Case Studies

Alvis House

“I have never had a minute of doubt about the importance of the PREA legislation and the need for these standards, and I wanted in on the ground floor of their implementation in community corrections. In my view, compliance with PREA is a moral obligation, not just a legal one.”

—Denise Robinson, President and CEO, Alvis House

Alum Creek

Alvis House, a nonprofit human services agency in Ohio, has been at the forefront of residential community corrections agencies planning for PREA implementation. In 2007, Denise Robinson, president and CEO of Alvis House and then the immediate past president of the International Community Corrections Association, testified before the National Prison Rape Elimination Commission on the duty of community corrections agencies to protect their clients from sexual abuse. Under Robinson’s leadership, Alvis House has implemented numerous policies and procedures aimed at protecting clients from sexual abuse and fully embraced the recently released PREA standards. Starting with a strong zero-tolerance policy toward all forms of sexual abuse, facility directors and staff work to ensure all aspects of the agency’s sexual abuse prevention and response efforts create a culture of zero tolerance. These efforts include:

  • Comprehensive staff training and client education;

  • Use of intake screening information to determine room assignments and develop individualized plans for clients;

  • Multiple channels for clients to report abuse;

  • A two-pronged approach to sexual assault response, using clinical client assistance teams (CATs) and administrative sexual assault response teams (SARTs); and

  • Physical plant vulnerability assessments and targeted use of video-monitoring technology.

As Alvis House works to comply with the US Department of Justice’s PREA standards, leadership will continue to assess operations, plan for change, and implement policies and procedures. Leaders are currently researching staffing and hiring practices, planning for ways to implement more frequent background checks, and changing employee verification procedures.

Facts About Alvis House and Timeline of PREA Events

  • Alvis House has two divisions: one serving individuals and families involved in the criminal justice system and one that provides services to individuals with developmental disabilities.

  • Operates a total of 23 locations that serve more than 7,000 people a year.

  • No secure, locked-down facilities.

  • More than 300 staff and more than 460 residential community corrections beds.

  • Nine residential facilities located throughout Ohio.

  • Programs use a research-based, integrated treatment approach.

  • Typical length of stay in Alvis House residential community corrections programs is 90–120 days for clients without specialized mental health needs or developmental disabilities.

Alvis House Timeline

Keeping PREA in Perspective

At Alvis House, client safety has always been a priority, and leadership and staff approach PREA as one more way of ensuring a safe, healthy culture. Like many in corrections who have embraced PREA, Alvis House leaders employ current best practices in community corrections to help combat sexual abuse. For example, Alvis House uses gender-responsive classification and treatment tools, motivational interviewing techniques, and individualized case management practices to run safe facilities. By leveraging Alvis House’s existing policies and practices to help prevent sexual abuse and improve response when it does happen, leaders have established a nimble system that prioritizes staff training and clear policies and procedures to protect the safety and well-being of clients.

As Robinson explains, “PREA just formalizes and establishes uniform standards to: prevent sexual abuse; provide avenues for reporting sexual abuse; establish support systems for victims; investigate and respond to allegations of sexual abuse; and train staff, clients, and vendors in how to prevent, recognize signs of sexual abuse, and report.”

By taking this straightforward approach of working with what they have, rather than creating entirely new structures and systems, Alvis House has been able to assess its policies and operations according to the requirements in the PREA standards, plan for changes, and implement those changes in stages.

Alvis House’s PREA Efforts

This section highlights some, but not all, of the efforts Alvis House has made to embrace PREA. These useful and, at times, innovative practices may be helpful to other community corrections agencies as they consider how to comply with PREA.

Staff Training

Alvis House leadership counts its employee training structure and process as one of the most effective tools the agency has for preventing and responding to sexual abuse. All new employees attend training during orientation week that covers:

  • The agency’s zero-tolerance policy on sexual abuse/assault/harassment toward clients and staff;

  • Specific procedures for documenting and reporting allegations of client or employee sexual misconduct; and

  • The agency’s Code of Ethics, which explicitly prohibits staff forming personal relationships with former clients for the first two years after clients complete the program.

Additionally, residential program staff are required to complete in-service training as follows:

  • Staff must complete a minimum 40 hours of annual in-service training, which includes training on sexual abuse prevention and response. This helps ensure that residential staff stay current on all mandatory and critical processes and procedures and also reinforces the agency’s commitment to protecting its clients’ physical, emotional, and mental health.

  • Alvis House has implemented weekly “Back to Basics” training in mandatory staff meetings. The “Back to Basics” training takes the form of dialogue and discussion on different PREA-related topics and allows staff and treatment teams to explore different client issues, needs, and possible solutions on an ongoing basis.

Alvis House leaders credit this training with helping to keep staff “at the ready” when it comes to sexual abuse, given how infrequently incidents occur.

Client Education

Clients receive a comprehensive information packet upon admission to Alvis House. This packet covers sexual abuse prevention and intervention and affirms the client’s right to be safe from sexual abuse as well as the client’s right to confidentiality and privacy. It also directs clients on how to seek medical help, explains the investigative process, lists counseling programs for victims of sexual abuse, and lists who to contact if a client is sexually abused. After learning about these policies at intake, clients have the opportunity to discuss them in depth with their case managers or in house meetings, which take place every other week.

Intake Screening

Since the late 1990s, clients have completed a health care screening during their initial intake into Alvis House. The current screening questionnaire has evolved over time to include questions about gender, sexual orientation, and prior sexual victimization. Once completed, treatment teams—comprising the facility director, clinicians, parole and probation officers, case managers, family members (if the client chooses), and any community providers working with the clients—use the results to develop individualized treatment plans for each client. These individualized treatment plans include room assignments, programs, trauma response, and mental health care. While the health screening questionnaire helps staff consider potential risk factors for sexual vulnerability or aggression, Alvis House is also in the process of developing a specific screening instrument for risk of sexual abuse.

Reporting

Alvis House has made a concerted effort to ensure clients have multiple ways to report sexual abuse. During client orientation, staff let clients know they can report verbally to any staff member. Alvis House has a hotline to report sexual abuse, and clients can also call 9-1-1 directly to report. Additionally, the client handbook, which all clients receive, outlines the grievance procedure, which clients can use to report abuse. If a client reports an incident of sexual abuse through the grievance system, the facility manager immediately reports it to the PREA coordinator, human resources, and/or the vice president of programs. The complaint is then transferred out of the grievance system, and the CAT, SART, and law enforcement are notified.

Another particularly innovative reporting mechanism currently under development at Alvis House is an online form for reporting sexual abuse/harassment. The form, currently in draft, eventually will be available publicly on Alvis House’s website and accessible to clients and third parties who might want to report sexual abuse on a client’s behalf. The form includes fields for basic information about an incident, and the user will receive an automatic response upon submitting the form with the PREA coordinator’s contact information.

Finally, Alvis House administers satisfaction surveys to clients twice during their stay—once during the middle of their stay and again upon release. The survey gives clients an opportunity to report anonymously any abuse, mistreatment, or complaints they have. Survey results are sent to the director of quality assurance who aggregates the data and presents it to the vice president of operations, associate vice president of communications, and president. They review the data and take any necessary action.

Client Assistance Teams and Sexual Assault Response Teams

When the National Prison Rape Elimination Commission issued its recommended PREA standards in 2009, Alvis House determined its Client Assistance Teams (CATs), comprising clinicians and designed to prevent and respond to suicides and homicides, were the most qualified bodies to respond to client victims of sexual abuse, as well. When a report of sexual abuse is made, the facility manager (or manager on call, if after business hours) contacts a designated CAT member, reports to the PREA coordinator, and notifies law enforcement. The CAT member immediately makes direct contact with the victim, evaluates his or her needs, and informs him or her of the options and resources available for treatment and healing. The CAT member also accompanies the victim to the hospital if a forensic medical exam is indicated.

The CAT member reports his or her assessment of the incident and the victim’s needs to the PREA coordinator, who convenes an administrative sexual assault response team (SART). The SART, which evolved out of a quality assurance committee, includes the vice president of clinical services (a licensed psychologist), vice president of operations (PREA coordinator), vice president of agency programs (residential facilities), director of accreditation, program directors (residential facilities), quality assurance/staff development coordinator, volunteer coordinator, and the associate vice president of communications. The SART reviews the entire incident to make sure agency policies and procedures were followed and to determine what went well and what improvements should be made for future cases. The SART discusses the details of the case and reviews the CAT’s assessment to make sure the victim is safe and receiving appropriate treatment. It also looks at whether criminal investigators were able to substantiate the incident. If policy or protocol changes are required as a result of these reviews, the SART has the authority to make changes. Recommended changes are drafted and presented to the agency president for consideration.

Video-Monitoring Technology

When Alvis House began conducting physical plant vulnerability assessments of its residential facilities in 2006, it found a number of unmonitored, potentially vulnerable areas. Leadership worked with facility directors to relocate existing cameras and widen the angle of view to minimize blind spots, but also chose to invest significant resources in purchasing additional cameras for residential facilities. Alvis House also installed and upgraded DVR systems, which has enhanced security, accountability, and transparency by:

  • Increasing recorded video capacity from two weeks to 30 days; and

  • Providing facility directors with remote access to facilities 24 hours a day.

Alvis House has also used cameras to assist local policing efforts to curb illegal drug activity around some of its residential facilities. Recognizing that some facilities are located in communities with high drug-related activity, the agency placed cameras outside those facilities. Because Alvis House recognizes the connection between drug use and risk of victimization, particularly for its female clients, it views its partnership with law enforcement as part of the broader efforts to prevent sexual abuse.

Q&A with Denise Robinson, President and CEO of Alvis House

Alvis House Logo

Q. From your PREA work to date, what advice can you share with residential community corrections practitioners who are just beginning to review the standards and grapple with compliance?

A. The first thing I would say is: Don’t panic. Many of the best practices that have been implemented throughout community corrections—such as gender-responsive classification and treatment, motivational interviewing, and case management—have all contributed to effective prevention and response to sexual misconduct, even though they were not instituted in direct response to PREA. So you are already further along than you think you are. 

Agencies should do a self-audit of their current policies and procedures compared to the PREA standards. When they do, they will realize that many of their existing policies and procedures can be enhanced, and they don’t need to reinvent the wheel. I don’t know of any organization that does not have a basic policy against sexual harassment. This can serve as the baseline for assessing what it would require to comply with the PREA standards, and they can go from there. The likely challenges will involve communicating client rights and options upon entry to your program, and being clear that this is a serious issue without appearing to encourage frivolous, unfounded claims against other clients or staff.

My other piece of advice is don’t create a PREA bureaucracy; the focus should be on establishing a system that flows quickly and keeps the safety and well-being of clients at the forefront of all agency policies and procedures.

Q. Which of the PREA standards should a community corrections agency tackle first?

A. Before an agency tackles any standards, its leadership needs to make a commitment to the importance of becoming PREA compliant, and leadership needs to be vocal about this support. There should be no question in the agency about leadership’s high level of commitment to client care and meeting the PREA standards. Then, leaders will need to review staff and appoint a PREA coordinator. The best fit for this position is likely someone with human resources experience, because those individuals are generally well-versed in how to handle sexual harassment, discrimination, and related issues in the workplace. Next, an agency should conduct an assessment of its current policies compared to the PREA standards. When the assessment is done, an agency will have its “to-do” list to meet the PREA standards.

Q. As you continue to work toward compliance with the PREA standards, what challenges do you anticipate facing? How do you think you will overcome those challenges?

A. Right now, there is a lot of information and interest in becoming PREA compliant. We are talking about it a great deal at the agency and have revised some staff training materials, client care procedures, and added reporting mechanisms specific to PREA. However, our history tells us sexual assault within our programs is very rare. One challenge going forward will be to maintain a level of readiness in the absence of events.  

Another challenge not specific to PREA is money. There are costs to implementing some of the standards. For example, PREA requires criminal background checks at a higher frequency than we had been doing in the past, and there are costs that go along with conducting additional background checks. We have overcome that challenge by being proactive and working ahead to ensure we build those costs appropriately into future budgets. That also helps us to look at different ways to meet the standard as efficiently as possible. Specifically with background checks, we have committed to purchasing new technology, which has a high up-front cost but will save us money over the long term.

We have also addressed monetary concerns by carefully looking at what we already have in place and how it can be adapted to meet PREA standards at little to no cost.

Alvis House Resources

Additional Resources

Preventing and Responding to Corrections-Based Sexual Abuse: A Guide for Community Corrections Professionals by Carrie E. Abner, Jane Browning, and John Clark

Colorado Department of Human Services, Division of Youth Corrections

“Youth correctional agencies have both a legal and moral obligation to prevent sexual violence in our facilities. That is why it is critical to implement and promote policy, procedure, practice, training, and awareness for both staff and youth.”

—John Gomez, Director, Colorado Department of Human Services, Division of Youth Corrections

Division of Youth Corrections

With the recent release of the final PREA standards by the US Department of Justice (DOJ), correctional agencies are working hard to come into compliance. The Colorado Department of Human Services, Division of Youth Corrections (DYC) is poised to embrace these standards, building on a strong framework created in 2007 that allows DYC to adapt to new challenges as they arise.

In 2007, DYC organized a committee to review the Prison Rape Elimination Act, assess agency operations, and develop a process for sexual abuse prevention and education. Working with The Moss Group and the National Institute of Corrections, and using resources from the Washington College of Law’s Project on Addressing Prison Rape, the PREA committee’s early efforts focused on training staff, developing educational materials for youth, and creating an assessment tool for screening youth for risk of sexual victimization and/or aggression. Since that time, DYC has refined and implemented a number of policies and procedures aimed at keeping youth and staff safe from sexual abuse:

As DYC prepares to implement DOJ’s PREA standards, leadership will ground their efforts in the established framework of assessing operations, planning for change, and implementing policies and procedures. DYC has already assembled a short-term PREA assessment team and has committed to integrating PREA into all aspects of the agency’s culture and operations.

Facts about DYC’s State-Operated Facilities and Timeline of PREA Events

  • Ten secure, state-operated facilities in four regions throughout the state
  • Approximately 395 adjudicated youth committed to state-operated facilities
  • No more than 422 pre-adjudicated youth detained in state facilities at any given time
  • Average length of stay for adjudicated youth is 18.3 months
  • Colorado statute permits custody until age 21
  • Average length of stay for pre-adjudicated youth is 13 days

CO DYC Timeline

Keeping PREA in Perspective

DYC’s leadership team believes that facility culture impacts all aspects of a facility, including sexual abuse. DYC therefore grounds all of its decisions, including its approach to PREA, in the division’s Key Strategies and Core Values. As Director Gomez explains, “the strategies are how we do our work. The values are how we expect our staff to treat youth, families, and each other.”

Key Strategies

To illustrate how strategies work in concert with PREA, DYC’s strategy to “provide the right services at the right time” coincides with the PREA requirement to provide victims with timely access to medical and mental health care. Another example is DYC’s strategy to “ensure safe environments,” which lines up with the standards’ overall goal to ensure sexual safety. One way DYC does this is through its Sexually Aggressive Behavior/Vulnerability to Victimization (SAB/VV) Assessment, which is designed to ensure safe placement of youth and heighten staff awareness of risk. Likewise, DYC conducts annual physical plant vulnerability assessments, which reveal risk areas and allow for planning to mitigate the risk, such as mirrors, windows, or removal of walls. In addition to annual assessments, PREA incidents trigger assessment of the area where the incident occurred—an administrator and select staff immediately assess the area to determine what steps must be taken to prevent future incidents.

The division’s core values are designed to build a culture that can support PREA, but go above and beyond PREA’s requirements. For example, staff who act with integrity will create an environment in which residents feel safe to report perceived risks of victimization or actual incidents of sexual abuse. Such staff do not support a code of silence, but instead report staff misconduct. Similarly, staff who regularly treat all youth with respect will be more inclined and equipped to respond to victims of sexual abuse in a compassionate, victim-centered way, rather than a distrustful, victim-blaming manner.

DYC’s PREA Efforts

The sections that follow highlight some, but not all, of the efforts DYC has made to embrace PREA. These useful and, at times, innovative practices may be helpful to other agencies as they consider how to embrace PREA.

Sexual Contact Prevention Policy

DYC’s Sexual Contact Prevention Policy sets out comprehensive procedures to identify, monitor, counsel, and track juveniles who may have a “propensity to perpetrate sexual abuse or who may be vulnerable to sexual victimization.” The policy also requires that DYC employees, contractors, volunteers, and individuals providing services at the facility be trained to recognize abuse and take appropriate action. Finally, the policy requires that juveniles receive orientation and education about sexual abuse and the reporting mechanisms available.

Sexually Aggressive Behavior/Vulnerability to Victimization Instrument

In 2007, DYC instituted their Sexually Aggressive Behavior/Vulnerability to Victimization (SAB/VV) Overall Risk Assessment Instrument. In developing the instrument, DYC referred to screening instruments developed in Florida, Ohio, and New Zealand. DYC staff administer the instrument within two hours of intake on all new arrivals, whether detained or committed. DYC also uses the tool to reassess juveniles deemed a potential/documented sexual victim or sexual aggressor; convicted of a major rule violation for nonconsensual sexual contact or abusive sexual contact; or who have disclosed being a victim of nonconsensual sexual contact or abusive sexual contact. In 2012 DYC revised their instrument to include the ability for staff to use researched collateral information for more accurate assessments. In addition, the instrument scoring was changed to provide more concrete, consistent scoring outcomes. Finally, in 2012 DYC developed a guide to accompany the instrument. The guide provides interpretation of questions, scoring requirements, and a guide for consistent approaches to overriding results.

While not validated, the SAB/VV enables DYC to assess the needs of juveniles on an ongoing and consistent basis, allowing staff to make informed decisions about juveniles’ housing placements within the facility. In addition, the instrument provides classification of risk, which is used for monitoring groups within programming. Finally, the instrument is one of many tools used to establish direction and provide services based on identified needs.

Staff Training

DYC provides a comprehensive training program to prevent sexual assaults and misconduct through initial and ongoing training. The division utilizes a three-pronged approach to training staff. All new personnel complete a three-week training designed to teach skills in the areas of policy, procedure, PREA, staff safety, and programming expectations. Within the pre-service academy, staff not only receive PREA-related expectations, but are trained in components of de-escalation, working with difficult youth, and safe programming. Upon completion of pre-service training, all staff receive an on-the-job period for training on facility-specific operational procedures. From a PREA perspective, they are taught how to administer and interpret instruments and how to develop a milieu culture that promotes zero tolerance for sexual activity. Finally, each staff receives annual training in the arena of PREA. Annual training is designed to review all aspects of PREA standards, utilization of instruments, milieu management, and a healthy zero-tolerance culture.

PREA Workgroup

After release of the final PREA standards in May 2012, the DYC leadership team established a short-term assessment workgroup—similar to the teams assembled in 2007 and 2009—to assess the standards, determine the extent of DYC’s compliance, and recommend necessary improvements to ensure full compliance. The workgroup’s term is expected to last three months and will involve members from the leadership team, quality assurance, regional staff, research, behavioral health and medical services, educational services, a Department of Human Services’ human resources representative, a representative from contracted facilities, and representatives from state-operated facilities. During its tenure, the workgroup will undertake a multi-dimensional assessment of the DYC organization and facilities. The workgroup will use the results of this assessment to develop a comprehensive work plan to guide DYC’s efforts to bring them into full compliance.

Youth Survey – Sexual Contact

In 2008, DYC began surveying youth about sexual safety in individual facilities. In 2009, DYC began administering a formalized, statewide survey to both detained and committed youth regarding sexual contact. The survey, adapted from the National Survey of Youth in Custody (NSYC) by the Bureau of Justice Statistics (BJS), asks detained youth about their sexual contacts at their current facility over the previous three months and committed youth about their experiences over the previous six months. DYC administers the survey multiple times a year. Since its launch, the survey has been administered eight times. DYC uses the data primarily to help guide prevention efforts within the facilities.

DYC considers this survey process an effective tool for measuring how well the culture of its facilities reflects policies and procedures prohibiting sexual abuse. For example, DYC policy requires that staff distribute educational brochures about sexual abuse to youth, and the survey asks youth whether they received this information. If a number of youth answer “no,” facility leaders know to talk to staff and determine when and where the breakdown occurred. Similarly, while the survey is designed for data collection only, if youth report sexual contacts occurring in specific areas or at certain times of day, leaders are alerted to problem spots they need to address. If, for instance, youth report sexual contacts occurring during school hours, leaders will talk to teachers and assess whether classroom configurations need to be altered.

Q&A with Dave Maynard, Director of Facility Operations, North Central Facilities DYC Logo

Q. From your PREA work to date, what advice do you have to share with those who are just beginning to review the standards and grapple with compliance?

A. At DYC, we have been committed to working toward compliance with the PREA standards since the early days of PREA. Along the way, there have been changes to both the DYC and the proposed PREA standards, but our commitment to keep juveniles in our custody safe remains strong. Our advice for facilities just beginning to grapple with compliance is:

  • Take it slow.
  • Don’t implement the PREA standards just for the standards’ sake.
  • Have a good assessment and develop a good plan.
  • Look at the interplay between different aspects of the facility, what is currently being done, and the PREA standards.
  • Don’t recreate the wheel—use existing resources.
  • Train, train, train.
  • At the end of the day, PREA is no more and no less important than any other responsibility to ensure the safety of youth and the facility.

Q. What initial steps do you recommend an agency take that will show early results of PREA compliance?

A. DYC recommends that agencies develop formal plans to assess, communicate, and implement changes. It is important that agencies do not assume they are in compliance with a standard—you have to verify policies, procedures, and practices. Assessments should determine the consistency between policy, procedure, and practice. Agencies’ communication also has a big impact. A strategy for communication that includes social marketing should speak not just to the standards and reason for compliance, but to the importance of prevention both for youth safety and organizational success. For implementation, agencies should develop a strategic plan that identifies immediate and long-term organizational changes. Implement those changes that are immediate and/or easy to change first. This approach will show early progress and success. Including affected staff in the planning process also generates investment in and sustainability of the changes.

Q. As you continue to work toward compliance with the PREA standards, what challenges do you anticipate facing? How do you think you will overcome those challenges?

A. While not unique to DYC, adequate funding is an ongoing challenge. DYC is committed to PREA but must make do with limited funds to dedicate to these efforts. Annually, the State of Colorado allocates PREA-specific funds from its general fund to pay for myriad resources including training materials (CDs, posters, brochures, etc.), as well as physical plant improvements such as windows in doors and mirrors. The funds are minimal, with only about $8,000 total per year for all DYC facilities to share, requiring strategic planning to maximize the impact of the funds. DYC also utilizes internal fiscal resources based on identified need, but these resources are also shared with non-PREA-specific physical plant and operational needs.

Although DYC has been working to comply with PREA for several years, the organization still faces challenges to comply with one standard in particular: 115.313 – Supervision and Monitoring, which requires specific staffing ratios.

DYC does not mandate specific staffing ratios; rather, DYC operates using critical post staffing—posts that must be staffed 24 hours a day and seven days a week. DYC calculates its overall staffing needs using this methodology and bases its annual budget on these staffing calculations. Under any scenario, staffing analysis is a complex determination that must account for, among other items, an agency’s population count, characteristics, operations, service delivery, programs, and physical plant. PREA’s mandated staffing ratio will require DYC to revisit its methodology for determining staffing levels, and may result in an increased number of staff requested. The PREA workgroup will review current staffing levels and determine a plan for coming into compliance by the 2017 deadline.

DYC Resources:

Additional Resources

Juvenile Assessment Toolkit

Training resources from American University’s Project on Addressing Prison Rape