Kentucky Department of Juvenile Justice
Conditions of Confinement Assessment
Summary of Key Findings and Recommendations

September 2017

 INTRODUCTION

In February 2017, the Kentucky Department of Juvenile Justice (DJJ) entered into a contract
with the Center for Children’s Law and Policy (CCLP) in Washington, DC to conduct an
assessment of conditions in DJJ’s juvenile detention facilities. At the direction of Commissioner
Carey D. Cockerell, CCLP staff and a team of experts conducted on-site inspections of three
DJJ-operated detention facilities: Fayette Regional Juvenile Detention Center, Breathitt Regional
Juvenile Detention Center, and McCracken Regional Juvenile Detention Center. CCLP also
reviewed state-level policies and training materials related to DJJ’s secure detention programs.
This document summarizes the key findings and recommendations from CCLP’s review, as well
as the cross-cutting issues identified during the three facility assessments. In this document, we
attempt to prioritize areas of concern in need of immediate attention by DJJ in order to operate
safe and humane juvenile detention facilities for youth and staff.
METHODOLOGY

From February to September 2017, CCLP staff and a team of experts in medical care, mental
health care, and educational services conducted the assessment of DJJ’s secure detention
operations. As mentioned above, team members conducted on-site inspections of the Fayette
Regional Juvenile Detention Center (FRJDC), Breathitt Regional Juvenile Detention Center
(BRJDC), and McCracken Regional Juvenile Detention Center (MRJDC). Team members also
reviewed documents and materials provided in advance of the on-site visits, as well as state-level
trainings and policies employed as part of DJJ’s detention operations. CCLP and its experts also
conducted an assessment of the Louisville Metro Youth Detention Services’ (LMYDS) secure
detention facility as part of its contact with DJJ, although DJJ has no responsibility for operating
the LMYDS facility. Findings and recommendations for LMYDS are outlined in a separate
narrative report and checklist of compliance with the JDAI standards.
When conducting this assessment, the team used the most demanding set of standards for
juvenile detention facilities in this country, the Annie E. Casey Foundation’s Juvenile Detention
Facility Assessment Standards. The standards were co-authored by CCLP and the Youth Law
Center for the Foundation’s Juvenile Detention Alternatives Initiative (JDAI). The standards are
used to assess and improve conditions in over 300 JDAI sites in 39 states (including Kentucky)
and the District of Columbia. The JDAI standards have been cited in investigations by the U.S.
Department of Justice’s Civil Rights Division. They have also served as the basis for federal and
state legislation, as well as many agencies’ policies. For example, CCLP staff worked with
legislative task forces in Louisiana and Mississippi in recent years to help those states develop
comprehensive mandatory statewide standards for their juvenile facilities following numerous
lawsuits and concerns about conditions in those states.
The Detention Facility Assessment Standards were initially released in 2006 and revised in 2014.
The standards were developed following an extensive review of applicable federal statutes;
federal and state court decisions; settlement agreements in conditions of confinement lawsuits
brought by the U.S. Department of Justice and public interest law offices; professional standards,
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 including those of the American Correctional Association, the National Commission on
Correctional Healthcare, and Performance-based Standards; best practices in jurisdictions
throughout the country; and consultation with over three dozen recognized subject matter
experts, including former facility administrators.
The standards are organized into eight categories that cover all major areas of a facility’s
operations and use the acronym CHAPTERS:
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Classification and intake;
Health and mental health services;
Access to family and counsel through mail, telephone, and visitation;
Programming, including education, special education, recreation, and religious services;
Training and supervision of staff;
Environment, including issues related to sanitation and the physical plant;
Restraints, room confinement, due process, and grievances; and
Safety of youth and staff in the facility.

Because of scheduling challenges, the team relied on different medical and education experts for
the three on-site facility assessments. The assessment team members for the three facility
assessments are outlined below. Biographical information for each team member, including their
experience conducting assessments of conditions in juvenile justice facilities, is provided in the
corresponding narrative report for each facility.

Breathitt Regional Juvenile Detention
Center and Fayette Regional Juvenile
Detention Center
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Mark Soler, Executive Director, Center
for Children’s Law and Policy
Jason Szanyi, Deputy Director, Center
for Children’s Law and Policy
Jennifer Lutz, Staff Attorney, Center for
Children’s Law and Policy
Andrea Weisman, Ph.D., Consultant and
Mental Health Expert
Robert Cohen, M.D., Consultant and
Medical Expert
Mark Zablocki, Ph.D., Assistant
Professor of Special Education, Illinois
State University College of Education,
and Education Expert

McCracken Regional Juvenile Detention
Center
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Mark Soler, Executive Director, Center
for Children’s Law and Policy
Jason Szanyi, Deputy Director, Center
for Children’s Law and Policy
Jennifer Lutz, Staff Attorney, Center for
Children’s Law and Policy
Andrea Weisman, Ph.D., Consultant and
Mental Health Expert
Michael Cohen, M.D., Consultant and
Medical Expert
Peter Leone, Ph.D., Professor,
Department of Counseling, Higher
Education, and Special Education at the
University of Maryland, and Education
Expert

 As part of the assessment of DJJ’s detention facilities, CCLP prepared the following:
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This summary of key findings and recommendations for DJJ based on the team’s review
of detention operations at the three facilities and corresponding statewide policy and
training materials.

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A comprehensive comparison of DJJ’s state-level policies with the JDAI detention
facility assessment standards, along with a prioritized list of recommended edits and
additions to DJJ’s policies.

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Three individual narrative reports of findings and recommendations for BRJDC, FRJDC,
and MRJDC.

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Three individual checklists of conformance with each of the JDAI detention facility
assessment standards for BRJDC, FRJDC, and MRJDC.

There are inherent limitations in this type of assessment. The team did not visit all of DJJ’s
detention facilities, nor did it visit the three facilities over an extended period of time.
Nevertheless, the comprehensiveness of the assessment standards; the extensive interviews
conducted with administrators, staff and youth; the experience of the members of the assessment
team, the review of available data and records; the observations made throughout the facilities;
and the receipt of consistent information from multiple sources provided a strong foundation of
information for the assessment. In addition, the assessment process inherently focuses attention
on areas of concern and may not fully explore all of the strengths of DJJ’s detention operations.
However, CCLP’s focus, as mentioned above, was to identify significant areas of concern that
warrant immediate attention by DJJ.
FINDINGS AND RECOMMENDATIONS

This summary of findings and recommendations outlines general areas of concern across DJJ’s
detention facility operations. It also prioritizes recommendations for DJJ in each of the eight
areas of the JDAI detention facility assessment standards. The narrative reports for each
detention facility, the corresponding checklists of compliance with the JDAI standards, and the
policy analysis outlined above provide much more detail on these and other findings and
recommendations. Those documents should also be reviewed in full.

GENERAL AREAS OF CONCERN
(1) DJJ’s detention facilities house many youth with significant mental health needs, but
access to mental health professionals is extremely limited.
Staff and administrators at the facilities that we assessed were the first to admit that their
facilities did not have access to adequate mental health services. DJJ currently does not have any
dedicated full-time or part-time mental health staff members on-site at its detention facilities.
Access to DJJ’s psychiatrist is at best only every 30 days, and psychological services were
provided by telephone at the facilities we visited. As outlined in the facility’s narrative reports,
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 the lack of mental health services jeopardizes the safety of young people with diagnosable
mental illness. It also places an unfair burden on staff, who are required to manage the behavior
of very troubled youth without guidance and support from professionals with expertise in
working with youth with mental health problems.
Recommendation: Hire mental health professionals who are on site in DJJ’s detention
facilities and who can work with staff to manage the mental health problems of detained
youth. Increase in-person access to DJJ’s psychological and psychiatric services.
(2) Staffing shortages, high staff turnover, and forced overtime are hindering the ability to
supervise youth in a safe and humane manner.
The team is very concerned with DJJ’s ability to recruit and retain qualified and dedicated youth
workers. Relatively low pay, coupled with the demands of a very difficult job, meant that there
was high rate of staff turnover in two of the three facilities we assessed. The lack of mental
health resources, as outlined above, also contributes to a feeling of burn-out among line staff, as
line staff are expected to manage youth with complex mental and behavioral health problems.
High rates of staff turnover have meant that staff who do remain are expected to work doubleshifts on a regular basis, which contributes to levels of stress and exhaustion. These staffing
concerns are a serious problem that jeopardize the safety of youth and staff at the facility. They
also contribute to the extensive use of room confinement, outlined below.
Recommendation: Address staffing shortages within DJJ’s detention facilities. This may
require salary increases, particularly in parts of the state where salaries are not attractive
enough to recruit and retain Youth Workers and other staff, such as medical and mental
health professionals.
(3) An overuse of room confinement is jeopardizing the safety and well-being of youth.
As mentioned above, significant staffing challenges, coupled with a lack of mental health
resources, have led to a significant over-use of room confinement in two of the facilities we
visited. Two facilities operate units where youth are in room confinement most of the day, and
all three facilities operated isolation cells away from living units that were monitored
inconsistently by staff or remotely by video feed. A court would almost certainly find that the
use of these isolation cells, when coupled with the lack of contact that youth have with
programming and other youth and adults, is a violation of youth’s constitutional rights. While we
were encouraged to hear about changes that had been made to the isolation cells at FRJDC
following our assessment, the use of room confinement in DJJ’s detention facilities presents a
threat to the safety and mental health of youth in detention.
Recommendation: Clearly limit the allowable use of room confinement to situations
where a youth is engaging in behavior that is an imminent threat to the safety of the
young person or others in the facility, and only for as long as the young person represents
an imminent threat to the safety of the young person or others.

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 (4) A lack of special education services denies youth with disabilities their right to a free
and appropriate education.
All three facilities had educational programs with notable strengths in certain areas, as outlined
in the individual narrative reports. However, all three facilities suffered from a lack of special
education staff, and all three facilities had limited access to the services and interventions that
schools are legally obligated to provide for youth with identified special education needs. Indeed,
the team obtained evidence of school staff taking steps to alter plans that had been developed in
community schools to reflect the limited access to special educators and special education
services in detention. This is unacceptable, particularly given the high numbers of youth with
learning disabilities and other behavioral and mental health challenges in DJJ’s detention
facilities. The lack of educational services deprives these youth of access to legally required
educational programming.
Recommendation: Collaborate with local school districts to obtain adequate special
education staff to meet the needs of youth with disabilities. Ensure that state law and
regulation clearly prohibits facilities from altering service plans to remove legally
required accommodations for youth with identified special education needs.
(5) Regimented and punitive behavior management systems in use in two of the three
facilities we visited are inconsistent with core principles of adolescent development, a
driver of the overuse of room confinement, and a vehicle that unfairly impacts youth
with disabilities and medical and mental health problems.
In two of the three facilities we visited, behavior management systems are overwhelmingly
focused on punishing rule-breaking behavior instead of incentivizing positive behavior and skill
development. Because those facilities set a number of very restrictive rules for behavior, such as
not looking or speaking to anyone without first raising a hand, youth were routinely being
punished for the most minor of violations. These violations quickly accumulated into situations
involving the use of room confinement, or they caused youth to become defiant and disruptive
because of a feeling of unfairness about the consequence, which then led to additional
consequences and room confinement. While all juvenile detention facilities should have clear
rules regarding behavior, the micromanagement of youth behavior coupled with a punitive
approach to behavior management has led to systems that drive the over-use of room
confinement. The systems also fail to align with well-established research on the power of
incremental incentives to create long-term behavior change in youth.
Recommendation: Eliminate facility rules that are at odds with normal adolescent
development, such as prohibitions on speaking to or looking at other youth without
permission. Support the creation of behavior management systems that are grounded in
the principles of Positive Behavioral Interventions and Supports, which are in use in
many juvenile facilities’ behavior management programs: https://www.pbis.org/
community/juvenile-justice.

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 (6) Grievance procedures in the facilities are not structured in a way that encourage youth
to report problems.
In the facilities we visited, administrators generally took grievances seriously and conducted full
investigations. However, DJJ policy allows for facilities to limit access to the grievance
procedure in problematic ways. For example, as outlined in the facility narrative reports, access
to grievance boxes is limited, policies require youth to attempt informal resolution of problems
without any stated exception for issues related to staff abuse or neglect, policies place a time
limit on when grievances can be filed, policies limit the range of grievable issues, and policies
require youth to identify specific policies or rules that have been violated for a grievance to be
considered legitimate. Administrators also generally treat the grievance process as an adversarial
one, when it should be an open avenue for communication between youth and facility
management. The grievance process is a vital avenue for administrators to receive information
about problems that may have developed at the institution. It is imperative that this process is
open, transparent, and responsive.
Recommendation: Make immediate changes to policy to eliminate the limitations on the
grievance process and ensure those changes are reflected in procedure and actual
practice.
(7) DJJ’s policies and standard operating procedures for detention should be enhanced in
many areas to align with best practices.
Through our review of DJJ’s policies and each detention center’s standard operating procedures,
we identified a number of strengths, including the overall comprehensiveness of the policies and
procedures. However, there were a number of areas of departure from the JDAI standards across
the policies and standard operating procedures. Moreover, standard operating procedures for
each facility often failed to specify exactly how the facility operationalized the requirements of
DJJ’s state policies (e.g., Who exactly at the facility is responsible for a particular task or
monitoring to see that a requirement is met?). In the accompanying policy review matrix, we
attempted to identify all areas of departure from the JDAI standards, but we also included a list
of prioritized recommendations to help guide revisions to existing policies.
Recommendation: Review the prepared list of suggested revisions and make appropriate
changes in state policy. Ensure that facilities revise standard operating procedures to
reflect those changes, using the revision to include additional specificity about how the
facility will operationalize the policy in daily practice.
(8) Staff would benefit from enhanced classroom-based and on-the-job training.
In our assessments, we encountered many relatively new staff members who did not have much,
if any, experience working with at-risk youth. The team heard from many staff members and
administrators that the training that staff receive from DJJ’s training academy includes helpful
information that staff need to know, but that the training does not prepare them for the realities of
working in a secure juvenile detention center. Staffing shortages also mean that Field Training
Instructors do not have the time to engage in the type of structured and supervised on-the-job
training that would help new staff translate their classroom instruction into practice. Although we
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 recommend a number of additions and enhancements to DJJ’s training program below, we see
immediate value in enhanced training on de-escalation strategies and crisis intervention in
particular.
Recommendation: In addition to incorporating revisions to DJJ’s training academy
below, introduce new and targeted training on helping staff build verbal de-escalation
skills to manage youth behavior. One such program is the Safe Crisis Management
training curriculum, which has been used in many juvenile justice facilities with
improvements to the facility’s safety for youth and staff: http://www.jkmtraining.com/.
(9) The wide variability in conditions across facilities and the identification of policies and
practices that jeopardize the safety of youth and staff warrant additional training of
and oversight by staff at DJJ who are responsible for monitoring conditions.
DJJ is one of a relatively small number of state juvenile justice agencies with responsibility for
operating secure detention facilities. This arrangement can have significant advantages, and
policy can be set for all facilities at once. However, as DJJ administrators know, even in a
centralized system such as this, there is often wide variability in how policies are interpreted and
operationalized in practice. The team’s experience in each of the three detention facilities
confirmed this. It also raised questions among team members about the rigorousness of existing
oversight mechanisms and auditing processes. For example, the team’s observations around the
use of room confinement and the monitoring of the youth while in room confinement raised
serious safety concerns. However, the team did not see that issue identified in any of the DJJ
audits that were provided to us. DJJ would benefit from a review of its facility oversight
activities, in addition to adding additional outcome measures (as opposed to process measures)
and red flag indicators to its assessments of detention facilities. We would be happy to assist
with these activities.
Recommendation: Review the need for additional oversight activities and standards for
DJJ’s review of its detention facilities after considering the findings and
recommendations in each of the facilities assessed, and develop and implement
corresponding improvements.

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 CLASSIFICATION AND INTAKE
Recommendation: Support facilities in their efforts to review Resident Handbooks and
re-write portions of the text that use vocabulary or sentence structure that are difficult for
youth to read and understand. An example of revising language to make it more youthfriendly and developmentally appropriate is Washington Judicial Colloquies Project, A
Guide for Improving Communication and Understanding in Juvenile Court (Team Child
2012), in which judicial colloquies with youth were revised to make the language more
understandable and accessible. Help facilities redesign Resident Handbooks - for
example, by using varied fonts, illustrations, and color - to make the appearance of the
material more interesting and easier to follow.
Recommendation: Modify the VSPAS to ask separate questions about a youth’s sexual
orientation and the youth’s gender identity, as well ask to ask one question about race and
a separate question about whether the youth is Hispanic or Latino.

HEALTH AND MENTAL HEALTH CARE
Recommendation: Address the nursing staff shortages by hiring or transferring
appropriate personnel, and explore options to increase the salaries of nursing staff to
improve hiring and retention.
Recommendation: Ensure that the DJJ Medical Director (1) regularly revises chronic
care guidelines for nursing staff and physicians, (2) regularly revises acute and chronic
care protocols for nursing staff, (3) revises and improves the model for clinical review of
provider practice (the form in use is more than 10 years old and contains out-of-date
references), (3) provides nursing and provider staff with access to current medical,
obstetric, and pediatric textbooks or electronic textbooks (e.g., “Up-do-Date), and (4)
provide accredited continuing education courses for nursing staff and medical providers
via webinar.
Recommendation: Revise and standardize emergency treatment protocols for
anaphylaxis, status asthmaticus, status epilepticus, opioid overdose, and other common
medical conditions of adolescents.
Recommendation: Develop clinical and laboratory monitoring protocols for
management of youth prescribed psychiatric medicine. Such protocols can be based on
the practice parameters promulgated by the American Academy of Child and Adolescent
Psychiatry.
Recommendation: Expand screening for sexually transmitted infections to include
syphilis and HIV. Identify and secure appropriate training for staff to provide counseling
for youth who identify as HIV-positive.
Recommendation: Obtain adequate staffing to maintain up-to-date vaccination records.
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 Recommendation: Identify and provide training to clinical and non-clinical staff on the
medical needs of transgender and intersex youth.
Recommendation: Provide routine dental screening and care to youth.
Recommendation: Reevaluate DJJ’s commitment to provide mental health care within
its detention facilities. While detention is not the venue within which to provide long
term intensive therapeutic services, facilities must provide screening, assessment and
crisis stabilization to youth with significant mental health histories. Mental health staff in
detention facilities, along with case management, must also ensure linkages to necessary
services upon the youth’s release, whether it be to the community or to a commitment
facility.
Recommendation: Request additional funds so as to be able to hire a sufficient number
of mental health staff. Until that occurs, develop a new understanding or contract
between DJJ and detention facilities so that mental health professionals are able to
provide a greater number of on-site assessments of the youth.
Recommendation: Given the reported levels of trauma that youth expressed, it is clear
that the introduction of a trauma-focused program designed for use in detention is
warranted. One such program is Trauma Affect Regulation: Guide for Education and
Therapy (TARGET).1
Recommendation: Ensure that qualified medical professionals are available daily for
medication administration.
Recommendation: Provide a supply of naloxone for each DJJ facility and develop
emergency care protocols and training for medical and non-medical staff on the
appropriate use of naloxone in the case of overdoses.
Recommendation: Resume annual emergency and “man down” drills in all facilities.
Recommendation: Establish a system-wide quality assurance program with (1) facilitygenerated QA studies and follow-up; (2) centrally generated QA studies and follow-up;
(3) annual emergency and “man down” drills in all facilities; and (4) integration of
medical and mental health services in quality assurance with respect to mental health
screening, use of isolation, integration of mental health care with chronic disease
management, and medication monitoring for psychiatric drugs.
Recommendation: Conduct a well-crafted audit to determine what proportion of youth
are getting their medicine continued without interruption and the reasons why they are or
are not. Analysis of the audit results should help direct attention to the specific issues that
need to be resolved to meet this standard: Are medicines started promptly when parents
1

Ford, J., Trauma Affect Regulation: Guide for Education and Therapy (TARGET), National Institute of Justice,
CrimeSOLUTIONS.gov (2011).

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 bring in their child’s prescription bottles? Are medicines delayed because there is no
nurse on duty? Because a physician cannot be reached to give an order? Because the
pharmacy did not deliver the medicine until the next day? Other reasons? Use this
analysis to identify improvements to medicine delivery, such as greater use of the backup
pharmacy to get initial doses promptly while waiting for the full prescription to be filled
by the contract pharmacy.
Recommendation: Determine which medicines must never be discontinued abruptly and
develop a plan to ensure such medications can be continued.
Recommendation: Provide assistance for youth without health insurance to become
insured. This may be a regional or a home office function. Currently “health navigators”
funded under the Affordable Care Act are assisting families in the community to obtain
health insurance. Health navigators based in DJJ could help youth and their families to
enroll in in Medicaid, the Child Health Insurance Program (CHIP) or another health
insurance program for low income children subsidized under the Affordable Care Act.

ACCESS
Recommendation: Clarify in written policy that staff should not read incoming or
outgoing non-legal mail unless they have a reasonable suspicion that the letter contains a
specific threat to the safety or security of the institution.
Recommendation: Clarify in written policy that staff are never to open or read incoming
or outgoing legal mail.
Recommendation: Clarify in written policy that staff should not routinely listen in to
non-legal calls unless there is reasonable suspicion that the call contains a specific threat
to the safety or security of the institution.
Recommendation: Clarify in written policy that staff are never to listen in on legal calls,
and identify accommodations to allow youth to make calls confidentially.

PROGRAMMING
EDUCATION

Recommendation: Work collaboratively with local school districts to develop school
rules that state what youth should do in schools instead what they should not do. These
rules should be based on the principles of Positive Behavioral Interventions and Supports
(PBIS): www.pbis.org.
Recommendation: Collaborate with local school districts to obtain adequate special
education staff to meet the needs of youth with disabilities. Ensure that state law and

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 regulation clearly prohibits facilities from altering service plans to remove legally
required accommodations for youth with identified special education needs.
Recommendation: Change KECSAC policy (704 KAR 19:002) to require the hiring of a
certified special educator or ensure that general education teachers have the appropriate
documented training to working with youth with special needs.
Recommendation: Under current state law, high school students may not take the GED
exam until they are 18. Petition the KDE, KECSAC, or appropriate legislative authorities
for a waiver for of this requirement.
GENERAL PROGRAMMING

Recommendation: Ensure that youth receive one full hour of physical recreation per day
outside of their cells and units.
Recommendation: Require facilities to create a policy for the management of youth with
disabilities. The policy should address how the facility will provide programming,
medical and mental health services, recreational activities, and reading materials to youth
with disabilities. The policy should designate a specific staff member to be responsible
for making legally required accommodations for youth with disabilities.
Recommendation: Require facilities to develop a policy outlining how staff will provide
meaningful programming, services, and education for limited English proficient youth.
Recommendation: Require facilities to eliminate rules that are at odds with normal
adolescent development, such as prohibition on speaking to or looking at other youth
without permission. Require the creation of behavior management systems that are
grounded in the principles of Positive Behavioral Interventions and Supports (PBIS),
which are in use in many juvenile facilities’ behavior management programs:
https://www.pbis.org/community/juvenile-justice.

TRAINING AND SUPERVISION OF EMPLOYEES
Recommendation: Explore options to increase the salaries of staff to improve hiring and
retention.
Recommendation: Enhance training to better prepare staff to deal with the causes,
nature, and symptoms of trauma that they will encounter in justice-involved adolescents.
Staff should receive additional training during the Academy, orientation training at the
facility, and annual training through the in-service training program.
Recommendation: Provide additional pre-service and regular in-service training on
crisis management and verbal de-escalation strategies. Adopt a training model that
prioritizes training time on prevention and de-escalation strategies as opposed to
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 obtaining physical control of youth. The Safe Crisis Management curriculum out of
Pennsylvania is one such program.
Recommendation: Provide direct care staff with a full day of suicide prevention training
followed by annual four-hour refreshers. The training should be specific to the juvenile
justice population and deal with roles and responsibilities, incorporating relevant agency
policy.
Recommendation: Provide training on the racial and ethnic backgrounds of youth in
custody and how to work with youth in a culturally responsive manner.
Recommendation: Develop and implement training curricula on the following topics,
which are not included in DJJ’s training academy:
• Signs of physical, intellectual, and developmental disabilities, the needs of youth
with such disabilities, and the ways to work and communicate effectively with
youth with those disabilities.
• Signs of mental illness and the needs of and ways of working with youth with
mental illness.
• The facility’s language access policies and plans, including how to access
language assistance services for limited English proficient youth.
• Gender-specific needs of youth in custody, including special considerations for
boys and girls who have experienced trauma, pregnant girls, and health protocols
for both boys and girls.
• Signs and symptoms of medical emergencies, including acute manifestations of
chronic illnesses (e.g., asthma, seizures) and adverse reactions to medication.
• Signs and symptoms of mental illness and emotional disturbance.
Recommendation: Develop a system to collect and review information and review
information about the use of discipline and incentives, including SOPs and Room
Confinement.

ENVIRONMENT
Recommendation: Require facilities to end the general prohibition on speaking during
meals and add any extra time needed in the facility cafeteria to accommodate the change.
Recommendation: Require facilities to include additions to existing emergency
preparedness plans that address the process for transporting essential medications off-site,
outline the process for notification of family members (including designating staff who
would be responsible for making the notifications), and address how to meet the needs of
youth with disabilities and limited English proficiency.
Recommendation: Require facilities to secure written agreements with outside agencies
about their willingness to provide transportation and relocation services if a total facility
evacuation is needed.
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 Recommendation: Require facilities to conduct a fire drill that requires staff to clear
youth from the building at least annually.
Recommendation: Require facilities to install grab bars and shower fixtures that would
meet the needs of youth with physical disabilities. Suicide-resistant grab bars with
welded steel between the wall and the bar are available from corrections supply outlets.

RESTRAINTS, ROOM CONFINEMENT, DUE PROCESS, AND GRIEVANCES
Recommendation: Engage Safe Crisis Management or another program that has
demonstrated effectiveness in multiple jurisdictions to provide training on de-escalation
for facility staff.
Recommendation: Require facilities to remove the “therapeutic restraints.”
Recommendation: Require facilities to remove the magnetic strips over the windows of
confinement rooms.
Recommendation: Clearly limit the allowable use of room confinement to situations
where a youth is engaging in behavior that is an imminent threat to the safety of the
young person or others in the facility, and only as long as the young person represents an
imminent threat to the safety of the young person or others.
Recommendation: Make immediate change to policy to prohibit the limitations on the
grievance process outlined in the facility narrative reports and ensure those changes are
reflected in procedure and actual practice.

SAFETY
Recommendation: Develop and add guidance to the undue familiarity policies and
procedures to address admissions to detention of relatives and family friends.
Recommendation: Add language to sexual misconduct prevention, detection and
response policies that does the following:
• Outlines the facility’s obligation to notify parents or legal guardians and the
attorney of record of allegations of sexual abuse and the results of investigations,
including who is responsible for making those notifications.
• Explicitly requires that victims and alleged perpetrators not drink, smoke, use the
restroom, or engage in other activity that could jeopardize collection of physical
evidence in policy, procedure, and first responder duties.
• Outlines the procedure for notifying youth of the personnel actions and charging
and conviction outcomes outlined in the PREA standards for staff perpetrators of
sexual abuse, and of charging decisions for alleged youth perpetrators of sexual
abuse.

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 Recommendation: Consult with emergency medical professionals to determine if a
longer evidence collection period than 72 hours is warranted following allegations of
sexual abuse.

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