BUREAU OF MONITORING AND QUALITY IMPROVEMENT PROGRAM REPORT FOR

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1 S T A T E O F F L O R I D A D E P A R T M E N T O F J U V E N I L E J U S T I C E BUREAU OF MONITORING AND QUALITY IMPROVEMENT PROGRAM REPORT FOR Martin Girls Academy G4S Youth Services, LLC (Contract Provider) 800 SE Monterey Road Stuart, Florida Review Date(s): February 21-24, 2017 PROMOTING CONTINUOUS IMPROVEMENT AND ACCOUNTABILITY IN JUVENILE JUSTICE PROGRAMS AND SERVICES

2 Rating Definitions Ratings were assigned to each indicator by the review team using the following definitions: Compliance Limited Compliance Failed Compliance No exceptions to the requirements of the indicator; or limited, unintentional, and/or non-systemic exceptions that do not result in reduced or substandard service delivery; or systemic exceptions with corrective action already applied and demonstrated. Systemic exceptions to the requirements of the indicator; exceptions to the requirements of the indicator that result in the interruption of service delivery; and/or typically require oversight by management to address the issues systemically. The absence of a component(s) essential to the requirements of the indicator that typically requires immediate follow-up and response to remediate the issue and ensure service delivery. Review Team The Bureau of Monitoring and Quality Improvement wishes to thank the following review team members for their participation in this review, and for promoting continuous improvement and accountability in juvenile justice programs and services in Florida: Paula Friedrich, Office of Program Accountability, Lead Reviewer (Standard 1) Tameko Gore, Pompano Youth Treatment Center, Facility Administrator (Standard 5) Patrick Morse, Office of Program Accountability, South Regional Supervisor (Standard 3) Shawna Prope, Office of Program Accountability, Regional Monitor (Standard 2) Maryann Sanders, Office of Program Accountability, Deputy Regional Supervisor (Standard 4)

3 Program Name: Martin Girls Academy QI Program Code: 1138 Provider Name: G4S Youth Services, LLC Contract Number: Location: Martin County / Circuit 19 Number of Beds: 30 Review Date(s): February 21-24, 2017 Lead Reviewer Code: 139 Methodology This review was conducted in accordance with FDJJ-2000 (Contract Management and Program Monitoring and Quality Improvement Policy and Procedures), and focused on the areas of (1) Management Accountability, (2) Assessment and Performance Plan, (3) Mental Health and Substance Abuse Services, (4) Health Services, and (5) Safety and Security, which are included in the Residential Standards. Persons Interviewed Program Director DJJ Monitor DHA or designee DMHCA or designee 2 # Case Managers 2 # Clinical Staff # Food Service Personnel 3 # Healthcare Staff 1 # Maintenance Personnel 2 # Program Supervisors Documents Reviewed 5 # Staff 5 # Youth # Other (listed by title): Accreditation Reports Affidavit of Good Moral Character CCC Reports Confinement Reports Continuity of Operation Plan Contract Monitoring Reports Contract Scope of Services Egress Plans Escape Notification/Logs Exposure Control Plan Fire Drill Log Fire Inspection Report Fire Prevention Plan Grievance Process/Records Key Control Log Logbooks Medical and Mental Health Alerts PAR Reports Precautionary Observation Logs Program Schedules Sick Call Logs Supplemental Contracts Table of Organization Telephone Logs Surveys Vehicle Inspection Reports Visitation Logs Youth Handbook 6 # Health Records 10 # MH/SA Records 5 # Personnel Records 10 # Training Records/CORE 5 # Youth Records (Closed) 3 # Youth Records (Open) # Other: 5 # Youth 5 # Direct Care Staff # Other: Observations During Review Admissions Confinement Facility and Grounds First Aid Kit(s) Group Meals Medical Clinic Medication Administration Posting of Abuse Hotline Program Activities Recreation Searches Security Video Tapes Sick Call Social Skill Modeling by Staff Staff Interactions with Youth Comments Staff Supervision of Youth Tool Inventory and Storage Toxic Item Inventory and Storage Transition/Exit Conferences Treatment Team Meetings Use of Mechanical Restraints Youth Movement and Counts Items not marked were either not applicable or not available for review. Office of Program Accountability Page 3 of 68 (Revised July 2016)

4 Standard 1: Management Accountability Residential Rating Profile Indicator Ratings 1.01 Standard 1 - Management Accountability * Initial Background Screening 1.02 Five-Year Rescreening 1.03 * Provision of an Abuse-Free Environment 1.04 * Management Response to Allegations 1.05 * Incident Reporting (CCC) 1.06 Protective Action Response (PAR) and Physical Intervention Rate 1.07 * Pre-Service/Certification Requirements 1.08 In-Service Training 1.09 Grievance Process Training 1.10 Grievance Process 1.11 Grievance Process Documentation 1.12 Life Skills Training Provided to Youth 1.13 Staff Training: Delinquency Interventions 1.14 Restorative Justice Awareness for Youth 1.15 Delinquency Intervention Services 1.16 Gender-Specific Programming 1.17 Logbook Entries and Shift Report Review 1.18 * Internal Alerts System 1.19 * Alerts (JJIS) 1.20 Education Acces 1.21 Youth Records (Healthcare and Management) 1.22 Youth Input 1.23 Advisory Board 1.24 Program Planning 1.25 Staff Performance * The Department has identified certain key critical indicators. These indicators represent critical areas that require immediate attention if a program operates below Department standards. A program must therefore achieve at least a Compliance rating in each of these indicators. Failure to do so will result in a program alert form being completed and distributed to the appropriate program area (detention, residential, probation). Office of Program Accountability Page 4 of 68 (Revised July 2016)

5 Standard 2: Assessment and Performance Plan Residential Rating Profile Indicator Ratings Standard 2 - Assessment and Performance Plan 2.01 Initial Contacts to Parent/Gaurdian 2.02 Court Notification 2.03 Youth Orientation 2.04 Written Consent of Youth Eighteen or Older 2.05 Classification Factors 2.06 Classification Procedures 2.07 Reassessment for Activities 2.08 Gang Identification: Notification of Law Enforcement 2.09 Gang Identification: Prevention and Intervention Activities 2.10 R-PACT Assessment 2.11 Youth Needs Assessment Summary 2.12 R-PACT Reassessments 2.13 Parent/Guardian Involvement in Case Management Services 2.14 Members of Treatment Team 2.15 Performance Plan Development Limited 2.16 *Performance Plan Goals 2.17 Performance Plan Transmittal 2.18 Incorporation of Other Plans Into Performance Plan 2.19 Treatment Team Meetings (Formal Reviews) 2.20 Treatment Team Meetings (Informal Reviews) 2.21 Performance Plan Revisions 2.22 Performance Summaries 2.23 Performance Plan Summary Transmittal 2.24 Career Education 2.25 Education Transition Plan 2.26 Transition Planning and Conference 2.27 Exit Portfolio 2.28 Exit Conference * The Department has identified certain key critical indicators. These indicators represent critical areas that require immediate attention if a program operates below Department standards. A program must therefore achieve at least a Compliance rating in each of these indicators. Failure to do so will result in a program alert form being completed and distributed to the appropriate program area (detention, residential, probation). Office of Program Accountability Page 5 of 68 (Revised July 2016)

6 Standard 3: Mental Health and Substance Abuse Services Residential Rating Profile Indicator Ratings Standard 3 - Mental Health and Substance Abuse Services 3.01 Designated Mental Health Clinician Authority or Clinical Coordinator 3.02 * Licensed Mental Health and Substance Abuse Clinical Staff 3.03 Non-Licensed Mental Health and Substance Abuse Clinical Staff 3.04 Mental Health and Substance Abuse Admission Screening 3.05 Mental Health and Substance Abuse Assessment/Evaluation 3.06 Mental Health and Substance Abuse Treatment 3.07 * Treatment and Discharge Planning 3.08 * Specialized Treatment Services 3.09 * Psychiatric Services 3.10 * Suicide Prevention Plan 3.11 * Suicide Prevention Services 3.12 * Suicide Precaution Observation Logs 3.13 * Suicide Prevention Training 3.14 * Mental Health Crisis Intervention Services 3.15 * Crisis Assessments 3.16 * Emergency Mental Health and Substance Abuse Services 3.17 * Baker and Marchman Acts Non-Applicable * The Department has identified certain key critical indicators. These indicators represent critical areas that require immediate attention if a program operates below Department standards. A program must therefore achieve at least a Compliance rating in each of these indicators. Failure to do so will result in a program alert form being completed and distributed to the appropriate program area (detention, residential, probation). Office of Program Accountability Page 6 of 68 (Revised July 2016)

7 Standard 4: Health Services Residential Rating Profile Indicator Ratings Standard 4 - Health Services 4.01 * Designated Health Authority/Designee 4.02 * Psychiatrist/Designee 4.03 Facility Operating Procedures 4.04 Authority for Evaluation and Treatment 4.05 Parental Notification 4.06 Notification - Clinical Psychotropic Progress Note 4.07 Immunizations 4.08 Healthcare Admission Screening Form 4.09 Medical Alerts 4.10 Youth Orientation to Healthcare Services 4.11 Designated Health Authority/Designee Admission Notification 4.12 Healthcare Admission Rescreening 4.13 Health Related History 4.14 Comprehensive Physical Assessment 4.15 Female-Specific Screening/Examination 4.16 Tuberculosis Screening 4.17 Sexually Transmitted Infection Screening 4.18 HIV Testing 4.19 Sick Call Process - Requests/Complaints 4.20 Sick Call Process - Visits/Encounters 4.21 Restricted Housing Non-Applicable 4.22 Episodic/First Aid Care 4.23 Emergency Care 4.24 Off-Site Care/Referrals 4.25 Chronic Illness/Periodic Evaluations 4.26 Medication Management - Verification 4.27 Medication Management - Orders/Prescriptions 4.28 Medication Management - Storage 4.29 Medication Management - Medication and Sharps Inventory 4.30 Medication Management - Controlled Medications 4.31 Medication Management - Medication Administration Record 4.32 Medication Management - Medication Administration By Licensed Staff 4.33 Medication Management - Medication Provided By Non-Licensed Staff 4.34 Medication Management - Psychotropic Medication Monitoring 4.35 Infection Control - Surveillance, Screening, and Management 4.36 Infection Control - Education 4.37 Infection Control - Exposure Control Plan 4.38 Prenatal Care - Physical Care of Pregnant Youth Non-Applicable 4.39 Prenatal and Neonatal Care - Nutrition, Education of Youth, and Lactation 4.40 Prenatal and Neonatal Staff Education * The Department has identified certain key critical indicators. These indicators represent critical areas that require immediate attention if a program operates below Department standards. A program must therefore achieve at least a Compliance rating in each of these indicators. Failure to do so will result in a program alert form being completed and distributed to the appropriate program area (detention, residential, probation). Office of Program Accountability Page 7 of 68 (Revised July 2016)

8 Standard 5: Safety and Security Residential Rating Profile Indicator Ratings Standard 5 - Safety and Security 5.01 Youth Supervision 5.02 * Ten-Minute Checks 5.03 Census, Counts, and Tracking 5.04 Key Control 5.05 Contraband Procedure 5.06 Frisk and Strip Searches 5.07 Vehicles and Maintenance 5.08 Transportation of Youth 5.09 Tool Inventory and Management 5.10 Youth Tool Handling and Supervision 5.11 Outside Contractors 5.12 Fire, Safety, and Evacuation Drills 5.13 Disaster and Continuity of Operations Planning 5.14 Storage and Inventory of Flammable, Poisonous, and Toxic Items and Materials 5.15 Youth Handling and Supervision for Flammable, Poisonous, and Toxic Items and Materials 5.16 Disposal of All Flammable, Toxic, Caustic, and Poisonous Items 5.17 Recreation and Leisure Activites 5.18 Elements of the Water Safety Plan Non-Applicable 5.19 Staff Training: Water Safety Non-Applicable 5.20 * Swim Test Non-Applicable 5.21 Visitation and Communication 5.22 Comprehensive Behavior Management System 5.23 Implementation and Consistency of Behavior Management System 5.24 Behavior Management System Infractions 5.25 Staff Training: Behavior Management System 5.26 Behavior Management System Monitoring 5.27 Search and Inspection of Controlled Observation Room 5.28 Controlled Observation 5.29 Controlled Observation Safety Checks 5.30 Controlled Observation Release Procedures * The Department has identified certain key critical indicators. These indicators represent critical areas that require immediate attention if a program operates below Department standards. A program must therefore achieve at least a Compliance rating in each of these indicators. Failure to do so will result in a program alert form being completed and distributed to the appropriate program area (detention, residential, probation). Office of Program Accountability Page 8 of 68 (Revised July 2016)

9 Strengths and Innovative Approaches The program was awarded a Perkins Grant to purchase and integrate a ten station training lab for the use of a three dimensional computer technology system called zspace. The system is a holographic platform technology which combines elements of virtual reality and augmented reality to create lifelike experiences on the computer which are immersive and interactive. The system provides activities based in science, technology, engineering, and mathematics (STEM) including the ability for youth to perform virtual anatomy dissection within a safe environment and without the use of scalpels or other real world dissection tools. This program also allows youth to build experiments, engage in physics experiments, and complete geometry and geology lessons. The zspace application includes curricula for academic levels of kindergarten through twelfth grade, as well as higher education, medical design and professional training. The skills learned through the use of the zspace system will assist the youth to more easily transition back to the community and mainstream schools. Dance groups (praise, hip hop), choir, drama and crochet club have all made appearances for the youth. The program recently partnered with StarStruck Productions to provide hip hop dance classes for youth. The twelve-week pilot was very successful and StarStruck was able to provide a benefactor for the program to continue. The youth advisory board (YAB) meets weekly and they attend the weekly crossdepartmental meetings to inform staff of their progress and collaborate on projects. The YAB has been preparing a newsletter for the community for the past several months which has been very successful. The YAB also conceived and planned a Halloween Carnival for the monthly incentive in October, When youth earn their high school diploma the program conducts a ceremony, complete with cap, gown, pomp and circumstance, and speakers. Whenever possible, families are invited to participate. Numerous pictures are taken and kept on display at the program for motivation. Cardiopulmonary resuscitation (CPR) training with staff and youth together has become an accepted practice at the program as conducting joint training is more efficient and it builds a sense of teamwork within the program. A local speech and language therapist provides services to youth on a weekly basis. Tables in the café are painted seasonally to reduce institutional appearance. They have been gold, purple, red/green and pastel based on the activities of the community. Office of Program Accountability Page 9 of 68 (Revised July 2016)

10 Standard 1: Management Accountability Overview The Department of Juvenile Justice contracts with G4S Youth Services, LLC to operate Martin Girls Academy, located in Stuart, Florida. The program is a secure intensive mental health services program for high-risk and maximum-risk female youth ages thirteen to twenty. At the time of the annual compliance review, the program had thirteen high-risk youth and five maximum-risk youth in the program. During the week of the annual compliance review, one new youth was admitted to the program. The program s management team consisted of a facility administrator, assistant facility administrator, health services administrator, director of clinical services, director of care management, and human resources coordinator. At the time of the annual compliance review, the program had eight vacancies consisting of four youth specialist I positions, three youth specialist II positions and one staff mentor (supervisor) position. The program conducted daily management meetings Monday through Friday, which were attended by department heads and the lead educator from the Martin County School District. The program provided training through the local academy and on-site instructor-led training Initial Background Screening Compliance Background screening is conducted for all Department employees, contracted provider and grant recipient employees, volunteers, mentors, and interns with access to youth. The background screening process is completed prior to hiring an employee or utilizing the services of a volunteer, mentor, or intern. An Annual Affidavit of Compliance with Level 2 Screening Standards is completed annually. The program had eighteen staff and twenty-one volunteers/interns applicable for pre-hire background screenings. All staff completed a background screening prior to hire and four staff were eligible with charges. The program submitted the Annual Affidavit of Compliance with Level 2 Screening Standards to the Department s Background Screening Unit on January 10, 2017, meeting the annual requirement Five-Year Rescreening Compliance Background screening is conducted for all Department employees, contracted provider and grant recipient employees, volunteers, mentors, and interns with access to youth. Employees and volunteers are rescreened every five years from the initial date of employment. The program had two staff applicable for the requirement of five-year rescreening during the review period. Reviewed documentation confirmed each five-year background rescreening was completed prior to the respective staff member s anniversary date. Both rescreening requests were submitted to the Department s Background Screening Unit at least ten business days prior to the five-year anniversary date. Office of Program Accountability Page 10 of 68 (Revised July 2016)

11 1.03 Provision of an Abuse-Free Environment Compliance The program provides an environment in which youth, staff, and others feel safe, secure, and not threatened by any form of abuse or harassment. Posting of the Florida Abuse Hotline telephone number and the Central Communications Center for youth 18 years of age and older telephone number. All allegations of child abuse or suspected child abuse are immediately reported to the Florida Abuse Hotline. Youth and staff have unhindered access to report alleged abuse to the Florida Abuse Hotline pursuant to Section (1)(a), F.S. The environment is free of physical, psychological, and emotional abuse. A code of conduct for staff who clearly communicates expectations for ethical and professional behavior, including the expectation for staff to interact with youth in a manner promoting their emotional and physical safety. The program maintained a written policy and procedures to address employee standards of conduct and performance, maintaining health professional boundaries, professional ethics, and youth rights. Documentation revealed the program s staff signed an acknowledgement of the provider s code of ethics, which was included in the employee handbook. The code of conduct detailed the core values of the provider and disciplinary actions which could result from violations of the policy. Observations made during the program tour included telephone numbers posted for the Florida Abuse Hotline and the Department s Central Communications Center (CCC) throughout the facility. During the review period, three calls were placed to the Florida Abuse Hotline and one allegation, sent by , was reported to CCC. Program logbooks notated when youth placed telephone calls to report suspected or alleged abuse. The program has a telephone in the dormitory which directly contacts the Florida Abuse Hotline. The program s practice is for staff to stand away from the youth while the call is placed; therefore, staff are not aware of the allegation being reported or whether the call was accepted. An interview with facility administrator indicated staff are expected to conduct themselves with the highest standards of conduct and professional performance. All allegations are investigated for disciplinary action based on the level of the infraction and the history of the employee. Critical offenses may result in suspension or immediate termination of employment. Five youth and five staff members were surveyed, all confirmed youth are given unhindered opportunity to call the Florida Abuse Hotline when requested. All five surveyed youth reported staff were respectful when talking with youth and they feel safe in the program. Two of the five youth reported never hearing any staff use profanity when speaking to youth, one youth reported hearing staff use profanity once, and one youth reported hearing staff use profanity occasionally. One youth reported being a witnessing or experiencing staff threats, intimidation, or humiliation of a youth. Office of Program Accountability Page 11 of 68 (Revised July 2016)

12 1.04 Management Response to Allegations Compliance Management shall be cognizant of youth and staff needs and provide direction to each on how to access the Florida Abuse Hotline. There is evidence management takes immediate action to address incidents of physical, psychological, and emotional abuse. There were four allegations of abuse reported to the Florida Abuse Hotline or Central Communications Center (CCC) during this review period. The program maintained a binder to document internal investigations which supported program management taking immediate action by initiating internal investigations related to three of the alleged complaints. Pursuant to policy, the program may not internally investigate any allegations related to Prison Rape Elimination Act (PREA). An interview with the facility administrator indicated the program s practice was to remove any staff identified in an allegation from contact with youth as soon as they learn of such allegations. At the time of the annual compliance review, there were no abuse allegations pending against staff for which they had been removed from youth contact Incident Reporting (CCC) Compliance Whenever a reportable incident occurs, the program notifies the Department s Central Communications Center (CCC) within two hours of the incident, or within two hours of becoming aware of the incident. The program had fourteen Central Communications Center (CCC) incidents reported in the six months prior to the annual compliance review. A review of five CCC reports validated all were reported within two hours of the incident or within two hours of the caller gaining knowledge of the incident. A review of internal incidents and grievances filed validated the program called in all incidents which should have been reported. An interview with facility administrator indicated all program staff complete preservice and annual in-service training relating to incident and abuse reporting. The program also hosted co-presentations by the Department of Juvenile Justice and the Department of Children and Families relating to reporting abuse Protective Action Response (PAR) and Physical Compliance Intervention Rate The program uses physical intervention techniques in accordance with Florida Administrative Code. Any time staff uses a physical intervention technique, such as countermoves, control techniques, takedowns, or application of mechanical restraints (other than for regular transports), a PAR Incident Report is completed and filed in accordance with the Florida Administrative Code. The program had thirty-three Protective Action Responses (PAR) in the last six months. Five PAR reports were reviewed and each included written statements from all involved staff, and each was completed by the end of the staff member s workday. Each of the five PAR reports were reviewed and processed within required time frames by all required parties. The program s residential three-month PAR rate during this review period was 13.93, well above the statewide average of 1.82; however, this was a decrease from fiscal year during which the program had a PAR rate of An interview the facility administrator indicated the program reviews each use of PAR in various ways including a staff debrief to discuss how the restraint was handled, reviews of video surveillance footage, and secondary reviews of all PAR paperwork conducted by both the facility administrator and assistant facility administrator. The program s management team met daily, Monday through Friday, during which all PARs, Central Office of Program Accountability Page 12 of 68 (Revised July 2016)

13 Communications Center (CCC) reports, internal incidents, controlled and/or secure observations, and security alerts are reviewed. Special treatment teams (STT) were conducted for each youth involved in a physical restraint. Youth with multiple restraints within a single month participated in a STT with the therapist, to review the youth s safety plan and to discuss any clinical issues related to triggers leading to the response. Each month the program submits to the Department a written clinical analysis of each PAR occurring during the previous month, inclusive of precedents to each incident and behavioral examination Pre-Service/Certification Requirements Compliance Contracted and State residential staff satisfies pre-service/certification requirements specified by Florida Administrative Code within 180 days of hiring. The program s 2016 pre-service training plan was submitted to the Department s Office of Staff Development and Training and approved on February 24, A review of five applicable preservice staff training files indicated all five staff were certified within 180-days of their hire as required. All five staff were certified in cardiopulmonary resuscitation (CPR), first aid, and automated external defibrillator (AED). Each staff was trained in Protective Action Response (PAR), suicide prevention, professionalism and ethics, emergency procedures, and child abuse reporting. All trainings in four of the five reviewed files were documented in the Department s Learning Management System (SkillPro). The remaining staff file completed all required preservice training; however, did not have all training documented in SkillPro. Documentation was provided on the last day of this review to reveal the trainings previously missing from SkillPro for the one staff was entered into SkillPro during the annual compliance review week In-Service Training Compliance Residential staff complete twenty-four hours of in-service training, including mandatory topics specified in Florida Administrative Code, each calendar year, effective the year after preservice/certification training is completed. Supervisory staff completes eight hours of training (as part of the twenty-four hours of annual inservice training) in the areas specified in Florida Administrative Code. Five applicable staff training files were reviewed for in-service training. There was documentation to support each staff completed between 121 hours and 198 hours of training in The training files validated each staff maintained current certification in cardiopulmonary resuscitation (CPR), first aid, automated external defibrillator (AED), and Protective Action Response (PAR). In addition, each staff was trained in professionalism and ethics, and each received at least six hours of suicide prevention training. All instructors were qualified to deliver the training provided. The training file of two supervisory staff validated the staff received seventeen and twenty-seven hours of training in management, leadership, employee relations, and communication skills. The program submitted an in-service training plan to the Department s Office of Staff Development and Training and the plan was approved on February 10, The program documented all completed instructor-led in-service training in the Department s Learning Management System (SkillPro) system as required. Office of Program Accountability Page 13 of 68 (Revised July 2016)

14 1.09 Grievance Process Training Compliance Program staff shall be trained on the program s youth grievance process and procedures. The program s policy and procedures required all staff to receive training on the grievance process. A review of five staff training files supported each staff completed training on the grievance process during in-service training Grievance Process Compliance The program adheres to their grievance process and shall ensure it is explained to youth during orientation and grievance forms are available throughout the facility. The program maintained a policy and procedures to address the youth grievance process. The program s procedure included informal, formal, and appeal phases. Grievance forms were accessible to the youth. The program s orientation checklist included an explanation of the grievance process. The grievance process was also outlined within the youth handbook. Five case management records were reviewed and found each contained an orientation checklist and documentation to support the youth received a copy of the youth handbook. In addition to the formal grievance process, youth utilize Chatty Cathy forms as a less formal complaint process, through which the youth request to speak with a specific staff to address any concerns. An interview with the facility administrator provided an overview of the program s grievance process in alignment with the programs policy and procedures, inclusive of required time frames and the three phases of informal, formal and the appeal process Grievance Process Documentation Compliance Completed grievances shall be maintained by the program for a minimum of twelve months. The program maintained all submitted grievances within a grievance binder. The binder included a monthly tracker which logged grievances received during each respective month over the previous twenty-four months. There were a total of fifty-one grievances filed in the last six months. Five submitted grievances were reviewed and each grievance was addressed by the grievance officer or designee within three days of submission as required by program policy and procedures. Documentation revealed each reviewed grievance was resolved in the informal phase and each youth agreed with the resolution. All five surveyed youth confirmed they were able to request assistance when filling out a grievance form. One of five youth rated the program s grievance process as very good, two rated it as good, one rated it as very poor, and one reported never having had a grievance Life Skills Training Provided to Youth Compliance The program shall provide interventions or instruction focusing on developing life and social skill competencies in youth. The program provided a variety of life and social skills intervention services. The clinical and direct care staff conducted groups on various topics, including Voices (A Program of Self- Discovery and Empowerment for Girls), SAVVY Sisters, Teen Relationships, and impulse Office of Program Accountability Page 14 of 68 (Revised July 2016)

15 control. Sign-in sheets documented youth who participated in groups addressing communication, interpersonal relationships, and interactions, non-violent conflict resolution, and critical thinking. The program s activity schedule contained daily groups. Additionally, the program provided groups on Don t Let Emotions Ruin Your Life, Girls for Success, healthy cooking classes, and mindfulness as part of Dialectical Behavior Therapy (DBT). Youth qualified to use class B tools are allowed to participate in the youth cleaning crew which complete housekeeping tasks on a regular basis. Youth participated in classes on manners, etiquette and cooking, including training on how to properly select fresh produce and meats. Public speaking training is also included for those youth training to lead tours for visitors entering the program Staff Training: Delinquency Interventions Compliance Staff whose regularly assigned job duties include implementation of a specific delinquency intervention model, strategy, or curriculum receive training in its effective implementation. There was documentation to support youth participated in Impact of Crime (IOC) and Thinking for a Change, (T4C) groups. An interview with the program s facility administrator indicated consideration is given to staff member s education, work experience, performance, and interest when determining which staff would deliver delinquency intervention groups and services. Additionally, the program conducts classification meetings to determine the needs of each youth based on their assessments and the team s discussion as to which staff/counselor/case manager would work best with each youth. A review of staff training files confirmed the appropriate training in specific interventions were completed Restorative Justice Awareness for Youth Compliance The program shall provide activities or instruction intended to increase youth awareness of, and empathy for, crime victims and survivors, and increase personal accountability for youths criminal actions and harm to others. The program completed three cohorts of the Impact of Crime (IOC) curricula for restorative justice since the last annual compliance review. The most recent IOC group initiated on January 11, An interview with the facility administrator and direct care staff as well as a review of program s daily activity schedule demonstrated the program provided instruction and regular activities which emphasized repairing harm caused by criminal behavior, increase empathy for crime victims and accountability for youth s criminal actions. The youth accept responsibility through reparation activities intended to restore victims and the community, including on-site community service projects. The youth participated in several restorative justice projects including creating health and hygiene gift bags for the homeless with Love and Hope in Action, Inc. and making fleece blankets for the residents of the Parkway Nursing and Rehabilitation Center. Youth in the program have the opportunity to earn community service hours on-site by participating in different projects such as cleaning crew, assisting with group preparation, and the youth advisory board. The facility administrator shared one recent activity initiated by the youth advisory board members who donated their program boutique points in order to buy items for the local pet shelter. Five case management records were reviewed and documentation revealed each youth s performance plan addressed restorative justice awareness. Office of Program Accountability Page 15 of 68 (Revised July 2016)

16 1.15 Delinquency Intervention Services Compliance The program shall implement a delinquency intervention model or strategy that is an evidencebased practice, promising practice, or a practice with demonstrated effectiveness, for each youth. Thinking for a Change (T4C) was used by the program as the primary delinquency intervention. T4C is noted in the Department s Sourcebook of Delinquency Interventions as an evidencebased intervention. The program also provided Impact of Crime, which is listed in the Sourcebook as a practice with demonstrated effectiveness. A review of the T4C group sign-in sheets and an interview with the facility administrator revealed the groups were delivered as designed. Examination of group sign in sheets and observations made during this review also revealed all youth received primary services including the gender-specific curricula Voices: A Program of Self-Exploration and Empowerment. All youth were matched with staff for intervention groups with input from the treatment team and clinical staff. Inspection of the program s daily activity schedule indicated sixty-five percent of the youth s awake hours encompassed structured, planned programming and activities Gender-Specific Programming Compliance The program provides delinquency intervention and gender-specific treatment services. An interview with the facility administrator indicated the program offered gender-specific treatment and delinquency intervention services through the utilization of various genderspecific curricula including Voices (A Program of Self-Discovery), Girls 4 Success, and Empowerment for Girls, which was provided in rotation with Teen Relationships. Staff were trained and used the SAVVY Sisters curriculum, which is tailored to the unique needs of the female youth population. Gender-specific treatment focus areas address sexual abuse, trauma, substance abuse, crime specific topics, as well as relational and emotional topics. The schedule indicated counseling groups were conducted each day of the week. Gender-responsive safety plans were tailored to each girl s individual trauma history, to ensure physical and emotional safety, assist in learning to regulate emotions, and develop healthy coping strategies. Additionally, the program allows youth to express themselves through individual selection specific clothing items such as underwear and a varied choice of offered hygiene products. Further, the program seeks recommendations from the youth advisory board for ways to make the program environment friendly to the population served. Five mental health records and group sign-in sheets were reviewed and documentation supported each youth s participation in groups applicable to their identified needs Logbook Entries and Shift Report Review Compliance The program maintains a chronological record of events, incidents, and activities in a central log-book maintained at master control, living unit logbooks, or both, in accordance with Florida Administrative Code. The program ensures direct care staff, including each supervisor, are briefed when coming on duty. The program utilized bound, hardcover logbooks with pre-printed numbered pages. Each logbook was specific to one month, and each preprinted date contained three sections, one for each shift. Facility logbooks were maintained by master control and the program did not utilize separate dormitory logbooks. Each reviewed entry contained the date, time, event, and printed name and signature of staff making the entry. All entries were documented in ink, with no Office of Program Accountability Page 16 of 68 (Revised July 2016)

17 erasures or correctional fluid observed. Very few errors were observed and each was stricken through with a single line. The logbooks documented admissions, releases, incidents, population counts, perimeter and security checks, drills and emergency situations, removal of youth from the population, as well as special instructions from mental health staff. Different entry types, such as head counts, alerts, and supervisor reviews were highlighted in different colors for ease of review. Supervisory reviews of the two previous shifts were consistently notated within the logbooks in red ink. The program utilized shift reports which were completed and reviewed with oncoming staff during briefings at the beginning of each shift in order for staff to review events from the previous two shifts Internal Alerts System Compliance The program shall maintain and use an internal alert system easily accessible to program staff and keeps them alerted about youth who are security or safety risks, and youth with healthrelated concerns, including food allergies and special diets. When risk factors or special needs are identified during or subsequent to the classification process, the program immediately enters this information into its internal alert system. The program ensures only appropriate staff may recommend downgrading or discontinuing a youth s alert status. The program maintained a written internal alert system which was accessible to program staff. The program maintained two dry erase communication boards in the employee break room, which identified youth placed on alerts for medical, mental health, safety, and special dietary precautions. The communication board also included a posted picture of each youth and their assigned sleeping room number. Confidentiality of information on the communication board was maintained by a wall mounted mini-blind, which was kept lowered to cover the alert board from casual view. During shift briefing, the internal alerts were addressed with all incoming staff. In addition, master control maintained an active internal alert board. The healthcare staff maintained a separate medical alert log to identify each applicable youth with medical condition restrictions, and to identify each youth s medical grade. An interview with the facility administrator and observations made during the annual review supported all alerts were updated daily by the program s departmental staff and/or shift mentors and reviewed by all staff at each shift briefing. Additionally, all critical alert issues are reviewed by program management during each morning meeting. Five surveyed staff indicated they utilized the alert board to stay informed of youth alerts. Additionally, staff indicated they also received youth alert information through the alert forms, the facility logbooks and shift meetings Alerts (JJIS) Compliance When risk factors or special needs are identified during or subsequent to the classification process, the program immediately enters this information into the Juvenile Justice Information System (JJIS). Upon recommendation from appropriate staff, JJIS alerts are downgraded or discontinued. A review of five case management records, five healthcare records, and five mental health and substance abuse records found all applicable medical, mental health, and/or gang alerts had been entered into the Department s Juvenile Justice Information System (JJIS) as required. There was documentation to support alerts were consistently and appropriately updated in JJIS when required, and removed when applicable. An interview with the facility administrator indicated alerts are entered and closed in JJIS by the appropriate staff for the type of alert, including medical, clinical and case management. Office of Program Accountability Page 17 of 68 (Revised July 2016)

18 1.20 Educational Access Compliance The facility shall integrate educational instruction (career and technical education, as well as academic instruction) into their daily schedule in such a way ensuring the integrity of required instructional time. A review of the program s daily schedule and observation during this review supported the incorporation of educational instruction into each youth s daily schedule. The reviewed documentation and an interview with the lead educator indicated each youth in the program were provided 250 days of instruction, consisting of 300 instructional minutes a day. A review of the schedule and facility logbooks reflected minimal interference with educational instruction hours. The lead educator indicated the program ensured the integrity of the required instructional time. The review of active and closed youth case management records found each youth s treatment team, transition plan, exit staffing included the attendance of representatives from the educational department Youth Records (Healthcare and Management) Compliance The program maintains an official case record, labeled Confidential, for each youth, which consists of two separate files: An individual healthcare record An individual management record. The program maintained three separate youth records for each youth consisting of healthcare, mental health and substance abuse, and case management. A review of five case management records found each was well organized and clearly identified the youth s name, Department of Juvenile Justice identification number (DJJID), date of birth, county of residence, and committing offense. Each case management record also included a color photograph of the youth on the exterior cover of the record. Each record was divided into six sections as required by Florida Administrative Rule 63E-7.015, and included a section for program information. Each reviewed record was marked Confidential. Each subsection was tabbed with preprinted dividers to facilitate ease of use. A review of five healthcare records and five mental health and substance abuse records found each identified the youth s name, identification number, date of admission, and were each marked Confidential. All youth records were securely maintained in locked offices with a Confidential sign on the door. Healthcare records were securely maintained in locked cabinets within the locked medical clinic when not in use Youth Input Compliance The program has a formal process to promote constructive input by youth. The program maintained a youth-led youth advisory board, which met monthly with facility administration to share feedback about the program, ideas for improvement, and plan future program activities. The elected president of the youth advisory board also served as a member of the community advisory board. The facility administrator indicated during an interview the Office of Program Accountability Page 18 of 68 (Revised July 2016)

19 program solicited input from the youth on a daily basis through the daily circle meeting where youth expressed issues and concerns relating to all areas of the program. Each program department sends a representative to the daily circle meeting to directly and immediately respond to the youth s concerns. Chatty Cathy forms are also used as a written process for youth to express their complaints and/or concerns directly to staff. The program utilized monthly electronic surveys administered to a random selection of youth to obtain their opinions specific to program services, and their perspective on how they were treated in the program. Youth and parent/guardian opinions were also obtained through a parent/guardian admission survey conducted through Survey Monkey. Additionally, youth and parents/guardians were also surveyed at the time each youth was discharged from the program. Five of five youth surveyed during this review reported having opportunities to provide input into what happens at the program Advisory Board Compliance The program has a community support group or advisory board meeting at least quarterly. The program director solicits active involvement of interested community partners. The program had a community advisory board comprised of representatives of community partners, the business community, Martin County School District, faith-based organizations, a local victim s advocacy agency, and a parent/guardian. The elected president of the program s youth advisory board participates on the community advisory board as the youth representative. An interview with the facility administrator revealed the community advisory board meets quarterly on the third Monday at 12 o clock noon. An interview with a board member representing a faith-based organization validated her involvement. In addition to attending the quarterly meetings, included establishing and facilitating a monthly book club with the youth, providing demonstrations and information on healthy cooking, and securing donations which were provided to the youth on Christmas morning. Documentation revealed the program solicited representatives of law enforcement and the judiciary for participation in the program s advisory board. Reviewed documentation demonstrated meetings were held each quarter with meetings conducted on March 28, June 27, September 26, and December 19, The program maintained documentation of invitation letters mailed on March 10, 2016 to solicit the participation of additional members. Additionally, s were utilized to remind members of upcoming board meetings Program Planning Compliance The program uses data to inform their planning process and to ensure provisions for staffing. The program solicited information on a range of issues through the utilization of quarterly electronic youth surveys, with forty-two youth surveyed since the last annual compliance review. Additionally, each youth s parent/guardian was mailed an invitation to participate on monthly conference calls in order to provide feedback to the program and to discuss any parent/guardian questions or concerns. Each parent/guardian was encouraged to complete an admission survey as an additional opportunity for their voice to be heard. Survey results were compiled into an aggregated report which was reviewed at the regional corporate level, by the program management and with staff at all-staff meetings. The program utilized the information obtained from the surveys for risk management processes, enhancement of systems, and key performance indicators. The facility administrator discussed the high level of employee morale at the program. The facility administrator and Assistant facility administrator attempt to make all staff meetings fun as well as informative and use them as an Office of Program Accountability Page 19 of 68 (Revised July 2016)

20 opportunity to recognize successes such as employee of the month and employee of the year. The program also conducted staff dress-up days such as jersey day for the Super Bowl. Program staff were provided survey results and various data reports at monthly all-staff meetings. Interviewed staff indicated the results aided in the focus of program improvement efforts. Additionally, trend data specific to the program from the provider s electronic records system is analyzed quarterly and shared with the program s management staff. The facility administrator reported the program s greatest area of staff turnover is related to the youth care specialist positions as they are entry-level positions whose selected candidates frequently leave for promotional opportunities or to return to school for educational advancement. Four of five staff responding to the survey reported being briefed on the Department s Comprehensive Accountability Report (CAR), youth and parent/guardian survey results, and annual compliance review reports. Four staff reported very good working conditions over the past year and one staff described the working conditions as good. Interviewed staff volunteered It s great working here, The program is constantly making improvement, Supervisors and workers are doing a great job with the youth and with each other Staff Performance Compliance The program ensures a system for evaluating staff, at least annually, based on established performance standards. The program maintained a written policy and procedures to address evaluation of staff performance. Documentation supported the program maintained position descriptions for each position title with corresponding performance standards. A reviewed of the position descriptions outlined the job functions and duties required of each position. A review of performance evaluations demonstrated the program conducted a ninety-day probationary performance evaluation for each new employee. Annual performance evaluations were completed for all staff agency-wide in the month of October. Annual performance evaluations included focus on the utilization of positive reinforcement and affirmation on a four-to-one ratio, whether or not staff interacted with youth in a fair, firm, and consistent manner, and the staff s use of motivational interviewing techniques with the youth. Staff were evaluated on their understanding and implementation of the program s positive performance system including consistency in providing rewards and/or consequences for behavioral violations. Staff were also measured on their understanding of youth stages of change. An interview with the facility administrator revealed the contents of annual evaluations are shared with staff who have the opportunity to provide input which may impact the scoring of their evaluation. Staff are encouraged to respond with comment as to their feelings regarding the evaluation. All five surveyed staff reported receiving written evaluations of their performance at least annually. Office of Program Accountability Page 20 of 68 (Revised July 2016)

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