Through a cooperative agreement between BJA and Impact Justice

Facility vs. Agency Audit

The PREA Online Audit System (OAS) allows users to complete facility or agency audits.  

Facility audits. The final PREA standards set forth guidance for the development of an audit that functions to evaluate and individual facility’s compliance with the PREA standards.  

Agency Audit is a new option for agencies to hire an auditor to conduct an agency-level – central office – audit of certain standards once annually.  The Agency Audit relieves facility auditors from the responsibility of auditing the same agency-level operations repeatedly during each facility audit; this will be particularly relevant for those agencies with more than one facility. 

The Agency Audit is an audit of a limited number of standards that regulate conduct that takes place primarily or solely at the agency or central office level. These standards are:

115.11(b) PREA Coordinator
115.12 Contracting with other entities for the confinement of inmates
115.17 Hiring and promotion decisions
115.66 Preservation of ability to protect inmates from contact with abusers
115.87 Data collection
115.88 Data review for corrective action
115.89 Data storage, publication, destruction
115.401(a) and (b) Frequency and scope of audits
115.403(f) Audit content and findings

Facility audits within that agency will not include a re-audit of those standards and provisions that cover operations that happen solely at the agency or central office level. However, certain standards or standard provisions that are part of the agency audit may be re-audited at the facility level if the facility has some responsibility, separate from the agency's responsibility for those standards or provision. For example, if an agency has a collective bargaining agreement that is governed by 115.66, but facilities within that agency have their own collective bargaining agreements with their staff, those facility agreements will have to be audited during the facility audit. If there are no separate facility agreements (i.e. the facility has no shared responsibility for the collective bargaining agreements), as determined by the facility auditor, then that standard will not have to be audited at the facility level.

The OAS allows the seamless sharing of specific information across audits within an agency and allows an Agency Audit to suffice where only agency operations are implicated, thus creating tremendous efficiencies for auditors and agency- and facility-based staff responsible for preparing for an audit.

The Agency Auditor will conduct interviews of agency-level staff, such as the head of the agency and the PREA Coordinator, and provide those notes so that facility auditors may view them while conducting facility audits (who, if adequate, may not have to repeat those interviews at each facility audit).

The OAS also creates the possibility for agencies to share extensive information prior to facility audits without having to send that information separately to each facility. Once completed by the Agency PREA Coordinator, the Agency Profile and Other Documentation checklist provides facility PREA Compliance Managers with agency-level policies, procedures, processes, and documentation. This will mean that when the facility-based audit preparation begins, the facility PREA Compliance Manager can pull relevant agency policies and information provided via the checklist into their Pre-Audit Questionnaire for their facility audit.

The results of an Agency Audit will be valid for one year. As long as the agency has a current (annual) Agency Audit in the OAS, facility auditors will not have to audit the relevant agency-level standards. If the Agency Audit becomes out of date, those standards that are part of the Agency Audit will automatically become part of the facility auditors' audits.