PREA AUDIT: AUDITOR S SUMMARY REPORT JUVENILE FACILITIES Name of Facility: Bucks County Youth Center Physical Address:1750 Easton Road Doylestown, PA 18901 Date report submitted May 13, 2014 Auditor information Dan McGehee Address PO Box 595 White Rock, SC Email: mc72fsud@aol.com Telephone number: 803-331-0264 Date of facility visit March 10-11, 2014 Facility Information Facility Mailing Address: (if different from above) Telephone Number: 215-340-8300 The Facility is: Military County XXX Federal Private for profit Municipal State Private not for profit Facility Type: Detention XXX Correction Other: Name of PREA Compliance Manager: John Corr Email Address: jfcorr@ co.bucks.pa.us Agency Information: Bucks County Youth Center Name of Agency Governing Authority or Parent Agency: Bucks County Court of Physical Address: 55 East Court St. Doylestown, PA Mailing Address: (if different from above) Telephone Number: Agency Chief Executive Officer Name: Ted Rice Email Address: tjrice@co.bucks.pa.us Title: Deputy Director Telephone Number: Title: Director Telephone number: 215-340-8300 Agency Wide PREA Coordinator Name: Ted Rice Email Address: tjrice@co.bucks.pa.us Title: Director Telephone number: 215-340-8300
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AUDIT FINDINGS NARRATIVE: The Bucks County Youth Center is a 60 bed juvenile center constructed and opened in 1996 in Doylestown Township. It provides secure detention and community-based residential services for the Bucks County Court of Common Pleas, Juvenile Court Division. Both programs are licensed by the PA Department of Public Welfare. The Bucks County Youth Facilities are comprised of two distinctive programs. Juvenile Detention provides secure care and custody for those youths presently being processed by the Bucks County Juvenile Court. The Residential Service Unit provides long-term residential and counseling services to adjudicated youths in a non-secure setting. It is a community-based program that allows adjudicated youths to attend traditional schools and seek employment while living in a structured and supportive setting. Secure detention services are initiated with a mental health assessment to help provide a safe and neutral setting for the youths while court proceedings are conducted to determine the best course of action in achieving balanced and restorative justice. In addition to the youths individual needs, the needs of victims and the community as a whole must be equally represented to satisfy the principles of restorative justice. The Residential Service Unit focuses on assessment, treatment planning and service delivery to youths including individual, group, and family counseling. In addition to these services, youths are offered a variety of competency development skills in order to aid them in becoming more productive citizens upon returning to their communities. DESCRIPTION OF FACILITY CHARACTERISTICS: The facility is a single-story, cinder block constructed building. It consists of 5 individual living units, 3 of them licensed as secure detention and 2 of them licensed for community based residential (non-secure). Each living unit contains 12 single occupancy rooms, a common day room, staff office, quiet room and bathroom facilities. The building also consists of a full sized gymnasium, 60 seat dining room, multipurpose area, 5 classrooms, control center, intake area, kitchen/laundry/maintenance area, and an outdoor courtyard. The overall indoor space is approximately 48,000 square feet. There is also a detached garage and vegetable gardens on the premises. A parking lot with 78 spaces is directly in front of the facility. The building has Honeywell Enterprise System that includes camera surveillance both on the interior (34 cameras) and exterior (17 cameras) of the facility; fire, smoke and sprinkler system; HVAC and a full building back-up generator that provides uninterrupted electrical power. Other security systems include a Senstar man down pager system for staff that uses an ultra-sonic signal and Pipe data system that records building security rounds. PREA AUDIT: AUDITOR S SUMMARY REPORT 3
SUMMARY OF AUDIT FINDINGS: The audit was conducted at the Bucks County Youth Center on March 10-11, 2014. It commenced with a brief entrance interview with the director and deputy director followed by a tour of all areas of the facility. The facility was exceptionally clean and well maintained. It was brightly painted, with art work of the residents hanging throughout the facility. There was a day-room space with recreation equipment located adjacent to the cafeteria. Staff were questioned throughout the facility about their areas and responsibilities. Following the tour staff and residents were interviewed separately about PREA and were all found very knowledgeable of the subject including reporting requirements and methods. Health care services for Bucks County Youth Center are provided by PrimeCare Medical, Inc., a private health care provider. Interviews with medical staff and review of related PREA medical policy and procedures indicated that they were trained in their responsibilities of the PREA law. Staff training included zero tolerance and detection and assessment of sexual abuse and proper reporting procedures. Any suspected substantiated case of sexual abuse is transported to a local medical facility for evaluation by a qualified SANE medical person. Computerized health care records have included PREA intake procedures. Residents of Bucks County Youth Center have at least two avenues to contact independent agencies to report instances of sexual abuse and/or sexual harassment. One is through the private health care provider, PrimeCare Medical, Inc. A sick call request can be placed in one of two secured sick call pass boxes located in the common dining area and checked several times daily. Only PrimeCare Medical, Inc. personnel have access to these boxes. The second is through Network of Victim Assistance (NOVA), a local 24-hour hotline for crisis support. This notification is through telephone calls placed through telephones located in the common area of each housing unit. Name and telephone numbers for NOVA are located at each telephone and contained in information given to residents during intake orientation. Unfortunately, when tested by the auditor, the system was inoperable. The facility was making efforts to have the phone service provider correct the problem as the auditor departed. The facility has had no accusations of staff sexual harassment or sexual abuse. Bucks County conducted one administrative investigation within the last 6 months and it was determined to be unfounded. At the beginning of the on-site visit, the auditor discussed with the facility director and the deputy director the lack of specificity in policy references on the PREA Pre-audit questionnaire. The facility director and his deputy worked for most of the first day of the visit adding that policy specificity for review by the auditor. It became evident that there were several areas where policy needed to be written or revised to cover the PREA standards. In some cases secondary documentation would also have to be developed and implemented for standards compliance to be achieved. Prior to leaving the facility, the auditor left a plan of action form as well as detailed notes on non-compliant standards for facility staff to begin working for a successful conclusion to the PREA audit. SINCE THE AUDIT: The Bucks County Youth Center Policy for PREA has been totally rewritten to include all of the language of the standards and procedures for implementing same. This impacted significantly on being able to find compliance with the applicable PREA standards for Bucks County. Number of standards exceeded:0 Number of standards met:42 Number of standards not met:0 PREA AUDIT: AUDITOR S SUMMARY REPORT 4
Standard 115.311 Zero tolerance of sexual abuse and sexual harassment. Standard 115.313 Supervision and Monitoring The policy and procedure needs to be revised to cover sections a, b, c, and d of the standard. Additionally, documentation needs to be provided for the annual review of the staffing plan. 2. Submitted documentation verifying that the staffing plan of 6:1 has always been followed. 3. Submitted the unannounced PREA rounds log for the last four months. Standard 115.314 Youthful residents Standard 115.315 Limits to cross gender viewing and searches. PREA AUDIT: AUDITOR S SUMMARY REPORT 5
Policy and procedure needs to be revised to cover all sections of the standard. 2. Submitted training curriculum lesson plan for resident body searches. 3. Submitted three examples of staff training signatures for attending staff training on how to conduct cross gender pat down searches and searches of transgender and intersex residents. Standard 115.316 Residents with disabilities and residents who are limited English proficient Policy needs to be revised to reflect all sections of the standards. Staff should develop documentation for residents with disabilities and limited English proficiency. SINCE THE AUDIT:1.Revised the policy and procedure to cover all requirements of the standard 2. Submitted resident information packet translated in Spanish as an example of communication to Non-English speaking admissions and supporting documentation. 3. Cited examples in policy covering Bi-lingual staff, educational audios for the blind, available tutors for learning disabled residents, and posting of bilingual posters in the facility. Standard 115.317 Hiring and promotion decisions Revise policy and procedure to include the language of the standard. Secondary documentation would be to provide samples mentioned in the policy: for example criminal background checks for employees and contractors. PREA AUDIT: AUDITOR S SUMMARY REPORT 6
2. Provided sample documentation of criminal background checks of employees and contractors. Standard 115.318 Upgrades to facilities and technology Standard 115.321 Evidence protocol and forensic medical examinations. Standard 115. 322 Policies to ensure referrals of allegations for investigations Facility should revise policy to cover all aspects of standard. The revised policy should then be posted on the website. 2. Published the policy regarding referrals of allegations for investigations on the Bucks County Youth Center website. PREA AUDIT: AUDITOR S SUMMARY REPORT 7
Standard 115.331 Employee training Facility should revise policy to cover all aspects of the standard. Employee training should be documented with employee signatures. 2. Provided sample documentation of employee signatures for receiving PREA training. Standard 115. 332 Volunteer and contractor training Facility should revise policy to cover all aspects of the standard. Training for volunteers and contractors should be documented. 2. Provided sample documentation of volunteer/contractor signatures for receiving PREA training. Standard 115.333 Resident education PREA AUDIT: AUDITOR S SUMMARY REPORT 8
Facility should revise policy to cover all aspects of the standard. Signatures of employees on training rosters should be provided. 2. Provided sample documentation for residents reviewing the Bucks County Resident education video for PREA entitled What you need to know. Standard 115.334 Specialized training: Investigations Revise policy and procedure to cover the facility director and deputy director conducting administrative investigations. Also document the training with employee signatures. 2. Provided documentation of both the training curriculum and the signatures of administrators who had received training in conducting administrative investigations. Standard 115.335 Specialized training: Medical and mental health care Revise policy and procedure to cover all aspects of the standard. Document training for medical and mental health staff with signatures. 2. Provided a roster of employees who have received PREA training signed off on by the Prime Care regional administrator. PREA AUDIT: AUDITOR S SUMMARY REPORT 9
Standard 115.341 Screening for risk of victimization and abusiveness Standard 115. 342 Use of screening information Revise policy and procedure to cover all aspects of the standard. Documentation of where policy was followed for bed assignment should be provided. 2. Provided 3 sample copies of the BCYC Health and Safety evaluation. 3. Provided 3 sample copies of resident safety plans for the same three residents. Standard 115.343 Protective custody Standard 115.351 Resident Reporting
Revise the policy and procedure to cover all aspects of the standard. Provide documentation where policy was followed SINCE THE AUDIT: 1. Revised policy and procedure to cover all requirements of the standard 2. Provided a copy of the resident handbook showing reporting information for both residents and parents. 3. Revised policy under resident reporting to have phone system verified weekly by senior staff and document findings 4. Provided three examples of senior staff verifying a working phone system. Standard 115.352 Exhaustion of administrative remedies Revise the policy and procedure to cover all aspects of the standard. SINCE THE AUDIT: 1. Revised policy and procedure to cover all requirements of the standard. 2. Provided a copy of the resident grievance policy as supporting documentation that provides procedure information to residents. Standard 115.353 Resident access to outside confidential support services Standard 115.354 Third-party reporting
Standard 115.361 Staff and agency reporting duties Standard 115.362 Agency protection duties Standard 115.363 Reporting to other confinement facilities Revise policy and procedures to cover all aspects of the standard. Standard 115.364 Staff first responder duties
Standard 115.365 Coordinated response Standard 115.366 Preservation of ability to protect residents from contact with abusers. Standard 115.367 Agency protection against retaliation Revise policy and procedures to cover all aspects of the standard. Standard 115.368 Post allegation protective custody
Standard 115.371 Criminal and administrative agency investigations Revise policy and procedures to reflect the standard. Standard 115.372 Evidentiary standards for administrative investigations Revise policy and procedures to cover all aspects of the standard. Standard 115.373 Reporting to residents Standard 115.376 Disciplinary sanctions for staff
Revise policy to cover all aspects of the standard. Standard 115.377 Corrective action for contractors and volunteers Policy revision to cover all aspects of the standard Standard 115.378 Disciplinary sanctions for residents Revise policy to cover all aspects of the standard. Standard 115.381 Medical and mental health screenings: history of sexual abuse Revise policy to cover all aspects of the standard. Needs sample of secondary
medical/mental health forms Consent documentation for over 18 years of age. Sample of resident confinement records, etc. SINCE THE AUDIT: 1. Revised policy and procedure to cover all requirements of the standard. 2. Provided a copy of the Pennsylvania Dept of Public Welfare 3800 regulations defining medical/health care standards as supporting documentation. Standard 115.382 Access to emergency medical and mental health services Revise policy to cover all aspects of the standard. Standard 115.383 Ongoing medical and mental health care for sexual abuse victims and abusers Revise policy to cover all aspects of the standard. 2. Provided a copy of the MOU (Memorandum of Understanding) with NOVA (Network of Victims Assistance) as supporting documentation. Standard 115.386 Sexual abuse incident reviews
Revise policy to cover all aspects of the standard. Documentation of sexual abuse incident reviews. 2. Provided a list of incident review team members as supporting documentation Standard 115.387 Data collection Revise policy and procedures to cover all aspects of the standard. Data collection instrument sample Standard 115.388 Data review for corrective action Revise policy and procedures to cover all aspects of the standard. Documentation of corrective action plans and annual report of findings from data review. Post website where annual report is available. 2. Provided a copy of the published 2013 Bucks County Youth Center Annual Report overview as supporting documentation.
Standard 115.389 Data storage, publication and destruction Policy revision required to cover all aspects of the standard. Copy of the law indicating length of storage time. AUDITOR CERTIFICATION: The auditor certifies that the contents of the report are accurate to the best of his/her knowledge and no conflict of interest exists with respect to his or her ability to conduct an audit of the agency under review. _ May 13, 2014 Auditor Signature Date