Fill - Free fillable PREA AUDIT REPORT INTERIM FINAL ADULT PRISONS & (Federal Bureau of Prisons) PDF form

PREA AUDIT REPORT



INTERIM



FINAL

ADULT PRISONS & JAILS

Auditor Information

Auditor name:

Address:

Email:

Telephone number:

Date of facility visit:

Facility Information

Facility name:

Facility physical address:

Facility mailing address:

(if different

from above)

Facility telephone number:

The facility is:

Federal

State

County

Military Municipal Private for profit

Private not for profit

Facility type:

Prison

Jail

Name of facility’s Chief Executive Officer:

Number of staff assigned to the facility in the last 12 months:

Designed facility capacity:

Current population of facility:

Facility security levels/inmate custody levels:

Age range of the population:

Name of PREA Compliance Manager: Title:

Email address: Telephone number:

Agency Information

Name of agency:

Governing authority or parent agency:

(if

applicable)

Physical address:

Mailing address:

(if

different from above)

Telephone number:

Agency Chief Executive Officer

Name: Title:

Email address: Telephone number:

Agency-Wide PREA Coordinator

Name: Title:

Email address: Telephone number:

PREA Audit Report 1

Glynn Maddox

11820 Parklawn Drive, Suite 240, Rockville, MD 20852

glynn.maddox@nakamotogroup.com

478-278-8022

July 25-27, 2017

Federal Correctional Institution - McDowell

101 Federal Drive, Welch, WV 24801

P.O. Box 1029, Welch, WV 24801

304-436-7300

■

Barbara Rickard, Warden

316

1854 total, FCI-1726 & Camp-128

1150 total, FCI-1072 & Camp-78

Medium/In and Minimum/Out

20-86

Madonna Carver

Associate Warden

MCD/PREAComplianceMgr@bop.gov

304-436-7300

Federal Bureau of Prisons

U. S. Department of Justice

320 First Street, NW, Washington, DC 20534

202-616-2112

■

Thomas R. Kane

Acting Director

BOP-CPD/PREACoordinator@bop.gov

202-616-2112

Jill Roth

National PREA

Coordinator

BOP-CPD/PREACoordinator@bop.gov

202-616-2112

AUDIT FINDINGS

ARRATIVE

EA Audit Report

The on-site PREA (Prison Rape Elimination Act) audit of the Federal Correctional Institution (FCI), McDowell was conducted from July

25-27, 2017. The audit was completed by Glynn Maddox, a Nakamoto Group Inc. certified auditor. This is the second PREA audit for this

facility. Prior to the on-site audit, the facility submitted the Pre-Audit Questionnaire to the auditor and provided a comprehensive set of

supporting documents for the responses to the questionnaire. The documentation was in the form of Program Statements (PS), Institution

Supplements (IS) and other forms/memos etc. Program Statements are agency-wide governing policies developed by the Federal Bureau

of Prisons (BOP) and Institution Supplements stipulate institution specific policies when there is no agency-wide policy or when site

specific guidance is required to expand on agency Program Statements.

An entrance meeting was held the first day of the audit to discuss any concerns regarding the audit process and finalize the facility tour

and interview schedules. The following persons were in attendance: the Warden, the Associate Warden/Programs (Institution PREA

Compliance Manager), the Associate Warden/Operations, the Executive Assistant/Satellite Camp Administrator, the Acting Chief of

Psychology, one management analyst from the BOP Central Office, one American Correctional Association auditor and several facility

department heads and support staff. After the meeting, a comprehensive tour of the facility (FCI) and the minimum security satellite camp

(SPC) was completed. The tour included the FCI intake processing area, all housing units including the Special Housing Unit (SHU), the

Health Services department, recreation, food service, facility support areas, education, the visiting rooms and programming areas. During

the tour, it was noted that there was sufficient staffing and surveillance cameras to ensure a safe environment for inmates and staff. Signs

were posted (in English and Spanish) that indicated employees of the opposite gender were present in the housing units. Inmates were

able to shower, dress and use the toilet facilities without exposing themselves to employees of the opposite gender. Informal and formal

conversations with employees and inmates regarding the PREA standards were conducted. Postings regarding PREA violation reporting

and the agency’s zero tolerance policy for sexual abuse and harassment were prominently displayed in all housing units, meeting areas

and throughout the facility. Audit notice postings with the PREA auditors’ contact information were also located in the same areas. There

were no confidential letters received by the auditor as a result of the audit postings in the housing units. The FCI has been accredited by

the American Correctional Association. Both the FCI and the SPC were observed to be very well maintained, clean, orderly, and quiet.

A total of thirty-eight randomly selected correctional staff from both the FCI and the SPC were interviewed. All BOP staff at the institution

are considered correctional workers/officers. Correctional officers from all shifts were included. All were very aware of the agency’s zero

tolerance policy and knew their responsibilities to protect inmates from sexual abuse/harassment and their duties as first responders as

part of a coordinated response. The agency Director, agency PREA Coordinator and agency Contract Administrator had been previously

interviewed. Specialized staff were also interviewed and included: the Warden; the Associate Warden/PREA Compliance Manager; the

Acting Chief Psychologist and another staff psychologist; two SIS investigators, the Human Resources Manager, the Health Services

Administrator; the retaliation monitor; two intermediate or higher level staff who serve as institutional duty officers; two intake staff; two

staff who perform screening for risk of victimization or abusiveness; and a lieutenant who supervises inmates in segregated housing. A

contractor, two volunteers and a victim advocate were also interviewed. All interviewed staff, contractors, a community service provider,

and volunteers demonstrated a thorough understanding of the PREA and their responsibilities under this program, relative to their position

in or with the organization and employment status.

Fifty-two inmates randomly selected from both the FCI and SPC were interviewed. The interviewed inmates were of various ages,

nationalities and ethnic backgrounds. Additionally four limited English proficient inmates, two inmates who self-identified as being gay,

three inmates who self-identified as being transgender, three inmates who disclosed prior sexual victimization during risk screening were

also interviewed. All interviewed inmates demonstrated a good understanding of the PREA compliance program, the prevention,

protection, and reporting mechanisms. All inmates interviewed also stated that staff were responsive to their needs and stated they felt

safe from sexual abuse at the facility.

DESCRIPTION OF FACILITY CHARACTERISTICS

EA Audit Report

The mission of the Federal Bureau of Prisons is to protect society by confining offenders in the controlled environments of prisons and

community-based facilities that are safe, humane, cost-efficient and appropriately secure and that provide work and other

self-improvement opportunities to assist offenders in becoming law-abiding citizens. It is the mission of the Federal Correctional Institution

McDowell, to provide a safe, secure and humane environment for inmates and staff. There are opportunities for self-improvement

including work, education, vocational training, religious and counseling programs. These programs are designed to assist inmates during

confinement and upon release, as well as to facilitate the orderly operation of the institution.

This 1,726 bed male Federal Correctional Institution (FCI) and the 128 bed Satellite Prison Camp (SPC) is set on 344 acres of graded

land surrounded by rocky mountain outcroppings and cliffs in an almost canyon like setting. The institution was constructed on land that

was once a surface mine. It is a scenic setting if such can be said about a prison. The country is hilly with narrow two-lane roads,

meandering streams and creeks all with many twists and turns throughout this mountainous area. This makes for a secure location

surrounded by wooded areas which would make the threat of escape extremely difficult.

FCI McDowell was activated in 2010. Staff began arriving in May 2010 and received their first inmates at the SPC in September 2010 and

at the FCI in November 2010. Driving into the canyon like site, one notices the forty acre fenced FCI main site and the smaller camp with

a number of outbuildings. The facility is located in McDowell County, West Virgina, just outside the town of Welch.

The FCI has three general population housing units (each with two wings or "pods" that are two story) with double occupancy cells and a

Special Housing Unit (SHU-protective custody-single and double occupancy cells). The SHU segregates inmates from the general

population for various reasons. The satellite prison camp has one housing unit (dormitory style). The FCI only houses adult male

offenders with medium, low, or minimum security designations, while the satellite camp houses adult male offenders with minimum

security designations. At the time of the audit, the total population was 1150. The facility does not house females or youthful offenders.

Currently, the institution has a number of cameras strategically placed to ensure the safety and security of both inmates and staff. No

significant "blind spots" were discovered during the tour (staffing deployment, cameras, and mirrors were used to eliminate potential "blind

spots").

FCI McDowell offers a wide variety of educational programs which provides each inmate the opportunity to develop academic, vocational,

leisure,and wellness skills. These courses will allow inmates to effectively utilize his time while incarcerated as well as prepare him for

release. Our goal is to assess each inmate upon arrival and design an individualized educational plan, so that he can attain the skills

needed for successful re-entry into society. Inmates who do not have a verified high school diploma or GED are required to participate in a

Literacy Program. The Literacy Program includes GED, English as a Second Language (ESL), and Special Learning Needs. Potential

GED students take the Test of Adult Basic Education (TABE) upon arrival and placed in one of three levels of GED class. In addition, the

facility offers vocational training programs which includes carpentry, masonry, and electric. These programs run between 125 and 150

hours which include classroom work as well as simulated live work. FCI McDowell's vocational training programs are accredited through

the National Center for Construction Education and Research (NCCER).

Recreation programs consist of the following team sports: basketball, flag football, softball, soccer, handball, racquetball, and volleyball.

These intramural sports are offered at specific times throughout the year. Individual wellness programs are also available throughout the

year. The wellness courses consist of anatomy & physiology, nutrition, spin bike, various core/stability classes, dietary information, a year

round walk/jog program and an extreme fitness class which incorporates endurance and stamina drills. The National Federation of

Personal Trainers course is taught and the test can be taken with the facility recreation staff proctor. The Health & Wellness Resource

Room, located in the leisure center, is where inmates can research wellness & health information via literature and videos related to

physical fitness, nutrition and healthy lifestyle living. The hobby craft program offers leather craft, painting, drawing, crocheting, learning

air brush and stick art. Inmates are permitted to do arts & crafts projects in their housing units provided they are enrolled in the hobby

craft program and have proper proof of identification. The “in-cell” projects consist of card making, drawing & crocheting. Finally, there is

a music area/band room where inmates can come and play instruments, participate in a band and take classes related to guitar, drums

and bass guitar. The instruments available for inmate musical activities are drums, brass instruments and acoustic & bass guitar. The

facility also provides a number of religious programs involving numerous faith groups.

The FCI and SPC offer an excellent re-entry into society program which prepares inmates for release back into the community. This

initiative is a directed program that focuses on inmates taking responsibility for their release planning. Through this program inmates are

allowed to create resumes, participate in mock employment interviews and are given tips for handling adversity and rejection. The facility

also provides court-mandated legal resource materials for inmates including agency policies, institution supplements, and federal law.

SUMMARY OF AUDIT FINDINGS

Number of standards exceeded:

Number of standards met:

Number of standards not met:

Number of standards not applicable:

EA Audit Report

When the on-site audit was completed, another meeting was held with the Warden and other staff to discuss audit findings. The facility

was found to be fully compliant to the PREA. One standard was determined to be not-applicable and the remaining 42 standards were

determined to meet standards. The auditor had been provided with extensive files prior to and during the audit for review to support a

conclusion of compliance to the PREA. All interviews and observations also supported compliance. The facility staff were found to be

extremely courteous, cooperative, and professional. Staff morale was very good and the observed staff/inmate relationships were

excellent. All areas of the facility were observed to be very clean and very well maintained. At the conclusion of the audit, the auditor

thanked the Warden and staff for their hard work and dedication to the PREA audit process.

Standard 115.11 Zero tolerance of sexual abuse and sexual harassment; PREA Coordinator

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.12 Contracting with other entities for the confinement of inmates

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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Program Statement (PS) 5324.12, Sexually Abusive Behavior Prevention and Intervention Program and Institution Supplement (IS)

5324.12C, Sexually Abusive Behavior Prevention and Intervention Program address the requirements identified in the standard. The

agency has appointed a psychologist assigned to the BOP Correctional Programs Division as their National PREA coordinator. The

Warden has appointed the Associate Warden/Programs as the Institution PREA Compliance Manager (IPCM) and the Acting Chief of

Psychology Services to assist the IPCM. The IPCM reports directly to the Warden regarding all PREA related concerns. Interviews with

the agency PREA Coordinator and IPCM confirmed that each has sufficient time and authority to coordinate efforts to comply with PREA

standards. The agency and facility directives outline a zero tolerance policy for all forms of sexual abuse and sexual harassment.

Inmates are informed orally about the zero-tolerance policy and the PREA program during in-processing procedures, by viewing a video

and during additional admission and orientation procedures. The video is offered in English and in Spanish. Inmates are also informed

about the program and zero-tolerance in the Admission and Orientation (A&O) Handbook, a pamphlet, and through postings throughout

the facility (observed during the tour). All written documents are available in English and Spanish. Additional interpretive services are

available for inmates who do not speak or read English. All interviews with staff, volunteers, contractors, and inmates confirmed that each

was aware of the zero-tolerance policy towards all forms of sexual abuse/harassment. The commitment to the enforcement and

implementation of the PREA meets the required compliance to this standard. An examination of documentation also confirms compliance

to this standard.

■

The agency meets the requirements of this standard. A review of the documentation submitted confirmed the agency requires other

entities contracted with for the confinement of inmates (privatized prisons and residential re-entry centers or "half-way houses") to adopt

and comply with the PREA standards. All agency contractual agreements were modified to incorporate the language requiring all

contractors to adopt and comply with PREA standards. The FCI and SPC do not individually contract for the confinement of inmates.

Standard 115.13 Supervision and monitoring

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.14 Youthful inmates

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 3000.03, Human Resource Management Manual, the facility staffing report and the Workforce Utilization Committee meeting minutes

address the requirements of the standard. A review of the facility staffing plan and the quarterly Salary and Workforce Utilization

Committee meeting minutes for the previous twelve months confirmed that PREA issues were considered when filling positions and

developing work rosters/assignments. Interviews with the Warden and the Human Resource Manager confirmed that the facility considers

the items detailed in the standard when developing the staffing plan. The facility and the agency review the staffing plan at least quarterly.

The IPCM is a member of the Salary and Workforce Utilization Committee and may provide input as to whether adjustments to the staffing

plan may be required to meet PREA requirements. There have been no judicial findings of inadequacy, findings of inadequacy from

federal investigative agencies or findings of inadequacy from internal or external oversight bodies relevant to this standard. All essential

posts are filled each shift and no essential posts are kept open for salary savings. The review of Institution Duty Officer unannounced

PREA rounds logs confirmed that intermediate-level or higher-level supervisors (department heads at a minimum) conduct and document

such visits throughout the institution. Staff are prohibited from alerting other employees regarding unannounced rounds. Interviews with

inmates and housing unit officers also confirmed that random, unannounced rounds are conducted by Institution Duty Officers daily,

including nights and weekends. An examination of supporting documentation also confirms compliance to this standard.

Not Applicable - Neither the FCI nor the SPC houses youthful inmates.

Standard 115.15 Limits to cross-gender viewing and searches

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.16 Inmates with disabilities and inmates who are limited English proficient

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12 and PS 5521.06, Searches of Housing Units, Inmates and Inmate Work Areas address the requirements of the standard. The

facilities rated capacity exceeds 50 inmates. The institution does not permit cross-gender strip searches or cross-gender visual body

cavity searches, except in exigent circumstances or when performed by medical practitioners. There were no cross-gender visual body

cavity or strip searches conducted in either facility during the audit period. Officers would be required to document all cross-gender strip

searches and cross-gender visual body cavity searches. Interviews with staff confirmed that they were aware of the prohibition of visual

body cavity or strip searches of the inmates of the opposite sex except in exigent circumstances. Staff interviews also confirmed that

female officers had been trained to conduct cross-gender pat searches. Inmate interviews also confirmed that inmates are not delayed or

prohibited from attending regularly available programming or other out-of-cell opportunities in order to comply with this standard. As

confirmed by observation during the tour of all housing units, inmates are permitted to shower, perform bodily functions and change

clothing privately. The agency and facility have a “knock and announce” policy and procedures requiring staff of the opposite sex to

announce their presence or otherwise notify the inmates when entering an inmate housing unit. Inmate interviews confirmed that female

staff announce their presence when entering housing units where inmates of the opposite gender are housed. The practice was observed

during the tour of the FCI and SPC. An intercom announcement is made over a loud speaker, at the beginning of each shift, that tells

inmates that male and female employees are on duty in their units. Staff do not search or physically examine a transgender or intersex

inmate for the sole purpose of determining the inmate’s genital status. Interviews with inmates confirmed that they had been pat-searched

by officers properly. Interviews with staff, observations and an examination of documentation confirm compliance to this standard.

■

PS 5324.12 and the Admission and Orientation (A&O) Handbook address the requirements of the standard. Through policy and practice,

the facility ensures that inmates with disabilities have an equal opportunity to participate in and benefit from all aspects of the agency’s

efforts to prevent, detect and respond to sexual abuse and sexual harassment. The limited English proficient inmates interviewed stated

they were instructed concerning PREA compliance in a manner that they could understand. All PREA related information, including

postings, brochures and handouts are available in English and in Spanish. Translation services are available through a contracted

language service for inmates who are not English proficient. Communication services are also available for inmates who use sign

language. The facility also employs staff who are proficient in languages other than English. The facility does not rely on inmate

interpreters, inmate readers or other types of inmate assistants in matters related to the PREA process. Interviews with first responders,

medical, mental health and investigative staff confirmed their awareness of the prohibition for using inmate interpreters for PREA

compliance functions. Interviews with four limited English proficient inmates confirmed the availability and use of the staff and telephonic

interpretive services. Interviews with staff and an examination of documentation also confirmed compliance to this standard.

Standard 115.17 Hiring and promotion decisions

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.18 Upgrades to facilities and technologies

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 3000.03, PS 3420.11, Standards of Employee Conduct, the Pre-Employment Guide, SF85P (Questionnaire for Public Trust Positions)

and a BOP recruitment document address the requirements of the standard. All employees who have contact with inmates have had a full

field background investigation in addition to finger printing and inquiry into the FBI’s National Crime Information Center (NCIC). Employee

backgrounds are re-checked every five years. Contractors and volunteers who have regular contact with inmates also have criminal

background checks completed prior to having contact with inmates. Volunteer and contractor background checks are repeated yearly.

The facility does not hire or promote anyone who may have contact with inmates, and does not enlist the services of any contractor who

may have contact with inmates, who has engaged in any type of sexual abuse/harassment. Employees have a duty to disclose such

misconduct and material omissions regarding such misconduct would be grounds for termination. Submission of false information by any

applicant is grounds for not hiring the applicant. The Human Resources Manager was interviewed and confirmed that the agency

attempts to contact prior employers for information on substantiated allegations of sexual abuse or resignations which occurred during a

pending investigation of sexual abuse. The Human Resource Manager also stated that the agency, not the local Human Resources

Department, provides information on substantiated allegations of sexual abuse or sexual harassment involving a former employee upon

receiving a request from an institutional employer for whom such employee has applied to work. The agency, not the local Human

Resources Department, notifies appropriate licensing/certifying agencies when professional staff are terminated for substantiated

allegations of sexual abuse or harassment. A review of documentation also supports compliance to this standard.

■

The facility has an extensive video and visual monitoring system in place. There have been no substantial expansions or modifications to

the facility or installation of updated monitoring technology since the previous PREA audit.

Standard 115.21 Evidence protocol and forensic medical examinations

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.22 Policies to ensure referrals of allegations for investigations

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 5324.12, IS 5324.12C, the Guide for First Responder/Operations Lieutenant-When Approached with an Inmate Allegation of Sexual

Abuse or Harassment, PS 6031.04, Patient Care and the PREA Checklist & Instructions address the requirements of the standard.

Interviews with correctional and health services personnel confirmed that they were all knowledgeable of the required procedures for

obtaining, preserving and securing physical evidence, when sexual abuse is alleged. Staff were aware that the Special Investigative

Service Lieutenants (SIS), the Office of Internal Affairs (OIA), the Office of Inspector General (OIG) or the FBI (Federal Bureau of

Investigation) conducted investigations relative to sexual abuse/harassment allegations. The agency follows a uniform evidence protocol

as described in the U.S. Department of Justice’s Office on Violence Against Women publication, “A National Protocol for Sexual Assault

Medical Forensic Examinations, Adults/Adolescents”. Victims of sexual assault are referred to health services for initial examination and

treatment. Such treatment would be for life preservation only and the victim would be transported to a community hospital for

examination, treatment and forensic evidence gathering by a SANE. Routinely, administrative investigations are conducted by trained

investigators who are full time employees of the facility. The review of training records confirmed that investigators have received

investigator training offered by the BOP on the investigation of sexual abuse and harassment in confinement settings. Interviews with

staff, a SANE from a local hospital, and an examination of documentation also confirm compliance to this standard.

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PS 5324.12 addresses the requirements of the standard. Policy requires administrative or criminal investigations to be completed on all

allegations of sexual abuse or sexual harassment. Administrative investigations are routinely assigned for completion by the Special

Investigative Services (SIS) investigators. If, during the course of an investigation, evidence surfaces indicating criminal misconduct, the

case would be initially referred to the FBI for criminal investigation. Two of the SIS investigators were interviewed and were aware of their

responsibilities in the investigative process. The FBI would conduct criminal investigations for the facility involving inmate on inmate

sexual abuse and the OIG would investigate staff on inmate criminal sexual abuse. An investigation would never be terminated due to an

inmate being transferred or released or an employee leaving the agency. The facility has a Evidence Recovery Team (ERT), which is a

group of specially trained staff who would be called to a potential crime scene to preserve evidence. Nine members of ERT were

interviewed as part of the compliance audit. A review of training documents confirmed that all investigators received instruction in

conducting sexual assault investigations in a confinement setting. Interviews with staff, the investigators, and an examination of

documentation confirm compliance to this standard.

Standard 115.31 Employee training

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.32 Volunteer and contractor training

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12 and IS 5324.12C address the requirements of the standard. All BOP employees are considered correctional workers and all

new employees attend training locally and at the Federal Law Enforcement Training Center. This training addresses all of the topics

identified in the standard. Related education is provided annually during refresher training. The review of facility lesson plans, training

logs and PREA Power Point presentations confirmed that the provided training also addressed all elements identified in the standard.

Staff must acknowledge in writing their understanding of the PREA. Employees have PREA information noted on their desk computers

and carry a PREA reference card. Staff annual training files were reviewed and contained documentation supporting compliance to this

standard. All staff interviewed indicated that they received the required PREA training initially and annually. Officers assigned to the SHU

also receive additional training. The extensive training provided and staff knowledge of PREA requirements confirm that the facility meets

the requirements of this standard.

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PS 5324.12 and IS 5324.12C address the requirements of the standard. The review of volunteer and contractor PREA training sign in

forms and other documents by the auditor confirmed that all facility contractors and volunteers have received training related to their

responsibilities concerning the PREA (zero-tolerance, detection, prevention, response, and reporting requirements) during the previous

twelve months. Staff, contractor and volunteer interviews confirmed that the training was provided and that they understood the agency’s

zero-tolerance policy for sexual abuse and harassment and their responsibilities under the PREA. A review of the PREA contractor and

volunteer training presentation confirmed that the level of instruction is appropriate for the services provided and emphasizes the facility’s

zero-tolerance and reporting policies and procedures.

Standard 115.33 Inmate education

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.34 Specialized training: Investigations

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12 and IS 5324.12C address the requirements of the standard. During in-processing procedures, each inmate receives an

inmate Handbook and a pamphlet describing the agency’s PREA compliance program. The information identifies the key elements of the

program and informs them of the zero-tolerance policy regarding sexual abuse and sexual assault and multiple ways to report sexual

abuse or sexual harassment. The information also informs the inmates that both male and female staff routinely work in and monitor the

housing units. The information is available in English and Spanish. A staff member conducts an education program regarding the PREA

for all inmates within 30 days of their arrival at the facility. The program includes definitions of sexually abusive behavior and sexual

harassment, prevention strategies and reporting modalities. Inmates also have access to TRULINCS, a computer program which also

provides PREA information and a reporting outlet. Staff interpreters and telephonic translation services are available to inmates who are

not proficient in English. Staff routinely conduct "town hall" meetings (group meetings that provide information and a question and answer

session) in the housing units to address issues that may include PREA discussions. Inmate interviews confirmed that they received PREA

information and they were aware of numerous reporting methods to include anonymous and third party reporting, the zero-tolerance policy

and their right to be free from retaliation. The tour of the facility confirmed that PREA education posters were prominently displayed in all

housing units, the visiting room, and all program areas. Interviews with staff and an examination of documentation also confirm that the

facility meets the requirements of this standard.

■

PS 5324.12, the SIS/SIA Training Lesson Plan, Sexual Violence PREA Training and DOJ/OIG PREA Training address the requirements of

the standard. The facility investigators, OIA, OIG and FBI investigators have received PREA specialized training through the Department

of Justice. The auditor reviewed specialized training documentation to include the SIS/SIA Training Instructor Guide, the BOP Course

Completion List for Investigating Sexual Abuse in a Confinement Setting training and the OIG PREA Criminal Investigator Certification

Training List. Administrative investigations are conducted by trained investigators who are full time employees of the facility. When

criminal investigations are indicated, they are conducted by the Federal Bureau of Investigation or the Office of the Inspector General.

Interviews with staff, two of the SIS investigators, and an examination of documentation confirm compliance to this standard.

Standard 115.35 Specialized training: Medical and mental health care

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.41 Screening for risk of victimization and abusiveness

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 5324.12 and IS 5324.12C address the requirements of this standard. When required, both medical and mental health providers are

available for immediate call back to the facility during off duty hours. The review of medical and mental health personnel training records

by the auditor confirmed that these employees receive the same PREA training as correctional officers and have a duty to report when

they have knowledge of sexual abuse/assault, even when disclosed in the course of a health care encounter. Further review of training

records confirmed that all mental health and medical staff have also received specialized training on victim identification, interviewing,

reporting and required clinical interventions. Training does not refer to certifications needed to conduct forensic examinations. All cases

requiring the processing of sexual assault evidence collection kits are transported to a community hospital where Sexual Assault Nurse

Examiners are available at all times (a SANE was interviewed and confirmed access to these services). Interviews with medical and

mental health staff also confirmed the provision of specialized training and that they are aware of their duty to report allegations and

suspicions of sexual abuse or sexual harassment.

■

PS 5324.12 addresses the requirements of the standard. All inmates are immediately assessed for a history of sexual abusiveness and

risk of sexual victimization during in-processing procedures performed in the receiving and discharge (R&D) area. Also during

in-processing procedures, all inmates complete a self-disclosure questionnaire check sheet. Policy prohibits disciplining inmates for

refusing to answer or for not disclosing complete information during the screening. A member of the inmate’s housing unit team (case

manager or counselor) screens all new arrivals within the first 72 hours of the inmate’s arrival, but this activity ordinarily occurs on the day

of arrival. The review of documents by the auditor confirmed that inmates identified at high risk for sexual victimization or at risk of

sexually abusing other inmates were referred to a mental health professional and all received further assessment. Staff also conduct

screenings by reviewing records or other information from other facilities. A unit team member reviews all relevant information from other

facilities and continues to reassess an inmate's risk level within 30 days of his arrival. Staff and inmate interviews, a review of

documentation and observations of the intake process confirmed compliance to this standard. Information received during the screening

is only available to staff with a need-to-know and never to other inmates.

Standard 115.42 Use of screening information

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.43 Protective custody

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12 addresses the requirements of the standard. Risk screening information is used to determine housing, bed, work, education,

and program assignments with the goal of keeping separate those inmates at high risk of being sexually victimized from those at high risk

of being sexually abusive. Determinations for these assignments are made on a case-by-case basis to ensure the safety of each inmate.

The agency (through a committee) decides whether to assign a transgender or intersex inmate to a facility for male or female inmates.

The facility determines other housing and programming assignments for transgender or intersex inmates on a case-by-case basis,

whether a placement would ensure the inmate’s health and safety and whether the placement would present management or security

problems. Placement and programming assignments for each transgender or intersex inmate are reassessed at least once every six

months. Policy states that a transgender or intersex inmate’s own views with respect to his own safety is given serious consideration

when making these assignments. Transgender and intersex inmates are given the opportunity to shower, dress and use toilet facilities

separately from other inmates. Interviews with a self-disclosed transgender inmate confirmed that the inmates were able to shower

privately, are afforded other significant privacy and the inmate’s own views with respect to their safety was given serious consideration.

The interview with the agency’s PREA Coordinator confirmed that a transgender inmate’s genital status is not the sole criteria for

placement in a specific facility. Interviews with staff and an examination of documentation also confirm compliance to this standard.

■

PS 5324.12 addresses the requirements of the standard. The Special Housing Unit (SHU) houses both administrative (protective custody)

and disciplinary cases. Policy states inmates at high risk for sexual victimization shall not be placed in involuntary SHU status unless an

assessment of all available alternatives has been made and there is no available means of separating the inmate from the abuser (none

were placed in this status within the last year). The inmates are reassessed by a committee every 7 days after entering the SHU. If

protection is necessary for a SPC inmate, they may be housed at the FCI's SHU. An interview with a SHU lieutenant confirmed that to the

extent possible, access to programs, privileges, education and work opportunities are not limited to inmates placed in a SHU for the

purposes of protective custody, except when there are safety or security concerns. The facility would document the reasons for restricting

access and the length of time the restriction would last. Mental health and unit staff meet with each inmate in SHU status at least once

each week. A Safeguarding of Inmates Alleging Sexual Abuse/Assault Allegation form is completed when considering all appropriate

alternatives for safeguarding alleged inmate victims. Interviews with staff and an examination of documentation confirm compliance to this

standard.

Standard 115.51 Inmate reporting

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.52 Exhaustion of administrative remedies

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12, IS 5324.12C, the Admission and Orientation (A&O) Handbook, and PREA postings address the requirements of the

standard. A review of documentation indicated that there are multiple ways (including verbally, in writing, privately, from a third party and

anonymously) for inmates to report sexual abuse or harassment. Inmates are informed about the reporting methods through the A&O

Handbook, postings in the housing units and common areas and as part of the orientation process. Inmates also have access to

TRULINCS, a computer program which also provides PREA information and a reporting outlet. Through TRULINCS, the inmate can

contact the Office of the Inspector General anonymously and the email is untraceable at the institution level. During the tour of the facility,

a number of TRULINCS computers were observed in each housing unit. The tour of the facility also confirmed that there were numerous

posters on display explaining the reporting procedures. Staff accept reports made verbally, in writing, anonymously and from third parties

and promptly document any form of reporting. Staff are required to immediately document any allegation. Family and friends of inmates

may report sexual abuse/harassment by using the BOP website, making a phone call to the OIG or contacting facility staff. All inmates

interviewed confirmed that they were aware of multiple methods of reporting sexual abuse/assault allegations. Inmates at the FCI or SPC

are not detained solely for civil immigration purposes. Interviews with staff and an examination of documentation also confirm compliance

to this standard.

■

PS 1330.17, Administrative Remedy, addresses the requirements of the standard. Grievances (administrative remedies) filed alleging

sexual abuse/harassment would result in the immediate opening of a formal investigation. Policy states that there is no time frame for

filing a grievance relating to sexual abuse or harassment and does not require an inmate to use any informal grievance process before

filing an allegation involving sexual abuse/harassment. Policy states that matters in which specific staff involvement is alleged may not be

investigated by either staff alleged to be involved or by staff under their supervision. Allegations of physical abuse by staff shall be

referred to the Office of Internal Affairs (OIA) in accordance with procedures established for such referrals. Policy addresses the filing of

emergency administrative remedy requests. If an inmate files the emergency grievance with the institution and believes he is under a

substantial risk of imminent sexual abuse, an expedited response is required to be provided within 48 hours. Best efforts are made to

provide Regional Office and Central Office expedited appeal responses within five calendar days. If an inmate reasonably believes the

issue is sensitive and the inmate’s safety or well-being would be placed in danger if the remedy became known at the institution, the

inmate may submit the remedy directly to the appropriate Regional Office. There is no prohibition that limits third parties, including fellow

inmates, staff members, family members, attorneys and outside advocates, in assisting inmates in filing requests for grievances relating to

allegations of sexual abuse and are permitted to file such requests on behalf of inmates. Policy does not prohibit the facility from

disciplining an inmate for filing a grievance related to alleged sexual abuse, where the facility demonstrates that the inmate filed the

grievance in bad faith. There were no grievances alleging sexual abuse or sexual harassment filed within the previous twelve months.

Interviews with staff, inmates, and an examination of documentation confirm compliance to this standard

Standard 115.53 Inmate access to outside confidential support services

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.54 Third-party reporting

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12 addresses the requirements of the standard. Although the facility does house inmates who have immigration detainers, no

inmates placed in this facility are incarcerated solely for civil immigration purposes. The facility has entered into an agreement with a local

victim advocate organization (Women's Resource Center of West Virgina) to provide emotional support services related to sexual abuse.

The A & O Handbook instructs inmates to contact the Psychology Department who will provide contact information for the Women's

Resource Center. A representative of the Women's Resource Center was interviewed and confirmed that the facility had an MOU with the

Women's Resource Center and that the organization was prepared to provide victim advocacy services for any inmate victim of sexual

abuse if requested. Facility staff members, including mental health treatment providers, have also been trained as victim advocates.

Inmates are informed as part of their orientation process that all telephone calls (except properly placed legal calls) are subject to

monitoring and recording and that all mail, except for legal mail, is subject to monitoring as well. Inmates are informed that emails to the

Office of the Inspector General through TRULINCS - Request to Staff tab and selecting the Department Mailbox titled DOJ Sexual Abuse

are not monitored by the facility or BOP. Postings in the housing units and common areas, the PREA pamphlet issued upon the inmate’s

arrival and the A&O Handbook provide the address to the OIG and explain that inmates may confidentially submit written allegations of

sexual abuse or sexual harassment to this entity. The facility enables reasonable communication between inmates and these

organizations and agencies in as confidential a manner as possible. Interviews with staff, a representative of the Women's Resource

Center, and an examination of documentation confirm compliance to this standard.

■

The BOP pamphlet "Sexually Abusive Behavior Prevention and Intervention", the Admission and Orientation Handbook, PREA

posters throughout the facility, the posted Office of Inspector General Address and the BOP website: www.bop.gov address the

requirements of the standard. The website and posted notices (inside the facility and in the visiting rooms) assist third party reporters on

how to report allegations of sexual abuse/harassment. Interviews with staff and inmates also confirmed that they were aware that

anonymous and third-party reporting procedures were available.

Standard 115.61 Staff and agency reporting duties

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.62 Agency protection duties

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 5324.12, IS 5324.12C, and PS 3420.11 address the requirements of the standard. All staff, contractors and volunteers are required to

report any information regarding sexual abuse or harassment or any staff neglect or violation that may contribute to an incident or an act of

retaliation. The reporting is ordinarily made to the shift operations lieutenant. Policy requires the information concerning the identity of the

alleged inmate victim and the specific facts of the case to be limited to staff who need-to-know because of their involvement with the

victim’s welfare and the investigation of the incident. Interviews with employees, contractors and volunteers confirmed they were aware of

their reporting duties. Additional compliance with all aspects of the standard was verified through document and policy review. The facility

does not house inmates under the age of 18.

■

PS 5324.12 addresses the requirements of the standard. Staff interviews confirmed they were aware of their responsibilities when they

become aware or suspect that an inmate is being or has been sexually abused or sexually harassed. All staff indicated they would act

immediately to protect the inmate by separating and safeguarding the victim from the abuser; isolate the area (as a potential crime scene

to preserve evidence) where the act allegedly occurred; and would call the shift lieutenant for assistance. When notified, the interviewed

shift lieutenants stated they would further protect the victim, notify medical and mental health staff and advise the Institution Duty Officer.

In the previous twelve months, there were no instances in which the facility staff determined that an inmate was subject to substantial risk

of imminent sexual abuse. Interviews with staff and an examination of documentation confirm compliance to this standard.

Standard 115.63 Reporting to other confinement facilities

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.64 Staff first responder duties

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 5324.12 addresses the requirements of the standard. Policy requires the reporting of any PREA related allegation by an inmate that

occurred at another facility to the Warden of the facility where the incident is alleged to have occurred, by the Warden (or equivalent

person) of the facility in which the inmate is currently housed. When the inmate reports sexual abuse or sexual harassment from state,

non-Bureau privatized facilities, jails, juvenile facilities and Residential Reentry Centers (half-way houses), the Warden would contact the

appropriate office of the facility and notifies the Privatization Management or the Residential Reentry Management Branch of the BOP if

appropriate. The notification is to occur as soon as possible, but always within 72 hours of receiving the allegation. Policy also requires

that an investigation be initiated. During the previous twelve months, the FCI was not notified by another facility that an inmate alleged

abuse while housed at FCI McDowell, nor has staff at FCI McDowell received an allegation by inmates of sexual abuse while housed at

other facilities. Interviews with staff and an examination of policy confirm compliance to this standard.

■

PS 5324.12 and IS 5324.12C address the requirements of the standard. All staff interviewed were knowledgeable concerning their first

responder required actions when learning of an allegation of sexual abuse/harassment. All staff indicated they would separate the

inmates, secure the area as a crime scene, not allow inmates to destroy any evidence and contact the shift lieutenant. The shift lieutenant

would continue to protect the inmate and notify medical, mental health, ERT, and administrative staff. During the previous twelve months,

there was one incident requiring security staff to act as a first responder to an inmate allegation of sexual abuse. There were no

allegations of sexual abuse that required a non-security staff member to act as a first responder during the previous twelve months.

Interviews with staff and an examination of documentation confirm compliance to this standard.

Standard 115.65 Coordinated response

 E

xceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

tandard 115.66 Preservation of ability to protect inmates from contact with abusers

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

EA Audit Report

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PS 5324.12 and IS 5324.12C address the requirements of the standard. A pamphlet titled “One Source First Responder Reference Guide

-Sexual Assault Crisis Intervention” provides guidance to employees regarding the expected coordinated actions to take place in response

to an incident of sexual abuse or sexual harassment. Lieutenants use a PREA checklist to aid in their response to allegations of sexual

abuse or sexual harassment. The policies and information provide direction to security, medical and mental health practitioners,

investigators, victim advocates, community service providers (SANE), and facility leadership. Staff and a community provider interview

confirmed that they were knowledgeable regarding their responsibilities in the coordinated response. An examination of documentation

also confirmed compliance to this standard.

■

The Collective Bargaining Agreement (CBA), examined by the auditor, between the Federal Bureau of Prisons and Council of Prison

Locals, American Federation of Government Employees, dated July 21, 2014 - July 20, 2017 (extended until July 20, 2018) complies with

this standard. The agreement does not limit the agency’s ability to remove alleged staff sexual abusers from contact with any inmates

pending the outcome of an investigation or of a determination of whether and to what extent discipline is warranted.

Standard 115.67 Agency protection against retaliation

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.68 Post-allegation protective custody

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 5324.12 addresses the requirements of this standard. Policy prohibits any type of retaliation against any staff or inmate who has

reported sexual abuse, sexual harassment or cooperated in any related investigation. The Associate Warden/Programs (also the local

PREA Compliance Manager), is the designated Retaliation Monitor. She stated she would document and follow up on all potential cases

to ensure policy is being enforced and conduct periodic status checks on the frequency of incident reports, housing reassignments and

negative performance reviews/staff job reassignments. If there was a concern that there was the potential for possible retaliation, the

Associate Warden/Programs stated she would monitor the situation indefinitely. There have been no suspected or actual incidents of

retaliation in the previous twelve months. Compliance with this standard was determined by a review of policy and staff interviews.

■

PS 5324.12 addresses the requirements of the standard. Policy requires staff to assess and consider all appropriate alternatives for

safeguarding alleged inmate victims of sexual abuse or sexual harassment. Staff must first consider other alternatives based on the

circumstances of the allegation before considering placing an inmate in protective custody (SHU), placing him in another housing unit or

transferring the inmate to another federal correctional facility. To aid in that decision, policy requires the facility to complete the BOP’s

Safeguarding of Inmates Alleging Sexual Abuse/Assault Allegation form. The form serves to document consideration of all options.

Interviews with staff and the tour of the facility confirmed that there are usually viable alternatives to placing victims of sexual abuse or

sexual harassment in involuntary segregated housing (SHU). To the extent possible, access to programs, privileges, education and work

opportunities are not limited to inmates placed in a SHU or the facility infirmary for the purposes of protective custody. The facility would

document the reasons for restricting access and the length of time the restrictions would last. There was one inmate placed in

post-allegation protective custody status within the previous twelve months. That inmate only remained in protective custody status for 25

hours before staff could complete the assessment process and provide alternate means of separation from likely abusers. Compliance

with this standard was determined by a review of policy, documentation, and staff interviews.

Standard 115.71 Criminal and administrative agency investigations

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.72 Evidentiary standard for administrative investigations

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

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PS 5324.12 addresses the requirements of the standard. The institution’s SIS may conduct administrative investigations within the facility

and was interviewed by the auditor. When an allegation appears to be criminal in nature, the SIS, in conjunction the BOP’s Office of

Internal Affairs and the facility Warden, will refer the incident to the FBI for a criminal investigation if the investigation involves an inmate

on inmate allegation. Staff on inmate criminal investigations are conducted by the Office of the Inspector General. The FBI or OIG

investigator consults with the Assistant U.S. Attorney when necessary. If the FBI or OIG substantiates the allegation, the case is referred

to the local United States Attorney for possible prosecution. Although there were four allegations of inmate on inmate sexual abuse made

over the previous twelve months, there were no referrals for criminal investigations. The credibility of an alleged victim, suspect or witness

is assessed on an individual basis and is not determined by the person’s status as inmate or staff. The agency does not require an inmate

who alleges sexual abuse to submit to a polygraph examination or other truth assessment device as a condition for proceeding with the

investigation of such an allegation. The review of twelve case files of inmates alleging sexual abuse or sexual harassment revealed that

all investigations were completed promptly, thoroughly, and in compliance with policy. Compliance with this standard was determined by a

review of policy, documentation and staff interviews.

■

PS 5324.12 addresses the requirements of the standard. The evidence standard is a “preponderance of the evidence” in determining

whether allegations of sexual abuse or sexual harassment are substantiated. The investigators interviewed were aware of the evidence

standard. The evidence standard was utilized in the reviewed case files.

Standard 115.73 Reporting to inmates

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.76 Disciplinary sanctions for staff

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

■

PS 5324.12 addresses the requirements of the standard. The facility conducts administrative investigations. There were nine allegations

and completed investigations of inmate on inmate sexual abuse or sexual harassment over the previous twelve months. Six of the

allegations of inmate on inmate sexual abuse or sexual harassment were determined to be unsubstantiated and three were determined to

be unfounded. There were three allegations and completed investigations of staff on inmate sexual abuse or sexual harassment over the

previous twelve months. The determination in the investigations of allegations of staff on inmate sexual abuse or sexual harassment were

all unfounded. A review of documentation confirmed that in all instances, the inmates were informed regarding the results of the

investigation. When the allegation involves staff, the inmate would be informed if the staff member is no longer posted within their housing

unit, is no longer employed at this facility, if the staff member was indicted on a charge related to sexual abuse within the facility or the

agency learned that the staff member was convicted on a charge related to sexual abuse within the facility. Compliance with this standard

was determined by a review of policy, documentation, and staff interviews.

■

PS 3420.11 and PS 5324.12 address the requirements of the standard. Staff are subject to disciplinary sanctions for violating agency

sexual abuse or sexual harassment policies. There have been no substantiated cases of inmates engaging in sex with staff in the

previous twelve months. The Collective Bargaining Agreement (examined by auditor) between the Federal Bureau of Prisons and Council

of Prison Locals, American Federation of Government Employees, dated July 21, 2014 - July 20, 2017 (extended until July 20, 2018),

allows for disciplinary sanctions against staff, including termination, for the sexual abuse or sexual harassment of an inmate. All

terminations for violations of agency sexual abuse or sexual harassment policies, or resignations by staff who would have been terminated

if not for their resignation, may be reported to criminal investigators and to any relevant professional/certifying/licensing agencies by the

agency, unless the activity was clearly not criminal. Compliance with this standard was determined by a review of policy, documentation

and staff interviews.

Standard 115.77 Corrective action for contractors and volunteers

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.78 Disciplinary sanctions for inmates

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

■

PS 3420.11 and PS 5324.12 address the requirements of the standard. Any contractor or volunteer who engages in sexual abuse or

sexual harassment would be prohibited from contact with inmates and would be reported to the appropriate investigator and relevant

professional/licensing/certifying bodies unless the activity was clearly not criminal in nature. In cases that were not criminal in nature, the

facility would take appropriate remedial measures and consider whether to prohibit further contact with inmates. During the previous

twelve months there were no incidents where a contractor or volunteer was accused or found guilty of sexual abuse or sexual harassment

at the FCI or SPC. Compliance with this standard was determined by a review of policy, documentation and staff interviews.

■

PS 5270.09, Inmate Discipline Program and PS 5324.12 address the requirements of the standard. The Inmate Discipline Program

defines sexual assault of any person, involving non-consensual touching by force or threat of force, as the greatest severity level

prohibited act. The program identifies inmates engaging in sexual acts and making sexual proposals or threats to another as a high

severity level prohibited act. Consensual sex of any nature is prohibited and will result in discipline. Consensual sex between inmates

does not constitute sexual abuse. Sanctions are commensurate with the nature and circumstances of the abuse committed, the inmate’s

disciplinary history and the sanctions imposed for comparable offenses by other inmates with similar histories. Inmates are subject to

disciplinary sanctions pursuant to the formal disciplinary process defined in the Inmate Discipline Program. The BOP does not discipline

inmates who make an allegation in good faith, even if an investigation does not establish evidence sufficient to substantiate the allegation.

Interviews with investigators confirmed compliance to this standard. The disciplinary process considers whether an inmate’s mental

disabilities or mental illness contributed to the inmate’s behavior when determining what type of sanction, if any, should be imposed. If

mental disabilities or mental illness is a factor, the facility considers the offer of therapy, counseling or other interventions designed to

address and correct underlying reasons or motivations for the abuse. During the previous twelve months there were no investigations

determined to be substantiated where an inmate alleged sexual abuse or sexual harassment by another inmate at the FCI or SPC.

Compliance with this standard was determined by a review of policy, documentation, and staff interviews.

Standard 115.81 Medical and mental health screenings; history of sexual abuse

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.82 Access to emergency medical and mental health services

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

■

PS 5324.12 addresses the requirements of the standard. Interviews with medical, mental health, and specialized staff confirm the facility

has a comprehensive system for collecting medical and mental health information relevant to the PREA and has the capacity to provide

continued re-assessment and follow-up services. The review of psychology’s “Risk of Sexual Victimization” and “Risk of Sexual

Abusiveness” forms confirmed that inmates who disclosed prior victimization during screening were offered a follow up meeting with

medical or mental health staff within fourteen days. The meeting is usually completed on the same day or within three days. Treatment

services are offered without financial cost to the inmate. As confirmed by observation and a review of intake screening documents,

screening for prior sexual victimization in any setting is conducted by unit team staff during in-processing procedures. In-processing

procedures also screen for previous sexually assaultive behavior in an institutional setting or in the community. When indicated, staff

ensure that the inmate is offered a follow-up meeting with a mental health practitioner within fourteen days of the intake screening.

Information related to sexual victimization or abusiveness is limited to medical and mental health practitioners and other staff with a

need-to-know for treatment plans, security, housing, work, program assignments and management decisions. Signed and dated informed

consents are obtained from inmates before reporting prior sexual victimization that did not occur in an institutional setting. The facility

does not house inmates under the age of 18 or females. Compliance with this standard was determined by a review of policy,

documentation, and staff interviews.

■

PS 5324.12, IS 5324.12C and PS 6031.04 address the requirements of the standard. The facility medical and mental health staff provide

services to both the main facility and the minimum security satellite camp. Medical staff are on duty 16 hours a day, seven days a week

and are available for consultation or call-back at off hours. Mental health providers are on-site five days per week and are also available

for call-back at off hours. Inmate victims of sexual abuse receive timely, unimpeded access to emergency medical/mental health

treatment and crisis intervention services within the facility or are transported to a hospital in the community when health care needs

exceed the level of care available within the institution. Victim advocacy is offered through a local victim advocacy organization, Women's

Resource Center, or by trained staff members. There is no financial cost to the inmate for any sexual abuse or harassment related

incident medical or mental health care or advocacy service, regardless of whether the victim names the abuser or cooperates with the

incident investigation. Inmate victims of sexual abuse while incarcerated are offered information about and timely access to information on

sexually transmitted infection prophylaxis in accordance with professionally accepted standards of care, where medically appropriate.

Follow up mental health services and follow up testing and treatment for sexually transmitted diseases is provided within the FCI or SPC.

There were no allegations of sexual abuse that required referral for forensic evidence collection by a SANE provider in the previous year.

Compliance with this standard was determined by a review of policy, documentation, and interviews with a SANE, a victim advocate, and

medical staff.

Standard 115.83 Ongoing medical and mental health care for sexual abuse victims and abusers

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.86 Sexual abuse incident reviews

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

■

PS 5324.12 addresses the requirements of the standard. As confirmed by a review of policy, the facility may offer medical and mental

health evaluation and as appropriate, treatment to all inmates who have been victimized by sexual abuse in any prison, jail, lockup or

juvenile facility. Inmates are also re-evaluated within 30 days of admission to the facility. The evaluation and treatment of such victims

includes follow-up services. The facility would arrange for referrals for continued care following their transfer to or placement in other

facilities or after their release from custody. The facility has fully staffed medical and mental health departments and offers sexual abuse

or sexual harassment victims with medical and mental health services consistent with the standard of care available in the community.

Inmate victims, while incarcerated, would be offered testing for sexually transmitted infections as medically appropriate. Treatment

services are provided to the victim without financial cost and regardless of whether the victim names the abuser or cooperates with any

investigation arising out of the incident. Mental health evaluations are conducted on all known inmate on inmate abusers at least within 14

days of learning of such abuse history. When appropriate, treatment is offered by mental health practitioners. Compliance with this

standard was determined by a review of policy, documentation, and staff interviews.

■

PS 5324.12 addresses the requirements of the standard. Administrative and/or criminal investigations are completed on all allegations of

sexual abuse/sexual harassment. The facility SIS investigators and/or the FBI/OIG/OIA conduct all investigations. Interviews with the SIS

investigators confirmed that they were knowledgeable concerning the requirements of the program and that they provided information to

the Incident Review Team. The facility conducts a sexual abuse incident review at the conclusion of every sexual abuse investigation,

unless the allegation was determined to be unfounded. The Incident Review Team consists of the Warden, IPCM, the Acting Chief

Psychologist, the Captain and other administrative staff. Based on interviews with members of the Incident Review Team, the review is

conducted within 30 days of the conclusion of the investigation and consideration is given as to whether the incident was motivated by

race, ethnicity, gender identity, status or gang affiliation. The team also makes a determination as to whether additional monitoring

technology or staffing should be added to enhance inmate supervision. The facility implements the recommendations for improvement or

documents its reasons for not doing so. All required reviews by the team were completed within 30 days of the conclusion of all

investigations. Compliance with this standard was determined by a review of policy, documentation, and staff interviews.

Standard 115.87 Data collection

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

Standard 115.88 Data review for corrective action

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

PREA Audit Report

■

PS 5324.12 addresses the requirements of the standard. As confirmed by a review of documents, the facility collects accurate, uniform

data for every allegation of sexual abuse or sexual harassment by using a standardized instrument. The agency tracks information

concerning sexual abuse using data from the facility SIS, the agency’s Office of Internal Affairs and SENTRY, the BOP’s computerized

data management program. The data collected includes the information necessary to answer all questions from the most recent version

of the Survey of Sexual Violence, conducted by the Department of Justice. The agency aggregates and reviews all data annually. Upon

request, the agency would provide all such data from the previous calendar year to the Department of Justice no later than June 30.

Compliance with this standard was also determined by a review of policy, documentation and staff interviews.

■

PS 5324.12 addresses the requirements of the standard. The Bureau of Prisons and the institution reviews and assesses all sexual

abuse/sexual harassment data at least annually to improve the effectiveness of its sexual abuse prevention, detection and response

policies, to identify any trends, issues or problematic areas and to take corrective action if needed. The IPCM forwards data to the

respective Regional PREA Coordinator and then to the National PREA Coordinator. An Annual Report is prepared and placed on the

BOP website. The Annual Report was reviewed by the auditor. The report can be found at the following website address: www.bop.gov.

Compliance with this standard was determined by a review of policy, documentation and staff interviews.

Standard 115.89 Data storage, publication, and destruction

 Exceeds Standard (substantially exceeds requirement of standard)

 Meets Standard (substantial compliance; complies in all material ways with the standard for the

relevant review period)

 Does Not Meet Standard (requires corrective action)

Auditor discussion, including the evidence relied upon in making the compliance or non-compliance

determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion

must also include corrective action recommendations where the facility does not meet standard. These

recommendations must be included in the Final Report, accompanied by information on specific

corrective actions taken by the facility.

AUDITOR CERTIFICATION

I certify that:

 The contents of this report are accurate to the best of my knowledge.

 No conflict of interest exists with respect to my ability to conduct an audit of the agency under

review, and

 I have not included in the final report any personally identifiable information (PII) about any

inmate or staff member, except where the names of administrative personnel are specifically

requested in the report template.

Auditor Signature Date

PREA Audit Report

■

PS 5324.12 addresses the requirements of the standard. The National PREA Coordinator reviews data compiled by each BOP facility,

from SENTRY, from each Regional PREA Coordinator, from the Information, Policy, and Public Affairs Division of the BOP and from the

Office of Internal Affairs and issues a report to the Director on an annual basis. Facility data is maintained in locked files or on computer

data bases that are user ID and password protected. Agency PREA data is securely retained and is published on the BOP website after

removing all personal identifying information. The required reports cover all data required in this standard and is retained in a file.

Compliance with this standard was determined by a review of policy, documentation and staff interviews.

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