Georgia Department of Juvenile Justice

Transcription

U.S. Department of Justice, Bureau of Justice Assistance
Prison Rape Elimination Act Demonstration Grant Project
Implementing the Prison Rape Elimination Act:
Facility Sexual Safety Assessments Report Themes and
Recommendations
April 2013
Submitted by The Moss Group, Inc.
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This project was funded by the Georgia Department of Juvenile Justice,
U.S. Department of Justice, Bureau of Justice Assistance
Prison Rape Elimination Act Demonstration Grant
The Moss Group project team would like to thank the Agency Leadership, the Agency PREA
Coordinator, and each of the facility leadership teams and staff involved in making the assessments
possible.
The Moss Group, Inc. is a criminal justice consulting firm dedicated to assisting federal, state, and local agencies in
addressing correctional management issues.
The Moss Group, Inc.
1312 Pennsylvania Avenue, SE
Washington, DC 20003
www.mossgroup.us
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Table of Contents
Introduction ............................................................................................................................................................ 4
Scope of Work & Methodology ........................................................................................................................ 5
Influencing Factors............................................................................................................................................... 7
Systemic Themes and Recommendations ................................................................................................... 9
1.
2.
3.
4.
5.
6.
7.
8.
Safety and Reporting .................................................................................................................... 9
Data Collection
.................................................................................................................. 11
Staffing
.................................................................................................................. 12
Programming
.................................................................................................................. 13
Gender Responsiveness for Female Youth ................................................................................... 14
Key Control
.................................................................................................................. 16
Physical Plant
.................................................................................................................. 17
Training
.................................................................................................................. 18
Facility-Specific Reports.................................................................................................................................. 21
Facility-Specific Report: Sandersville Regional Youth Detention Center............................................... 22
Facility-Specific Report: Macon Youth Development Campus (YDC) .................................................... 29
Facility-Specific Report: Atlanta Youth Development Campus (YDC) ................................................... 36
Facility-Specific Report: Metro Regional Youth Detention Center (RYDC) ............................................ 41
Facility-Specific Report: Eastman Youth Development Campus (YDC) ................................................. 48
Conclusion............................................................................................................................................................. 55
Appendices ........................................................................................................................................................... 56
DJJ PREA Accomplishments ................................................................................................................ 57
PREA Accomplishments .................................................................................................................. 58
Document Request
.................................................................................................................. 60
Assessment Team Biographical Sketches............................................................................................ 65
PREA Policy Review
.................................................................................................................. 70
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Introduction
The Georgia Department of Juvenile Justice (DJJ) was awarded a Bureau of Justice Assistance Prison
Rape Elimination Act (PREA) Demonstration Grant in 2012. As a component of the Grant, DJJ selected
The Moss Group, Inc. (TMG) through a request for proposal process to conduct facility sexual safety
assessments at five facilities, provide PREA training to management-level staff, conduct Central Office
interviews of key staff with PREA responsibilities, and provide an executive-level debrief of initial
assessment findings. These grant strategies were developed to assist DJJ in its efforts to comply with the
PREA standards and to identify opportunities that may further support the Department in its continued
work to promote sexually safe environments.
The information gathered through the assessment process has been analyzed and compiled in this
report to highlight systemic themes related to implementing PREA as well as facility-specific themes
identified during each facility sexual safety assessment. The five facilities assessed included both
Regional Youth Detention Centers (RYDC) (short-term facilities) and Youth Development Campuses
(YDC) (long-term facilities). The full list of facilities that were selected by DJJ for assessments is as
follows:




Sandersville Regional Youth Detention Center (December 11-12, 2012)
Macon Youth Development Campus (December 13-15, 2012)
Atlanta Youth Development Campus (December 17-18, 2012)
Metro Regional Youth Detention Center (December 19-21, 2012)

Eastman Youth Development Campus (February 18-20, 2013)
Each facility is unique and, as such, each facility assessment process collects certain data that are
specific to that facility. The opportunities identified by the Assessment Team that are unique to each
facility are addressed in the “Facility-Specific” section of this report. The benefit of conducting multiple
facility assessments within an agency is the opportunity to identify themes impacting agency PREA
implementation system wide, in addition to the facility-specific issues.
The key systemic themes identified and presented to Commissioner Niles on February 21, 2013, include:
1.
2.
3.
4.
5.
6.
7.
8.
Safety and Reporting
Data Collection
Staffing
Programming
Gender Responsiveness for Female Youth
Key Control
Physical Plant
Training
This report addresses these eight areas in the “Systemic Themes” section.
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The Moss Group was impressed with the considerable work already completed and underway to
address the PREA requirements. The Agency PREA Coordinator is dedicated to integrating PREA
throughout DJJ by engaging stakeholders to support and sustain these efforts. Throughout the
assessment process, DJJ continuously worked on a number of areas to implement PREA. This report
highlights some of these accomplishments, which are documented in Appendix 1.
Additionally, DJJ leadership continues to fully support the Agency PREA Coordinator, sending a clear
message of zero tolerance and a commitment to PREA compliance. DJJ has built a strong foundation to
comprehensively address the PREA standards and recognizes the importance of leadership and culture
in fully achieving sexual safety.
Scope of Work & Methodology
The TMG team conducted facility sexual safety assessments at Sandersville RYDC, Macon YDC, Atlanta
YDC, Metro RYDC, and Eastman YDC. Assessments of this nature provide a “snapshot” of the facility
through assessment of policies, practices, reporting culture, and operational issues related to the
prevention, detection, and response to sexual abuse. In accordance with the scope of the Grant, TMG
focused primarily on the components of the facility that impact sexual safety and the implementation of
PREA. Due to extensive experience in the field, the TMG Assessment Teams understand PREA and sexual
safety to be systemic, intersecting with all aspects of the facility. TMG utilizes an on-site protocol to
guide the assessment process. The protocol domains include:
TMG’s approach to this work is grounded in the final PREA standards and evidence-based, genderinformed, and nationally-accepted best practice related to sexual safety and working effectively with
youth in the juvenile justice system. Our work is guided by several core values, including promoting
positive relationships with our clients and respecting the staff working every day to ensure the safety of
the youth in their care.
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Document Review
Prior to the facility assessments, TMG reviewed select agency and facility-specific documentation.
Requested documents included policies and procedures related to PREA and sexual safety; programming
and educational options for the youth; major reports/audits; the grievance procedure; and a sampling of
incident reports, investigations, and disciplinary actions. (See Appendix 2 for the complete document
request list.)
Selection of Assessment Teams
The Assessment Team members were selected for this project based on the following areas of expertise:






Prison Rape Elimination Act
Classification, programming, and treatment for youth
Evidence-based and gender-informed practices
Operational practice in juvenile facilities
Organizational culture and leadership
Medical and mental health services
(See Appendix 3 for Assessment Team bios.)
The on-site assessment process was developed to ensure that information is obtained and verified in
several ways at each facility, to include the following:
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Staff focus groups with staff on all shifts
Interviews with key staff
Interviews with youth
Anonymous staff surveys
Informal conversations with both staff and youth
Document review

Observations of operations and programs during the site visits
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Influencing Factors
When assessing a facility and developing systemic themes, the Assessment Team seeks to build an
understanding of the factors that influence the day-to-day management and operations of each facility,
as well as the agency overall. This larger context of understanding allows the team to frame the report
recommendations within the reality of the competing priorities, challenges, and strengths of the agency,
and to support the aspirations that go beyond PREA compliance to promote sexually safe environments
with healthy cultures and strong leadership at all levels within DJJ. The primary influencing factors
identified by the Assessment Team include:
Culture Collision: There is new leadership at multiple levels within the organization including agency
executive, facility directors, and facility leadership teams. At all levels, the Assessment Team observed
leadership (new and existing) to be committed to the values of DJJ and excited about the opportunities
to improve services, culture, and outcomes and to be uncompromising regarding the safety for youth.
Many of the individuals who are new to their current leadership positions have come from other
organizations, often from the Georgia Department of Corrections. These individuals were specifically
recruited to assist the agency in addressing its significant concerns regarding facility safety and security.
Staff and youth generally view this as positive, reporting to the Assessment Team that the new
leadership is very focused on security and operations. There are best practices in both adult and juvenile
corrections that the agency can draw upon. It is critical that staff place equal value on the strengths
from both adult (safety and security) and juvenile (programming and treatment) correctional models to
manage the youth effectively and consistently. This same consideration is true for Central Office in
addition to the facilities.
A culture collision between security staff and programming/treatment staff also appears to exist to
varying degrees within DJJ facilities. The Assessment Team noted that the changes in DJJ leadership
provide an opportunity to improve services, culture, climate, and outcomes at each facility. Each of
these components is necessary for the sexual safety of youth in DJJ facilities. There is a greater
opportunity for this to happen if there is an intentional investment in the development of the new
leaders as well as all staff through training provided to all employees. The experiences of facility
leadership in their previous assignments and agencies did not necessarily provide them with the
knowledge and tools necessary to be successful in their current positions and to contribute to the
overall success of DJJ. They are learning new responsibilities, facing new challenges, and implementing
new agency initiatives as well as growing into their leadership roles, and the agency has an important
opportunity to provide guidance and support.
The Assessment Team observed that the facility-based plans and master schedules are one area where
this culture collision is most notable. As the facility leaders implement the new master schedule, there
appears to be some conflict between security/operations responsibilities and programming/treatment
responsibilities. The schedule will be most effective if facilities are able to incorporate programs and
activities that are age, gender and developmentally appropriate for the youth at each facility. This may
require modifications of the facility schedule or activities that meet unique needs of each facility. The
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size (physical plant and population) and resources of each facility along with the facility culture will
affect the success or ineffectiveness of the implementation of the master schedule.
Juvenile Justice Reform: DJJ and the State of Georgia are undertaking significant reforms in the state’s
juvenile justice system. During the assessment, staff articulated that these reforms will be influencing
factors; however, staff are not able to anticipate or plan for the impact of these factors. Staff expressed
hope that one outcome will be a significant reduction in the number of youth in the RYDCs who are
awaiting placement in an YDC. This may also reduce the co-mingling of RYDC (short-term) and YDC (longterm) youth within facilities—a situation that results in the challenge of managing long-term youth in a
short-term program for extended periods of time. Proposed reforms are intended to reduce the
inappropriate commitment of youth to a YDC when they can be safely and appropriately served in the
community. For those youth that are committed, it is critical that they are connected in a timely manner
to long-term programming in a YDC.
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Systemic Themes and Recommendations
The Assessment Team identified the following systemic themes after conducting five facility sexual
safety assessments.
1.
2.
3.
4.
5.
6.
7.
8.
Safety and Reporting
Data Collection
Staffing
Programming
Gender Responsiveness for Female Youth
Key Control
Physical Plant
Training
Assessors identified and confirmed themes through a combination of staff focus groups, staff surveys,
staff interviews, youth interviews, informal conversations with staff and youth, and facility observations.
In order for issues to rise to the level of “themes,” the Assessment Team must receive verification from
multiple sources; in the case of systemic themes, they must be observed at several facilities. These key
themes represent the primary issues that emerged throughout this process that are opportunities to
further support DJJ’s efforts to enhance sexual safety and/or to meet PREA standards.
1. Safety and Reporting
There are a number of juvenile PREA standards that have to do with reporting, indicating how important
a healthy reporting culture is to promoting sexually safe environments for youth and staff. These
standards include:
115.331 Employee training
115.351 Resident reporting
115.353 Resident access to outside support services and legal representation
115.354 Third-party reporting
115.361 Staff and agency reporting duties
115.363 Reporting to other confinement facilities
115.367 Agency protection against retaliation
115.333 Resident education
115.332 Volunteer and contractor training
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DJJ has worked diligently to ensure that staff and youth receive the appropriate information on how to
report and how to receive reports as staff members. Additionally, each facility has a number of posters
promoting zero tolerance of sexual abuse.
Many youth and staff reported that they felt safe
in their facilities, particularly when asked if they
felt sexually safe. One factor was specifically
mentioned as contributing to a feeling a safety;
staff reported that reducing the number of youth
allowed in one area at a time seemed to be
helpful for staff in supervising the youth,
particularly during dinning and recreation.
Though this seemed to be helpful to staff in many
ways, there were also some challenges expressed
by youth and staff related to such changes. These
issues will be addressed in the “Programming”
section.
Combined staff survey responses from all
the facilities indicated that
approximately 72% of staff agreed or
strongly agreed that youth were sexually
safe.
Approximately 17.4% of the staff
disagreed or strongly disagreed that
youth were sexually safe, and the
remaining 10% of staff responded not
applicable.
Conversely, although staff felt youth were generally sexually safe, at the time of the assessment, some
staff that responded to the surveys indicated a concern over emotional safety for themselves and for
the youth. This was due in large part to staffing shortages and holdovers of staff. Staffing issues will be
addressed further in the “Staffing” section.
Combined survey results indicated that
45.5% of staff disagreed or strongly
disagreed that their facility was an
emotionally safe environment for staff.
Of surveyed staff, 42.2 disagreed or strongly
disagreed that their facility was a
physically safe environment for staff.
Many youth, particularly the males, stated that if they
were being sexually harassed or threatened by another
youth that they would “take care of it themselves.”
Several factors may explain why youth respond this way,
including cultural factors, gender, and perhaps a lack of
trust in available reporting mechanisms.
Generally, the grievance process was found to be credible
in many of the facilities; however, in some facilities, youth
indicated that they did not trust the grievance box as an effective way to file grievances related to sexual
abuse. Additionally, some youth expressed that they did not feel that they had a staff member they
could trust to report an incident related to sexual abuse.
Recommendations:


Continue to emphasize, through youth orientation and Town Hall Meetings with youth, their
right to be free from sexual abuse and the multiple ways they can report any issues related
to sexual abuse or harassment.
Consider reminding youth of available reporting mechanisms throughout their time in DJJ’s
care, either through education, programming, or on their housing units after school.
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



Repetition is critical for youth to fully understand and to remember what they can do to
report.
Complete the MOU process with an identified outside organization to accept reports from
youth so that youth will have access to an outside entity to report per PREA standard
115.351 Resident reporting, part (b).
Ensure that staff are reminded in roll call and throughout their shift about how to receive
reports of sexual abuse or harassment and ways to respond appropriately to these specific
types of reports.
Ensure that grievances and third-party reports are accepted by facilities. This includes
grievances filed by youth on behalf of other youth, per PREA standard 115.352 Exhaustion
of administrative remedies, part (e). Ensure that third parties, such as parents, receive
information on how they can report to the facility or the agency.
Consider revising posters, once the hotline is available, to clearly indicate ways youth can
report incidents of sexual abuse or harassment. Currently, the information provided via
posters is valuable, but it is communicated in the Youth Safety Guide Poster with a very
small font and too many words for youth to quickly determine how they should report.
2. Data Collection
The Juvenile PREA standards address data collection, analysis, retention, and dissemination. These
standards include:
115.386 Sexual abuse incident reviews
115.387 Data collection
115.388 Data review for corrective action
DJJ has already begun to address PREA standards related to data collection. The PREA Coordinator
modified the Department’s Serious Incident Report codes to more accurately capture PREA-related
incidents and data. Data collection and analysis can be an important tool to assist in enhancing safety.
By reviewing grievances, incident reports, disciplinary reports, and sanctions at the facility and central
office levels, leaders will be able to base decisions on data rather than on anecdotal information. They
will be able to target identified issues by modifying policy and/or practice.
The Assessment Team found insufficient data review and analysis at the facility level. Rather, facilities
send data to Central Office for aggregating and review to meet PREA standards. This is a lost opportunity
to empower facilities to analyze data related to sexual abuse or harassment as well as any other serious
incident reports to track patterns and develop individualized responses and solutions to outstanding
issues.
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Recommendations:



Ensure that each facility management team fully understands their role in PREA standard
115.386 Sexual abuse incident reviews.
Consider going beyond the PREA standards to engage facilities in collecting and analyzing
relevant data in addition to submitting the required data to the Central Office. Document
these efforts and any resulting recommendations.
Continue to develop the agency’s PREA website page by adding the appropriate data to the
website, per PREA standards 115.388 Data review for corrective action and 115.389 Data
storage, publication, and destruction.
3. Staffing
Staffing levels, as they relate to appropriate supervision of youth to prevent sexual abuse, is addressed
in the following PREA standard:
115.313 Supervision and monitoring
Many agencies are encountering challenges in meeting PREA standard 115.313. There are many
components and requirements within this standard, one being the staffing ratio requirements of 1:8
security staff to youth during waking hours and 1:16 during sleeping hours. DJJ is aware of this standard
requirement, and the fact that it does not go into effect until October 1, 2017. However, the Assessment
Team observed some challenges that require more immediate attention. The Team noted that most
facilities have difficulty in retaining adequate levels of staffing and qualified security and treatment staff,
especially in medical and mental health treatment. The Assessment Team heard a number of reasons for
these challenges from staff, namely non-competitive wages for the skill level, the location of some of
the facilities, the stress associated with working with youth, long work schedules, and competition from
other, similar agencies in proximity to the facilities. Coupled with the factors mentioned above, many
staff expressed that they are tired, and morale issues in most of the facilities seemed to be directly
associated with intense and long work days. For security staff, there seem to be a number of holdovers
where staff end up working sixteen-hour days. These stressors can certainly impact how staff respond to
youth, particularly at the end of shifts. This could contribute to the issues raised in the section of “Safety
and Reporting.” If staff morale and energy levels continue to decrease, due to holdovers and shortstaffing, this may impact the way staff interact with youth and create a potential for unintentional
negative responses to youth, and risk both youth and staff safety.
Recommendations:

Ensure each facility develops a staffing plan as required in PREA standard 115.313 (a) to
determine adequate staffing levels to detect, prevent, and respond to sexual abuse and
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

harassment. Document these efforts and recommendations, ensuring that each component
listed in this standard is addressed.
Ensure that facility directors and Central Office have ways to hear and respond to staff’s
concerns and challenges.
Consider working with facilities to develop incentive programs to support staff, without
having to utilize substantial financial resources. One example could be the provision of free
meals on days when a staff person is held-over.
4. Programming
Providing meaningful programs and reducing idleness is a significant component of enhancing sexual
safety in facilities. The Assessment Team observed significant idle time in the facilities. There are three
primary factors that contribute to idleness: staff vacancies, budget reductions, and changes in the
population that have not yet been incorporated into programming. There has been an emphasis on
youth receiving their GED or high school diploma while they are in a YDC. This is a very significant
achievement for DJJ youth, and the Assessment Team observed many positive interactions among
teachers and youth that promoted positive learning environments. After the GED, however, there are
few opportunities for further education or career and technical training. The facilities that have
vocational training that certify youth for employment have a demand that exceeds the available
resources. Youth with long stays are exhausting all the educational and vocational opportunities
available to them long before they qualify for release consideration.
DJJ has distributed resources differently to facilities designated as RYDC compared to YDC. As a result of
commitments and capacity limitations, many youth are awaiting YDC placement in an RYDC for more
than six months. The RYDC is not staffed to deliver the same services as an YDC, but must do so to be
compliant with agency policy and procedure. This shortage stresses the resources of the facility and may
result in a greater emphasis on crisis response than individualized case planning and programming. This
was notable in the area of mental health and social services. Youth may complete programs at the RYDC
and then be required to repeat the same program at the YDC. Youth shared with the Assessment Team
that, in these instances, they do not feel like they are making progress and gaining skills that will help
them succeed after release, especially if they have long sentences.
Recommendations:

Although culture collision was noted as an influencing factor overall, it is also an opportunity
for improvement in the area of programming. For example, the master schedule requires
youth to be engaged in programming and out of their dorms for the majority of the day and
evening. The Assessment Team noted facility challenges in the successful implementation of
the schedule, particularly in terms of activities and programs that engage the youth at each
facility. There is an opportunity to modify the schedule based on the programming needs of
the youth at each facility, as determined by their age and developmental level, as well as
gender, and the physical and human resources of each facility.
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

Engage volunteers to expand the schedule’s program diversity and inclusion of life skills.
Consider ways to allow more volunteers in the facility, to include ex-offenders to continue
programs and speak with youth in group settings and with DJJ staff supervisors. Many staff
see this program as very beneficial to the youth.
Add additional life skills and vocational programs for youth that are age and gender
appropriate.
5. Gender Responsiveness for Female Youth
Research indicates that the differences between the profiles and service needs of girls and boys entering
the juvenile justice system present a significant challenge for the professionals who serve them. This is
due in part to the pathways by which girls enter the criminal justice system. Many girls in the system
have experienced traumatic events, including sexual and physical abuse and neglect, which create a
1
unique set of challenges in addressing the needs of girls effectively. The pathways of girls impact
services, communication, and overall management and supervision of youth. This is true for the
implementation of PREA as well. There are several standards identified by TMG that have gender
implications. These standards include:
115.313 Supervision and monitoring
115.315 Limits to cross-gender viewing and searches
115.321 Evidence protocol and forensic medical examinations
115.333 Youth education
115.334 Specialized training: Investigations
115.335 Specialized training: Medical and mental health care
115.341 Obtaining information from residents
115.342 Placement of residents in housing, bed, program, education, and work
assignments
115.351 Resident reporting
115.353 Resident access to outside confidential support services
1
Watson, Liz; Peter Edleman, Improving the Juvenile Justice System for Girls: Lessons Learned from the States.
Georgetown Center on Poverty Inequality and Public Policy; October 2012.
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115.364 Staff first responder duties
115.371 Criminal and administrative agency investigations
115.378 Interventions and disciplinary sanctions for residents
115.382 Access to emergency medical and mental health services
115.383 Ongoing medical and mental health care for sexual abuse victims and abusers
115.387 Data collection
DJJ has demonstrated a commitment to providing female youth with gender-specific services by
developing a position at Central Office to oversee and coordinate female services. At the time of the
assessment, this position was newly appointed. At the facility level, the benefits had not yet been
realized. Macon is the only YDC dedicated to female youth, however, many RYDCs also house female
youth. DJJ understands the need for services and programming that are gender specific for the female
youth. As noted in the facility-specific de-brief at Macon YDC, positive programs are in place to address
some of the trauma and unique needs of females.
In addition to programming, gender-specific training for staff is essential to working effectively with
females. This is particularly true when addressing PREA and sexual safety. Staff at the RYDCs and YDCs
had not received any extensive training on working with females. Some identified training areas that
could enhance safety and working with females include:
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




Relationships
Trauma
Gender and Safety
Gender and Communication
Gender and Health
Professional Boundaries
Gender-Responsive Operational Practice
A challenge identified by the Assessment Team is that many staff at all levels within the facilities,
especially the RYDCs, were not aware that a body of research and specific training existed for working in
female services. There will need to be a significant communication and outreach strategy to support the
efforts to implement gender-specific services.
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Recommendations:

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



Continue to develop an overall female services strategy in collaboration with Central Office
female services staff and with facilities housing females.
Consider how PREA implementation may need to be modified to better address sexual
safety specific to female youth.
o For example, review youth orientation materials, how staff are trained on
communicating with female youth, methods to speak with female youth after an alleged
incident or report of sexual abuse or harassment, and pat-down search procedures and
policy.
Develop a training initiative for leadership and staff who work with female youth. Ensure
training incorporates recent research and operational implications specific to working with
females.
Engage national resources as necessary for training and technical assistance to assist in
training delivery. The Moss Group can help in identifying some useful resources.
Continue to implement gender-specific and age-appropriate programs and services for the
female youth.
Develop ways to communicate with staff that work in female services to ensure they
understand why additional training and modified approaches are helpful to them in working
with female youth. Build upon the best practices utilized for the Butterfly Program and
Behavioral Management Unit (BMU) at Macon YDC to engage staff in this recommendation.
6. Key Control
From a security perspective, key control is primarily intended to prevent escape and minimize access to
sensitive areas of a facility in the event keys are lost or there is a disturbance in a facility. From a PREA
perspective, key control is meant to augment these security practices by also minimizing access to
isolated areas or areas not commonly used and curtailing the potential for false allegations. When areas
of a facility are not routinely used, the keys to those areas should be restricted by either removing those
keys from circulation or by rekeying the locks cylinders, thus restricting access. Keys to areas not
routinely used by supervisors should be drawn only when needed, and a record should be maintained to
document the period of times those keys were used.
All of the facilities visited by the Assessment Team comply with the Department’s key control directive
(Policy 8.12). However, all but one of the assessed facilities maintain a paper inventory of their keys
rather than an automated or computerized system. One facility had a very good in-house automated key
management program, yet their spare keys and key blanks were kept inside the secure portion of the
facility. Policy 8.12, section II, notes that the location of the “back-up and key pattern keys” is to be
determined by the Director. Unfortunately, the policy does not mandate that the location selected be
outside the secure perimeter of the facility. Best practice dictates that spare keys should be maintained
outside the secure fences as an extra security precaution.
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Key Issuance, as prescribed in section VI of Policy 8.12, is governed by Department policy. However, it is
a cumbersome and time-consuming process for the Control Center staff who are also tasked with
opening gates and doors and, in many cases, monitoring cameras. For all of the staff with restricted key
access, the Control Center staff obtains the staff’s personal keys, chits, and their 24-hour take-home key.
They unlock the individual restricted key box, exchange the keys, relock the box, and then make sure the
staff receiving the keys properly logged the keys out. The potential for keys to be drawn without being
properly logged out poses a vulnerability issue for the facilities. From a sexual safety perspective, it is
vital that facilities are able to document who has keys to what areas and to maintain a proper
accounting of when keys are drawn and returned. This issue can be mitigated by assigning staff to
Control Centers at high volume shift changes to exclusively distribute and document key exchange.
Another option is to use an electronic key watch system that maintains a real-time inventory of actively
used keys.
The Key Control Officer, by policy, is designated by the facility Director. However, there appeared to be
no documented requirements or training for this position. Staff are generally trained by the person they
are replacing or left to self-train with nothing to guide them but the policy or their past experience.
Recommendations:




In order to create a sense of uniformity, at a minimum, Key Control Officers should receive a
cursory orientation to key control practices.
Conduct regular information exchange meetings with Key Control Officers from every facility to
enhance and promote key control best practices.
As resources allow, consider converting key control systems to key watch systems that are
computerized, to enhance monitoring and mitigate vulnerability.
Conduct a vulnerability key assessment at each facility to ensure unused areas and vacant rooms
are no longer accessible by staff. This may be particularly timely as DJJ’s population decreases
and areas becoming less populated or unused.
7. Physical Plant
Cameras are never a substitute for good staff supervision; however, they are a useful tool in supporting
staff, PREA standards compliance, and deterring negative behaviors. PREA addresses monitoring
technology in the following PREA standards:
115.318 Upgrades to facilities and technologies
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There is good camera coverage in many of
the facilities assessed, although the
Combined staff surveys indicated that 20.4% of staff
physical plants and camera needs vary
responded with disagree or strongly disagree when
asked
if isolated areas where staff or youth could be
greatly from facility to facility. For
hurt
within this facility have been identified, and
example, Atlanta YDC is primarily
whether operational procedures have been put in
contained within one structure and has an
place to enhance safety and security.
outstanding camera system of 162
cameras with dedicated monitoring and
very few blind spots throughout the facility. Sandersville, in contrast, has several exterior modular
buildings with only 38 cameras and a 14-day recording capability. At Macon YDC, all movement is
conducted in an open campus. School, recreation, and meals are all in separate buildings, yet, out of 124
cameras, only seven are dedicated to cover the five acres inside the fence.
In each of the assessed facilities, staff reported that they were familiar with facility blind spots, were
aware of their areas of vulnerability, and compensated for those areas through additional supervision or
restricted movement. However, based on staff surveys, focus groups, and individual interviews reported
that these modifications to supervision were not formal responses to physical plant vulnerabilities and
that isolated areas were still a challenge at each facility. When staff are temporarily assigned to an area
that they are not familiar with, this creates an additional burden and risk.
Recommendations:


Utilize facility staff to conduct a physical plant vulnerability assessment, formally
documenting any blind spots, line of sight challenges, and other vulnerabilities at each
facility. Use this documentation to develop training and recommendations for
enhancements. This will assist each facility in meeting PREA standard 115.313 Supervision
and monitoring.
Encourage facility collaboration to utilize the rich expertise and knowledge of camera
systems and placement of cameras when conducting these reviews. Atlanta YDC could be an
excellent model for other facilities.
8. Training
Through the PREA standards, there is a clear emphasis on the importance of training in multiple areas to
better prevent, detect, and respond to sexual abuse. These standards include:
115.332 Volunteer and contractor training
115.334 Specialized training: Investigations
18
DJJ has done an excellent job of integrating PREA training into each facility and tracking and
documenting employee PREA training for purposes of meeting PREA standards. There are eight staff
training modules available online. Staff receive training on those modules based on their role and level
of contact with youth, consistent with PREA. Additionally, through the PREA Steering Committee, the
Agency PREA Coordinator has engaged stakeholders in specialized areas such as medical and mental
health to augment training needs. For example, at the time of the assessment, mental health staff were
receiving additional training on trauma with the intention to subsequently assisting in training facility
staff on trauma and working with youth. This is an excellent use of resources to build capacity within
each facility. Additionally, at the time of the assessments, DJJ was working on developing training
specific to working with LGBTI youth, but it has not yet been fully implemented. Many staff were not
sure what the term transgender or intersex meant, and there was some expressed concerns over
cultural awareness in addressing these issues that should be explored further. When rolling out these
trainings, it will be beneficial to support staff and volunteers in balancing their personal beliefs with
their jobs and services.
Volunteers and contractors are also required to train on PREA, and this training is well documented. The
regional investigators reported that many are certified and trained as sex offender investigators.
Although PREA training is occurring in an ongoing and consistent manner, the Assessment Team
received feedback in some areas regarding training that indicates that, in addition to providing
widespread general training, there are some areas that may require more in-depth discussion and
teaching that cannot be provided through an online presentation. In particular, staff identified firstresponder training and training on the dynamics of sexual abuse as areas that may require more focus
and interaction with a subject matter expert.
Another training opportunity identified by staff and the Assessment Team included supervisory and
leadership training for facility management teams. Many of the assessed facilities had relatively new
facility leadership with little or no experience in their current role or with DJJ. During formal and
informal conversations with leadership, many expressed a desire to be successful in their current roles
and sought direction in how to excel. By supporting leadership and providing them with useful
management tools, large-scale initiatives such as PREA are better implemented and sustained.
Recommendations:


Consider ways to provide and reinforce PREA trainings, specifically in the areas of firstresponder duties and the dynamics of sexual abuse in confinement settings. Some examples
could include developing first-responder pocket cards that outline the steps a first
responder should take in a PREA-related incident. Periodically, bring up these issues with
staff during roll call and staff meetings.
Consider shortening the amount of time or splitting up the modules so that staff can better
absorb the PREA training. Receiving training on eight modules in a row was considered
overwhelming for some staff. Many of the staff interviewed recalled that they passed the
tests but could not remember the content of the various modules.
19




Ensure that the LGBTI training has components that address cultural awareness and
personal beliefs to better prepare and support staff in this complex issue. Consider utilizing
resources developed by TMG and National Institute of Corrections on working with
transgender youth. Also consider utilizing resources provided by the National PREA
Resource Center to augment efforts in this area.
Consider developing leadership training or coaching for new facility directors. Many of these
administrators could benefit from transitional training—to help prepare them for their new
positions—and from peer mentoring from some of the more senior administrators in the
agency.
Consider ways to engage the facility management team as a whole to build their supervisory
and leadership skills and help sustain PREA implementation efforts.
In conjunction with the PREA Steering Committee, review PREA and related training
offerings to develop ways to reinforce training without having to utilize extra resources or
additional staff time. For example, develop a PREA memo that reminds staff of important
points, or ask supervisors during roll call to reinforce different topics each day to ensure that
staff understand and retain important information.
20
Facility-Specific Reports

Sandersville RYDC

Macon YDC

Atlanta YDC

Metro RYDC

Eastman YDC
21
Facility-Specific Report: Sandersville Regional Youth Detention Center
On-Site December 10-11, 2012
Sandersville RYDC, located in Sandersville, Georgia, is a regional youth detention center that houses
both boys and girls. The capacity is 30, with 22 beds for males and eight beds for females. Youth can be
housed at this facility if they are waiting to go to court or have been adjudicated and are awaiting
placement to a secure care facility. Sherry Shoats is the Director of Sandersville and had been at the
facility one year at the time of the assessment. The on-site assessment took place December 10 and
December 11, 2012.
Facility Strengths
At Sandersville RYDC, the facility staff identified a number of strengths that serve as a foundation for a
positive and safe culture. The staff felt that they worked positively with one another and that they were
a close-knit group. Sandersville has very low staff turnover compared to many other DJJ facilities,
creating a sense of continuity and contributing to the community feeling expressed by the staff. Due to
the small size and low turnover of staff at the facility, they also felt able to communicate effectively with
one another. While on site, the Assessment Team observed positive interaction among staff and youth,
professional demeanor and dress of staff, and a clear dedication of staff to their work with the youth.
Staff expressed that they felt safe and that they felt that youth were also safe. The youth indicated that
they had access to the grievance system and found that it was a credible reporting mechanism that
could be utilized if necessary. At the time of the assessment, all staff at Sandersville had received the
online PREA training developed by DJJ.
Programmatically, the Assessment Team observed
Staff surveys indicated that 100% of staff felt
strong individualized education that appeared to
physically and sexually safe at the facility. 85%
engage the youth. Grade-appropriate resources are
of staff strongly agreed or agreed that they felt
available to youth. In many cases, youth are able to
emotionally safe.
stay up with classes in their home school district. In
conversations with the youth either through
interviews or informal discussions while on site, the
youth indicated that the education offerings were positive at Sandersville RYDC. The facility utilizes a
card system to reward positive behavior. The Assessment Team found this system as beneficial and that
it provides incentives and accountability for the youth.
The facility benefits in many ways operationally from being a small physical plant. There is structured
and orderly movement of the youth between classes, programs, appointments, and dining throughout
the day. The facility management staff has addressed many facility blind spots through adjustments in
camera coverage and staff supervision.
The leadership team utilizes data by reviewing incidents to identify trends and potentially vulnerable
physical plant areas. This is a best practice and will help meet PREA standard 115.386 Sexual abuse
incident reviews. Staff also utilize a handheld camera for any incident that may require use of force,
22
restraints, or intervention between youth.
This is a good system for documenting
incidents and can be a valuable training
tool for reviewing these incidents.
Supervisors conduct unannounced rounds,
and leadership and supervisors are
present on all shifts at the facility level.
Conducting and documenting
unannounced rounds on all shifts is
considered a best practice and will help
meet PREA standard 115.313 Supervision
and monitoring.
Of surveyed staff, 100% agreed or strongly agreed that
isolated areas where staff or youth could be hurt within
the facility have been identified, and operational
procedures have been put in place to enhance safety and
security.
Of surveyed staff, 100% agreed or strongly agreed that
prevention of sexual misconduct and abuse is openly
discussed.
Facility Opportunities
Many positive practices are in place at Sandersville RYDC. The leadership clearly promotes safety and
security for staff and youth at the facility. There has been an emphasis on consistent application of
agency policy, which staff report has enhanced safety and security. To build on this foundation, the
Assessment Team identified the following opportunities to further enhance the facility’s efforts in
implementing PREA and sexual safety.
Staffing: Although staffing is noted as a systemic issue for the agency to consider, the Assessment Team
found that many staff feel stretched as they work long hours, and there is a lack of relief available. This
is due in part to the small size of the facility, as staff wear many hats to support the facility needs.
Turnover has been low for direct supervision staff, but treatment and support positions have had more
turnover. For example, there have been five Social Service Providers (SSP) in five years.
Recommendation:

To support the needs of the facility to ensure the facility management team develops and
reviews a staffing plan—documenting adequate levels of staffing—and identifies areas
where the facility may benefit from cameras and additional monitoring. Review PREA
standard 115.313 Supervision and monitoring for specific items to consider in the facility
staffing plan to help meet this requirement. These items include not only physical plant
considerations and the composition of the resident population but institution programs that
occur on a particular shift (such as intake, social and mental health services provided to
individuals and groups, and volunteer services).
Showers/bathrooms: One of the key concerns identified by the Assessment Team was the showering
procedure for the youth in the dorm area. According to management staff, only one youth is to shower
at a time. However, in focus groups and informal conversation with staff and youth, assessors heard
conflicting information on the consistent application of its practice. This can be problematic, as there is
23
limited privacy in the showers and limited supervision to reduce the opportunity for inappropriate
behavior.
Additionally, though toilets are located in each cell, staff can view youth going to the restroom through
the windows in the door, due to the location of the toilets in the cell. Staff are mindful of these
situations; however, PREA standard 115.315 Limits to cross-gender viewing and searches states that
youth should be able to perform bodily functions and change clothing without nonmedical staff of the
opposite gender viewing their breasts, buttocks, or genitalia, except in exigent circumstances or when
such viewing is incidental to routine cell checks.
Recommendations:




Ensure that policy and practice are consistent with only one youth showering at time. This is
best practice as it minimizes opportunities for inappropriate behavior.
Facility management team or supervisors of the same gender as the youth should consider
conducting unannounced rounds during this time to ensure that appropriate showering
practices are in place.
Consider providing some coaching or mini-trainings with staff to remind them of the crossgender supervision and viewing standard and the ways they can ensure that both privacy
and supervision occur at the same time on a unit. This training should also be documented.
Consider ways to modify the current physical plant challenges around each of the toilets.
Some facilities have utilized shower curtains and a PVC stand that the youth can arrange
24
when using the restroom to block accidental viewing; these still allow a good line of sight to
ensure safety.
Key Control: Key control practices were considered generally positive and security minded. However,
some supervisors have access to areas that are not essential to their job function. One example is the
keys to the education buildings, after hours.
Recommendations:

Consider reviewing the key control practices to mitigate opportunities to access isolated
areas. Keys for access to specific areas after hours should be drawn from the Control Center
and their use should be documented.

Consider updating the key control system with an electronic key watch system that
automatically records when keys are drawn.
Training: Though staff have completed the online PREA training, many staff were unclear of the
responsibilities of first responders. Additionally, at the time of the assessment, staff had not received
training specific to working with LGBTI youth. PREA standard 115.331 Employee training indicates that
training should include how to communicate effectively with LGBTI youth and should take into account
the gender of the youth that staff are supervising. The Assessment Team was notified after the
assessment that training on LGBTI youth is under development. PREA standard 115.332 Volunteer and
contractor training states that training for volunteers should minimally include their responsibilities
related to sexual safety and reporting and should be based on the services they provide and their level
of contact with residents. Please see the gender-responsive section for more detailed recommendations
related to working with young women.
Recommendations:



Consider providing additional first-responder training for staff. This could be a single module
provided to staff as refresher course or a combination of reminders at shift change and inperson training by the facility PREA Coordinator to ensure staff understand their duties as
outlined in PREA standard 115.364 Staff first responder duties. In some jurisdictions,
agencies have developed pocket-card reminders that outline the steps first responders
should take when arriving on the scene of an incident. This may be an alternative way to
remind staff of their duties.
Ensure that staff receive training related to working with LGBTI youth and understand the
implications under PREA in working with these populations.
Ensure that volunteers receive PREA training based on the services they provide and their
level of contact with residents.
Specialized Training: The Assessment Team found that specialized training in investigations, trauma,
and medical and mental health care for youth who have been sexually abused or harassed (historically
25
or in a currently reported serious incident) was reported as either unavailable to staff or sufficiently
incomplete for staff to feel comfortable in providing quality services in these areas.
Recommendations:


Ensure that specialized training is documented within the training record.
Consider surveying staff to help identify specialized training needs before developing the
next annual training conference for conducting investigations, assessments, and medical
and mental health (behavioral health) care.

Consider having staff evaluate specialized training modules 90-180 days after training and as
part of after-incident reviews to measure how helpful training is in actual practice.
Gender-Specific Considerations: The Assessment Team observed female youth in jumpsuits while at the
facility. This attire is not consistent with best practice. Upon noting this observation to facility leadership
and Central Office staff, there was immediate action to resolve this issue, while demonstrating a
willingness to promote gender-specific policies and practices for the female population.
The Assessment Team also noted that there is a lack of gender-responsive programming for female
youth. This was a need identified by staff at multiple levels in the facility. Research and best practice
indicate that programming specific to females increases positive outcomes by targeting their specific
needs. Female youth often enter the criminal justice system in different ways than male youth. They
often need to address different issues from their male counterparts including trauma, low self-esteem,
and past abuse and exploitation. Finally, current staff training does not include gender-specific
information about the female population or how to work effectively with female youth. This becomes
particularly challenging for male staff that are periodically assigned to the female unit to assist in
coverage.
Recommendations:




Ensure that practices and policy are reviewed with a gender-responsive lens to ensure best
practices are included in working with both genders. This includes appropriate garments,
property list, hygiene, diet, and programming offerings, to name a few.
Consider augmenting the current program offerings to provide some gender-specific
programming that addresses the unique needs of females. Consider reaching out to
community providers to assist in providing such programming, and work with the newly
appointed female services staff person in Central Office for additional resources and
guidance.
Ensure that staff are trained to work with female youth and to understand the unique
pathways through which they enter the criminal justice system. Understanding these
pathways can help staff better supervise and respond to specific needs of this population.
Recruit part-time SSPs to focus on gender-responsive programming and trauma-informed
care.
26
Medical and Mental Health: The Assessment Team observed medical and mental health services staff as
capable and dedicated to serving the population. They conduct initial screenings within 24 hours and
indicate whether youth have experienced prior victimization as required by PREA standard 115.381
Medical and mental health screenings: history of sexual abuse. They also test for STDs and pregnancy.
As required by PREA standard 115.382 Access to emergency medical and mental health services,
residents have access to emergency medical and mental health services. Mental health staff are
qualified to deliver services that focus on trauma and disassociation and make general
recommendations to staff on what will work best in supervision. However, the staff were stretched very
thin with intense caseloads, turnover, and vacancies at the time of the assessment. Though many youth
remain at the facility for short time periods, some are there for much longer, and these services are
critical to supporting the youth during their time in DJJ’s care.
Recommendations:


As staffing plans are developed, consider not only the staff ratios for supervision but also
institution programs and the demands of youth awaiting placement in an RYDC. Add staff to
enhance delivery services as well as utilize community providers. Ensure that mental health
staff are working with youth to understand and address past trauma, helping to reduce the
likelihood of re-victimization.
Ensure that medical and mental health staff understand their role in the facility (and
security staff understand their role as well) should a youth allege an incident of sexual abuse
or harassment while at the facility. Several PREA standard requirements outline the critical
role of medical and mental health staff in helping prevent, detect, and respond to sexual
abuse. Ensure that mental health staff are trained on these standards and their role and that
they have the resources to meet expectations. Standards include:
115.381 Medical and mental health screenings: History of sexual abuse
115.382 Access to emergency medical and mental health services
115.383 Ongoing medical and mental health care for sexual abuse victims and abusers
115.342 Placement of residents in housing, bed, program, education, and work
assignments
o 115.361 Staff and agency reporting duties
o 115.365 Coordinated response
o
o
o
o
o
o
Reporting: As noted, staff are aware of their responsibilities as mandated reporters of sexual abuse and
harassment. And youth report that the grievance system is credible and readily accessible to them. PREA
standard 115.351 Resident reporting requires multiple internal ways for residents to privately report;
one of those ways must not be part of the agency. It also requires that there is a method for both staff
and youth to privately report sexual abuse and sexual harassment of residents. DJJ has developed a
strong internal reporting process. The Assessment Team observed, however, that there is not a
27
documented way to make reports that are not part of the agency. Staff are also not aware of any way
that they can privately report allegations of sexual abuse or sexual harassment.
Recommendation:

Review reporting options and formalize one external reporting process that can be utilized
by both residents and staff.
28
Facility-Specific Report: Macon Youth Development Campus (YDC)
Macon YDC, located in Macon, Georgia, in Bibb County, is the only YDC dedicated to serving females.
The facility capacity is 94 youth—24 RYDC youth and 70 in long-term programs. The facility serves young
women from low-risk to high-risk and provides a variety of programming, recreation, vocational, and
education services for the youth. Director Debbie Blasingame has been the Director at Macon YDC for 10
years and has worked at the facility for 25 years.
Facility Strengths
A number of strengths were identified by staff and observed by the Assessment Team while they were
on site at Macon YDC. Most staff were seen interacting positively with the youth throughout the
campus. The leadership team and staff that the Assessment Team spoke with expressed a commitment
to working with the youth and wanting to make a difference in the lives of the residents. The staff
expressed that there was a team approach and willingness to continue to improve Macon YDC. The
Assessment Team saw this commitment in the openness of staff that spoke to them, expressing that
they wanted to enhance the safety and services for youth. The facility leadership team and staff were
welcoming and very hospitable while the team was on site.
Programmatically, the Assessment Team identified a number of strengths. There are specialized groups
for all residents as well as specialized cottages that offer more focused programming. These groups and
programming include the Butterfly Program, which has an art therapy component, the Behavior
Management Unit, the Graduates Unit, individual and group counseling, substance abuse treatment,
and anger management groups. The education building contained positive messaging and classrooms
that were conducive to positive learning environments. There is a recreation coordinator that provides
organized activities and social skill-building opportunities for the youth. Though budget cuts have been
made, the facility strives to continue to deliver the same quality and continuum of services for the
youth.
It was estimated that nearly 95% of the youth at Macon YDC are on the mental health caseload. Staff
confirmed that 58 youth were on the mental health caseload, excluding the RYDC, and 36 had a trauma
diagnosis. To respond effectively to these unique needs of young women, the facility has two boardcertified child/adolescent psychiatrists on staff that provide a total of 34 hours of service weekly, as well
as six masters-level mental health counselors. All mental health staff have been trained in TraumaInformed Cognitive Behavioral Therapy. The facility also employs a juvenile detention counselor for each
dorm. The anger management group that was observed during the assessment was research informed
and engaged all the girls in the group. Both staff and youth provided positive feedback on The Butterfly
Program, which is an intensive three-month program on the Mental Health Unit for girls who have been
sexually abused. This program is delivered within a milieu that is safe for the youth and supportive of
the program. It also includes an art therapy component. The behavioral management dorm is viewed as
a therapeutic unit, not as a behavioral sanction. Its focus is on confronting anti-social characteristics as
well as conducting trauma-informed care of the residents. Once placed in this unit, the girls must work
29
through a structured and individualized plan that is based on a five-step program. Overall, the clinical
staff at the facility were seen as a significant strength, with long-term stability and experience.
The assessment and orientation process and practice was considered a facility strength. The unit where
all youth first arrive was designed specifically for the intake process. The initial mental health and
medical assessment are completed within two hours of a youth’s arrival on campus. The assessment
tools that mental health staff and the SSP II use are considered to be best practice by the profession.
The Juvenile Correctional Officer (JCO) assigned to intake and orientation is experienced in the process
and interacts professionally and compassionately with new intakes. The medical examinations and
screenings are integrated into the process as well.
The facility has a computerized key management system that allows them to monitor keys by key
numbers and key sets. Although not one of the most sophisticated systems, the Assessment Team it as
the most advanced system currently in use in the YDC and RYDC facilities. The facility has 124 cameras
and a 30-day recording capability. This allows the facility to retrospectively examine incidents during the
investigative process. The facility also utilizes individual handheld cameras, assigning one to each of the
cottages. Staff must examine and verify that the handheld cameras are fully operational before the start
of a shift. When physical intervention techniques (PIT) are required, they are able to audio and video
record the incident. The staff then reviews, the incident as a training tool to ensure they are using best
practices as prescribed in training. In addition to the cameras, after a physical intervention incident, the
youth and the staff members involved are collectively interviewed to examine ways to prevent similar
incidents in the future. The mental health unit has been redesigned to mitigate sightline issues by
removing walls and opening up the staff work area. The redesign allows staff to better supervise the
residents in that program.
As it relates specifically to meeting PREA standards, facility staff have completed the online PREA
training. PREA posters were present throughout the facility, and staff stated that they felt comfortable
responding to an incident or allegation of sexual abuse. Staff understood the zero-tolerance policy and
knew about PREA. This knowledge was tested during the general staff meeting that took place during
the assessment. Staff have taken precautions by ensuring windows and doorways to classrooms and
cottages have good lines of sight and are not blocked with posters or artwork. During the transportation
of youth, policy dictates that at least one staff must be female and that there must be, at minimum, two
staff to conduct the transport. This is consistent with best practice. The youth also indicated an
understanding of PREA and felt that they had at least one staff person they could speak with to if they
need to report an incident.
Gender-Responsive Needs: As the only YDC for young women at DJJ, it is important their unique needs
are met. There is a body of knowledge based on research and best practices that supplies a strong
foundation for working with this population. There is additional research that is specific to adolescent
women in the juvenile justice system that also informs best practice programs. Though many staff have
a strong commitment to working with female youth, most have not been exposed to the existing
30
knowledge and best practices available to the field. By providing information related to working with
females, and more specifically adolescents, staff will be better equipped to effectively manage and serve
this population.
Recommendations:



As DJJ continues to focus on this area at the Central Office and facility levels, ensure that
policies and practices are modified to meet the needs specific to young women. A more
specific recommendation on searches will be made later in this report.
Continue to work with Central Office staff charged with helping to deliver specialized
programs for young women within the agency through specific trainings, policies, and local
operating procedures that will support facilities that house females. This may also extend to
community services and the successful reentry or transition of youth to their home
communities.
Reinstate the delivery of a broad range of activities that are gender specific as well as those
that are appropriate for adolescents in general through an active volunteer effort involving
both staff and community members.
Staffing and Staff Morale: During focus groups and informal conversations, staff reported that morale
was low due to holdovers and staffing shortages, particularly for security staff. When asked in the staff
surveys about their own perceptions of emotional safety, 52% of staff said that the facility was not
emotionally safe for them. This response may be attributed to their fatigue, feeling burnt out, difficulty
in obtaining leave time (sick, vacation, earned time etc.) and/or the limitations on filling non-security
staff vacancies. Staff also indicated that they felt underappreciated and not recognized by their
supervisors.
Several updates related to staffing and staff morale were provided since the assessment. Holdovers
have been minimal due to fewer staff on FMLA and the number of security vacancies. Positive Behavior
Intervention Strategies (PBIS) have been implemented, which includes a component for staff recognition
that may help increase staff morale.
Recommendations:


Ensure that the facility develops a staffing plan as required by PREA standard 115.313
Supervision and monitoring. Based on this standard, there should be adequate levels of
staffing, including those necessary for institutional programs, and an annual review of the
staffing plan. In addition, the facility management should continue to conduct documented
unannounced rounds. Review the standard for the full list of requirements that should be
included in the staffing plan.
Consider holding Town Hall Meetings with the facility leadership and staff during or
immediately before their shifts so they do not have to be held over for extended periods of
time to attend the meetings. Ensure the facility management team is present during both
shifts to address staff needs in addition to those of the youth. Continually acknowledge staff
31


effort and positive results as they occur throughout the facility. Staff recognized and were
most supportive of those colleagues and supervisors who simply expressed appreciation for
a job well done.
Ensure middle managers are supported in addition to line staff. Consider providing
supervisory training for sergeants and higher ranks that incorporates some of the unique
needs of a female facility in addition to managing staff. The current sergeant’s academy
training is geared toward working in male facilities. This was reported as clashing with some
of the treatment and programming goals of the facility.
As a way of stimulating morale, provide staff that are forced to work longer than their
normal shift with meal breaks and bathroom breaks.
Training: Staff at Macon YDC have not received gender-responsive training to work with female youth.
According to the staff surveys, over 20% of staff felt that they had not been provided with appropriate
training and guidance to address the needs and challenges of this population. This training should
include trauma-informed care and include the PREA staff training on gender-specific issues related to
preventing, detecting, and responding to sexual abuse and sexual harassment. The Assessment Team
also identified the need for some training on addressing lesbian, transgender, or bisexual relationships,
as staff and youth indicated that youth do have relationships with one another. It is difficult for staff to
acknowledge different sexual preferences and gender nonconforming behavior within a facility; this can
be compounded by cultural or religious beliefs. Further, it was noted that, at the time of the assessment,
not all medical and mental health staff met the specialized training required in PREA standard 115.335
Specialized training: Medical and mental health care.
Recommendations:




Training should incorporate areas such as communication, adolescent development,
understanding of pathways into the criminal justice system, and trauma-informed
techniques specific to female offenders.
Ensure that medical and mental health staff receive training through a gender-responsive
lens to enhance staff understanding of the unique signs that female youth may exhibit if
they have been sexually abused and how to respond effectively to this specific population to
more fully meet standard 115.335. Also ensure that medical and mental health staff receive
the basic employee PREA training in addition to the specialized PREA training. The annual
meeting of these staff is an existing opportunity to deliver this training. Continue to
document all trainings that staff complete.
Provide specific training on lesbian, bisexual, and transgender youth, providing staff with
tools to respond productively to same-sex relationships that female youth may form while
at Macon YDC as well as to gender nonconforming behavior.
Consider providing specialized training for the facility management team specific to female
offenders, gender-responsive programming, and implications for PREA.
Reporting: PREA standard 115.351, Resident reporting requires that multiple internal reporting
mechanisms are available to youth to report an incident of sexual abuse or sexual harassment, in
32
addition to one outside method for youth to report. Although the youth felt that there was some staff
they could report to, many youth had very little confidence in the grievance system. The residents
indicated that as grievances are investigated, staff named in the grievance become aware of the
complaint and then go directly to the youth who reported the grievance in their cottage, “outing” them
in front of the rest of the youth. The girls reported that this method has deterred many of them from
using the grievance system to report sensitive issues. Additionally, at the time of the assessment, youth
were only allowed to send outside correspondence via postcards rather than letters sealed inside
envelopes, making it very difficult for them to communicate any sensitive issues to family members.
Recommendations:




Ensure that youth have access to the grievance system and the response to grievances is
confidential and credible.
To improve the credibility of the system, consider reinstating the student council to provide
recommendations to improve the system. (Update: the Student Council has been
reinstated).
Ensure that youth have access to paper and envelopes rather than postcards so they can
communicate privately to outside family members. This practice was being reviewed at the
time of the assessment and may have been modified since then. (Update: Students are able
to mail out two letters in envelopes per week in which postage is provided by the facility,
per policy).
Identify a public or private entity or office that is not part of the agency and that is able to
receive and immediately forward resident reports of sexual abuse to agency officials.
Education and Vocational Training: Many youth remain at Macon for long periods of time. After
completing high school or obtaining their GED, female residents stated that there were not sufficient
activities or programs to continue their growth and learning after school. They reported that they
continued to repeat work and programs that they had already successfully completed. Though it was
reported that some computer-based, college-level classes would soon be available, at the time of the
assessment, youth reported these systems were not yet operational. Additionally, youth did not have
many options for vocational training due to budget cuts. Keeping youth engaged and productive can
enhance the safety of the facility by reducing idle time and opportunity for negative behavior.
Recommendations:


Continue to engage the community for potential partnerships for college-level educational
or vocational opportunities; these will be most successful if based on youth interests as well
as on the current job market.
Work with Central Office female services staff to identify additional post-GED classes and
vocational opportunities that the Department could provide.
Pat-Down Searches: At the time of the assessment, staff were required to pat down the youth as youth
leave each area, as dictated in policy. The frequent number of required searches is staff intensive. When
33
observing the pat-downs, some staff conducted them as strictly outlined in policy, while other staff were
more lax or lenient in their pat-downs due to the frequency with which they were required. This caused
some inconsistencies and opportunity for youth to complain that some staff were conducting them
inappropriately (although they were following policy) compared to other staff. Additionally, the youth
who were known to often take contraband from classrooms or dining were required to have a more
thorough pat-down in a bathroom with only one staff member present. (Update: The Facility
Management has addressed this practice.)
Recommendations:



Even though safety and security is a priority for Macon YDC, the pat-down searches may be
more effective if conducted randomly rather than every time youth transition from one
space to another. This is not only a more effective way of conducting pat-down searches
from a safety and security perspective, but this method is also more consistent with genderresponsive practices, as past traumas may cause behavioral outbursts and re-traumatization
when they occur so frequently. Additionally, the practice of conducting random searches
will alleviate some of the demands on staff; yet, it still achieves the same goal.
Continue to ensure that staff receive training on conducting appropriate pat-down searches
of female youth.
Review the practice of conducting the more invasive pat-down searches for females who are
known to often take contraband. The current practice can make staff vulnerable to
allegations, as the pat-down search is done without any additional staff supervision.
Key Control and Physical Plant Vulnerabilities: As noted, Macon YDC has a good computerized key
management program; however, the keys are currently kept in C Cottage, inside the secure portion of
the facility. Further, while the mental health cottage has excellent lines of sight, the general population
cottages have limited or even poor visibility, and many of the residents’ room doors that are designed to
buzz when opened do not have operable buzzers. (Update: Those are now operable; buzzers have been
mounted into covers so they cannot be removed by students.
As noted, the facility has a good camera system; however, only seven cameras cover the five acres of
grounds within the secure fenced-in area of the facility.
Example of poor line of sight in the cottage
bathrooms, officers monitoring the
bathrooms cannot see around the wall.
34photograph illustrates part of the five-acre campus at
The
Macon YDC.
Recommendations


Best practice dictates that the spare keys and key blanks kept in Cottage C should be moved
to a more secure location somewhere outside of the secure perimeter.
Ensure that staff are aware of the poor visibility in the general population dorms and that
they modify their supervision to address these issues, especially in the bathroom areas.
Consider adding these supervision challenges to facility-specific training for new staff to
ensure they are aware of some of the physical plant vulnerabilities that exist. Document this
training.
When conducting the staffing plan, consider reviewing and documenting where current cameras are
placed and where the facility would benefit most from additional cameras to enhance supervision and
safety. Though cameras are not a substitute for good staff supervision, they are a useful tool in
supporting staff in their work.
35
Facility-Specific Report: Atlanta Youth Development Campus (YDC)
Atlanta YDC, located in College Park, Georgia, is the newest YDC in the Department. At the time of the
assessment, the facility had been open for approximately seven months. The capacity of the facility is 80
male youth. The new facility boasts an excellent camera system and brand new classrooms and facilities.
Sharon Shaver is the Director of the facility, having transferred from the Department of Corrections to
the Department of Juvenile Justice.
Facility Strengths
The facility management team exhibited a commitment and willingness to making Atlanta YDC a
successful facility. The staff at all levels indicated that they cared for the youth under their supervision
and wanted to make a difference in their lives.
Related to programming and treatment, the Assessment Team identified strengths in the areas of
medical, education, social services, and programming. Medical services are comprehensive and
delivered by very experienced staff. The medical clinic provides services 13.5 hours per day, seven days
a week. The clinic is fully staffed, with all nurses having ten or more years of experience. Medical
services include assessments, on-site, weekly, physician-provided medical/dental/psychiatric care, sick
call, and medication administration. Forensic examinations are available at Grady Hospital. Other
medical services are available at Scottish Rite Children’s Hospital. Medical and mental health service
providers meet monthly as a treatment team. This meeting is also an opportunity for quality assurance.
Medical service providers do receive and
respond to parental complaints.
Education was identified as a strength by
staff and the youth at the facility. The selfpaced CAPS and GED courses provide youth
with a sense of progress. The classrooms are
new and provide a positive learning
environment. The Assessment Team
observed teachers engaging the youth and
providing necessary support.
The Assessment Team observed positive
evidence-based program models for traumafocused Cognitive Behavioral Therapy (CBT) and specialized groups based on youth needs. Atlanta YDC
has a number of specialized programs and groups that are available to youth, 47% of whom are
identified as needing specialized treatment. In addition to DJJ mental health and social services staff, the
facility has weekly consultant services from a psychiatrist and part-time staff that offer family and
substance abuse counseling. Most services are provided in groups; individual counseling is available as
needed. There is a sex offender treatment program that occurs twice weekly in a small facilitated group.
36
Atlanta YDC also provides special management plans with youth to inform housing and education
assignments. These plans also provide security staff with clear “early warning signs” and strategies for
prevention and early intervention as well as for crisis management. The plans are available in the
Control Center and are reviewed at shift briefings. This is an excellent practice to achieve desired youth
behavior and outcomes, particularly those related to youth safety.
The intake and assessment process is a strength at Atlanta YDC. The medical assessment that is required
to occur within 24 hours of intake is most often completed within two hours. The HIV B questionnaire
does ask about prior sexual victimization and abuse; all reported abuses are reported to Department of
Children and Family Services (DCFS) and as an incident report. Because arriving youth have spent time at
other DJJ facilities, they have been previously tested for STDs. As a result, they are only tested if they are
experiencing symptoms. The mental health assessment is completed in accordance with DJJ policy
expectations. The intake and assessment process occurs within a designated area of the facility. This
area provides a unique opportunity for staff to interact with youth and set the stage for their placement
at Atlanta YDC.
Operationally, Atlanta YDC has an advanced
camera and monitoring system, unique from
other facilities in the Department. The facility
has very few blind spots, and the facility staff
has done an outstanding job in identifying
the areas of vulnerability. They utilize 162
cameras and actively monitor those in a
separate internal Central Control Unit. All
other Control Center functions, such as
managing and distributing keys, are
relegated to the lobby Control Center. The
camera system is now being used as a model
for other facilities.
The movement of youth is secure and organized, and safety is enhanced through single cell housing for
each youth. Staff and youth reported that youth are able to shower separately and one at a time,
consistent with recommended best practice. Though gang activity was a concern for many staff when
Atlanta YDC first opened, the staff have been
able to minimize gang activity. During our tour,
Of the staff surveyed, 96% agreed or strongly agreed
the Assessment Team did not observe gangthat they received training on how to respond to
related groupings, colors, activities, or graffiti. incidents or allegations of sexual abuse or harassment.
There were posters along the dining hall and in Of the staff surveyed, 91% agreed or strongly agreed
that they were comfortable in being the first responder
education with anti-gang messages.
to an allegation of sexual abuse.
Staff have taken the online PREA training and
understand their responsibilities under the
law. Youth knew about PREA and received
37
updated youth orientation. This occurs during education as part of a statewide effort to ensure all youth
received the required PREA information.
Culture Collision: Originally, this facility was slated to be for the “worst of the worst” kids in the
Department. The mission later changed, and the facility was identified as a transitional facility to serve
Atlanta-based youth. At the time of the on-site visit, the Assessment Team observed clear divisions
among different groups of staff within the facility. Some of the divisions were between security and
program/treatment, while other divisions existed within the ranks of line staff that had come from other
facilities in neighboring areas. The culture collision has resulted in a lack of clarity around the facility’s
mission. It was reported by youth that staff were not consistent and had different expectations; some
youth described it as “staff not knowing what they are doing.” It was reported by staff and observed by
the Assessment Team that a mixture of practices stemming from staff’s past experiences at RYDCs,
YDCs, and adult corrections has also contributed to the uncertainty around the mission of Atlanta YDC.
Recommendations:



Engage the facility management team in strategic planning to outline goals and mission of
the facility as a team.
Conduct Town Hall Meetings with staff to reinforce the direction, mission, and vision of the
facility and allow staff the opportunity to engage in discussions with the facility leadership.
Continue to encourage teamwork and positive communication among program/treatment
staff and security staff. This was identified as a challenge by a number of staff in the staff
surveys.
Reporting Culture: Sensitive issues involving
sexual abuse and sexual harassment are
very difficult for most people to report. This
is even truer in confinement settings,
particularly in settings that house young
men. The Assessment Team consistently
heard from youth that they would not
report an incident of sexual abuse or
harassment if it included another youth,
rather they would “take care of it
themselves.”
Staff surveys indicated that 27% of staff disagreed or
strongly disagreed that youth report incidents of
sexual abuse or harassment if they see or hear about
them.
Conversely, only 34% of staff strongly agreed or
agreed that youth reported incidents, while the
remainder of respondents circled not applicable.
Recommendations:

Continue to support a positive reporting culture by ensuring staff are fully trained on how to
receive reports and that youth have access to an outside entity to report any allegations of
sexual abuse or harassment.
38


Consider engaging youth in a discussion around what can be done to improve the grievance
system through the Town Hall Meetings.
Continue to promote a positive reporting culture for staff as well. This can be done by
reinforcing the zero-tolerance policy, ensuring staff are trained on the reporting process at
the facility, and that staff have a method to privately report sexual abuse or harassment of
youth, per PREA standard 115.351 Resident reporting.
Education and Programming: Current educational offerings were identified as a strength at Atlanta YDC.
However, staff and youth both identified that upon completing the CAPS and GED program, there is a
lack of alternative programming or vocational training available for youth to participate in during the
day. The Assessment Team observed at least one youth who had completed his education standing in
the hall, because he had nothing else to do and nowhere to go. At the time of the assessment, the
facility leadership was working on providing some of these services. From a PREA perspective, youth
who are engaged and invested in programming are less likely to engage in negative behavior.
Recommendations:


Utilize resources in the metro-Atlanta area by reaching out to local universities and
community colleges to provide college-level classes, vocational training, or other programs.
Continue to engage the community for volunteers and programming that is age appropriate
and focused on life skills and career building to help prepare youth for reentry back into the
community.
Key Control: Key control at the Atlanta YDC is
in keeping with sound security practices.
Personal keys are not allowed into the facility,
and restricted keys are maintained in
separate boxes in the outer Control Center,
which is consistent with procedures for the
Department. However, the Assessment Team
observed some challenges around key control
management. The facility does not have an
automated key management system to track
and inventory individual keys and key ring
sets. An automated key system would help
the key control staff instantly identify which
keys open which doors and it would identify the sets and which staff they are assigned to. Also an
electronic key watch system would provide better management and monitoring of key distribution.
From a PREA perspective, key management is critical to reducing access into isolated areas and
mitigating false allegations of misconduct. At the time of the assessment, spare keys and key blanks
were kept in a closet in the administrative hallway. An automated system (purchased or facility
developed) would help the facility to be better organized overall but especially with regard to its key
system.
39
Recommendations:


From a PREA perspective and facility management perspective, ensuring that keys are
managed consistently is critical to safety. Consider reviewing where spare keys and key
blanks are kept and reducing accessibility.
Ensure that all key and tool control is well organized and that the policy and practices are
understood and reinforced at the facility level.
40
Facility-Specific Report: Metro Regional Youth Detention Center (RYDC)
Metro RYDC is located in Atlanta, Georgia. The facility has a capacity of 200 youth—150 males and 50
females. Youth are intended to reside for short-term stays at Metro RYDC. Youth held at this facility are
either awaiting trial or they have been adjudicated and are awaiting placement in a YDC. During the time
of the assessment, construction was underway to enhance the medical and educational areas. Since the
assessment, Debbie Alexander has replaced Director Robinson as acting Director.
Facility Strengths
The Assessment Team observed a strong management team committed to Metro RYDC’s mission and to
helping the youth. Many members of the facility management team had worked for DJJ for a number of
years; overall the facility has experienced, specialized practitioners and leaders. The Assessment Team
observed positive interactions between staff and youth, and a staff that exhibits appropriate language
and responses to youth. Leadership, including management, mental health, and counseling, were
observed to be visible during all meals and major youth movement. Staff stated consistently during
focus groups, interviews, and informal conversations, that they felt supported by their immediate
supervisors and that the facility leadership was present and visible throughout the facility.
Medical and mental health services exceed those available to youth in the community and are a strength
for Metro RYDC. Medical and mental health services receive support from nearby Grady Hospital. Metro
RYDC has an agreement with Grady to conduct all forensic medical exams, which includes support from
the county Rape Crisis Intervention Department for follow-up services. Additionally, there are
experienced medical and mental health staff within Metro RYDC that provide a strong foundation in
these areas.
Medical services include a health assessment, physical examinations, a mental health nurse to support
psychiatric and chronic mental health care, sick call, medication administration, and dental assessments
and acute treatment. Approximately 25% of the population at Metro RYDC is on the mental health
caseload. In addition to mental health screening of all youth, mental health services provide assessment,
individual and group counseling, psychiatric services, and crisis intervention. In both medical and mental
health service delivery, the Assessment Team observed a strong system of services. However, this
system is challenged by a significant workload associated with timeframes required for all new intakes,
the size of the facility population, and additional requirements for youth that are awaiting placement in
a YDC or requiring chronic care. Staff reported that security and non-custody staff work very well
together, stating that they make a concerted effort to support one another in their roles to meet the
mission of the facility and the needs of the youth.
The Assessment Team also observed the intake and assessment process for youth as a strength at Metro
RYDC. The process is comprehensive and includes medical, mental health, and education screening in
the Intake Unit. A health assessment, which includes a review of past traumatic experiences, is
completed within the first 24 hours. This is particularly challenging when the number of new intakes
41
exceeds the scheduled coverage. Mental health assessments are completed based on the results of the
Intake Unit screening; mental health staff are available on an on-call basis around the clock. Both
medical and mental health staff address issues during the intake process that are related to sexual
exploitation in the community. The Assessment Team observed a professional and collaborative
relationship among security staff in the Intake Unit. Medical and mental health staff and management
not only complete the intake and assessment process within agency timeframes, but are also responsive
to the anxiety and behaviors of youth that were apparent throughout the process. It is noteworthy that
youth could clearly articulate the intake and assessment process and reported that it included their
rights and responsibilities and “how to report allegations and to get help.” This is consistent with PREA
standard 115.333 Resident education, part (a).
As it relates to facility operations, the physical plant was undergoing some updates at the time of the
assessment. There are 128 cameras, which are monitored in the Central Control Unit. There is generally
good placement of cameras within the facility. The Central Control Unit is also responsible for key
distribution, front gate operations, and electronic door access into the wings. Key control is conducted
in a manner consistent with departmental policy and is well managed. Youth are housed in single
cells/rooms, which is a positive practice that helps to diminish inappropriate behavior. The only
exception to this was the temporary placement of youth in recreation areas while units were being
painted. The facility had carefully considered which youth would receive these temporary assignments.
At the time of the assessment, the facility had recently reduced the number of youth being moved or in
a single area at one time. Staff felt this improved safety and security at the facility. As will be noted later,
this change has had unintended impacts on staff and program schedules.
The facility is implementing a number of
positive practices consistent with meeting PREA Results from the staff surveys indicated that only
8% of staff disagreed that the prevention of
standards. The leadership team has been
sexual misconduct and abuse is openly discussed.
thoughtful about the facility renovations,
indicating where cameras were going to be
placed, as well as considering lines of sight and
appropriate supervision to ensure the safety of youth. This is consistent with PREA standard 115.318
Upgrades to facilities and technologies. The contracted maintenance staff has been trained on PREA as
well as the volunteers who work with the youth. Documentation is maintained to keep track of these
trainings consistent with PREA standard 115.332 Volunteer and contractor training. Overall, there has
been an intentional effort to have program, security, and support areas work together to improve
culture and to ensure sexual safety of youth.
The youth have received appropriate orientation on PREA, and the parents of the youth receive
pamphlets on how to report concerns while their youth is at Metro RYDC. The unit mangers occasionally
attend weekend visitation to talk with family members and parents of youth to ensure they are aware of
the services and ways to communicate concerns at Metro RYDC.
At the time of the assessment, the facility PREA Compliance Manager had only been recently assigned to
the role, however, she was clearly enthusiastic and dedicated to learning more about the facility’s
42
obligations under PREA. The PREA Compliance Manager ensures that the grievance box located on each
unit is checked twice every day. Youth knew how to report issues, including those related to PREA, and
knew who checked the grievance boxes. If youth did not want to utilize the grievance box, they also had
access to the Director’s box and could speak directly with the Psychologist or Unit Directors as well as
the Assistant Director. Youth felt that the grievance system was credible and that they had at least one
staff member they could trust to report sensitive information. The access to multiple reporting
mechanisms is consistent with PREA standard 115.351 Resident reporting, part (a).
Staffing and Staff Morale: Maintaining appropriate custody staffing levels and qualified mental health
staff were identified by staff and the facility management team as the most critical challenges facing the
facility at the time of the assessment. There was a concerted effort to hire staff. However, as quickly as
staff are hired, staff are also leaving. Several factors may contribute to high staff turnover including the
facility’s close proximity to Atlanta, where staff may find higher paying jobs. In addition, the vicious cycle
of new staff immediately having to be held over, leading to staff burnout and resignations.
Compensation is higher for mental health staff, both for comparable community positions and for JDC
staff. During the Assessment Team’s time on site, an entire shift was required to be held over for a third
shift, due to staff taking sick leave or just not showing
up for their shift. Several personal cars had been
Staff surveys indicated that approximately 37% broken into during the assessment process, which
of staff strongly disagreed or disagreed that the
was identified as a specific reason for staff not
facility was emotionally safe for staff.
showing up for their shift. These staffing issues were
impacting morale at the time of the on-site
assessment.
The low morale could be due in large part to the holdovers and the resulting stress and mental fatigue
that can occur when staff are working 16 hours in a day. As it relates to mental health staff, many staff
were gaining valuable experience and receiving the professional supervision required for licensure while
working at Metro for a year or two and then leaving for higher paying jobs elsewhere. Leadership at the
facility was clearly aware of this issue during the assessors’ time on site and was working to address the
staffing levels. The staff also identified that the overall stress of these constant holdovers was creating a
facility environment where staff tended to become impatient with one another, as well as with the
youth.
Recommendations:

Though the leadership at the facility was aware of the morale issues related to staffing, the
Assessment Team heard from staff in focus groups and during informal conversations that
there are several ways the leadership team can mitigate this challenge. While staff
expressed that they would appreciate better pay and overtime pay, they were equally
interested in such things as receiving a greater expression of appreciation and respect,
incentives for those staff who are reliable and consistently come in for work, breaks for staff
43

that work 16 hours straight, and positive and open communication with the leadership team
so that staff can air their concerns and issues. During the assessment, the team did observe
that unit directors were especially engaged with staff, even working side by side during a
sprinkler release. But, staff expressed a desire for even more opportunities for positive
interaction with them, especially with the Director and Assistant Director.
As directed in PREA standard 115.313 Supervision and monitoring, develop a staffing plan
that provides adequate levels of staffing. The staffing plan should also include, where
applicable, video monitoring to protect residents against sexual abuse. In calculating
adequate staffing levels and determining the need for video monitoring, facilities shall take
into consideration:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Generally accepted juvenile detention and correctional/secure residential practices
Any judicial findings of inadequacy
Any findings of inadequacy from federal investigative agencies
Any findings of inadequacy from internal or external oversight bodies
All components of the facility’s physical plant (including blind spots or areas where staff
or residents may be isolated)
The composition of the resident population
The number and placement of supervisory staff
Institution programs occurring on a particular shift
Any applicable state or local laws, regulations, or standards
The prevalence of substantiated and unsubstantiated incidents of sexual abuse
Any other relevant factors
An additional challenge to compliance with this standard at Metro RYDC is that the exceptions to the
current staffing plan have become the norm.
Master Schedule, Programs, and Activities: While assessors were on site, the facility was implementing
the agency-wide master schedule and reducing the number of youth that could be moved at one time or
be present in a general area together at one time. In some ways, this has increased security by
controlling movement with fewer youth. However, this has also exacerbated some of the challenges
related to adequate activities and programming offerings for the youth at Metro RYDC. Though Metro is
designed for youth to stay only a short period of time, as in the other assessed RYDCs, this is not always
the case.
Many youth are staying for extended periods of time waiting for placement. Some youth spend their
entire sentence in the RYDC without ever stepping foot into a YDC. This challenge creates a larger
demand for staff to provide adequate programming and activities for youth who are staying for long
periods of time. This challenge, as noted earlier, has been exacerbated by the requirements of the
master schedule and restricted movement, where only ten youth can come out of their cells at one time
in the common room or to go to recreation and the dining room. That means that while half of the
youth population is out of their cells, the other half is forced to remain in their cells. This restriction of
44
free time in the dayroom can be particularly challenging for youth who are remaining at Metro for
longer periods of time or who have mental health issues. This restriction also impacts who can have
access to programs and activities, as there are limited numbers now for how many youth can attend a
program or volunteer-led activity. Additionally, there is generally a lack of programming to meet the
needs of the youth at the facility. This is creating idleness after school, resulting in additional stress on
youth and staff. Both youth and staff interviews identified youth engagement in positive programs and
activities as a critical factor for both safety and culture.
Further, there is a particular need for gender-specific programming to be provided for the female youth,
as well as a focus on youth in general who need to address trauma. This is particularly true for the youth
who remain at Metro for longer periods of time.
Recommendations:




Consider collaborating with Central Office on identifying facility-specific alternatives related
to the restricted movement and master schedule that can more fully meet some of the
unique needs of Metro RYDC.
Engage the Central Office female services staff person to provide some gender-specific
programming for the female youth housed at Metro RYDC.
Collaborate with the volunteer coordinator at the facility to develop some creative ways to
provide additional activities and services to youth. Continue to engage the participation of
volunteers that can provide a variety of programs for the youth.
Identify youth who remain at Metro for an extended period of time and consider ways to
provide meaningful programs to them in way that can meet some of their unique
rehabilitation needs.
Data Collection and Review: There are several standards related to data collection and review of data to
enhance sexual safety. Data review can be a valuable tool to continue to improve operations and safety
and security. Though appropriate data are being collected and reported to Central Office, the interviews
and focus groups with staff indicated that the data may not be fully utilized at the facility level.
Recommendations:


Ensure that the facility is satisfying the requirements of PREA standard 115.386 Sexual
abuse incident reviews. In part, it states that the team reviewing these data should include
not only the facility leadership, but also input from supervisors and non-custody staff.
In addition to reviewing incidents directly related to sexual abuse, consider reviewing
disciplinary reports, grievances, and incident reports to further enhance safety and
operations. When analyzing these data, it is recommended that, in addition to reviewing
what the report is about, the reviewer also notes the time of day, the location of the event,
the staff involved, and the youth involved to discern trends that may be informative.
Document these efforts and any recommendations or resulting changes made in response
to the data analysis.
45
Reporting: The Assessment Team observed that youth do understand and have full access to the
grievance system at Metro RYDC. However, it was reported that youth cannot file a grievance on behalf
of another youth. Though there are practical reasons for this rule, PREA standard 115.351 Resident
Reporting, part (c) states that staff shall accept reports made verbally, in writing, anonymously, and
from third parties and shall promptly document any verbal reports. Informally, it appeared that any
grievance would be addressed; however, it should be made clear that third-party grievances related to
sexual abuse should be accepted.
Recommendation:

Third-party reports, including grievances from one youth on behalf of another youth that
are related to sexual abuse and sexual harassment, should be accepted to adequately satisfy
this standard. This pertains to only those grievances related specifically to sexual safety, not
all grievances. Continue to document all youth grievances, even those that are resolved
informally.
Housing Placement: At the time of the assessment, most youth were placed in dorms that had available
bed space. Though a screening is completed at intake, there was not any indication that the screening
informed housing and bed assignments. The total population of the facility was reported to be the most
critical factor in these assignments.
Recommendation:

To more fully satisfy the requirements in standard 115.342 Placement of residents in
housing, bed, program, education, and work assignments, consider formalizing the dorm
and cell/room assignment process so that information gathered from the screening and
assessment at intake is more fully utilized.
Physical Plant Modifications: As mentioned previously, the facility was undergoing major renovations
and new construction. There were thoughtful plans to determine appropriate supervision and camera
monitoring in the newly constructed areas.
Recommendation:

Ensure that the facility is incorporating the requirements of PREA standard 115.318
Upgrades to facilities and technologies, which states “When designing or acquiring any new
facility and in planning any substantial expansion or modification of existing facilities, the
agency shall consider the effect of the design, acquisition, expansion, or modification upon
the agency’s ability to protect residents from sexual abuse. (b) When installing or updating a
video monitoring system, electronic surveillance system, or other monitoring technology,
the agency shall consider how such technology may enhance the agency’s ability to protect
residents from sexual abuse.” The Assessment Team heard verbally that the facility
leadership and construction company were taking the above issues into account. However,
46
in preparation for facility audits, assessors recommend that the facility also clearly
document these considerations to help satisfy the standard.
Operations: The Assessment Team made several observations related specifically to facility operations
that could enhance safety. First, access to the facility is gained through a reception lobby. There is a
metal detector just inside the administrative corridor, which means that a person has to enter this
administrative corridor before being screened. Secondly, the Key Control Officer was transferred to
another facility and was orienting the new Key Control Officer to her new tasks. The key inventory,
although maintained per policy, was done so manually. The activities in the Central Control Unit are
extremely hectic, especially during youth movement and shift changes. The key exchange process,
especially with restricted keys, can be cumbersome and time consuming, which leaves little to no time
to monitor cameras.
Finally, related to staffing and operations, the facility custody staff are scheduled to work 8-hour shifts
(6:00 am - 2:00 pm, 2:00 pm - 10:00 am, and 10:00 pm - 6:00 am). Three 8-hour shifts require more staff
than two 12-hour shifts. Longer shifts also allow more overlap and communication between shifts.
Recommendations:



If the facility wishes to have staff and visitors screened before they enter the administrative
corridor, the metal detector and screener should be positioned in the lobby, just outside the
solid door. If the intent is to screen individuals prior to entering the secure portion of the
facility, the screening station could be moved closer to the main sally-port, reducing the
congestion that takes place during shift change.
As resources allow, for a more accurate accounting of keys, keysets, doors, and staff key
assignments, the key inventory could be automated. There are some very good off-the-shelf
programs available, or the agency can choose to develop its own electronic system. Utilizing
an electronic key watch distribution system that allows staff to draw keys using pin numbers
would help maintain an accurate accounting of key use, including who draws keys and the
times that keys are drawn and returned. This would aid not only in conducting investigations
of alleged staff sexual abuse but in freeing up Control Center staff to better monitor
activities in the facility via the CCTV system.
Although running 8-hour shifts affords staff shorter workdays, with staff shortages and the
inability to retain staff, the facility may consider the 12-hour shift model adopted by other
DJJ facilities. The 12-hour shift schedule requires approximately 11.1% less staff than the
traditional 8-hour shifts and provides staff alternate weekends off. The schedule change
could positively impact weekend call-ins, as staff would not have to wait seven weeks for a
full weekend off. If this change is made, the facility may also consider tracking the number
of call-ins and 16-hour shifts.
47
Facility-Specific Report: Eastman Youth Development Campus (YDC)
On-Site February 18-20, 2013
Eastman YDC is located in Eastman, Georgia. It is a long-term male facility with a capacity of 330 youth
and an operational capacity of 256, currently capped at 200 due to staff vacancies. The facility was
originally opened in 1993 by the Georgia Department of Youth Corrections for “Heinous Juvenile
Offenders.” In 1997, Eastman was converted to a YDC under the DJJ. As a YDC, long-term youth receive
education, program, and vocational offerings. Eastman has been informally designated as managing
some of the toughest youth under supervision at DJJ. David Frazier is the Director at Eastman YDC and
served the majority of his career with the Georgia Department of Corrections prior to accepting the
Director position at Eastman.
Facility Strengths
There are a number of strengths identified by the facility staff as well as the Assessment Team to
support the mission of the facility and to promote sexual safety. Staff indicated that, even though they
are responsible for housing some of the toughest youth, many staff do care about the well being and
success of youth. Staff agreed that they were doing a good job maintaining order in such a difficult
environment. The Assessment Team heard through focus groups and informal conversations that staff
morale was generally improving since the new leadership took charge of the facility. The staff reported
feeling supported by leadership, creating a more positive working environment for many staff.
Youth are housed in single rooms, mitigating the risk of inappropriate behavior during sleeping hours.
The staff observed positive education and GED classes. When youth are engaged in the high school and
GED class offerings and attending classes in the education building, they are receiving excellent services.
Staff identified that the recreation program is well run and engaging for youth; the Assessment Team
verified this observation. Vocational training classes are available to some of the youth through Oconee
Fall Line Technical College. The current offerings include horticulture, auto tech, carpentry, and
computers.
Experienced and well-qualified staff provide mental health services to the youth. A full-time psychologist
and licensed social service providers support the mental health needs of youth. The facility has the
personnel and capacity to deliver several programs, including sex offender counseling, substance abuse
treatment, victim impact groups, Thinking for a Change, and SEALS. Many of the youth have received
SEALS and victim impact at the RYDC; both youth and staff perceive these programs to be repetitive and
not contributing to the youth’s progress. Medical services include assessments, annual physical exams,
sick call, and referral for special consultations when needed, dental services, psychiatric services, and
medication administration. It is noteworthy that the current psychiatric provider is reviewing the
reasons for prescribing psychotropic medication to youth. The result is a significant reduction in the use
of these medications for anything other then psychiatric disorders. All medication is crushed prior to
administering it.
48
The intake process at Eastman YDC is viewed as a strength. One sergeant is assigned as the intake
officer. This individual completes all initial screening of youth. Every resident receives an initial mental
health screening within two hours of being admitted on campus. All staff are trained on administering
the mental health screening in case youth are admitted during “off-hours.” A counselor completes the
orientation of youth and provides all required information to them, including PREA. The medical and
intake unit were currently being renovated and expanded during the Assessment Team’s time on site.
The facility leadership is addressing supervision and monitoring in the newly renovated areas to help
meet PREA standard 115.318 Upgrades to facilities and technologies.
Facility staff reported an improved working relationship between security staff and program and
treatment staff. This is a critical relationship that, when working well, supports the mission of the facility
and enhances safety. There are many experienced and reliable staff working at Eastman. At the time of
the assessment, there was reported to be minimal vacancies and minimal use of sick leave.
The facility utilizes 12-hour rotating shifts with every-other weekend off. There are four keys with an
average of 30 to 33 staff per key, and the Chief of Security ensures that the keys are balanced. There are
currently 185 cameras in the facility with motion detection capabilities and 14 monitors in the Central
Control Unit. The facility conducts shift briefings with staff inspections 15 minutes prior to the beginning
of each shift. During the briefings, the officer in charge and the Sergeant update the staff on any
important events or policy changes.
Staff are aware of PREA and the zero-tolerance policy, and they understand their responsibility to report
allegations of sexual abuse. Youth are also generally aware of PREA. There are many posters visible
related to reporting PREA incidents. Mental health staff are scheduled to receive trauma-informed
training, which will complement the specialized training requirements under PREA standard 115.335
Specialized training: Medical and mental health care.
Facility Culture and Culture Collision: An interesting phenomenon has occurred at Eastman YDC in that
there is a unique acceptance of many Department of Corrections (DOC) staff that have recently
transferred to the Department of Juvenile Justice. Often, when adult correctional staff transfer to
juvenile justice and vice versa, there is a lack of acceptance of the different models. This was not
observed to be the case at Eastman. Rather, due to some of the challenging behavior and sense of chaos
that was once a daily reality at Eastman, many staff have welcomed the “DOC approach” to supervising
youth. The result has been a mixture of adult and juvenile approaches that can sometimes be
counterproductive when working with the juvenile population.
49
Additionally, because Eastman typically houses older youth, many staff see these youth as adults that
should be treated more like adult inmates. Meanwhile, other staff are working to address adolescent
needs and behaviors. This culture collision identified by the Assessment Team was not restricted to
security or program staff. Rather, it was a collision of broader ideas about which approach to take in
managing youth behavior. For example,
at time of the assessment, a recent
Results from the staff survey indicated that approximately
youth assault against a mental health
53% of staff disagreed or strongly disagreed that Eastman
staff person had reinforced the notion
was a physically safe environment for staff.
of a need for more consequences and
stricter discipline for youth. This
situation created a stronger impetus for
an “adult model.”
The impact of the lack of incentives and positive reinforcement seems to be profound, as youth are
engaging in many negative behaviors that promote the staff view that youth need to be more tightly
controlled and held more accountable. Recent research specific to this issue states:
If designed and implemented in a
developmentally informed way,
Results from the staff surveys indicated that
procedures for holding adolescents
nearly 35% of staff disagreed or strongly
accountable for their offending, and
disagreed that Eastman was a physically safe
the services provided to them, can
environment for youth.
promote positive legal socialization,
Nearly 75% of staff disagreed or strongly
reinforce a pro-social identity, and
disagreed that youth treat staff with basic
reduce reoffending. However, if the
respect.
goals, design, and operation of the
juvenile justice system are not
informed by this growing body of
knowledge, the outcome is likely to be
negative interactions between youth
and justice system officials, increased disrespect for the law and legal authority, and the
reinforcement of a deviant identity and social disaffection.2
Recommendations:

Develop alternative, age-appropriate recreational and program-specific activities to reduce
idleness, to help keep youth engaged, and to prepare youth for reentry. Creating a system
of age-appropriate incentives for the youth should also help to counterbalance the
disincentives that the behavioral management unit or the Special Management Unit (SMU)
offers. This could also help address adverse behavioral issues related to boredom and
2
National Research Council. (2012). Reforming Juvenile Justice: A Developmental Approach. Committee on
Assessing Juvenile Justice Reform, Richard J. Bonnie, Robert L. Johnson, Betty M. Chemers, and Julie A. Schuck, Eds.
Committee on Law and Justice, Division of Behavioral and Social Sciences and Education. Washington, DC: The
National Academies Press.
50


idleness. Some examples of programming include additional recreation, vocational training,
and community college classes for post-GED students.
Review the utilization of education resources for youth. It was reported that only 44 of the
facility’s 192 youth were attending general school. The remaining youth were either in BMU
or had received their GED. Two special education-certified teachers are assigned to BMU to
provide educational services for special-education youth. However, those youth continue to
be enrolled in the general education program. Consider ways to better utilize special
education staff for youth, as they appear to be under-utilized and can be an excellent
resource to augment youth programs at Eastman YDC.
To address some of the personnel challenges, consider engaging Central Office staff that
oversee mental health and programming to help design facility-specific incentive programs
for youth and training for staff on adolescent development and appropriate responses. It is
recommended that this be done as a collaborative effort and that it engage facility
leadership as well as mental health and social services staff.
Master Schedule: At the time of the assessment, the facility had just started to implement the agency’s
master schedule. Staff reported frustration over the implementation of the master schedule; the
number of youth and size of the facility make it very difficult to follow the schedule as intended. Staff
reported that, prior to implementing the schedule, the facility had more flexibility to help youth make
appointments, receive haircuts, and participate in recreation and programming. Though this identified
issue is not directly related to a PREA standard, it nevertheless impacts staff morale, youth access to
certain programs and activities, and the overall environment and perceived safety of the facility.
Recommendation:

Engage Central Office in collaboration with facility leadership to discuss potential options to
modify the master scheduleto meet some of the specific needs of Eastman YDC, such as ageappropriate activities for all youth at the facility, movement after dark, and staff scheduling
issues.
Behavioral Management Unit/ Exposure: At the time of the assessment, Eastman staff were facing
many challenges related to youth exposing themselves to staff, particularly female staff. The Assessment
Team observed frustration over a lack of response or consequences for the youth involved in the
behavior. Staff were utilizing the BMU as one sanction for such behavior, however, it did not seem to
deter youth from continuing the behavior while in the BMU. Interviews and informal conversation with
youth indicated only negative behaviors receive the attention of staff, so youth engage in such behaviors
to receive some form of attention. After further conversation, staff reported that youth often target
newer staff to test them. Additionally, some of the youth housed in the BMU throw feces and urine at
staff and flood their cells. While on site, the Assessment Team also learned that an SMU is being
developed.
51
Recommendations:

The facility has anecdotal information regarding the youth who expose themselves to staff
and the staff to whom this occurs. As prescribed in PREA standard 115.387, we recommend
that the facility utilize data that they currently collect in order to analyze the instances of
exposures and help formulate targeted data-informed intervention strategies.
Programming/Activities: The Assessment Team heard reports from staff and youth that there is
significant youth idleness. This is due in part to budget cuts that have reduced vocational training. Youth
idleness and boredom often leads to negative behaviors and acting out. From a PREA perspective, a lack
of activities provides greater opportunities for misconduct and diminished safety to include sexual
safety.
Recommendations:




Structure, accountability, and consequences—when integrated with programming,
incentives, and skill development (all of which should be age and developmentally
appropriate)—constitute good corrections practice for adults and juveniles.
Expand program options so that youth do not repeat programs they previously received at
the RYDC, unless youth do not demonstrate a mastery of skills taught through those
programs.
Provide youth with tools for adult living, including employment and social skills.
Continue to engage the community and volunteers to help fill some of the programming
gaps.
Operational Considerations: Though there are 185 cameras at the facility, the Assessment Team
observed some blind spots and physical plant challenges. The facility management team has done a
good job identifying and trying to mitigate those blind spots through staff awareness and, where
possible, cameras. The renovation in the medical and intake unit includes a plan for some additional
cameras and mirrors. The DVR recording system is analog rather than digital, therefore, it only has a 14day recording capability, making it challenging to review reported incidents after two weeks.
It was difficult to assess the facility’s key management system; at the time of the assessment, the Key
Control Officer was not at work. Thus, information on the system was limited.
Recommendations:


Ensure that the facility adheres to the plan of updating cameras in the new construction
areas and the DVR recording system to a digital one with longer recording capabilities. To
more fully meet PREA standard 115.318 Upgrades to facilities and technologies, ensure
that documentation can be provided for these physical plant changes.
There is no indication that the facility has an automated key management system to track
and inventory spare keys and blanks. Update the key management system. For example,
52

consider investing in an automated system that cross-references keys, doors, keys sets, and
staff key assignment.
Develop standardized training for both the primary and secondary key control staff to
ensure the adoption of uniform, consistent knowledge of practices related to key control in
the facility.
Reporting: Although there is a grievance system in
Staff surveys indicated that approximately
place, the Assessment Team received mixed
35%
of staff disagree or strongly disagree that
responses on the effectiveness of the system.
youth report incidents of sexual abuse when
Some youth reported that they used it and found
they see or hear about them.
it credible, while others did not. Additionally,
youth indicated that they did not feel there was a
staff person to whom they particularly felt
comfortable reporting sensitive issues. Rather,
they preferred to “take care of the situation
themselves.”
Recommendations:



Continue to communicate to youth about the grievance system and the different ways they
can report issues.
Continue to promote a positive reporting culture among youth and staff to diminish any
opportunity for sexual abuse or for an incident going unreported. Ensure the grievance
system is perceived as credible by providing timely and fair responses to youth.
Ensure third parties have a way to report allegations of sexual abuse or harassment to the
facility. This could include third-party reports from youth or a parent or guardian contacting
the facility to report an incident. Refer to PREA standard 115.351 Resident reporting for the
full reporting requirements.
Training: The facility has dedicated and
experienced trainers to help implement required
Approximately 16% of staff who responded to
trainings for facility staff. With the additional
the staff survey disagreed or strongly
disagreed when asked if they had been
administrative building completed, training occurs
provided with appropriate training and
on campus outside the gate, which is extremely
guidance to address the needs and challenges
convenient for staff. Some additional training
of this population.
needs were identified by staff and the Assessment
Team during the on-site process to help work with
the population and continue to effectively prevent,
detect, and respond to sexual abuse.
53
Recommendations:



Work with facility training staff to integrate more of the security and program staff into
training together. This cross-section of staff can lend to differing perspectives and richer
dialogue when training is conducted in a more diverse group. Additionally, staff gain a better
sense of what staff in other positions are trying to accomplish.
When DJJ is ready with this, incorporate the LGBTI training for staff. Ensure areas such as
appropriate communication and searches are included in the training.
Utilize the mental health staff and psychologist to provide training to custody staff on youth
trauma and adolescent development, addressing how these issues can impact custody
staff’s jobs and responses to situations.
54
Conclusion
In considering next steps, The Moss Group encourages the Agency PREA Coordinator to engage the
agency leadership and PREA Steering Committee to prioritize approved recommendations and develop
action plans.
DJJ is implementing many promising practices to work towards PREA compliance. It is clear from the
assessment process that PREA is an agency priority. The efforts in place seem to be addressing standards
currently, as well as creating systems that can be sustained for the long term. For example, PREA has
been integrated into DJJ’s strategic plan and assigned a budget for future efforts. For these reasons and
as a result of the facility assessments, the Assessment Team is confident that DJJ is moving in a positive
direction towards PREA compliance. The challenge moving forward—particularly during a time of reform
and competing priorities—is ensuring that PREA continues to be more than a “checklist,” but instead
becomes, “a way to do business” as an agency.
55
Appendices
56
Appendix 1
DJJ PREA Accomplishments
57
PREA Accomplishments
TMG wanted to highlight some of the many PREA efforts that are completed or underway at DJJ.
Throughout the assessment process the agency continued to address PREA and remains extremely
proactive. The Assessment Team was impressed with the thoughtfulness and responsiveness of the
Agency PREA Coordinator and Agency Leadership in maintaining the momentum of this work. These
areas highlighted below are of note because they are promising practices in PREA implementation and
are strong examples that demonstrate creative solutions to address the PREA initiative.
1. Initiated and actively engaged the Agency PREA Steering Committee to help revise and
implement new policies and training consistent with the standards. The Committee represents
all major divisions in the agency.
2. Developed a Georgia Response to PREA Manual. This manual was initially rolled out in late 2012
to facility and agency leadership. The manual was the result of much of the work accomplished
by the PREA Steering Committee to include:
o
o
o
o
Integration of PREA into relevant policies
Training Module matrix
PREA Program Model
Identification of facility PREA Compliance Managers for RYDCs, YDCs, and Community
Offices/Residential Programs
3. Together with TMG, hosted a one-day PREA Management Training for mid-level to senior
managers in September, 2013, to encourage buy-in and understanding of the initiative.
4. Engaged contract providers in addition to DJJ-run facilities to integrate PREA. Planning to
conduct trainings for the providers to ensure they understand PREA and know about the
standards and upcoming audits.
5. Developed Serious Incident Report codes specific to PREA-related incidents to better track PREA
incidents and meet the PREA standards for data collection.
6. Modified hiring and promotion background checks to more fully comply with the standards.
7. Developed a number of posters for facilities to educate youth and staff on PREA and reporting.
8. Provided guidance to facilities as to where exactly they are required to post the information.
9. Completed the PREA checklist and developed action plans for standards that the agency was not
in compliance with.
10. The Agency PREA Coordinator engaged in national-level meetings and trainings to include:
o
o
o
o
o
The PREA Coordinator Meeting for Juvenile Agencies, hosted by the PREA Resource
Center in Florida.
Member of the PRC Juvenile PREA Coordinator List Serv.
Participation in the 18th National Symposium of Juvenile Services Conference October
14 - 18, 2013.
Participation in PRC trainings and webinars.
Anticipated attendance at the upcoming PRC Audit Regional Training in May, 2013.
58
11. Engaged the facility PREA Compliance Managers through on-site meetings to ensure they
understand their roles and responsibilities.
12. Developed a comprehensive PREA website to include statistics, policies, reports, and other
pertinent information.
13. Included PREA in DJJ’s overall Strategic Plan with specific goals, strategies, and resource
allocation to ensure the PREA initiative remains a priority for the agency .
14. In addition to routine monitoring by the facilities, a team of staff has been designated to provide
quality assurance evaluation statewide to ensure local policy, Georgia Law, and national PREA
Standard requirements are adhered to and monitored for compliance.
59
Appendix 2
Document Request
60
Request for Documents
The following items will assist The Moss Group consultant team in meeting the goals of the
Bureau of Justice Assistance Prison Rape Elimination Act Demonstration Grant that was
awarded to the Georgia Department of Juvenile Justice.
Please send all materials electronically, if possible, to Mara Dodson at [email protected]
by November 1, 2012. All materials that cannot be sent electronically can be sent in hardcopy to
the name and address below:
Mara Dodson
Associate, Business Operations and Special Projects
1312 Pennsylvania Avenue, SE
Washington, DC 20003
List of Requested Documents
Agency-Level:
1. Agency mission statements and/or guiding principles, to include copies of memorandums
from leadership related to communication to the field and stakeholders around PREA and
sexual safety.
2. Agency policies and procedures informing the mission and operations of the facility that
would assist in implementing PREA. These may include but are not limited to policies and
procedures addressing the issues of:
1. PREA
2. Sexual harassment;
61
3. Placement of residents (classification), including Classification Assessment and
Reassessment, Victim / Predator Assessment, Housing Assignment, Program
Placement policies and instruments, Risk/Need Assessment, and Case
Planning/Release Planning;
4. Gender Specific Practice (Cross gender supervision, cross gender search / pat, safety
for LGBTI inmates, etc.)
5. Staff/youth relations, Volunteer/offender relations;
6. Medical and Mental Health policy related to PREA, including policies addressing the
following: mandatory reporting, confidentiality, and the prevention, detection,
response and roles and responsibilities related to PREA;
7. Outside medical or mental health referrals;
8. Hiring and background checks of staff and volunteers;
9. First responders/SART
10. Investigation procedures;
11. Employee discipline procedures;
12. Employee grievance procedures;
13. Youth discipline processes
14. Youth grievance processes
15. Youth transportation and youth escorts
16. Policy related to media response, in particular to PREA allegations
17. Policy related to community outreach for services to victims of sexual abuse while in
confinement
18. Youth handbook
3. Organizational chart for agency administration, including both position titles and names of
individuals assigned to each key position.
4. Training plans and curricula for staff, including that which is available to supervisors and
middle management as it relates to sexual safety, professional boundaries, gender-responsive
training, PREA, and working with lesbian, gay, bi-sexual, transgender, intersex (LGBTI)
populations.
62
5. Overview of current data collection methodology and reporting mechanisms, as it relates to
PREA reporting, current analysis of the data collected, and any training plans and curricula
for supervisory staff on the use of the data.
6. Any current memorandum of understanding and/or agreements with outside agencies that
provide services to the facilities (e.g., education, medical services, mental health, substance
abuse, etc.) as it relates to sexual safety/PREA.
7. Major reports relating to sexual safety, including:
a. Any other reports deemed relevant, including reports applicable to the treatment
and/or programming for the population.
8. Major incidents or lawsuits related to sexual abuse, as well as any claims or settlements
related to sexual safety/PREA.
9. Youth population demographics (e.g., age, race, custody level, sentence length, offense,
etc.—as available).
Facility-Level: (Please include only those documents that were not addressed in the agencylevel document request.)
1. Facility mission statements and/or guiding principles.
2. Facility policies and procedures informing the mission and operations of the facility that
would assist in implementing PREA. These would include any facility-specific policies
addressing the issues listed above in the Agency-level list under request #2.
3. A copy of any facility-specific risk/need assessment and classification and/or assessment
tools in use in working with the population.
4. Policy, procedures and youth orientation and education materials related to sexual safety,
boundaries, and healthy relationships, including any materials or procedures designed for
specific populations such as LGBTI inmates.
5. Any local current memorandum of understanding and/or agreements with outside agencies
that provide services to the facilities (e.g., education, medical services, mental health,
substance abuse, etc.) as it relates to sexual safety/PREA.
6. Organizational chart for each facility, including both position titles and names of individuals
assigned to each key position (e.g., management team, department heads, etc., including
lines of supervision). Please identify the institutional executive team.
7. A flowchart or a brief paragraph describing the movement of inmates at each facility.
8. Staff-to-youth ratio and the staffing for each housing unit. Please include gender of staff as
well.
9. Bona Fide Occupational Qualification (BFOQ) positions, if applicable
63
10. List of programming available to youth and participation level at each facility,
11. Property list for youth
12. Visitation schedule and requirements as to how youth qualifies for visitation
13. Incident reports during the last six (6) month period related to sexual abuse. Please indicate
any incidents that made it to the level of prosecution.
14. Disciplinary reports during the last 3 month period, related to sexual abuse or otherwise.
15. Employee grievances related to sexual abuse during the last (6) month period.
16. Youth grievances related to sexual abuse during the last (6) month period
17. Summaries of any significant/critical PREA-related incidents occurring during the previous
six (6) months.
18. Investigation reports and/or summary of investigation reports related to PREA during the last
three years.
19. Audits or accreditation reports of inspections conducted by professional groups in at least the
past three (3) years.
20. Facility schema/map including footprints of buildings and housing units identified.
21. Facility staff shift rosters, to be provided in a format that includes demographic information
such as: name, position title, regular days off, gender, race, age, and—if possible—years of
service at the facility.
22. Youth programming/education schedule at each facility.
Please send the following materials electronically, if possible, to Mara Dodson at
[email protected] .The facility shift rosters and inmate programming schedules will be
utilized to create the staff focus group rosters and agendas for the on-site work, and therefore
TMG will require this information to be accurate and up-to-date as of the date of the assessment
period.
64
Appendix 3
Assessment Team Biographical Sketches
65
Andie Moss, TMG President
Andie Moss is President of The Moss Group, Inc., a Washington, DC-based criminal justice consulting
firm established in 2002. The Moss Group, Inc. provides consulting services to federal, state, and local
agencies and private organizations using the expertise of experienced practitioners with a commitment
to excellence. Through her organization, Ms. Moss has managed multiple strategies to assist the field in
the implementation of the Prison Rape Elimination Act (PREA). Ms. Moss has served as an expert to the
National Prison Rape Review Panel, the Vera Institute of Justice, the National Institute of Corrections,
the Bureau of Justice Assistance, the Bureau of Justice Statistics, and the National Prison Rape
Elimination Commission.
Through her work with the National Institute of Corrections and through independent contracts, Ms.
Moss has consulted on-site with numerous correctional organizations, in both the adult and juvenile
arenas. Currently, among other initiatives, Ms. Moss continues to manage a NIC PREA cooperative
agreement, is a partner in the Office of Justice Programs and Bureau of Justice Assistance Resource
Center for Justice Involved Women, and is a subject matter expert and advisory member for the NICfunded Gender Informed Practice Assessment.
Ms. Moss has an extensive history working on sensitive correctional management issues, particularly
with women offenders. In the Georgia Department of Corrections, she provided oversight for reform in
women’s services. Later on, as an Assistant Deputy Commissioner in the Georgia Department of
Corrections during the Cason v. Seckinger lawsuit in the early 1990s, and as a Program Manager with the
NIC from September, 1995, to February, 2002, she was involved in the development of early strategies
to address staff sexual misconduct in the field of corrections. Throughout her career, Ms. Moss has
valued the importance of addressing staff–offender sexual abuse by understanding the nature of the
organizational culture of correctional settings as well as the day-to-day operational practice.
Ms. Moss is published in professional periodicals and authored a chapter in a correctional
administrator’s textbook on staff sexual misconduct. She is active in professional organizations, is the
Chair for the ACA Women Working in Corrections Committee, and is past President of the Association of
Women Executives in Corrections. Ms. Moss has received numerous honors for her work including the
NIC Executive Director’s Award and the Georgia Governor’s Award for Outstanding Service.
Andie is proud to have served in the Georgia Department of Corrections for fourteen years earlier in her
career and is excited to be working with the Department in assisting with PREA implementation.
Dave Marcial, TMG Consultant
David Marcial is currently an independent criminal justice consultant. He has worked as a Senior
Associate with the Criminal Justice Institute, Inc. (CJI) and the Association of State Correctional
Administrators (ASCA) of Middletown, Connecticut. As a Senior Associate Mr. Marcial has been involved
with a variety of collaborative initiatives between CJI and ASCA and the Bureau of justice Assistance
66
(BJA). One of the projects he oversaw involved developing a national clearinghouse of grant and policyrelated information in order to provide a sole source of information for correctional jurisdictions. He
also actively contributes to an initiative that is focusing on the implementation of national performance
standards for the field of corrections, enabling all states and major metropolitan agencies to compare
and contrast correctional performance data utilizing standardized definitions, variables, and criteria.
In his role as a national consultant, Mr. Marcial has worked with the National Institute of Corrections as
a subject matter expert in the areas of operational practices and gender-responsive programming in
women’s prisons, as well as in policy review and development, security auditing, Management of HighRisk Offenders and staff training. He has been a technical assistance provider for the national Prisoner
Rape and Elimination Act (PREA)-related initiatives, and has served as a security and policy consultant
for juvenile justice services at the Connecticut Juvenile Training School.
Mr. Marcial has an extensive background in correctional operations and management, having worked in
a variety of positions for the Connecticut Department of Correction over his 26-year career. He retired
from the Department in 2003, after having served as a warden for eleven years, where he implemented
and augmented facility programs related to relapse prevention, sex offenders, victim empathy, and
parenting/fatherhood.
Beginning his career in 1974, Mr. Marcial worked with both male and female pre-trial detainees with
identified mental health issues, pending competency evaluations. He later worked for the Connecticut
Department of Corrections, rising up through the custody ranks, holding the positions of Correctional
Officer, Lieutenant, Captain, and Major, as well as prominent roles with investigations (internal affairs)
and developing gang intervention initiatives. He also served as a Regional Director for the state,
overseeing the operation of six correctional facilities and supervising the expansion of one of the state’s
female facilities. He also oversaw the opening and activation of two correctional institutions: a women’s
facility and a large male pretrial facility.
Related to PREA, Mr. Marcial has trained correctional staff and administrators on issues of sexual
misconduct. Also, during his time as department investigator and as Chief of Security at the state’s
women’s prison—coupled with his years as a warden—Mr. Marcial has had a great deal of experience
investigating and resolving instances and allegations of sexual misconduct.
Mr. Marcial also has considerable knowledge and experience in organizational culture assessment,
having participated in numerous organizational culture assessments in jails and prisons. He has trained
in the application of the assessment protocols and has successfully applied assessment protocols in a
variety of correctional settings. He has also worked with institutional staff and leadership to develop and
support successful organizational change strategies.
Mr. Marcial is a member of the American Correctional Association. He is a Past President of the Board of
Directors for Centro de la Comunidad, a Hispanic / Latino social service agency in New London,
Connecticut, and served on the Board of the Connecticut Hispanic Association of State Employees
(CHASE). Mr. Marcial previously served on the Board of Directors for the Middle Atlantic States
Correctional Association (MASCA) and is a past member of the North American Association of Wardens
67
and Superintendents. He holds an Associate of Science degree in Criminal Justice and a Bachelor of
Science degree in Human Services, and is currently pursuing a Masters degree in Organizational
Management. He is also bi-lingual and bi-literate.
Jeffrey Shorba, J.D., Consultant
State Court Administrator Jeff Shorba took office on October 10, 2012, after having served as Deputy
State Court Administrator since July 2002. Prior to joining the Judicial Branch, Jeff was the Assistant
Commissioner for Management Services and General Counsel for the Minnesota Department of
Corrections from 1999-2002. He served as the Associate General Counsel for Legislative and Correctional
Issues in the Office of General Counsel for the Federal Bureau of Prisons, U.S. Department of Justice
from 1991-1999. Prior to his service with the federal government, Jeff was in private practice with the
law firm of Bell, Boyd & Lloyd in Washington, DC, from 1989-1991. Jeff has also been a law clerk for
Chief Justice Peter Popovich on the Minnesota Supreme Court from 1988 to 989.
Jeff is currently a member of the Judicial Council, the administrative policy-making body for the
Minnesota Judicial Branch. He is also faculty for the Institute for Court Management, a Certified Court
Manager, and a member of the Minnesota State Bar. Jeff also serves as a consultant and trainer for The
Moss Group, Inc., a criminal justice consulting firm, and the National Institute of Corrections. Jeff is a
subject matter expert in the area of PREA, investigations, legal liability, and human resources in
corrections. Jeff also authored the draft community corrections standards for the National Prison Rape
Elimination Commission.
Jeff is a 1988 cum laude graduate of Harvard Law School and received his undergraduate degree magna
cum laude in 1985 from Carleton College.
Cherie Townsend, Consultant
Cherie Townsend is an independent consultant and executive coach for individuals and organizations.
She incorporates her nearly 40 years as a juvenile justice practitioner and leader into her writing,
research, and consulting practice.
Prior to her retirement from public service, she served as the executive director of the Texas
Department of Juvenile Justice. From 2008 to 2011, she served as executive director or executive
commissioner of the Texas Youth Commission. Cherie assumed these positions following findings of
serious staff sexual misconduct in multiple state-operated juvenile facilities and accepted the challenge
of leading change in the system. She is recognized for successfully leading staff in a significant system
reform effort while also closing six secure facilities and eliminating 2,000 staff positions. The reform
effort resulted in implementing and maintaining PREA standard-compliant practices, operating sexually
safe facilities, ACA accreditation, engagement of families, expanded specialized treatment and an
investment in prevention and reentry services. Previously, she served as director of juvenile justice
68
services in Clark County, Nevada (Las Vegas), a Juvenile Detention Alternatives Initiative replication site,
and as director of juvenile court services in Maricopa County, Arizona (Phoenix).
Cherie chaired the Council of Juvenile Correctional Administrators’ PREA Committee from its inception
until June, 2012. In this role, she participated in focus groups regarding best practices to ensure sexual
safety for youth in all juvenile justice residential and secure settings, provided input on the PREA draft
standards as well as the BJS Sexual Victimization Survey in Juvenile Facilities, and led the organization’s
response to each publication of the draft standards.
She is the 2012 recipient of the George M. Keiser Award for Exceptional Leadership. Cherie’s leadership
and work has been recognized by many organizations, including the Texas Corrections Association, the
Council of Juvenile Correctional Administrators, the National Juvenile Court Services Association, and the
National Association of Probation Executives. She has an M.P.A. from Southern Methodist University
and an M.B.A. from the University of Texas. Ms. Townsend continues to serve as a member of the
Suicide Prevention Resource Center Steering Committee and was recently named to the National Reentry Resource Center Advisory Committee on Juvenile Justice.
Mara E. Dodson, Associate, Business Operations and Special Projects
Mara Dodson began working for the Moss Group, Inc. in 2008, initially providing program support and
research services. Notably, Mara worked on the National Prison Rape Elimination Commission Report by
conducting a national survey to identify current practice in agency responses to sexual abuse, designed
The Moss Group Resource Center, provided support in leadership development programs, provided onsite support during facility assessments and operational reviews, researched and edited reports,
developed curricula, and provided project assistance in sole-sourced, Bureau of Justice Assistance, and
National Institute of Corrections-funded projects and technical assistance events.
In December of 2010, Mara transitioned into a new position for The Moss Group as Associate of
Business Operations and Special Projects. In this capacity, Mara provides project management,
coordination and subject matter expertise for major Grants and sole-sourced projects, focusing primarily
in the areas of PREA and female offenders in both adult and juvenile settings. A critical component of
this role includes managing and coordinating facility sexual safety assessments, trainings, and major
meetings. Mara has been responsible for managing over 20 facility sexual safety assessments in adult
and juvenile settings. In addition, she co-manages the National PREA Resource Center Juvenile PREA
Coordinator List Serv.
Mara graduated cum laude from Tufts University, majoring in Middle Eastern Studies and Arabic.
69
Appendix 4
PREA Policy Review
70
Policy Review
Chapter 1: Administration
Subject: Citizen and Volunteer Involvement





Volunteer is defined as regular and occasional volunteers as well as public and private speakers
and presenters.
The policy provides that ex-offenders may serve as volunteers if they meet the same
requirements they would for employment (see policy 3.52 background checks). We did not
receive this policy for review, so it is unclear if it meets the background check requirements of
PREA standard 115.317 Hiring and promotion decisions, part (e). The policy does not indicate
there will be background checks every five years.
Training and orientation of volunteers must be documented according to policy that complies
with PREA standard 115.332 Volunteer and contractor training, part (c).
The policy does not dictate that volunteers must receive training regarding their responsibilities
under the agency’s sexual abuse and sexual harassment prevention, detection and response
policies and procedures pursuant to PREA standard 115.332(a). The level and type of training
should vary depending on the level of contact with youth pursuant to PREA standard 115.332(b).
The policy provides that volunteer service may be curtailed for a variety of reasons. It does not
specify volunteers engaging in sexual abuse pursuant to PREA standard 115.377 Corrective
action for contractors and volunteers, part (a).
Chapter 8: Safety and Security
Subject: Sexual Assault



Policy provides that, if possible, the pre-selected hospital emergency room should be one that is
trained in the collection of forensic evidence. PREA standard 115.321 Evidence protocol and
forensic medical examinations requires that forensic exams follow specific DOJ protocol.
The policy does not indicate how consent will be obtained for performance of a forensic medical
exam or other medical services. It seems to imply the procedure will be conducted without
consent.
PREA standards 115.321(d) requires that an individual accompany a youth to the hospital for the
forensic medical exam. The first choice is an individual from a rape crisis center. If an individual
from a rape crisis center is not available either a qualified staff member from the agency or a
community-based organization should accompany the youth [115.321(d)].
71
Chapter 8: Safety, Security, and Control
Subject: Vendor Access to Secure Facilities






Vendors have to sign a vendor acknowledgement form. We were not provided that form but it
appears to require a vendor to acknowledge a previous conviction for physical or sexual abuse
of a child.
Vendor is defined as a person not regularly employed by DJJ who is contracted to provide a
service to the physical plant.
Vendors must be separated from youth to limit interaction as much as possible. The policy
provides a few suggestions on how to limit interaction with youth including being escorted by a
staff member or locked into an area of the plant where no youth are present.
The policy provides that vendors will not have personal dealings with youth or maintain
personal associations with youth.
The definition of vendor under the policy may meet the definition of “contractor” under the
PREA standards. As such, the DJJ should consider whether background checks of vendors who
may have unsupervised contact with youth should be conducted [115.317(e)].
If a vendor meets the definition of “contractor” he or she would also be subject to PREA
standard 115.332 and PREA standard 115.377.
Subject: Inspections


Inspection teams will inspect the facility weekly for safety, security, and sanitation issues.
Corrections will be reported to necessary maintenance changes.
Subject: Administrative Duty Officer


The Administrative Duty Officer (ADO) is a senior official designated by the Director to function
in his or her absence or outside normal business hours
Situations that required contacting the ADO including allegations of sexual assault of a youth.
Subject: Security Management

The policy provides that each facility shall establish the minimum number of staff that must be
on duty. PREA standard 115.313 Supervision and monitoring, part (c) establishes minimum
staffing standards in secure juvenile facilities. The staffing ratio requirements are 1:8 during
youth waking hours and 1:16 during youth sleeping hours. Only security staff are included in
72
these ratios. For those not already required to maintain these staffing ratios, the facility shall
have until October 1, 2017, to come into compliance.
Subject: Searches and Contraband Control


Only same-sex staff may conduct strip searches to comply with PREA standard 115.315 Limits to
cross-gender viewing and searches, part (a).
Pat down searches are conducted by same-sex staff when at all possible. PREA standard
115.315(b) provides that cross-gender pat down searches may only be conducted in exigent
circumstances. DJJ should incorporate this “exigent circumstances” requirement and use the
definition provided in the PREA standards.
Chapter 11: Health and Medical Services
Subject: Medical Intake Screening


This policy provides for medical screening of youth. A tool is used to screen all youth. For further
review we would like to review the medical screening tool used to screen youth.
This policy does not indicate that any type of screening that shows a youth has experienced
prior sexual victimization or has perpetrated sexual abuse will result in a referral to medical
pursuant to PREA standard 115.381 Medical and mental health screenings: history of sexual
abuse.
Chapter 12: Behavioral Health Services
Subject: Mental Health Assessment


This policy provides for mental health screening of youth. A tool is used to screen all youth. For
further review, we would like a copy of the mental health screening tool.
This policy does not indicate that any type of screening that shows a youth has experienced
prior sexual victimization or has perpetrated sexual abuse will result in a referral to mental
health pursuant to PREA standard 115.381.
Chapter 15: Rights of Youth
Subject: Grievance Process


Informal resolution of grievances is available but not required in compliance with PREA standard
115.352 Exhaustion of administrative remedies, part (b)(3).
Other provisions of PREA standard 115.352 that are not contained in the DJJ grievance policy:
o
115.352(b)(1)—No time limit for filing a grievance related to sexual abuse. The policy
does not appear to impose a time limit, but it is not explicit in the policy.
73
o
o
o
115.352(c)—The policy should make clear that a youth who alleges being a victim of
sexual abuse does not have to submit the grievance to the staff member who is the
subject of the complaint and it will not be referred to the staff member who is the
subject of the complaint. For example, the complaint could be about the Grievance
Officer who is the one retrieving complaints from the grievance box.
The policy only allows staff to assist youth with grievances when they are unable to
adequately complete the grievance form. PREA standard 115.352(e)(1) provides that
third parties, including fellow youths, staff members, family members, attorneys, and
outside advocates should be permitted to assist youths in filing grievances. These
individuals should also be able to file requests on behalf of youths.
Emergency Grievances. PREA standard 115.352(f) provides that emergency grievances
(which include allegations of substantial risk of imminent sexual abuse) must be
answered within 48 hours, with a final agency decision within five calendar days.
Chapter 17: Admission and Release
Subject: Custody and Housing Assignment


This policy provides for the use of a Housing Assessment when determining the appropriate
roommate for a youth. For further review, it would be helpful to review the Housing
Assessment.
It is not clear from the policy if the Housing Assessment takes into consideration the criteria
outlined in PREA standard 115.341 Obtaining information from residents.
Chapter 17: Admission and Release
Subject: Youth and Parent Orientation

The policy provides that youth will be provided a formal orientation presentation within one
working day of admission to a facility. The PREA policy contains provisions related to youth
education that meet the PREA standards, but they are not cross referenced in this orientation
policy.
Chapter 20: Community Case Management
Subject: Screening of Committed Youth


The policy provides for the use of a Comprehensive Risk and Needs Assessment (CRN). This tool
is used to classify youth and to determine risk, placement, and level of supervision.
The policy provides a list of the minimal information used by the screening committee. This list
of criteria should be reviewed with the list in PREA standard 115.341 to ensure compliance.
74
Chapter 22: Investigations
Subject: Lesbian, Gay, Bisexual, Transgender, Intersex (LGBTI)

This policy complies with applicable provisions of the PREA standards.
Chapter 22: Investigations
Subject: Prison Rape Elimination Act (PREA)
Policy

The policy provides that DJJ prohibits any form of consensual sexual activities between youth
and staff, contractors, volunteers, and interns. Is there such a thing as “consensual” sexual
activity between youth and these individuals under Georgia state law?
Definitions


PREA Coordinator. The policy directs the designation of an Agency PREA Coordinator and PREA
contacts, which we are assuming meet the requirement of a PREA Compliance Manager for each
facility pursuant to PREA standard 115.311 Zero tolerance of sexual abuse and sexual
harassment: PREA coordinator, part (c).
Sexual abuse includes a number of specific acts that are not defined in the policy. Many but not
all of them are defined in the Sexual Assault policy including “Lewd or Lascivious Conduct,” and
“Sexual Abuse/Sexual Exploitation Off DJJ Property.” In addition,
“staff/contractor/volunteer/intern on youth sexual harassment” is not included in the list. These
lists should be cross referenced, and the sexual assault policy should be referenced.
Intake




DJJ should review PREA standard 115.341 Obtaining information from residents to determine
whether the DJJ screening instrument ascertains information as laid out in the standard.
Information obtained from the screening should be used not only to make housing assignments
but also bed, program, education, and work assignments per PREA standard 115.342 Placement
of residents in housing, bed, program, education, and work assignments.
Assigning transgender or intersex youth to a facility for male or female youth it shall be done on
a case-by-case basis and reassessed at least twice a year per PREA standard 115.342(d-e). A
transgender youth’s views with respect to his or her own safety shall be taken into
consideration in these decisions per PREA standard 115.342(f)].
The policy provides that youth at risk of sexual victimization will receive a Special Management
Plan. The policy does not indicate how special housing or other means of isolation may be used
to protect those at risk of sexual victimization. PREA standard 115.342(b) should be reviewed to
ensure that isolated housing is only used as a last resort, the reasons for its use should be
documented and reviewed every 30 days per PREA standard 115.342(b)(h-i).
75
Staff Training and Education




The policy does not provide for training of current staff members within one year of the
effective date of the PREA standards [115.331 Employee training, part (c)].
The policy does not provide that staff training will be documented [115.331(d)].
The policy does not indicate the components of the staff training curriculum. DJJ should review
the requirements under PREA standard 115.331(a).
The policy does not provide for specialized training of investigative staff (115.334 Specialized
training: Investigations) or medical and mental health staff (115.335 Specialized training:
Medical and mental health care).
Detection and Response








The policy does not indicate how third party reports will be accepted and the reporting process
will be advertised to third parties per PREA standard 115.354 Third-party reporting.
Agency protection duties. The policy does not contain procedures for protecting both youth and
staff from retaliation pursuant to PREA standard 115.367 Agency protection against retaliation.
This includes monitoring those who report for at least 90 days to ensure no indication of
retaliation.
Investigations. The policy does not contain language requiring that all allegations are referred to
investigators for investigation per PREA standard 115.361 Staff and agency reporting duties,
part (f).
The policy does not dictate the evidentiary standard to be used for administrative investigations
per PREA standard 115.372 Evidentiary standard for administrative investigations.
The policy does not contain requirements for reporting the results of investigations to youth per
PREA standard 115.373 Reporting to residents.
The policy does not contain a requirement that all substantiated allegations against staff that
could involve criminal behavior will be referred for prosecution per PREA standard 115.371
Criminal and administrative agency investigations, part (i)
The policy does not contain a requirement that the agency retain all investigative reports for as
long as the alleged abuser is incarcerated or employed by the agency, plus five years, per PREA
standard 115.371 Criminal and administrative agency investigations, part (j).
Interventions and Disciplinary Actions Youth. The policy provides that the Director of the Office
of Investigations will refer youth for criminal prosecution where appropriate. The policy should
make clear that referrals will occur in all cases where substantiated incidents of potentially
criminal behavior by youth have occurred.
Monitoring

The policy provides that the Office of Investigations Intelligence Unit, along with the PREA
Coordinator will review, analyze and use all sexual abuse data. It does not indicate that an
annual report will be prepared comparing the current year’s data and corrective actions with
76

those from prior years per PREA standard 115.388 Data review for corrective action. This report
must be made available to the public through the agency’s website.
The policy does not require that sexual abuse data be maintained for at least 10 years after its
initial date of collection per PREA standard 115.389 Data storage, publication, and destruction.
Additional Standards not found in this Policy or Others






115.312 Contracting with other entities for the confinement of residents—Policy should make
clear that any contracts by the agency for confinement of youth will require compliance with the
PREA standards.
115.315 Limits to cross-gender viewing and searches, part (d)—Policy should make clear that
youth may shower, perform bodily functions, and change clothing without nonmedical staff of
the opposite gender viewing their breasts, buttocks, or genitalia.
115.313 Supervision and monitoring, part (e)—Policy should be implemented to ensure
intermediate- or higher-level supervisors conduct and document unannounced rounds to
identify and deter staff sexual abuse and sexual harassment.
115.353 Resident access to outside support services and legal representation—Policy should
ensure that youth have access to outside victim advocates for emotional support services
related to sexual abuse. The agency shall maintain or attempt to enter into memoranda of
understanding with community service providers that can provide these support services.
115.353(d)—Policy should also ensure that youth are provided with reasonable and confidential
access to their attorneys or other legal representation and reasonable access to parents or legal
guardians.
115.376 Disciplinary sanctions for staff—Policy does not provide for disciplinary sanctions for
staff.
77

Georgia Department of Juvenile Justice

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