The DOJ PREA Management Office operates under a statutory obligation to evaluate all PREA auditors for compliance with the auditor certification agreement, and is responsible for the enforcement of minimum qualifications for and ethical responsibilities of PREA auditors, including taking disciplinary action as appropriate. (See 34 U.S.C.
PREA Standard 115.401(h) states, “The auditor shall have access to, and shall observe, all areas of the audited facilities.” In order to meet the requirements in this standard, the site review portion of the onsite audit must include a thorough examination of the entire facility. The PREA audit site review is not a casual tour of the facility. It is an active, inquiring process that includes standards-driven observations, tests of critical functions, and informal conversations with people confined in the facility, staff, volunteers, and contractors. During the site review, auditors must observe all areas and test all critical functions as outlined in these documents. If something in the site review instructions is not applicable to the facility or it is not possible to observe or test, auditors must discuss barriers to observations/testing in the relevant standard specific discussions and the Post-Audit Reporting Information section of the Auditor Compliance Tool. Pursuant to the PREA Auditor Handbook (Handbook), auditors are not permitted to conduct the site review portion of the onsite audit remotely.
As required in the Handbook, auditors must take thorough notes and document their observations during the site review, including any issues identified, tests of critical functions, and any other areas or practices that may require additional discussions with individuals or proof documentation from the facility. Auditors are encouraged, but not required, to take notes using the PREA Audit Site Review Checklist.
PREA Audit Site Review Instructions
PREA Audit Site Review Checklist
The Site Review Checklist is an optional tool that auditors may use to guide and track documentation of evidence gathered during the site review:
The PREA Standards require auditors to conduct interviews with inmates, residents, and detainees, as well as staff, supervisors, and administrators. The audit instrument includes interview protocols for the various roles and positions that require an interview. The DOJ has clarified the basic requirements of the interview process, including minimum numbers, selection/sampling criteria, and privacy considerations, which are discussed in detail in the PREA Auditor Handbook.
Each interview protocol is designed to elicit information about facility practices that relate to specific PREA Standards, and more general attitudes about preventing, detecting, and responding to sexual abuse and sexual harassment in confinement. Auditors are not limited to the interview questions included in the protocols; rather, these questions are designed to serve as a starting point for eliciting information about the facility’s compliance with the PREA Standards. Auditors are strongly encouraged to use the interview protocols as a baseline only, and to ask additional questions to probe compliance issues.
It is important to note that some of the interview protocols provided below include multiple protocols under one title. For example, specialized staff includes approximately 25 discrete roles and positions that should be interviewed as part of every audit (the auditor should explain in their audit reporting why any particular roles or positions were not interviewed). All audit stakeholders should be aware that the interview process is extensive and is a key evidence-gathering obligation of the auditor. Adequate time should be allowed for the auditor to conduct thorough interviews as required by the handbook.
The checklist of documentation provides a non-exhaustive list of the documentation that the auditor should request from the audited agency and facility as part of an audit. The names and formats used by corrections, detention, and law enforcement for record-keeping usually vary from agency to agency, so auditors are strongly encouraged to approach the checklist of documentation as a helpful resource to think about the kinds of records, files, logs, and other materials that should be reviewed during an audit. Auditors are also strongly encouraged to begin early – during the pre-onsite phase of the audit – to understand the audited agency’s and facility’s way of naming and identifying documents and records.
Please note, this checklist was developed in 2014. An updated version is anticipated to be launched in 2025. Until that time, DOJ’s PREA Management Office and the PRC recommend using this document, as well as the Auditor Compliance Tool and Auditor Handbook, as resources for documentation that need to be reviewed to evaluate compliance with the PREA Standards, and retained, consistent with Standard 115.401(j).
The checklist of documentation provides a non-exhaustive list of the documentation that the auditor should request from the audited agency and facility as part of an audit. The names and formats used by corrections, detention, and law enforcement for record-keeping usually vary from agency to agency, so auditors are strongly encouraged to approach the checklist of documentation as a helpful resource to think about the kinds of records, files, logs, and other materials that should be reviewed during an audit.
The PREA Standards require auditors to conduct interviews with inmates, residents, and detainees, as well as staff, supervisors, and administrators. The audit instrument includes interview protocols for the various roles and positions that require an interview. The DOJ has clarified the basic requirements of the interview process, including minimum numbers, selection/sampling criteria, and privacy considerations, which are discussed in detail in the PREA Auditor Handbook.
PREA Standard 115.401(h) states, “The auditor shall have access to, and shall observe, all areas of the audited facilities.” In order to meet the requirements in this standard, the site review portion of the onsite audit must include a thorough examination of the entire facility. The PREA audit site review is not a casual tour of the facility. It is an active, inquiring process that includes standards-driven observations, tests of critical functions, and informal conversations with people confined in the facility, staff, volunteers, and contractors.
The Pre-Audit Questionnaire, a tool used to gather information during the pre-onsite phase of the audit, identifies the minimum information and supporting documents that the agency and facility should provide to the auditor before the onsite phase of the audit begins. Submission of the Pre-Audit Questionnaire and the auditor’s initial analysis of agency and facility documentation are critical components of the audit process. These steps lay the foundation for the audit and form the basis for the auditor’s understanding of the facility’s operations, terminology, structure, population, and other important information. Agencies and facilities should remember that the PREA Standards place the burden to demonstrate compliance with the Standards on the agency (§115.401(e)).
The Pre-Audit Questionnaire is a snapshot of information gathered at one point in time. It is entirely normal and expected that information may change between the time the facility submits the Pre-Audit Questionnaire and any other point in time during the audit process. Agency and facility personnel and auditors are encouraged to treat information submitted in the Pre-Audit Questionnaire accordingly, and to recognize changes in some details as an ordinary part of the audit process. For example, a facility’s population may change between when the facility uploads the Pre-Audit Questionnaire and when the onsite phase of the audit begins. The auditor should be attentive to such differences and determine whether such changes have implications for audit findings.
Once an audit has been created in the Online Audit System (OAS), the PREA Coordinator(s) and PREA Compliance Manager(s) can begin entering information and uploading documentation into the Pre-Audit Questionnaire. After a Pre-Audit Questionnaire is submitted, all information and documentation provided by the agency and facility is automatically populated into the “pre-audit” section of the Auditor Compliance Tool. Additionally, some of the agency and facility information is automatically populated into the Audit Report Template, which reduces the auditor’s burden when preparing the interim and final audit reports.
Access fillable and non-fillable versions of the Pre-Audit Questionnaire:
The Auditor Compliance Tool guides auditors in making compliance determinations for each provision of every PREA Standard, including identification of key sources of evidence that auditors should gather to assess compliance. The Auditor Compliance Tool walks the auditor step-by-step through evidence collection, application of evidence to each provision of each Standard, and review and analysis of the detailed requirements for compliance.
The Auditor Compliance Tool in the Online Audit System (OAS) is the auditor’s “home base.” In the OAS, every Standard in the Auditor Compliance Tool includes the following sections:
The Auditor Compliance Tool also includes the post-audit reporting information questions. Auditors who use the OAS to conduct an audit must complete the post-audit reporting information directly in the OAS before they can complete the audit. To view the post-audit reporting information questions outside of the OAS, please download the pdf version of the Auditor Compliance Tool.
The pdf versions of the Auditor Compliance Tool are to be used only as a reference. As of June 30, 2022, all auditors are required to conduct and report their PREA audits using the Online Audit System1:
1After June 30, 2022, the PREA Management Office will consider, on a case-by-case basis, rare exceptions that may require an auditor to conduct an audit using the paper audit instrument. Auditors who are approved to conduct an audit using the paper audit instrument will receive copies of the paper audit instrument from the PREA Resource Center and will be required to complete their post-audit reporting requirements using the OAS Paper Audit Reporting Portal.
The Audit Report Template standardizes audit reports, addresses the reporting requirements in the PREA Standards, and prompts auditors to address each of the PREA Standards, including each provision and element in each Standard. In the OAS, when an auditor submits their Auditor Compliance Tool, the audit report (whether an interim or final) is automatically generated from information provided by the agency and facility (i.e., agency profile and facility information) and the auditor (i.e., overall compliance determinations and narratives, provision findings, and post-audit reporting information). Auditors can access the system-generated reports (i.e., interim or final report) at any time to print, download, or review as necessary.
It is important to note that the OAS does not send a copy of the audit report to the agency or facility. It is the auditor’s responsibility to send the interim and/or final report to the agency and facility. Agency- and facility-based users are able to access the audit report 15 days after the audit report is completed in the OAS. However, this does not relieve auditors of their obligation to submit the final report to the audited facility and/or agency.
The pdf versions of the Audit Report Template are to be used only as a reference. As of June 30, 2022, all auditors are required to conduct and report their PREA audits using the Online Audit System2:
2After June 30, 2022, the PREA Management Office will consider, on a case-by-case basis, rare exceptions that may require an auditor to conduct an audit using the paper audit instrument. Auditors who are approved to conduct an audit using the paper audit instrument will receive copies of the paper audit instrument from the PREA Resource Center and will be required to complete their post-audit reporting requirements using the OAS Paper Audit Reporting Portal.
The Audit Report Template standardizes audit reports, addresses the reporting requirements in the PREA Standards, and prompts auditors to address each of the PREA Standards, including each provision and element in each Standard.
The Auditor Compliance Tool guides auditors in making compliance determinations for each provision of every PREA Standard, including identification of key sources of evidence that auditors should gather to assess compliance. The Auditor Compliance Tool walks the auditor step-by-step through evidence collection, application of evidence to each provision of each Standard, and review and analysis of the detailed requirements for compliance.
The Pre-Audit Questionnaire, a tool used to gather information during the pre-onsite phase of the audit, identifies the minimum information and supporting documents that the agency and facility should provide to the auditor before the onsite phase of the audit begins. Submission of the Pre-Audit Questionnaire and the auditor’s initial analysis of agency and facility documentation are critical components of the audit process.