state: FL

facility_name: JoAnn Bridges Academy

summary: PREA

raw_content:
PREA AUDIT: AUDITOR’S SUMMARY
REPORT JUVENILE FACILITIES
Name of Facility: JoAnn Bridges Academy
Physical Address: 950 SW Greenville Hills Rd., Greenville, FL 32331
Date report submitted: February 24, 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: January 28, 2015
Facility Information
Facility Mailing Address: 950 SW Greenville, FL 32331
Telephone Number: (850) 948-4220
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: Tuwollar Mobley Title: Facility Administrator
Email Address: Tuwollar.Mobley@youthservices.com Telephone Number:
(850) 948-4220
Agency Information
Name of Agency: Youth Services International, Inc.
Governing Authority or Parent Agency: NA
Physical Address: 6000 Cattle Ridge Dr., Suite 200, Sarasota, FL 34232
Mailing Address: Same as Above
Telephone Number: (941) 953-9199
Agency Chief Executive Officer
Name: James Slattery Title: Chief Executive Officer
Telephone (941) 9533-9199
Email Address: Jim.Slattery@ysii.com
Number:
Agency Wide PREA Coordinator
Name: Jesse Williams Title: PREA Coordinator
Email Address: Jesse.Williams@youthservices.com Telephone (941) 704-8796
Number:
1
AUDIT FINDINGS
NARRATIVE:
The JoAnn Bridges Academy, located in Greenville, Florida, is a 27-bed moderate risk residential
facility that houses female juvenile offenders in the age range of 12-18. The facility is operated by
Youth Services International, Inc. (YSI) through a contract with the Florida Department of Juvenile
Justice (DJJ). The average length of stay is nine months. While in the facility residents participate in
programming that include education/vocation services; social services; mental health/substance abuse
services; and recreation. Fifty-two residents have been admitted to the facility during the past 12
months.
Fifty-nine staff members have been employed at the facility during the past year. On-site medical
services are provided by a full-time Registered Nurse and a contract physician who visits the facility
at least weekly. Additional medical services are provided by the Health Department. Mental health
staff includes the Clinical Director, three Therapists, two Case Managers, and a consulting
psychiatrist who visits the facility at least twice a month. Education/vocational services are provided
on-site by contract staff. Residents also participate in group activities that address problem solving;
substance abuse; victim awareness; parenting; and management of individual emotions.
A behavior management system exists that provides privileges based on positive behavior exhibited
by the resident. The system contains four levels with the responsibilities and privileges increasing
with each level earned; negative behavior may cause the resident to lose privileges or lose a level. In
addition to basic program activities and services, the facility offers gender specific educational groups
and classes. Subjects covered in these groups and classes contain various subject matter and some of
them are: nutrition; study skills; seeking safety; emotions management; sex respect; and team
building.
DESCRIPTION OF FACILITY CHARACTERISTICS:
The main building contains the lobby entrance; offices; housing; medical clinic; kitchen; dining
room; class rooms; two small conference/meeting rooms; large multi-purpose room area; and storage
areas. There is a building that houses mental health and case management staff and another building
where maintenance is located. A fourth building is used for storage. In the main building the housing
areas anchor each side of the building, A Wing and B Wing. The rooms in each housing area are
attractively accessorized and painted in various blending colors. Each wing has a bathroom that
affords residents a reasonable amount of privacy while they shower, change clothes and perform
bodily functions. The Honors Room is located on B Wing which is decorated to look and feel very
comfortable and special for one occupant who has earned the privilege to be housed in the room for
at least 30 days, unless the privilege is shortened due to the resident’s behavior. A laundry room is
also located in each housing area.
The multi-purpose area may be used for various activities, including recreation and visitation. It also
serves as dayrooms for A Wing and B Wing. Within the multi-purpose room are two small rooms
that have been built and called day houses. Both are furnished comfortably like small conference
rooms. The intimate settings provide space for more privacy for meetings and activities for residents;
one is designated for A Wing and the other for B Wing. The outside grounds contain ample space for
recreation and other activities. Youth Workers provide direct supervision of residents in daily
activities and during the residents’ movement to and from activities and services.
2
SUMMARY OF AUDIT FINDINGS:
The process began with a conference call which included the Facility Administrator, PREA Auditor
and other YSI and DJJ staff 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 received approximately four weeks prior
to the on-site audit. After reviewing the information on the flash drive, a follow-up call was made to
the Facility Administrator to discuss data and for clarification of information. Additional
information was provided or clarified as requested.
The on-site audit was conducted January 28, 2015. An entrance meeting was held with the Facility
Administrator. After the meeting, interviews were conducted with staff from the overnight shift. At
the conclusion of the interviews, a comprehensive tour of the facility was conducted jointly by the
Facility Administrator and two residents of the program. The YSI PREA Coordinator and the YSI
Regional Vice President for North Florida were present during the tour. Observations of program
activities revealed that staff members were directly supervising and interacting with the residents.
The interviews conducted included random staff, specialized staff and residents.
File folders were set up in a very neat and organized manner that contained supplementary
information for this Auditor’s review. 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 Facility Administrator, YSI PREA
Coordinator and YSI Regional Vice President for North Florida.
Number of Standards Exceeded: 0
Number of Standards Met: 39
Number of Standards Not Met: 0
Number of Standards Not Applicable: 2
3
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 utilizes Policy 1.28, Prison Rape Elimination Act (PREA) that provides
guidelines for implementing compliance with the requirements of the PREA standards. Policy
1.28 states a 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.
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 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)
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 per the
current contract. A hold-over system and schedules are in place to maintain the required staff
ratios. Efforts are underway for the new contract to reflect the staffing plan required by the
standard. The annual assessment of the staffing plan and other areas has 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.
4
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. In the event of any occurrence, documentation of the
situation is required. Interviews revealed that the facility practice is no cross-gender searches
and that none of these type searches have been conducted during this audit period.
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.
Interviews with staff and residents confirm these 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 they would
prefer to conduct the search.
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:
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.
5
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 Florida DJJ Policy 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.
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 includes real time monitoring and it has the ability to record for over 30 days before
recording over the current information. The system may be accessed from remote locations.
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 addresses this standard and 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 local law enforcement.
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 has a Memorandum of Understanding (MOU) with Refuge House, Inc. which
provides victim advocacy services that include training for staff and residents, counseling
services and access to the rape crisis hotline.
6
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 and FDJJ 1919 requires that staff report all allegations
of sexual abuse and sexual harassment. There has been one allegation from a resident during
this audit period. The allegation was reported as required and the OIG has not yet completed
a written report of findings. The DCF was also notified and they conducted an investigation
which concluded that there were No Indicators as a result of interviews and the information
obtained.
The facility posts related information regarding reporting allegations in areas which are
accessible to the public. The DJJ website 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. Documentation of staff participating in training is maintained and
staff interviews confirmed that training occurs.
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 and the training contains a
review of the DJJ and facility PREA Policies.
7
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:
Interviews with residents and staff confirm that residents receive information about the
facility’s zero-tolerance policy and how to report incidents or suspicions of sexual abuse or
sexual harassment. Training sessions with residents are documented. Through resources
identified in Policy 1.28, a review of other documentation and staff interviews, it has been
determined that 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 confirm the specialized training for medical and mental
health staff. The facility Nurse does not conduct forensic medical examinations.
Standard 115.341 Screening for Risk of Victimization and Abusiveness
Exceeds Standard (substantially exceeds requirement of standard)
8
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 review of documentation and staff and resident interviews confirm 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 interviews provide for residents to receive reassessments
within the first 30 days and periodically after that.
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:
The facility prohibits placing gay, bisexual, transgender, or intersex residents into
confinement based 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 Policy prohibits considering gay, bisexual, transgender, or intersex
identification or status as an indicator of likelihood of being sexually abusive.
The facility reports that during this audit period there have been no residents placed in
isolation because of being at risk for victimization. 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.
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:
According to Policy 1.28 and staff and resident interviews, 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 complete a grievance form;
9
complete a JBA Youth Speak Out Form where a resident requests to talk to a specific
staff member identified on the Form; talk to any staff member; and third parties may report
allegations to staff. The grievance and other written requests or notes may be placed in the
locked grievance box located on the housing wings.
PREA related information is posted in each wing and in the multi-purpose room. 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. The
DJJ and Refuse House hotline numbers are accessible from any office phone and there is a
designated phone located on B Wing. The designated phone connects to the hotline number
once the receiver is picked up.
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 or note in the locked grievance box located
on each wing. 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 for the procedures regarding reporting allegations to 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. The documented MOU provides for services that will be delivered by
Refuge House, Inc. The advocacy agency’s liaison for the facility, Sexual Assault Response
Trauma Team Coordinator, was interviewed while she was visiting the facility. She confirmed
the services to be provided as stated in the MOU and shared that the facility would have
10
access to a Sexual Assault Nurse Examiner. Information about Refuge House is posted and
accessible to the residents and residents are informed about the agency’s reporting rules
regarding privacy.
Visitation is held at the facility at least weekly where residents may see their parents and the
residents are allowed to make weekly telephone calls. Attorneys or other legal representation
may visit the facility and these visits may be conducted in a confidential manner.
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.
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:
According to Policy 1.28 and Florida Statute, all staff members are mandated reporters. Staff
members 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. The 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)
11
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 supervision by staff; reassignment of a room or a wing;
change in dayroom or classroom assignment; or transfer to another facility. Reportedly, 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.
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:
According to Policy 1.28, upon receiving an allegation that a resident was sexually abused
while confined in another facility, the Facility Administrator (FA) will notify the Central
Communications Center (CCC) of the allegation within two hours. The Policy also provides
that the FA 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 an account of first responder duties and responses. There has been one
allegation by a resident regarding sexual abuse within the last 12 months which was reported
as required. The allegations were investigated by DCF and the report determined that there
were No Indicators. The investigation is ongoing by the OIG. Initial staff training and
refresher training have been provided, including the duties of the first responder.
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)
Auditor Comments:
The facility has a written Coordinated Response plan. A review of training records and
interviews with staff confirmed the staff’s knowledge of their responsibilities. The plan
coordinates the actions to be taken among staff including first responders, leadership,
12
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. Staff has been
identified and given the responsibility of monitoring for possible retaliation. If the conduct is
identified the practice is that the monitoring is ongoing. The facility reports that no incidents
of retaliation have occurred 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)
Does Not Meet Standard (requires corrective action)
Auditor Comments:
Policy 1.28 ensures that if there is any use of segregated housing, it is 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 have isolation; however, a resident will
be separated and protected from potential abusers when needed and will receive
programming and services as required.
13
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 criminal investigations are conducted by DCF and local law
enforcement. 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 supports 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)
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.
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)
14
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:
According to Policy 1.28, the 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 require 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)
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)
15
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.
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 based on their professional judgment. Staff interviews and Policy 1.28 state that
emergency medical and mental health services will be provided at no financial cost to the
victim and whether or not the abuser is named.
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:
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)
16
Auditor Comments:
Policy 1.28 will serve 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.
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)
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.
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 and requires that 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.
17
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.
February 24, 2015
Auditor Signature Date
18

source: DJJ

report_type: PREA