staff.
The outside grounds also contain a fenced area for recreation and other activities.
The length of stay ranges from three to nine months. The number of staff currently employed at the
facility that may have contact with residents is 32. In the past 12 months there have been three
contracts for services with contractors who may have contact with residents. The number of
residents admitted to the facility in the past 12 months is 673.
SUMMARY OF AUDIT FINDINGS:
The process began with a conference call which included the facility and other YSI staff, DJJ
statewide PREA Coordinator, and the PREA Auditor to discuss the audit process. The notifications
of the on-site audit were later posted in various parts of the facility at least six weeks prior to the site
visit. Photographs were taken of the various sites where the notices had been posted and the
photographs were electronically sent to this Auditor, noting their locations. The Pre-Audit
Questionnaire and the supporting documentation were uploaded to a flash drive which was mailed to
the Auditor. After reviewing the information on the flash drive, a follow-up call was made to the
Program Director to discuss the data and for clarification of information. Additional information
was provided or clarified as requested.
The on-site audit was conducted on October 5, 2015. An entrance meeting was held with the
Program Director and a comprehensive tour was provided. Interviews were conducted with staff that
covered all three shifts. Six random staff and six residents were interviewed. Eleven specialized
interviews were conducted and included one volunteer intern. Observations of program activities
revealed that staff members were directly supervising and involved with the residents.
File folders were set up in a very neat and organized manner and supplementary information was
provided. A close-out meeting was held at the conclusion of the on-site audit and a summary of the
audit findings was provided to the Program Director, Assistant Program Director and the YSI PREA
Coordinator who participated by telephone.
Number of Standards Exceeded: 0
Number of Standards Met: 39
Number of Standards Not Met: 0
Number of Standards Not Applicable: 2
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Standard 115.311 Zero Tolerance of Sexual Abuse and Sexual Harassment.
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
The facility has an internal zero-tolerance policy, 1.28-Prison Rape Elimination Act (PREA),
which provides guidelines for achieving the requirements of the PREA standards. Policy 1.28
provides the strategies for zero-tolerance toward all forms of sexual abuse and sexual
harassment. The Policy contains definitions of the prohibited behaviors and sanctions for those
who participate in such behaviors. The Florida Department of Juvenile Justice Policy 1919
(FDJJ 1919) is also used and adhered to for support of the PREA standards. FDJJ 1919 Policy
and Procedures serve as the overarching guide to the facility for ensuring PREA compliance.
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)
X Standard Not Applicable
Auditor Comments:
The facility does not contract with other facilities for the confinement of its residents.
Standard 115.313 Supervision and Monitoring
Exceeds Standard (substantially exceeds requirement of standard)
XMeets 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:
Policy 1.28 provides for the implementation of a staffing plan with adequate staffing levels to
protect residents against sexual abuse and refers to the current staffing assignments of a
minimum of 1:6 during the resident waking hours and 1:8 during the resident sleeping hours.
A hold-over system and schedules are in place to maintain the required staff ratios. The
Policy provides details regarding scheduling requirements and a staffing plan exists. The
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annual assessment of the staffing plan and other related areas have been conducted to
determine whether adjustments are needed. A review of the staffing has been documented
through the completion of the Staffing Plan Assessment form. A staffing plan assessment was
conducted by the Florida DJJ statewide PREA Coordinator and one was conducted by the
Program Director.
Unannounced rounds of the facility for the maintenance of a safe environment are conducted
and documented by appropriate staff as identified by Policy 1.28. The Policy and facility’s
practice prohibit staff from alerting other staff while the unannounced rounds are being
conducted. Staff interviews and a review of documentation confirmed the practice of
unannounced rounds being conducted.
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:
Policy 1.28 prohibits cross-gender pat-down searches, cross-gender strip searches and cross-
gender visual body cavity searches of residents, except in exigent circumstances or when
performed by medical practitioners. The Policy further provides that in the event of any
occurrence, documentation of the situation is required. Staff interviews supported that the
facility practice is that no type of cross-gender searches are conducted.
Policy 1.28 has been implemented providing for residents to shower, perform bodily
functions, and change clothes without being observed by staff of the opposite gender. In
ensuring that all staff and residents are aware of the bathroom procedures, the general rules
were posted at the entrance. Interviews with staff and residents confirmed the practices.
Policy 1.28 states that staff shall not search a transgender or intersex resident to determine the
resident’s genital status. The Policy also directs staff to ask a transgender or intersex resident
which gender of employee they would prefer to conduct the search. The training curriculum
regarding LGBTI youth was reviewed.
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)
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Auditor Comments:
According to Policy 1.28, support of various services is provided for residents with
disabilities and residents who are limited English proficient so that they may benefit from
and participate in PREA education. Resident education materials are accessible in languages
other than English. Policy 1.28 ensures that the facility will not rely on resident interpreters
or resident readers. The policy contains information regarding the resources to be used and
how they will be accessed. A review of the documentation provided and staff interviews
confirmed that residents would not be used as interpreters or readers to assist other residents.
Documentation was reviewed showing that the Program Director conducted a review of the
American Disabilities Act with staff.
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:
Policy 1.28 and FDJJ 1919 provide for background checks on all employees and contractors
through a process that is aligned with the standard and used statewide. A review of
documentation and interviews with staff confirmed that prior to the hiring of an employee or
contractor, background checks are conducted. Both Policies require that criminal background
checks be conducted every five years on employees and on contractors who may have
contact with residents. The facility considers prior incidents of sexual harassment in
determining whether to hire or promote anyone or to enlist the services of any contractor.
An Annual Affidavit of Compliance with Level 2 Screening Standards was signed by the
Program Director affirming that all employees and volunteers have been screened as
required.
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:
A secondary monitoring system is used in addition to direct staff supervision. The camera
system updates include additional cameras that were installed in the lobby and in the
conference room.
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Standard 115.321 Evidence Protocol and Forensic Medical Examinations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 states that staff will cooperate in investigations conducted by the FDJJ Office of
the Inspector General (OIG). The OIG is responsible for administrative investigations and
investigations are conducted by the Florida Department of Children and Families (DCF) and
the Pembroke Pines Police Department (PPPD).
Correspondence from the PPPD indicates that while they will not be signing the submitted
MOU from the facility, they will serve as the lead investigative agency for sexual assault
investigations that occur due to the facility being located within their jurisdiction. The
correspondence states that the PPPD supports the internal facility protocols that are
implemented as a requirement of PREA that are cited in the MOU. It is further documented
that reported allegations of sexual assault will be fully investigated under protocols
established through PPPD General Orders and other regulations; procedures required for
successful criminal prosecution via the Broward State Attorney’s Office; and applicable case
law best practices.
Policy 1.28 provides for forensic medical examinations to be completed at no financial cost
to the victim. There have been no forensic examinations conducted during this audit period.
The facility does not have a signed Memorandum of Understanding (MOU) with an
advocacy agency at this time; however, The Nancy J. Cotterman Center (NJCC) is reviewing
a draft MOU. The NJCC is Broward County’s children’s advocacy center and certified rape
crisis center and there is documentation of collaboration between NJCC and the facility. The
personnel of NJCC indicates that the advocacy services will be provided due to the facility
being located in Broward County and that forensic exams are provided with no cost to the
community.
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:
Facility Policy 1.28 provides that the appropriate investigative entity will be contacted
regarding the reporting of allegations. Policy FDJJ 1919 requires that staff report all
allegations of sexual abuse and sexual harassment. There has been no allegation from a
resident during this audit period.
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The facility posts related information regarding reporting allegations in areas which are
accessible to the public and parents/guardians receive a copy of the Student Handbook. The
DJJ website also contains information regarding the referral of allegations for investigations
of sexual abuse.
Standard 115.331 Employee Training
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 and FDJJ 1919 provides for the PREA training of all staff. The facility staff
received the DJJ training and the facility has conducted refresher training in the key areas
referenced in the standards. Topics within PREA are reviewed in the monthly meetings for
all staff members. Documentation of staff participating in training is maintained and staff
interviews confirmed that PREA training is provided.
Standard 115. 332 Volunteer and Contractor Training
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 contains information regarding the training of volunteers and contractors who
have contact with residents. Receipt of the training is documented on the Prison Rape
Elimination Act Acknowledgement information sheet, which is signed by the participant.
An interview with an intern supported the occurrence of the PREA training.
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)
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Auditor Comments:
Policy 1.28 and interviews with residents confirmed that they receive information about the
facility’s zero-tolerance policy and how to report incidents or suspicions of sexual abuse or
sexual harassment. A staff interview and supporting documents also showed that the PREA
education occurs with the residents. Training sessions with residents are documented. Policy
1.28 identifies training resources that are used for resident education and training materials
were reviewed. The facility will provide support services in accessible formats for residents
who are limited English proficient, deaf, visually impaired, or otherwise disabled.
Standard 115.334 Specialized Training: Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
FDJJ 1919 states that staff in the OIG will be trained on the related policies and procedures
regarding the handling of sexual misconduct incidents and reports. Training is provided to
investigative staff regarding conducting investigations in the DJJ settings.
Standard 115.335 Specialized Training: Medical and Mental Health Care
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 addresses PREA training for medical and mental health staff. A review of
documentation and staff interviews confirmed the specialized training for medical and
mental health staff. Forensic medical examinations are not conducted at the facility.
Standard 115.341 Screening for Risk of Victimization and Abusiveness
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
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Auditor Comments:
Policy 1.28 and practice document that each resident is screened for vulnerability to
victimization and sexually aggressive behavior. A review of documentation and staff and
resident interviews confirmed that screening for risk of sexual abuse victimization or sexual
abusiveness toward other residents is being conducted on each admission to the facility. The
initial screening is done during the intake process and Policy 1.28 and staff and resident
interviews provide for residents to receive reassessments within the first 30 days and
periodically throughout the resident’s stay at the facility.
Standard 115.342 Use of Screening Information
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 and FDJJ 1919 prohibits placing gay, bisexual, transgender, or intersex residents
into particular housing, bed or other assignments solely on such identification or status.
According to Policy 1.28 housing and program assignments require determinations on each
transgender or intersex resident on a case by case basis. The Policies also prohibits
considering gay, bisexual, transgender, or intersex identification or status as an indicator of
likelihood of being sexually abusive.
The facility staff report that isolation is not used. Policy 1.28 provides that residents may be
separated or isolated from others only as a last resort when less restrictive measures are
inadequate and until other arrangements can be made to keep the resident safe. If separation
or isolation should occur, the Policy provides that residents are afforded their rights as
required.
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:
Policy 1.28 and staff and resident interviews confirmed that there are internal ways a resident
may report allegations of sexual abuse; sexual harassment; retaliation for reporting; and staff
neglect or other violations that may lead to abuse. A resident may report allegations of abuse
or sexual harassment by completing a grievance form; completing a Speak Out Form
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requesting to talk to a specific staff member; talking to any staff member; and third parties
may report allegations to staff. PREA related information is posted within the facility,
accessible to the residents, staff and visitors. Residents are provided access to a telephone to
report allegations of sexual abuse and sexual harassment to the abuse reporting hotline or law
enforcement, depending on the age of the resident.
Interviews revealed that staff members are aware of their responsibility to report sexual abuse
and sexual harassment. They are also aware that they are to accept reports of sexual abuse
and sexual harassment made verbally, in writing, anonymously, and from third parties in
accordance with Policies 1.28 and FDJJ 1919. Staff members are directed to promptly
document any verbal reports.
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:
Residents may put a completed grievance form in the locked grievance box. Residents are
not required to use an informal grievance process regarding allegations of sexual abuse and
sexual harassment. The facility considers resident complaints regarding sexual abuse to be
an allegation and when such a complaint is received, Policy 1.28 provides that the
procedures for reporting allegations be initiated.
Standard 115.353 Resident Access to Outside Confidential Support Services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 requires the facility to provide the residents with access to outside victim
advocacy services by the Nancy J. Cotterman Center (NJCC). The MOU drafted by the
facility is currently in the review process of the NJCC. There is documented collaboration
with the NJCC, a certified rape crisis center for Broward County. Information about the NJCC
is provided to the residents. Residents may receive visitors while in the facility and they are
allowed to make weekly telephone calls. Attorneys or other legal representation may visit the
facility and these visits are conducted in a confidential manner.
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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:
Policy 1.28 provides guidelines regarding third-party reporting. Information about reporting
incidents of sexual abuse is posted in the facility, accessible to the public. Staff and resident
interviews supported that the facility has a method for third party reporting. The YSI website
contains a link to the DJJ website which provides information on how to report resident
sexual abuse or sexual harassment. Parents and/or guardians are also provided a copy of the
Student Handbook.
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:
Policy 1.28, FDJJ 1919 and Florida Statute address this standard and provide that all staff
members are mandated reporters. They are to immediately report any knowledge, suspicion
or information they receive regarding sexual abuse and sexual 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. Policy prohibits staff from sharing
information regarding sexual abuse other than as needed to make treatment, investigation,
and other security and management decisions. Staff interviews confirmed their knowledge of
this information.
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)
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Auditor Comments:
Policy 1.28 states that when a staff member learns that a resident is subject to substantial risk
of imminent sexual abuse, immediate action is taken to protect the resident. Protection
measures may include one-to-one staff supervision; reassignment of a room; or change in
classroom assignment. There have been no incidents in the last 12 months where the agency
or the facility took any action in regards to a resident being in substantial risk of imminent
sexual abuse while in this facility.
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:
Policy 1.28 provides that upon receiving an allegation that a resident was sexually abused
while confined in another facility, the Program Director will notify the Central
Communications Center of the allegation within two hours. The Policy also provides that the
Program Director will notify the facility of which the allegation was made, no later than 24
hours.
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:
Policy 1.28 provides a detailed account of first responder duties and responses. There has not
been an allegation by a resident regarding sexual abuse within the last 12 months. Initial
PREA training and refresher training have been provided to all staff.
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)
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Auditor Comments:
There is a written Facility Coordinated Response Plan for Reports of Sexual Abuse. A
review of training records and interviews with staff confirmed staff members’ knowledge of
their responsibilities. The Plan coordinates the actions to be taken among staff including first
responders, leadership, medical and mental health in response to an incident 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 Standard Not Applicable
Auditor Comments:
This standard is not applicable. The facility does not maintain any collective bargaining
agreements.
Standard 115.367 Agency Protection Against Retaliation
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 provides guidance to staff regarding protection against retaliation for residents
and staff who report allegations of sexual abuse or sexual harassment. According to the
Policy, the Program Director or the Assistant Program Director will have the responsibility of
monitoring for possible retaliation. If the conduct is identified the practice is that the
monitoring is ongoing during the length of stay for the resident and the duration of the staff
member’s employment. The have been no allegations of sexual assault or sexual harassment
during 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)
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Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 ensures that if there is any use of segregated housing, it will only be used as a
last resort and that the resident is afforded access to the program and services provided by
the facility. Staff interviews supported that the facility does not use isolation; however, a
resident will be separated and protected from potential abusers when needed and will receive
programming and services as required.
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:
Policy 1.28 and FDJJ 1919 address this standard. Administrative investigations are
conducted by OIG and DCF is called for all allegations of sexual assault. The Pembroke
Pines Police Department conducts criminal investigations. Both Policies direct facility staff
to cooperate with the OIG investigations. Substantiated allegations of conduct that appears to
be criminal are referred for prosecution.
Standard 115.372 Evidentiary Standards for Administrative 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:
FDJJ 1919 and Policy 1.28 support that a standard of the preponderance of the evidence is
used for determining if allegations are substantiated.
Standard 115.373 Reporting to Residents
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
15
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 and FDJJ 1919 provide for notifying residents following an investigation of
whether an allegation has been determined to be substantiated, unsubstantiated, or
unfounded. It is required that all notifications or attempted notifications are documented.
The Program Director is aware of the requirements of the standard and the Policies.
Standard 115.376 Disciplinary Sanctions for Staff
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 and FDJJ 1919 provide for disciplinary sanctions for staff to be up to and
including termination for violation of the sexual abuse and sexual harassment policies. The
Policies require that staff terminations or resignations by staff who would have been
terminated for violating the Policies, be reported to local law enforcement and that relevant
licensing bodies be contacted. No staff has been terminated or has resigned for violating
PREA related policies during this audit period.
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:
Policy 1.28 provides that a contractor or volunteer who engages in sexual abuse will have no
contact with residents and will be reported to law enforcement, unless the activity was clearly
not criminal, and to relevant licensing bodies. The Policy requires that remedial measures be
taken and prohibits future contact with residents in the case of any other violation of the PREA
related policies. During the past 12 months, no contractor or volunteer has been reported to
law enforcement or any investigative entity for allegations of sexual abuse.
Standard 115.378 Disciplinary Sanctions for Residents
Exceeds Standard (substantially exceeds requirement of standard)
16
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:
Policy 1.28 provides direction to staff regarding this standard. A resident who engages in
resident-on-resident sexual abuse will be placed in a DJJ Juvenile Detention Center and
receive a court hearing and a determination will be made regarding the subsequent placement.
Standard 115.381 Medical and Mental Health Screenings; History of Sexual Abuse
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 states that residents who disclose a history of sexual abuse or who disclose
previously perpetrating sexual abuse will be referred for a follow-up meeting with a medical
or mental health practitioner within 24 hours of the screening. Staff interviewed confirmed
awareness of the policy and the requirements of the standard. A meeting with mental health
staff is a part of the intake process for all residents.
Standard 115.382 Access to Emergency Medical and Mental Health Services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 provides for timely access to emergency medical treatment and crisis
intervention services for victims of sexual abuse. According to the Policy and staff
interviews, the nature and scope of the services are determined by medical and mental health
practitioners’ professional judgment. Policy 1.28 states that emergency medical and mental
health services will be provided the victim whether or not the abuser is named or whether the
victim cooperates with any investigation arising out of the incident. Interviews with medical
and mental health staff confirmed the Policy.
Standard 115.383 Ongoing Medical and Mental Health Care for Sexual Abuse Victims and
Abusers
Exceeds Standard (substantially exceeds requirement of standard)
17
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:
Policy 1.28 provides for ongoing medical and mental health care for sexual abuse victims. It
also provides for medical and mental health evaluations and appropriate treatment and
follow-up services as referred to in the standard. According to Policy 1.28 and staff
interviews, medical and mental health care are consistent with the community level of care.
Standard 115.386 Sexual Abuse Incident Reviews
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the standard
for the relevant review period)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 serves as the guide for staff in conducting incident reviews. The incident review
team has been identified and interviews revealed an understanding of the purpose of the
process. The PREA Sexual Abuse Incident Review form will be used to document the
meeting and the process.
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:
According to Policy 1.28, the facility reports data to DJJ on a monthly basis. Policy 1.28 and
FDJJ 1919 state that there is the collection of accurate, uniform data for every allegation of
sexual assault. The DJJ has developed a data collection instrument that includes the required
data.
Standard 115.388 Data Review for Corrective Action
Exceeds Standard (substantially exceeds requirement of standard)
18
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:
Policy 1.28 and FDJJ 1919 address this standard. The Policies require the review of data for
corrective action towards improving the effectiveness of the agencies’ prevention, protection
and response policies, practices, and training. The annual report prepared by DJJ is made
available to the public.
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:
Policies 1.28 and FDJJ 1919 address this standard. Data is collected and securely retained for
10 years. The aggregated PREA data is reviewed, all personal identifiers are removed, and
the information is posted on the DJJ website.
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.
October 23, 2015
Auditor Signature Date
19

report_type: PREA

program_name_raw: broward girls academy


state: FL

summary: PREA

raw_content:
PREA AUDIT REPORT  INTERIM  FINAL
JUVENILE FACILITIES
Auditor Information
Auditor name:
Address:
Email:
Telephone number:
Date of facility visit:
Facility Information
Facility name:
Facility physical address:
Facility mailing address: (if different from above)
Facility telephone number:
The facility is: Federal State County
Military Municipal Private for profit
Private not for profit
Facility type: Correctional Detention Other
Name of facility’s Chief Executive Officer:
Number of staff assigned to the facility in the last 12 months:
Designed facility capacity:
Current population of facility:
Facility security levels/inmate custody levels:
Age range of the population:
Name of PREA Compliance Manager: Title:
Email address: Telephone number:
Agency Information
Name of agency:
Governing authority or parent agency: (if applicable)
Physical address:
Mailing address: (if different from above)
Telephone number:
Agency Chief Executive Officer
Name: Title:
Email address: Telephone number:
Agency-Wide PREA Coordinator
Name: Title:
Email address: Telephone number:
PREA Audit Report 1
AUDIT FINDINGS
NARRATIVE
PREA Audit Report 2
DESCRIPTION OF FACILITY CHARACTERISTICS
PREA Audit Report 3
SUMMARY OF AUDIT FINDINGS
Number of standards exceeded:
Number of standards met:
Number of standards not met:
Number of standards not applicable:
PREA Audit Report 4
Standard 115.311 Zero tolerance of sexual abuse and sexual harassment; PREA Coordinator
 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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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)
 Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 5
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 6
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 7
Standard 115.318 Upgrades to facilities and technologies
 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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 8
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 9
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 10
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 11
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Standard 115.342 Use of screening information
 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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 12
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 13
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 14
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 15
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 16
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 17
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 18
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Standard 115.372 Evidentiary standard 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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 19
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 20
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 21
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 22
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 23
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report 24
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 discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
AUDITOR CERTIFICATION
I certify that:
 The contents of this report are accurate to the best of my knowledge.
 No conflict of interest exists with respect to my ability to conduct an audit of the agency under
review, and
 I have not included in the final report any personally identifiable information (PII) about any
inmate or staff member, except where the names of administrative personnel are specifically
requested in the report template.
_
Auditor Signature Date
PREA Audit Report 25

source: DJJ

program_name_raw: broward juvenile detention center