2019 Jackson County, Missouri A CRIMINAL JUSTICE SYSTEM ASSESSMENT Document Submitted January 11, 2019 In association with Jackson County Facility Needs Assessment Table of Contents Project Team STEVE DAVIS AND MICHAEL LEWIS SHIVE-HATTERY, INC. DAVID BOSTWICK HDR ELIZABETH FALCON FALCON, INC. REBECCA BROWN FURTHER THE WORK MARK MARTIN MJ MARTIN JANEEN BUCK WILLISON URBAN INSTITUTE For questions, please contact: Michael Lewis, Shive-Hattery mlewis@shive-hattery.com 515.223.8104 Ext. 174074 or Steve Davis, Shive-Hattery sdavis@shive-hattery.com 515.223.8104 Ext. 179736 Jackson County Facility Needs Assessment Table of Contents TABLE OF CONTENTS I. Executive Summary ............................................................................................................................................. 1 II. A Note on Methods ............................................................................................................................................. 3 III. Jail Population Analysis/Profile .......................................................................................................................... 3 A. Summary of Jackson County’s Jail Facilities .................................................................................................... 4 B. Jail Population Trends ..................................................................................................................................... 5 C. Jail Population Characteristics ........................................................................................................................ 7 D. Recommendations For Jail Population Analysis and Management............................................................... 16 IV. Jail Operations and Staffing .............................................................................................................................. 18 A. Jail Profile ...................................................................................................................................................... 18 B. Jail Physical Plant .......................................................................................................................................... 18 C. Jail Staffing and Operations .......................................................................................................................... 20 D. Recommendations for Jail Operations and Staffing ...................................................................................... 24 V. Capacity and Facility Projections ...................................................................................................................... 27 A. Consequences of Jail Overcrowding .............................................................................................................. 28 B. A Systems Approach ...................................................................................................................................... 29 C. Jail Capacity Forecast Data ........................................................................................................................... 29 D. Arrest Data .................................................................................................................................................... 32 E. Incarceration Rate ......................................................................................................................................... 33 F. Projected Jail Capacity needs: Two Scenarios ............................................................................................... 34 G. Jail Projections: Additional Factors ............................................................................................................... 35 H. Jail Projections Less the Participation of Kansas City and Kansas Police Department .................................. 37 VI. Physical Plan Options and Life Cycle Cost Comparisons .................................................................................. 38 A. A New Facility versus Reuse of the Existing Facilities .................................................................................... 38 B. New Facility Options 1, 2A and 2B: Key Assumption ..................................................................................... 38 C. Renovation and Expansion: Option 3 ............................................................................................................ 41 D. Cost and Life Cycle Cost Analysis Summary ................................................................................................... 45 E. Summary of Capitol and Life Cycle Cost Findings .......................................................................................... 49 VII. Reference List of All Specific Recommendations ............................................................................................. 50 Jackson County Facility Needs Assessment Executive Summary I. EXECUTIVE SUMMARY In January 2018, Jackson County, MO (JCMO) issued a solicitation for a system-wide assessment and jail operations review that would address critical questions about its jail including how current deficiencies and capacities could be remedied. From proposals submitted in response to this solicitation, in April 2018 Jackson County retained a team of consultants led by Shive-Hattery and HDR (consultant team) to conduct a rapid-turnaround, high-level review and analysis of the local criminal justice system, including (but not limited to) the jail, and to produce a final report of findings and recommendations. This document constitutes that report. The scope for this project includes seven areas of inquiry: 1. Using available data, conduct jail population analysis 2. Review current jail operations and staffing issues 3. Develop jail capacity recommendations 4. Use the jail capacity recommendations to inform projected scale and scope and compare facility options; Reuse of Existing vs. Build-New Supplemental/Support Areas of Inquiry: 5. Conduct a high-level review and analysis of the Jackson County criminal justice system 6. Identify system drivers potentially affecting jail use 7. Review current custodial mental and medical health systems To understand how any system works, it is critical to understand not only the system’s components, but the interactions among the constituent parts. As with any system, a criminal justice system is comprised of a “group of interacting, interrelated, and interdependent components that form a complex and unified whole.”1 Within that framework, a community’s jail is just one component of the overall criminal justice system in which the jail exists. Its operations, including who enters the jail, for what reason and purpose, and for how long, are influenced by the policies and practices of other justice system actors, including local law enforcement, prosecutors, defense attorneys, and judges, as well as agencies responsible for pretrial and post-adjudication community supervision. Thus, it is important to note and recognize that to a large degree, a community’s jail is largely a “downstream” recipient of “upstream” decisions made by criminal justice policies and agencies beyond the control of a jail’s administration. It is also important to note and recognize the difference between “jail” and “incarceration.” By this, we mean that a jail is a matter of infrastructure and operations; incarceration, on the other hand, is a criminal justice methodology used by entities that hold distinct roles and decision-making authority throughout the criminal justice continuum, beginning with arrest and carrying all the way through sentencing, custody, reentry, and post-release supervision. In the context of this study, it is especially important to recognize that the Jackson County criminal justice system is shaped and affected by an unusually complex set of entities: By Kansas City Police Department, the Sheriff’s Office, and local law enforcement agencies from surrounding towns and cities; by the municipal prosecutor and courts; by the county prosecutors and courts; and by state Probation and Parole, among others. The region’s governing authorities are equally complex: For example, the County Legislature is responsible for setting County budgets, while the County Executive is responsible for County operations, 1 Jackson County Facility Needs Assessment Executive Summary including 1managing the Department of Corrections. The Kansas City Police Department, which serves as the law enforcement agency for Kansas City and is paid through its budget, does not report to the City Council for Kansas City but to a five-member Police Commission, of whom four are appointed not locally but by the Governor. And responsibilities for local probation and parole are under the authority of the Western Region for the Missouri Department of Corrections Board of Probation and Parole. Even Jackson County’s own jail facilities involve multiple authorities: 2KCPD holds jurisdiction over people it brings into the booking facility, the JCDOC is responsible for custody and operations in the JCDC and RCC, and the KCDOC contracts RCC beds to City of Kansas City/Municipal Court. It is the consultant team’s impression that this welter of authorities and duties has led to a highly disconnected and disjointed system in which entities typically operate largely in silos. While there are various multi-agency tables (such as the Kansas City Assessment and Triage Center work group and the multi-agency Population Control Group, among others), these efforts address only limited elements of the overall system. Given these complexities, it appears that the region’s criminal justice stakeholders have encountered longstanding barriers that persistently interfere with their individual and collective abilities to gather sufficient foundational and common knowledge, deepen collective understanding, and develop meaningful agreements on philosophy, policies, and practices. Despite such endemic barriers and divisions, the people involved in the Jackson County criminal justice system–both the people who are brought into the system and the agencies involved in criminal justice policy and operations–are in fact part of one single system. Whether a person is arrested by KCPD, brought into custody as a “municipal” inmate at the RCC or as a “state” inmate at the JCDC, prosecuted by the City Prosecutor or County Prosecutor, defended by public defenders or by nonprofit Legal Aid, heard before the Municipal Court or the District Court, supervised on County House Arrest or State Probation and Parole: These are all one community, operating within one collective system. The intention of this report is to use objective, transparent, independent analysis to deepen shared knowledge and inform local decision-making regarding not just the jail but this larger system of which it is a part. To that end, this study takes a holistic approach to studying Jackson County’s criminal justice landscape, using a Sequential Intercept model as a conceptual framework to guide its assessment of the Jackson County criminal justice system. Using this framework, in this report we identify and analyze local criminal justice policies and practices that affect jail use; provide an analysis of the incarcerated populations in Jackson County facilities (calling on available data); review current jail staffing and operations; review current custodial mental health and medical health care; review current in-custody programming and identify opportunities for community-based interventions or services; and propose recommendations regarding potential future needs for jail bed capacity. Based on our research, it is clear that Jackson County is wrestling with consequential issues of justice, safety, efficacy, cost, accountability, and politics. The jurisdiction has repeatedly witnessed sudden and unplanned shifts in leadership in multiple agencies and positions; the consequences of crowding the jail beyond its functional capacity for decades while deferring maintenance have overwhelmed the physical plant; under-investment in data infrastructure and data analysis have precluded the use of data-driven decision-making both for individual agencies and the system as a whole; and the lack of consistent, well-supported, and collective frameworks for shared learning and agreement have hobbled the system’s capacity to examine issues – such as racial and ethnic disparities in the criminal justice system, the role of both criminal justice fines and money bonds in driving up incarceration, and the need to identify and develop intentional, shared priorities and approaches to address violent crime. 2 Jackson County Facility Needs Assessment Jail Population Analysis/Profile At the same time, it is also clear to us that Jackson County’s stakeholders share a marked and noteworthy sense of commitment to improving what is widely perceived as a difficult and challenging system. Over and over again in our research, we were struck by the local stakeholders’ dedicated, persistent, and urgent desire to recognize embedded challenges, push past roadblocks, and work together to build a better system, one that offers both safety and justice in equal measures. To this end, it is our hope that this report’s detailed analysis and recommendations enrich both planning and action in Jackson County. 1 Since this report was completed, Jackson County voters approved a charter amendment transferring responsibility for running the jail from the County Executive to the Sheriff’s Office. 2 On June 22, 2018 (during the course of this study), Jackson County gave notice to terminate an agreement whereby the County processes and houses Kansas City arrestees arrested on municipal charges. This notice set into process a one year timeline for Kansas City to make other arrangements for housing of their inmates II. A NOTE ON METHODS To undertake this scope, the consultant team interviewed dozens of stakeholders to explore and document system-wide operations that affect the size and composition of the jail population, conducted multiple site visits, gathered and analyzed quantitative data, convened a half-day workshop to present our preliminary analyses and recommendations to a group of 17 criminal-justice policy-makers and agency heads from throughout the jurisdiction, participated in meetings with the Jail Task Force and the public, and made several presentations to the Jackson County Legislature. Using quantitative data gathered with the help of multiple departments and agencies, we developed a quantitative analysis of the incarcerated population and current and historical jail usage. We toured the jail facilities, reviewed policy and operations documents for relevant agencies and functions, analyzed jail operations, and produced a jail staffing plan. Using both quantitative and qualitative data provided during continuous research and fact-finding, we produced a mid-project summary reference and resource guide and presented both preliminary recommendations and proposed action steps. III. JAIL POPULATION ANALYSIS/PROFILE The objectives of the Jail Population Profile analysis were three-fold: 1) to answer critical questions about who is in the jail, why, for how long, and how people detained in the Jackson County Department of Corrections (JCDOC) are released; 2) to identify potential factors or “drivers” of the jail population (i.e., “aging cases” or increasing lengths of stay, etc.) linked to overcrowded conditions; and 3) to identify potential cost-effective alternatives to safely reduce the jail population and improve jail operations (i.e., reduce overcrowding). To address these three objectives, the consultant team drew on multiple data sources, but primarily the county’s Booking and Release Information System (BARIS) and hand-coded tallies of internal jail population records, to obtain aggregated trend and snapshot data from the three secure adult facilities comprising the county’s jail system. 3 Jackson County Facility Needs Assessment Jail Population Analysis/Profile A. SUMMARY OF JACKSON COUNTY’S JAIL FACILITIES 1. The Jackson County Detention Center (JCDC). The JCDC, referred to locally as “the Tower,” is used to hold people awaiting trial on state-level charges, people sentenced to 364 days or less in the JCDC following conviction for a state-level criminal offense, people detained for violating court-ordered supervision, and people awaiting transfer (either pre-trial or postconviction) to another facility such as the Missouri Department of Corrections, a federal facility, or another County’s jail. It has the capacity to house 760 people although the facility’s functional capacity (85 percent of rated capacity) is closer to 549 beds; at times the JCDC has housed as many as 977 people. Typically, approximately 83 percent of the JCDC population is awaiting trial and between 10-13 percent are sentenced to serve time in the JCDC. The JCDC population accounts for roughly 80 percent of people confined in the Jackson County jail system. 2. The 153-bed Regional Correctional Center (RCC). The RCC houses both people charged with and convicted of municipal (Kansas City) offenses or low-level misdemeanor crimes. People convicted of a municipal offense may serve a maximum of six months (180 days); however, people convicted of multiple municipal offenses may serve their sentences sequentially resulting in stays of 18-24 months or longer (theoretically). Stakeholders estimate that people awaiting adjudication (pretrial detainees) currently comprise roughly 50 percent of the RCC population, up from one-third in recent years due to increased failure to appear rates. The RCC’s functional capacity is 130 beds. The RCC population comprises approximately 14 percent of the Jackson County jail system. 3. The 132-bed Jackson County Detention Center Annex (Annex). The JCDC Annex Ground Floor houses the municipal (RCC) disciplinary and Admin. Seg. unit as well as the inmate worker pods, one for state workers (kitchen) and one for laundry workers (state). The upper level Annex is comprised of five Direct Supervision housing pods, four housing state inmates and one housing municipal inmates. Most people brought to the Annex by KCPD are booked and released, often within 4 hours. Data requests and analyses proceeded in an iterative fashion allowing the consultant team to engage stakeholders familiar with the data while also clarifying analytic output and documenting critical data limitations. To gauge the availability and quality of the county’s jail data, the consultant team first asked the JCDOC to populate an Excel spreadsheet with monthly jail population counts for the 12-month period spanning April 2017-May 2018.2 This exercise revealed several data challenges, including missing necessary to readily calculate or report on a variety of basic metrics such as average length of stay, inmate demographics, bond amounts, etc. In the absence of comprehensive and consistent data, the consultant team, in partnership with key local stakeholders, navigated these challenges by requesting a combination of data that could be produced reliably and verified.3 This included amassing a series of “snapshots” to effectively capture data with limited shelf life. Using historical data for average daily population for elements from calendar years (CY) 2012-2018, monthly booking and release counts and monthly ADP data (April 2017-May 2018), a six-month cohort analysis of people released from the JCDC (January-June 2018), and demographic data drawn from multiple oneday jail population snapshots provided by Jackson County stakeholders over the first seven weeks of the assessment period, a profile of the Jackson County jail population emerged along with several critical observations regarding system capacity and jail population characteristics. These observations form a mosaic of the Jackson County jail system that informs several recommendations and offers direction for future inquiry. 4 Jackson County Facility Needs Assessment Jail Population Analysis/Profile B. JAIL POPULATION TRENDS Table 1 presents average daily population data for the Jackson County jail system and its three secure facilities spanning nearly six years. Two key observations are apparent. First, the system’s total average daily population (ADP) increased 18 percent between CY2012 and CY2018. Second, the Jackson County jail system has consistently and persistently operated above its functional capacity for the past six years. The graph’s red line denotes the system’s functional capacity— i.e., optimal operating conditions defined here as using approximately 85 percent of all jail beds. Red figures indicate when ADP exceeds a facility’s functional capacity. Table 1. Average Daily Confined Population, 2012-2018 1200 1000 934 854 822 948 929 969 848 811 800 694 705 694 150 154 772 787 770 810 600 400 200 128 0 2012 2013 total 2014 JCDC 133 131 128 128 28 30 31 31 2016 2017 2018 2015 Total Functional Capacity Source: Monthly Jail Population Report Excel spreadsheet updated July 2018. Note: Calendar Year (CY) 2018 data reflects January-April 2018. CY2015 KCPD data includes May-December 2015 consistent with the shift in operations. As of March 2018, the average daily confined jail population in Jackson County was 966.4 Table 2 plots the monthly ADPs for March 2017-April 2018, serving as an extension of Table 1 with slightly more granular and current information. As illustrated, the Jackson County incarcerated population has remained relatively stable since April 2017, with small fluctuations. In 2016, Jackson County’s ADP was 948 people, yielding a jail incarceration rate of approximately 139/100,000,5 which is lower than both Missouri’s jail incarceration rate (240/100,000)6 and the national jail incarceration rate (229/100,000).7 5 Jackson County Facility Needs Assessment Jail Population Analysis/Profile Note: The jail incarceration rates relative to Jackson County, the state of Missouri, and that nation are offered as a descriptive point of comparison, not a focal point of analysis. The Jackson County jail incarceration rate is based on the number of people incarcerated in the Jackson County jail system relative to the county’s population, the focus of the present analysis. Stakeholder interviews did not indicate either (1) that a substantial number of people were being held by other counties or (2) local law enforcement entities across the county were holding significant numbers of people that would otherwise be housed in the Jackson County jail system, thus the analysis focused on the characteristics of the jail population including major “referral” sources as reported on p.6. The consultant team relied on publicly available data including FBI NCIC and NIBRS data, MODPS, and annual reports (where available) for data on agencies other than KCP. Table 2. Average Daily Confined Population, April 2017- March 2018 1200 1000 800 960 799 957 977 966 795 815 804 120 119 129 132 25 30 34 29 933 944 942 749 771 772 767 757 119 124 132 141 141 30 32 31 33 33 926 909 905 785 768 760 135 126 37 32 901 944 600 400 200 132 29 0 Apr-17 May-17 Jun-17 Jul-17 Aug-17 Sep-17 Oct-17 Nov-17 Dec-17 Jan-18 Feb-18 Mar-18 Source: Monthly Jail Population Report, Physical Headcounts, Received July 2018 Table 3 shows the expected average length of stay (ALOS) across the Jackson County jails overall and by facility over a nearly a six-year period spanning CY2012 and May 2018. The ALOS across Jackson County has been relatively steady over this period. Compared to national figures, Jackson County’s overall expected ALOS is relatively low at 15 days, but the JCDC’s ALOS of 27 days exceeds the national average; in 2013, the ALOS for jails nationally was 23 days.8 Lastly, analysis of aggregate monthly booking and release counts for June 2017-June 2018 indicates bookings into the Jackson County jails slightly exceeded releases: During the 12-month period, there were 25,821 bookings and 25,633 releases. Total bookings translate to approximately 2,151 bookings per month or roughly 72 bookings per day, of which 28 per day were remanded to the JCDC, 15 per 6 Jackson County Facility Needs Assessment Jail Population Analysis/Profile day were remanded to the RCC, and 26 per day were arrested, booked and released by the KCPD within hours (Table 3). On average, KCPD accounted for approximately 22 percent of JCDC admissions and 89 percent of RCC admissions.9 From January-June 2018, three local law enforcement agencies accounted for 87 percent (N=6509) of booked and released cases in the Jackson County DOC: KCPD comprised 59 percent (N=4384) of all booked and released cases, while the Jackson County Sheriff’s Office comprised 18 percent (N=1330) and the Independence Police Department comprised 11 percent (N=795). More than thirty entities, including city, county, state and federal agencies, brought people to the Jackson County jail facilities. Table 3. Average Expected Length of Stay, CY2012-April 2018 JCDC RCC KCPD Total 30 28 28 28 25 20 27 26 20 28 26 20 18 16 15 14 10 15 14 9 9 8 8 7 5 0 2012 2013 2014 8 7 1 1 1 2015 2016 2017 1 2018 Source: Monthly Jail Population Report, Physical Headcounts, Received July 2018 C. JAIL POPULATION CHARACTERISTICS Twelve-month trend and snapshot data compiled at three points in time10 present a consistent picture of who is confined in the Jackson County DOC. The Jackson County jail population is predominantly male (88%) and black (58%). African Americans are disproportionately represented in the jail system, comprising 24 percent of the Jackson County population but nearly two-thirds of the jail population. This is substantially higher than the national average; African Americans comprise 36 percent of the nation’s jail population.11 7 Jackson County Facility Needs Assessment Jail Population Analysis/Profile Table 4. Confined population by Race, March 2018 Source: Jackson County Monthly Jail Report, Excel Spreadsheet June 2018 8 Jackson County Facility Needs Assessment Jail Population Analysis/Profile Table 6. Confined Jail Population by Race, Snapshots April and June 2018 4% 4% 56% 3% 59% 58% 37% 39% 40% 4/26/18 White 6/8/18 Black 6/20/18 Other Jackson County Department of Corrections Snapshots April and June 2018, received July 2018 As of March 2018, the confined jail population was 88 percent male and 12 percent female. This gender breakdown has remained relatively consistent since April 2017. Table 7. Confined Jail Population by Gender, April 2017-March 2018 Male Female 1200 1000 102 101 99 100 100 833 808 792 788 800 110 111 115 815 823 822 109 118 818 853 835 Jan-18 Feb-18 Mar-18 100 112 800 600 400 845 200 0 Apr-17 May-17 Jun-17 Jul-17 Aug-17 Sep-17 Source: Jackson County Monthly Jail Data Excel Spreadsheet, June 2018 9 Oct-17 Nov-17 Dec-17 Jackson County Facility Needs Assessment Jail Population Analysis/Profile More recent snapshot data for April and June 2018, respectively, suggest this gender composition largely stands (Table 8). Table 8. Confined Jail Population by Gender, Snapshots April and June 2018 Male Female 100% 90% 11% 12% 12% 89% 88% 88% 4/26/18 (N=838) 6/8/18 (N=842) 6/20/18 (N=839) 80% 70% 60% 50% 40% 30% 20% 10% 0% Jackson County Department of Corrections Snapshots April and June 2018, received July 2018 Additional data on the characteristics of the jail population are limited or, in some instances, unavailable. Average age, for example, could not be reliably calculated: initial data from the county offered age data for less than 10 percent of the jail population during the specified 12-month period for which monthly jail population data were requested.12 Recidivism is also not routinely calculated, although in the past JCDOC staff compiled a monthly statistical report containing basic demographic, charge, status, program participation and recidivism data. High Jail Utilizers. Despite the data challenges listed above, JCDOC staff recently identified a subset of High Jail Utilizers—people booked into the jail repeatedly and whose incarceration presumably requires a disproportionate amount of jail resources. Between January and June 2018, 83 people had been booked into the JCDC for a total of 358 times; this represents an average of four bookings per person, or roughly a booking nearly every month. Of these 83 high-utilizers, approximately 60 percent had an identified mental illness. During the same six-month period, approximately 50 people cycled through the RCC three to four times. Confined Population Status. April and June 2018 snapshot data indicate approximately 83 percent (N=693) of the total confined Jackson County population was awaiting trial (Table 9). While pretrial rates are high in many jails, the pretrial population in the Jackson County jail exceeds national figures: Nationally, the pretrial population in jails comprises about two-thirds of a jail’s population. 10 Jackson County Facility Needs Assessment Jail Population Analysis/Profile Of people held pretrial, 64 percent were held on charges for a serious offense (Table 10), while probation/parole violators comprised 16 percent, according to the April 26, 2018 snapshot. Table 9. Confined Jail Population by Status (Snapshots from April and June) Pretrial 100% 1% 4% Post-Trial 1% 9% 90% Probation/Parole 4% 7% 4% 3% County Time 2% Other 5% 6% 1% 5% 6% 4% 3% 80% 70% 60% 50% 40% 83% 83% 85% April 26th 2018 June 1st 2018 June 8th 2018 83% 30% 20% 10% 0% June 20th 2018 Source: Jackson County Department of Corrections Memo, 6/4/18 and July 2018 Jail Report Data Table 10. Confined Jail Population by Most Serious Charge, Snapshot in April 2018 (N=838)13 Property Crime Other 7% 8% Drug Crime 10% Crime Against Person 33% Sex Crime 10% Homicide 15% Source: Monthly Jail Population Report, July 2018 11 Probation/Parole 16% Jackson County Facility Needs Assessment Jail Population Analysis/Profile Analysis of the Pretrial Population To better understand the substantial size of the pretrial population in the Jackson County jail, the consultant team obtained release data for a six-month cohort of people booked and released into JCDC between January 1 and June 30, 2018.14 Applying these parameters yielded approximately 7,749 JCDC pretrial releases for approximately 6,237 (unduplicated) defendants booked and released between January 1 and June 30, 2018. These 6,237 unique defendants were predominately male (79.9%), with approximately 49 percent White and 48 percent Black. The racial composition of female defendants also; 58 percent were identified as White while 40 percent were Black; the remaining 2 percent were Hispanic, Native American, Asian and “other.” Release type was missing (none entered) for 32 percent of releases (N=2396) reducing the valid cases for analysis to 5,053.15 The distribution for the 5,053 releases with valid release type data suggests “release to other jurisdiction” is the most prevalent release type, comprising 28 percent (N=1433) of releases during the focal period followed by: 12  Twenty-six percent Released on Own Recognizance (N=1328) after 12.83 days, on average, at the JCDC; this portion of the pretrial population accounts for approximately 17,264 jail bed days (1328*12.83) or roughly 96 beds per day (i.e., 13 percent of the JCDC’s capacity);  Sixteen percent Bond (N=796) after 9.25 days, on average, at the JCDC; this portion of the pretrial population consumes 7,363 bed days or roughly 40 beds per day (five percent of the JCDC’s capacity);  Thirteen percent Prison (N=645) after 105 days, on average, at the JCDC; this portion of the pretrial population consumes 67,725 bed days or roughly 376 beds per day (49 percent of the JCDC’s capacity);  Six percent Probation (N=281) after 133 days, on average at the JCDC; this portion of the pretrial population consumes 37,373 bed days or roughly 270 beds per day (27 percent of the JCDC’s capacity);  Five percent Time Served (N=260) after approximately 37 days, on average, at the JCDC; this portion of the pretrial population consumes 7,363 bed days or roughly 40 beds per day (five percent of the JCDC’s capacity);  Two percent County House Arrest (N=188), a key pretrial option, after spending an average of 57 days in the JCDC; this portion of the pretrial population consumes 10,716 bed days or roughly 59 beds per day (eight percent of the JCDC’s capacity). Jackson County Facility Needs Assessment Jail Population Analysis/Profile Little can be said about the pretrial population’s assessed risk or whether levels of assessed pretrial risk correspond with release decisions. Although Jackson County Commissioned the design and validation of a pretrial risk assessment tool in 2013, stakeholders report that it rarely informs pretrial decision-making. Poor data may also be a factor impeding the tool’s use: Of the approximately 1519 lines of pretrial risk assessment score data provided for the six-month release cohort, 559 lines were coded as NULL. The remaining 964 records had combined scores spanning 0-18, of which approximately eight percent scored a 12 or higher, indicating a high risk of pretrial failure to appear or risk to public safety. This means the remaining 92 percent were assessed as moderate to low risk for pretrial failure to appear or public safety and could remain in the community. A review of the pretrial ALOS distribution for each charge suggests quite a range even within categories—arson, for example, was associated with the longest average length of pretrial stay at 384 days, followed by murder/ homicide/ manslaughter at 352 days (murder) to 65 days (manslaughter). Notably, people charged with Driving Under the Influence (DUI) had an ALOS of 123 days, while felony DUI had a lower ALOS, at 82 days. The reliability of these charge-ALOS data could not be verified during the truncated assessment timeline. Overall, however, these data suggest the policies and practices related to pretrial detention is a significant driver of the jail use and contributes to overcrowding. As this data analysis makes clear, people eventually released on their own recognizance, bond, and county house arrest In Jackson County spend protracted periods in the jail awaiting release. Analysis of Aging Cases The JCDOC maintains a running list of individuals confined pretrial for more than 365 days. Referred to locally as the “aging cases” caseload, these cases are reviewed monthly at the county’s Jail Population Control meeting. On average, the list consists of approximately 114 cases each month. Analysis of the July 2018 aging cases caseload, which consisted of 111 cases (individuals), indicates 26 individuals (23 percent of the “aging” caseload) have multiple cases proceeding through the courts: 18 individuals on the “aging cases caseload” had two concurrent cases while two individuals had five cases proceeding concurrently. Virtually all cases on the aging caseload have multiple charges per case, with the number of charges per cases ranging from 1-15; the average number of charges per case is 3.2 while the average number of charges per person is 4.3. Overall, there are 478 charges associated with the 149 cases attached to these 111 aging cases. Charges consist mostly of violent person crimes such as murder (40%), followed by property crimes (21%) and rape and other sex offenses (14%); approximately 10 percent consist of other “crimes against a person” and five percent are drug offenses. 13 Jackson County Facility Needs Assessment Jail Population Analysis/Profile Of the 149 cases attached to these 111 aging cases, 20 involve “holds,” of which eight appear to be holds for other jurisdictions and five are for Immigration and Customs Enforcement (ICE). Lastly, 20 cases have noted “outcomes” including 16 guilty pleas with anticipated sentencing dates ranging from August 3, 2018 to June 14, 2019, which suggests a combination of case processing delays (i.e., multiple continuances, potentially sizeable gaps between disposition and sentencing) may account for these protracted periods of pretrial incarceration. Continuances are also common: This aging caseload includes 248 continuances, or approximately two continuances per case per person; the number of continuances per case ranges from 0-10. Between May-July 2018, 81 aging cases were disposed of and released from the JCDC after having been confined an average of 707 days or approximately 1.93 years. Days in custody ranged from 367 days to 1,429 days; median days in custody totaled 655 days. Individuals attached to these aging cases were 88 percent male and approximately 51 percent Black, 44 percent White, 5 percent other. Analysis of aging case releases indicates:  Average days in custody varied considerably by race: Cases (N=4) in the “Other” race category stayed 1,187 days on average, compared to Blacks at 628 days and Whites at 725 days.  The number of people released after spending 365+ days in the JCDC doubled from May to July 2018, although the reason for this increase is unclear. Twenty people were released in May 2018 after spending an average of 828 days in the JCDC pretrial (approx. 2.26 years) and another 20 were released in June 2018 after spending an average of 606 days in the JCDC pretrial (approximately 1.66 years); in July, 41 people were released after spending an average of 682 days in the JCDC pretrial (approximately 1.86 years). No clear reason for this increase in case clearances was readily discernable, and stakeholders pointed to both the vagaries of court calendars and variation among judges’ thresholds for continuances.  Release type varied greatly across the 81 cases. Approximately 44 percent (N=36) were released to the Missouri Department of Corrections, specifically the MDAI (prison), after disposition; on average, these people spent 580 days in the JCDC prior to release to MDAI. Another 37 percent (N=30) were released to Probation (N=21) after spending an average of 767 days at the JCDC or Discharged Probation (N=9) after 989 days in the JCDC, meaning these cases were resolved and either sentenced to Probation or a prior probation disposition was adjudicated as complete and the discharge ended the case. Approximately 19 percent (N=15) were released after an average of 728 days in the JCDC via Time Served (N=1), Acquittal (N=1), or Dismissal (N=6); seven people were releases on their own recognizance after 604 days. The high percentage of people held for extended periods in custody, only to be released to probation (after an average of 2.1 years held in custody) or to “discharged probation” (after an average of 2.7 years held in custody), is noteworthy and warrants close attention. In May 2018 the state of Missouri issued a report a justice policy brief that found “the average time from criminal case filing to sentencing increased 8 percent between FY2010 and FY2016 and now takes nearly 190 days on average in Missouri.”16 During this period, it reports, case processing delays in Jackson County increased by 41%, which suggests that such case processing delays may be a meaningful factor in unnecessary use of the jail. In sum, the Jackson County jail system is overcrowded; it has been consistently and persistently operating above capacity for years. As the system’s largest facility, the JCDC contributes the lion’s share of this overcrowding, apparently due in part to the considerable population held pretrial and to system processing delays that result in lengthy pretrial custody stays and a relatively static aging cases caseload. 14 Jackson County Facility Needs Assessment Jail Population Analysis/Profile While there are considerable data limitations and informational gaps that must be addressed, the present analysis of the jail population suggests several opportunities to safely reduce the jail population by focusing on the pretrial population and identifying and systematically resolving bottlenecks to improve case processing efficiencies. Jail Management Information System Strong data systems, including powerful and customizable infrastructure and consistent data-entry and quality management processes, are essential to data-driven decision-making and improvement. The consultant team found that many data systems and processes throughout Jackson County are ill- equipped to provide useful, accessible, and reliable data reports. Further, it is our impression that the system as a whole has not developed intentional and meaningful data-sharing agreements or practices. While we believe that the entire criminal justice system in Jackson County would benefit from increased attention to and investment in the elements necessary to enable data-driven decision-making, it is also true that as the agency responsible for jail management, the JCDOC’s ability to provide reliable, timely data is absolutely essential to effective criminal justice processes. Currently, the JCDOC’s management information system, also known as BARIS (Booking and Release Information System) is outdated and lacks key functionality. Further, as we understand it, JCDOC staff do not routinely receive formal, standardized training on BARIS data entry protocols, and the JCDOC has no data quality assurance protocol. As a result, data are missing, entered incorrectly, or unreliable. We strongly recommend that the County prioritize the need to identify and implement a new jail information management system as an urgent, imperative, and time-sensitive obligation. According to our research, the JCDOC is developing a Request for Proposals (RFP) to accomplish this task, but it is not clear to us that the process is proceeding on a clear and fast-tracked timeline with a targeted implementation date. It is also not clear to us whether the effort to develop this RFP is being meaningfully informed by the insights and recommendations of staff who have primary responsibility for such a system’s needs and efficacies. We believe that JCDOC would benefit from retaining highly qualified external technical assistance to ensure that the data system is both designed and implemented to ensure maximum functionality and utility. In the meanwhile, stakeholders familiar with data operations suggest that a new data system should have the following features, at a minimum: 15  Ability to take and store a photograph at booking, tied to an individual’s Master Number, to foster accurate identification and data-integration at intake  Ability to accurate enter dates and automatically calculate certain durations (such as length of stay); to enter current legal status while retaining prior legal status, rather than overwrite historical data; to automate date-stamps so status can be tied to date and duration  The use of pick-lists and drop-down menus, and limit or eliminate the use of open text fields, to standardize data-entry  The use of mandatory fields for booking information, such as race, gender, or date of birth  The use of validation rules - i.e., identify mandatory fields that must be populated before the screen can advance  Methods that limit and standardize comment fields related to cases and charges, and preclude ad hoc abbreviations Jackson County Facility Needs Assessment Jail Population Analysis/Profile  The use of charge codes that align with state penal codes (currently, the JCDOC charge codes do not match state charge codes)  The use of a “most serious charge” field in the intake process, to accommodate intakes that include multiple charges  The ability to link/integrate police, court and jail data systems so records can be easily aligned D. RECOMMENDATIONS FOR JAIL POPULATION ANALYSIS AND MANAGEMENT Recommendation # 1: Reduce Avoidable Jail Intakes KCPD, Jackson County Sheriff’s Office, and Independence Police Department collectively account for 83 percent of all Jackson County jail admissions. KCPD alone accounted for 4,384 jail bookings (59%) In the first six months of 2018; of these, the majority are arrested, booked and released within four hours. This process consumes limited resources (officer time, booking agent time) and is disruptive for both the officer and the individual. While KCPD is reported to use in-field “cite and release” procedures that do not require custodial booking, system stakeholders should examine jail “inputs” and law enforcement policies and processing data to identify additional opportunities to divert appropriate cases from unnecessary jail bookings. Recommendation # 2: Expedite Pretrial Case Processing to Reduce Pretrial Lengths of Stay Approximately 40 percent of the pretrial population (N=2572) is released after spending an average of 29 days in custody, of which 89.9 percent (N=2312) released on Bond, Own Recognizance (ROR or OR), and County House Arrest. These periods in custody for people released on limited conditions is unreasonably long and suggests the Jackson County criminal justice system could alleviate a great deal of pressure on the jail by expediting pretrial release by establishing a Case Expediter position17 and more implementing more systematic release processes: Reducing pretrial processing times for each of these three populations to just three days would free up 99 beds per day. Additionally, shorter pretrial release processing times reduce recidivism and minimize the instability (potential job loss, housing loss, and family disruption) associated with even very short periods of confinement. Now may be a particularly critical time to address pretrial practices as there is strong momentum both at the national and state levels. In Missouri, the state’s recent Justice Reform Initiative effort notes not only that jail populations and court processing times have steadily increased over the past seven years18 but identifies enhanced pretrial procedures as focal strategy. Nationally, several organizations are advancing pretrial reform through training and technical assistance (TTA), including the Laura and John Arnold Foundation, which will soon launch a comprehensive initiative to provide TTA to nearly 200 jurisdictions nationwide. Recommendation # 3: Strengthen Pretrial Releases Practices Stakeholders across the Jackson County criminal justice system routinely reported that the county’s pretrial risk assessment is under-utilized. System stakeholders should collaboratively examine how to improve the administration, performance and utilization of the tool to inform pretrial release decisions. Likewise, Jackson County stakeholders should review the quality and completeness of available pretrial risk assessment data to discern the underlying patterns and decisions affecting pretrial release. Recommendation # 4: Resolve Aging Cases; Reinstate Limits on Continuances Cases held more than 365 days pretrial comprise roughly 10 percent of the JCDC population and consume an enormous number of jail bed days. In most cases, these involve multiple charges and 16 Jackson County Facility Needs Assessment Jail Population Analysis/Profile substantial processing delays as they move through the courts. About 20 percent of the 81 aging cases released between May and July 2018 were released via a combination of ROR or via dismissal or acquittal; disturbingly, these people had spent an average of 728 days in custody. That people were held for two years in pretrial detention, only to be released without a custodial sentence or transfer to prison, suggests opportunities to substantially reduce jail usage, increase efficacy and equity, and reduce unnecessarily protracted pretrial detention. Stakeholders should embrace a more robust case review process to identify opportunities to shorten processing times, and work to identify and limit unnecessary continuances. Recommendation # 5: Expand Capacity for Diversion To reduce the “inflows” to the jail, we recommend that JCMO identify and build alternative approaches to managing high utilizers of the jail system; this would include increased use of the Kansas City Assessment and Triage Center (KC-ATC) and other alternatives to jail detention for people with behavioral health issues. Jackson County stakeholders should examine these cases and determine what portion, if any, could have been safely diverted and effectively served by the KC-ATC or some other community-based treatment option. Data maintained by the KC-ATC suggest there is ample capacity for additional law enforcement referrals; currently, KCPD referrals comprise just one-quarter of all referrals to the KC-ATC. Recommendation # 6: Address Data-Quality Issues in Jail Information Processes Local stakeholders should work proactively to identify and address data quality issues, including the routine input of charge and release information necessary to monitor jail flows. In the past, JCDOC staff compiled a monthly statistical report containing basic demographic, charge, status, program participation and recidivism data; this report should be reinstated following the hiring and onboarding of the newly approved Operations Analyst position. Furthermore, booking officers and ISC staff should continue to be routinely trained on data entry procedures and quality assurance checks continue to be performed to minimize missing data and enhance both the reliability and utility of the DOC’s data for analysis and decision-making. Recommendation # 7: Engage in System-Wide Data Analysis Stakeholders should establish and staff a system-wide data working group to review case process and flow data across the system, identify inconsistencies or gaps, and implement solutions to remedy any shortfalls. This group should regularly review and analyze arrest, case filings and dispositions, and jail bookings and releases to monitor system performance and identify opportunities to implement options that reduce harm to individuals, enhance public safety and promote equitable and efficient criminal justice administration. Recommendation # 8: Examine and Address Racial and Ethnic Disparities Examine racial and ethnic disparities and address putatively “race-neutral” policies that exacerbate these issues. The Jackson County jail population is predominantly and disproportionately African American. Stakeholders should examine practices including diversion options that may be “race neutral” on their face but which, in practice, may be unintentionally limiting access to jail diversion options. Recommendation # 9: Review and Address Role of Money Bond As is true in jurisdictions across the country, JCMO uses money bonds as one element of determining pretrial release eligibility and conditions. National research indicates that many people who are eligible for pretrial release on bond remain in custody for extended periods, or for the entire duration of the 17 Jackson County Facility Needs Assessment Jail Operations and Staffing criminal process, due to an inability to pay either the full bond or the 10% cost of a bail bondsman. This unnecessary detention has inequitable impact both on low-income people and people of color.19 Further, such avoidable detention comes at a cost both to individual defendants and to the larger economy. Finally, by allocating jail beds to people who would otherwise be released pretrial, unexamined money bonds can substantially—and counterproductively—increase a jurisdiction’s average daily incarcerated population. Therefore, we recommend that JCMO analyze its use of money bond and the effect on jail utilization; identify opportunities to reduce unnecessary detention; and develop and implement robust pretrial risk assessment processes to ensure consistent and equitable approaches to reduce money-based barriers to pretrial release for both the municipal and circuit courts. IV. JAIL OPERATIONS AND STAFFING In this section of the report, we provide an operational analysis, including a determination of staffing needs and/or staffing assignment patterns, for the JCDOC. We assess the adequacy of the existing staffing based on current programs, task levels, and post assignments, provide an objective review of the level of efficiency at which personnel are assigned to the various functions of the jail, and provide recommendations for minimum staffing required to safely and efficiently operate the facilities. A. JAIL PROFILE The operations and staffing of the Jackson County detention facilities are directly affected by the operational philosophy of the JCDOC, the mission of the jail, the people held in the facility, the design of the physical plant, and the number and characteristics of those in custody. In addition, court decisions and state and professional standards influence operations and staffing. Of note here is the expansion of the jail’s mission with the establishment of the Regional Jail concept and the addition of the municipal corrections inmate population in 2012 and the later addition of the KCPD’s arrestees in 2015. This brought about a substantial increase in the number of inmates under JCDOC supervision, the complications of providing supervision in an adjacent but separate building, and the challenges of managing both a short-term holding population and a longer-term municipal corrections population along with its traditional population of county inmates. It’s not clear that the staffing implications of these changes were fully addressed at the time these additional population groups were added. B. JAIL PHYSICAL PLANT The Jackson County jail facilities consist of three structures directly connected by means of a lengthy corridor system. 1. The Jackson County Detention Center (JCDC), constructed in 1981, has a current design capacity of 760 inmates. It is an eight-story building that consists of six levels of inmate housing, a top floor indoor and outdoor recreation area, a main floor with corridor tunnel access to the Jail Annex and Regional Correctional Center (RCC), and a below-grade basement level with additional detention holding cells for inmate transport to court, intake area for arrestees of the Kansas City Police Department (KCPD) and another corridor tunnel with direct access to RCC. The first floor of the main building houses the JCDOC Administration, Visitation Lobby, Master Control, and Men/Women Staff Lockers. At grade level, the KCPD municipal arrestees enter the 18 Jackson County Facility Needs Assessment Jail Operations and Staffing Jackson County jail system for processing, starting at the sally port, intake and booking area, and group and individual holding cells. 2. The Jail Annex was constructed in 1997 and occupied in 1999. The building has three levels with partial below-grade basement. The Annex houses the detention infrastructure for JCDOC. The jail intake and release component of the jail for county arrestees is in the Jail Annex. The Intake and Release processing area includes the Sally Port, Intake/Book area, Classification, Records, and holding cells. Other elements within the Jail Annex on the ground/ main Level include: main Service Dock for the complex, Kitchen and Storage, Central Supply, Laundry, Bonding and Transport. The upper levels include open dormitory pods with a total bed capacity of 153, social work support offices, a north and south indoor gymnasium, visitation, program room, mechanical and storage space also occupy space on the upper level of the Annex. 3. The Regional Correctional Center (RCC) is located in an adjacent building that was constructed in 1934. The building has five levels with a below grade basement. The existing building houses County Population Control, Jackson County Sheriff’s Department-Investigative Unit, County Circuit Court Records, the Circuit Court Information Technology (IT) Department, Records Administrator’s Office, and the Professional Standards Office. The original basement level was converted into two levels with the lower level housing the Jackson County Circuit Court IT Main Server and the level above housing Department of Civil Process and Court Information Technology Offices. The first floor houses Population Control, Professional Standards Office, Records Administrator’s Office, and the Jackson County Investigative Unit. Within the building, as well, are the Inmate Program Services and Training Rooms. Housing people with Municipal charges, the facility has open dormitory pods with a total capacity of 153. Jail Design: The layout and design of the multiple facilities that comprise the Jackson County Jail present significant staffing challenges and are extremely staff inefficient. Including the 8th-floor temporary housing in the North Gym, there are ten floors of inmate housing in three buildings, with 53 separate housing units of varying size and design.20 In addition, the physical plant includes two separate intake and release areas, each with temporary holding cells–one for county detainees in the ground level of the Annex and one for KCPD detainees in the ground level of the JCDC. Staff must be available to supervise and manage behavior in all of these areas and, in addition, manage internal inmate movement between housing and intake, program, and medical services areas. In addition, correctional officers’ ability to effectively supervise and manage the housing modules is hampered by the layout and design of the housing units in JCDC. Staff observation into housing areas is intermittent at best with officers stationed in security corridors where they observe dayroom areas through glazing in the dayroom walls. Staff are required, by policy, to enter each dayroom area to conduct well-being checks at least hourly, with secondary checks conducted in between by observation from the corridor. Electronic door controls for housing units are located in panels outside the units, requiring a second officer to be available to control access into and out of the units. Jail Capacities: A detention facility is usually defined as “overcrowded” when the incarcerated population consistently exceeds the facility’s design, or rated, capacity. However, symptoms of crowding may be apparent much earlier—once the jail reaches approximately 85 percent of rated capacity. At that level, properly housing and managing the diverse jail population begins to become much more difficult, compromising the jail’s classification system. Compromising a jail’s classification capabilities is inconsistent with the safe, secure, and humane operation of the facility. It may lead to increases in violence, tension, and access to contraband. Basic 19 Jackson County Facility Needs Assessment Jail Operations and Staffing functions (security, maintenance, sanitation, programs, recreation, etc.) begin to break down when they are stretched to their limit for extended periods of time due to crowding. These conditions increase the jail’s liability exposure and jeopardize the safety and well-being of both incarcerated people and staff. As suggested in Section 3, Jail Population Analysis, the number of people incarcerated in Jackson County’s detention facilities has persistently exceeded the functional capacity and at times has exceeded its rated capacity. This has led to the use of 235 temporary beds, designated as “overflow” beds, which have been gradually added to housing unit dayrooms, program areas located adjacent to housing units and in the North Gym on the eighth floor of the facility. While these were originally designated as temporary “overflow” bed needed, they are now occupied on a regular basis. Internal Standards: The Office of Professional Standards within JCDOC is responsible for reviewing employee involved critical incidents and investigating complaints of misconduct. The Office also works closely with Department and County Human Resources to recruit and hire correctional staff. The Professional Standards staff conducts background checks and coordinates much of the selection and hiring process for the JCDOC. The Office is also the primary point of contact for the legal department and does most of the work in securing copies of documentation in response to inmate litigation. The work of the Office generates a significant amount of sensitive information which much be processed and maintained. The lack of administrative support assistance contributes to backlogs and heavy workloads on existing staff. Facilities Standards and Accreditation: In the distant past, the Jackson County Detention Center had been accredited for more than a decade, by the accreditation standards of the time. However, this accreditation lapsed nearly 20 years ago. According to a September 2017 Jail Audit Report,21 a Department of Corrections Task Force recommended that the JCDOC work to achieve accreditation through the Commission on Accreditation for Corrections, in accordance with the Performance-Based Standards for Adult Local Detention Facility Standards, 4th Edition. C. JAIL STAFFING AND OPERATIONS Master Activity Schedule: The nature and scope of activities within a facility are defined largely by the mission of the facility, size and characteristics of the incarcerated population, standards and case law, facility capabilities, and sound security practice. The scheduling, sequence, and interactions of these activities must be coordinated with the location and coverage of posts and positions in order to avoid unnecessary peaks and valleys in the workload. A Master Activity Schedule paints a picture of the workload so it can be better balanced through adjustments to the schedule or adjustments to staffing levels when the workload is greatest. The JCDOC has been operating with a basic building schedule, but not with a comprehensive Master Activity Schedule. We recommend that JCDOC complete the Master Activity Schedule currently in development, ensuring that it includes all functions and activities and considerations of workload efficiency. Policies and Procedures, Post Orders, and Training: Written policies and procedures, post orders, training, and staff training are important elements of adequate staffing, institutionalizing practices to ensure that staff efficiently and accurately executing their tasks as assigned. 1. A review and update of the agency policies and procedures is currently in progress. Of the 236 policies in the jail policy and procedures manual, 119, or roughly 50 percent, have been revised/finalized and are considered current to 2018. As of August 2018, 46 additional policies have been revised and are in the internal review process. Approximately 117 remain to be updated. 20 Jackson County Facility Needs Assessment Jail Operations and Staffing 2. While the policies and procedures manual provides staff direction for what is to be done, why it is to be done, and how it is to be done, post orders detail the responsibilities and tasks for each post and position included in the jail staffing plan: what tasks are to be done, when they are to be done, and who will do them. Some of the JCDOC’s post orders date back to 1999. They are no longer in use, and some are not currently available on at least one of the housing posts. 3. Effective staff training is essential to optimizing staff performance. Training serves to improve consistency in operations, promote staff confidence and professionalism, improve morale, and reduce workplace stress, operational problems, and liability. Staff training contributes to effective operations by helping to ensure that staff understand and adhere to policies and procedures, know what to do while on duty and how to do it, and know how to operate complex jail systems and equipment. With new employees, training should focus on building entry-level knowledge and skills in the core tasks the performed in the course of duty. With existing employees, the focus is on addressing deficiencies and performance issues identified through an individualized performance analysis. To be of maximum benefit, the jail’s training program should address the training needs of both groups. Currently, the JCDOC training program includes the following: Table 11: JCDOC Training Program Pre-service and Associate Orientation Basic Academy Leadership Training for Sergeants In-Service Training Approximately 40 hours Approximately 160 hours, including weapons qualification training Approximately 40 hours Monthly, with additional 40 hours of on-the-job training Five to six times per year Twice a year JCDOC currently provides limited in-service training, due to the amount of new recruit training required and availability of qualified staff to conduct the training Overtime: Overtime usage in county detention settings varies by type and amount, depending on local policy, physical plant setting, staffing issues, and financial limitations. To avoid excessive costs for replacement overtime, agencies typically apply a relief factor in calculating they’re overall staffing needs. A Relief Factor or Net Annual Work Hours calculation accounts for time when staff are not available to work. Usually, three different types of overtime are found in detention facilities: 1. Partial overtime, or “spillage,” a common type of overtime, usually occurs when an officer must stay at work for part of an hour or for several hours beyond the scheduled eight-hour shift (or other work schedule) to finish an assignment. In this sense, it is work that “spills over” beyond the expected time on duty. If partial overtime occurs frequently, or in large amounts, it is a clue that some staffing problems exist. Otherwise, the use of partial overtime, when properly managed, is a normal and efficient method of delivering services. 2. Non-replacement overtime typically occurs when the agency requests that a line officer work an extra full shift because additional staffing is necessary, either because of special events or because not enough funded positions are available to complete the expected workload. In some cases, officers report for duty as scheduled, but unanticipated workloads require additional officers. Non-replacement overtime is a wise and efficient use of staff when it is used in limited quantities and for short periods of time, and not on a continuing basis. 21 Jackson County Facility Needs Assessment Jail Operations and Staffing 3. Replacement overtime typically occurs when the agency has an established minimum staffing policy for each work period and each day of the week, but the required numbers are not present as planned or scheduled, perhaps due to vacation time, sick time or other normal losses. In such circumstances, the agency typically requests that some officers work additional shift hours. In this replacement scenario, the agency is paying straight time pay for an absent officer, and overtime pay for the second officer. The use of replacement overtime is healthy only when used in limited quantities. When replacement overtime is used frequently, it is possible the cost of overtime may exceed what would have been the cost for adding a position. An analysis of financial and scheduling records can identify such circumstances. For this report, we analyzed the costs of JCDOC’s use of overtime from January through April 2018. The table below compares the total hours of overtime with the number of full-time equivalent (FTE) positions, based upon a 1692 Net Annual Work Hour calculation. Table 12. Overtime Utilization Jackson County Department of Corrections Overtime Utilization January - April 2018 Month Hours Costs FTE 's January 14,850 $363,569 105.3 February 10,515 $234,950 74.6 March 12,430 $289,625 88.2 April 11,331 $294,271 80.4 Source: Jackson County Department of Corrections It should be noted that the actual number of potential FTEs could vary from the numbers shown, since the overtime hours reflect all facility staff, not just correctional officer positions. The overtime information provided by Jackson County also does not clearly identify whether the overtime was “spillage,” non-replacement or replacement overtime. It’s also the case that over the four-month period studied, there were 45 terminations, including voluntary and involuntary resignations, which can increase overtime costs due to the demands of managing vacancy and training replacement officers. However, this analysis does suggest that a further analysis of the use of overtime would be appropriate. The persistent use of overtime can cause a ripple effects, due to the strain of chronic short-staffing. When officers tire of working overtime, officer availability then drops to less than projected, producing increased stress levels on the officers on duty. For these reasons it is imperative to make every effort to maintain staffing at levels where this does not occur. In general, staffing issues that adversely impact jail operations typically include (1) having too few staff, (2) not having staff members in the right types of jobs, (3) failing to provide staff with clear direction in the form of policies, procedures, and post orders, (4) not scheduling staff members efficiently, (5) not training staff properly, and (6) failing provide coaching and support to staff through proper supervision. These are the types of issues to be explored in a staffing study and addressed in a staffing plan; a wellconceived and properly implemented staffing plan will address many of these problems. Good staffing plans and practices contribute to safety for staff, inmates, and the public; enhances the jail’s ability to provide programs and services and supports efficient use of costly staff resources. 22 Jackson County Facility Needs Assessment Jail Operations and Staffing The types and frequency of facility operations and activities–such as routine custody operations, inmate services, and programs–influence the workload, schedule, and the number and type of staff required to manage the workload. Current staffing levels present challenges in carrying out routine custody operations such as security checks, maintenance, sanitation, searches, admissions and releases, escorts, transports, surveillance and monitoring, etc. When the facility is short-staffed, routine (but critical) custody operations may not be completed, may not be completed as often as is required, or may be performed on a perfunctory level that does not accomplish the intended outcome. Failure to carry out routine custody operations at a high, consistent level may result in serious breaches of security and increases in incidents in the jail. Staffing short falls and crowding present challenges in delivering essential services such as meals, laundry, sick call, medication rounds, visitation, mail, commissary, haircuts, recreation, etc. in a timely consistent manner. The FY2018 budget for Jackson County authorized 362 Full Time Equivalent (FTE) positions. This figure excludes FTE for maintenance personnel who were transferred to the Public Works Department when the responsibility for facility maintenance and upkeep was transferred to that County Department. Actual staffing levels as of August 2018 stood at 308, significantly below authorized strength levels. The following table compared authorized staffing to actual staffing levels. The shortfall in staffing, particularly in the Correctional Officer position, has presented substantial challenges in covering essential custody posts responsible for inmate care and supervision. Gaps in in coverage due to an insufficient number of Correctional Officers have led to increased overtime and activation of Transport Officers and Inmate Service Coordinators to cover posts in inmate housing. It should be noted that the number of vacancies decreased during the course of the staffing study due to a concerted effort on the part of the Administration to expedite hiring. Table 13: Authorized and Current Staffing JCDOC Staffing Study Authorized vs. Current Staffing Levels (as of 8/15/2018) Currently Actual Authorized Filled Vacancies Director 1 1 0 Deputy Director 2 1 1 Major 1 1 0 Captain 6 5 1 Lieutenant 15 10 3 Sergeant 26 26 0 Correctional Officer 218 185 33 Civilian/Other 95 79 16 Total 362 308 54 *includes 8 part-time officers Source: Jackson County Department of Corrections Staff Supervision: Supervisors are responsible for managing officers, not for direct interaction with incarcerated people. Officers are key to the success of the organization, and supervisors are key to the officers’ success. Supervisors set and convey clear expectations, monitor and evaluate performance, visit housing units regularly to support and monitor officers, and they provide insights to the administration on the day-to-operations. 23 Jackson County Facility Needs Assessment Jail Operations and Staffing Within the JCDOC organizational structure, sergeants are front line supervisors. While they make assignments on the shift for specific duties, they do not do conduct performance management. They cannot issue disciplinary reports and do not author performance appraisals. They cannot authorize leave time and they are not responsible for managing time and attendance. They do not decide who works on their floor or in their unit. And due to the staff shortages, they currently perform many correctional officer tasks on the floor. With this scope of authorities and duties, these, sergeants serve more as lead shift officers than as true supervisors. Table 14 provides a comparison of the estimated cost of the proposed staffing plan with current year (FY 2018) budgeted personnel costs. Based upon the cost estimates, full funding for the proposed staffing plan would represent an estimated increase of $3,328,01822 over current funding levels for personnel. Table 14: Comparison of Estimated Personnel Costs Comparison of Estimated Personnel Costs Current (FY18) Personnel Costs vs. Estimated Cost of Staffing Plan Salaries Benefits/Other Costs Current Staffing Cost $ 16,451,946 $ 5,761,703 $ Est. Cost of Proposed Staffing Plan $ 18,919,753 $ 6,621,914 $ Difference $ Total 22,213,649 25,541,667 3,328,018 Source: See endnote23 Staff and Population Management: The number and characteristics of the incarcerated population also influence staffing needs and operations. A facility’s classification plan should be based largely upon the risks and needs of the people it houses, as identified through intake assessments. Staff must be sufficient in number and competency to respond to the characteristics of the facility’s incarcerated populations. This might include age, gender, sexual orientation, race and ethnicity, primary language, medical or behavioral health issues, custody levels, severity of current charge, housing risk classification, and prior incarcerations, among others. All of these factors should be identified and quantified, as they affect the type of staff required for their care, management, supervision, and services. Staff supervision should be consistent with and responsive to the varying levels of risks, variety, and needs presented by the people in custody. D. RECOMMENDATIONS FOR JAIL OPERATIONS AND STAFFING Recommendation # 10: Address Chronic Overcrowding Growth in the incarceration population has led to persistent overcrowding and staffing levels have not kept pace with this growth. Recent trends include more incarcerated women, more people with significant medical and/or mental health needs; more people with higher housing-classification risk profiles.  We recommend that JCMO, the local criminal justice stakeholders, and the JCDOC reach consensus on the maximum capacity of the jail (by housing area) and agree on relief measures to prevent the jail from exceeding the agreed-upon capacity. The overall goal should be to limit the maximum number housed at no more than the original design capacity and to maintain an average daily population of no more than 80-85% of design capacity to allow for proper classification and housing of inmates. Recommendation # 11: Improve Operations and Activities Operations and Activities. Current staffing levels present challenges in carrying out routine custody operations, delivering essential inmate services, and maintaining inmate access to needed programs. 24 Jackson County Facility Needs Assessment Jail Operations and Staffing  We recommend that program areas on housing floors and the inmate exercise areas be restored to their original use to allow people meaningful access to exercise and opportunities to participate in programming and other productive activities.  We recommend that staff presence in housing units should be increased to facilitate more active supervision of the behavior of the incarcerated population.  We recommend that the job description of the Sergeant position be reviewed and updated to include full supervisory responsibilities as front-line supervisors, including authority establish performance expectations of correctional officers assigned to them and to monitor and evaluate performance based upon those expectations.  We recommend that sanitation continue to be a high priority.  We recommend that the Master Activity Schedule be completed to include as many intermittent functions and activities as possible included on the schedule. We recommend that that scheduling of functions and activities be adjusted to make optimum use of available staff to level out the workload across the day. Recommendation # 12: Improve Policies, Procedures, and Training It appears necessary for JCDOC to provide current written directives for staff and sufficient levels of training consistent with Standards.  We recommend that JCDOC update the Inmate Handbook to emphasize the effective inmate behavior management techniques.  We recommend that JCDOC continue the review and update of policies and procedures to reflect current standards, sound correctional practices, and the facility’s operational philosophy; update post orders and make them available on all posts; update the Inmate Handbook to reflect updated policy, schedules, and routines.  We recommend that sufficient resources be allocated to training to provide the orientation, basic, in-service and specialized training required for a facility of this scale. An annual training plan should be developed and updated annually. The annual plan should cover all job classes, including custody staff, support staff, volunteers, contract workers, and the administration. Corrections staff members should receive a minimum of 40 hours of in-service training each year that relates specifically to the operation of the jail. A special emphasis should be given to direct supervision training and/or inmate behavior management training for line officers and supervisors. Staff should also receive training in the updated policies and procedures and post orders. Recommendation # 13: Reduce Vacancies and Turnover The JCDOC has had difficulty in recruiting and hiring to get staffing up to full authorized strength. Staff retention has been a problem. Turnover, however, has decreased from a high of 52% in 2015 to 38% in 2017. 25  We recommend that the JCDOC continue to place high priority on filling vacancies as quickly as possible.  We recommend that JCMO support an initiative to recruit, hire, and train a sufficient number of custody staff as expeditiously as possible to provide sufficient staffing levels to cover key custody posts and get staffing up to currently authorized levels as a first step. The JCDOC and Jackson County Facility Needs Assessment Capacity and Facility Projections JCMO should then use the staff coverage plan presented in the staffing study completed pursuant to this initiative to establish of a baseline of staffing for the jail. New posts or positions identified in the staffing plan should be filled as they are authorized and funding is provided– which should be as soon as is feasible.  We recommend that JCMO support JCDOC and Human Resources efforts to streamline the recruitment and hiring process for correctional staff. Recommendation # 14: Calculate Net Annual Work Hours Staffing shortfalls are due, part, to an inadequate shift relief factor.  We recommend that the Net Annual Work Hour computation developed in conjunction with this study should be applied to the staffing plan to accurately reflect number of FTE’s required to meet coverage requirements. NAWH computations should be updated regularly, both to keep the shift relief factor current and valid for use in estimating staffing needs and to spot emerging trends. Recommendation # 15: Examine Overtime Usage JCDOC over relies on overtime to mitigate staffing shortfalls. This leads to increased costs, contributes to burnout and increased leave usage, and staff turnover.  We recommend that overtime use be better documented and tracked by reason for use. Strategies for reducing overtime such as filling vacancies quickly, better scheduling of vacation time by shift, stricter controls on the use of unpaid leave, updating the NAWH each year, and filling positions identified in this study should be considered and implemented. Recommendation # 16: Develop Informed Staff Coverage Plan Staff Coverage Plan. A full staffing study report has been prepared and submitted under separate cover. The staffing study includes a staffing plan for JCDOC which identifies coverage needs of all essential custody posts and positions. Administrative, support, and program positions are included in the staffing plan, but are not the primary focus of this study. Medical and mental health staffing needs are being addressed separately. The staffing plan includes a relief factor necessary to provide the number of FTE's necessary to provide the coverage indicated. The number of authorized, actual current staffing levels, and recommended FTE levels by job classification or rank are summarized in Table 15. Recommendation # 17: Commit to Data-Driven Whole-System Improvement 26  We recommend that Jackson County improve its capacity for all-system collaboration by forming and institutionalizing a holistic Criminal Justice Coordinating Council (CJCC), jointly authorized and supported by the County Legislature and County Executive. Establishing this body to serve as champions, stewards, and decision-makers is an essential, foundational element of progress for Jackson County.  We recommend that as an element of the CJCC, Jackson County form a multi-agency data group to institutionalize the shared use of data. Designed to foster a system-wide understanding of justice operations and to enhance collective, data-driven decision-making, this data group would initially identify critical key metrics that could substantially facilitate faster case processing. Jackson County Facility Needs Assessment Capacity and Facility Projections  We recommend that the JCDOC staff, train, and leverage the position of Operations Analyst to address several data-related issues of concern specific to the reliability of the jail’s data, and to serve as a primary source of information and analysis to drive other justice-system processes, such as pretrial release, aging-cases, population control docket, and diversion opportunities.  We recommend that JCDOC solicit and select a vendor/consultant to assist in the identification, customization, and implementation of a modern, powerful, web-based jail information system to replace the existing, outmoded database. Table 15: Staff Coverage Summary V.  We recommend that JCMO establish an authorized staffing level for the jail using the information from the staffing study.  We recommend that JCDOC develop an implementation plan that will provide for filling recommended posts and positions as expeditiously as possible as resources are made available.  We recommend that JCMO use the staffing plan recommendations as a baseline for comparison of estimated staffing requirements for any new facilities or facility use options which may be considered. CAPACITY AND FACILITY PROJECTIONS Given the numerous variables that affect jails and the frequent lack of detailed historical data, jail capacity planning is as much an art as a science. The approach herein using methodologies recommended by the National Institute of Corrections (NIC) uses available data to examine broad trends to derive estimates about future needs. The value of jail capacity planning can be measured as much in regard to the role it serves as an impetus for examination and change within the criminal justice system as in regard to mapping future capacity. Available beds in any correctional facility have a tendency to become filled–no matter what the size of the facility. As mentioned previously, jail crowding is a symptom of the policies and practices of the larger criminal justice system and these have been thoroughly studied by the Urban Institute as part of this study. There is generally no correlation between crime rates and incarceration rates. Instead, policies across adjudication decision points in the criminal justice system largely drive jail bed usage. In the end, the jail population is a function of two factors: the number of admissions and the average length of stay. 27 Jackson County Facility Needs Assessment Capacity and Facility Projections Table 31: Factors that influence Jail Population A. CONSEQUENCES OF JAIL OVERCROWDING As noted previously, crowding can create serious management problems and can compromise the safety of inmates and staff as the jail environment becomes increasingly volatile. The dynamics of a jail, with unpredictable inputs and daily fluctuations in population, require management flexibility in the form a few empty beds. Because of this, a jail is at capacity before reaching its design limits. Beds have to be set aside for classification (a male inmate cannot be housed in a female bed, nor can a maximum security inmate be housed in a minimum security bed), and sufficient beds need to be set aside to handle the population during peak periods. For projection purposes, the consultant team is recommending a 15% classification and peaking factor be applied to all average daily population forecasts for Jackson County. A crowded jail can result in the loss of system integrity. This occurs with inmates are released from the jail through “forced releases.” It does not take long for such practices to become common knowledge. At a national level, and as is true for Jackson County, the loss of integrity of the criminal justice system can be seen in the shrinking proportion of the jail population made up of sentenced inmates and the corresponding increase in proportion of pretrial inmates. Since 2000, the relative percentage of pretrial defendants in jails has increased from 56% to 65% in 2016.189 In Jackson County, the percentage of pretrial inmates is even higher. Analysis by the consultant team revealed that 83.5% of the County jail population is being held pretrial (April 26 to June 20, 2018). Inefficiencies in criminal case processes can extend the time to resolve cases, contributing to a rise in the percentage of pretrial inmates which, in turn, squeezes the availability of beds for the sentenced population. 28 Jackson County Facility Needs Assessment Capacity and Facility Projections The analysis of the medical and mental health data is grounded on nationwide standards and best practices in jail medical and mental health services as established by the National Commission on Correctional Healthcare (NCCHC).26 B. A SYSTEMS APPROACH Because the jail population is constantly changing, jail planning is not a one-time process. The process of developing a master plan for managing the jail population includes determining how efficiencies in the criminal justice system can be realized, what alternatives to jail should be in place, and how jail beds (existing and/or new) will be used. The consultant team’s approach to capacity planning includes the following information: • Jail snapshot data • Case processing analysis • Jail and County population trends • System assessment The data gleaned from these sources has generated a number of system recommendations designed to make the most efficient use of existing resources and manage change. C. JAIL CAPACITY FORECAST DATA Jail capacity forecasts are built on an analysis of four data types:     Admissions Average Length of Stay (ALOS) County Population Trends Average Daily Population (ADP) Jail capacity forecasts are compared against local and state incarceration rates to determine to what degree local practice align with historical and regional contexts. Admissions Jail admissions provide an indicator of workload; over time, they help gauge changing pressures on the jail. Factors that influence the number of admissions include the population of the jurisdiction, police resources, availability of pre-booking alternatives, pretrial failure rate, and supervision failure rate. From 2012 to 2017 (See Table 32), jail admissions in JCMO have increased 7.7%. From 2013 to 2014, there was a sharp increase in admissions, which jumped from 15,499 in 2013 to 17,542 in 2014 (an increase of 13.2%). Since 2014, admissions have declined. Overall during this time period, admissions trended up by approximately 292 admissions, year over year. 29 Jackson County Facility Needs Assessment Capacity and Facility Projections Table 32: Historical Jail Admissions Source: Jackson County, MO Average Length of Stay ALOS data can be a measure of system efficiency reflecting, for example, the time needed to move from booking to pretrial release or from booking to case disposition. ALOS can indicate the seriousness of offenses that counties prosecute or reflect changes in policy. From 2012 to 2017 (See Table 33), ALOS in JCMO increased 4.9%. From 2013 to 2014, there was a sharp decrease in ALOS. This coincides with the sharp increase in admissions over the same time period. After 2014, ALOS increased. Overall during the 2012-2017 time period, ALOS trended up approximately .22 days year over year Table 33: Historic Average Length of Stay Source: Jackson County, MO County Population Trends 30 Jackson County Facility Needs Assessment Capacity and Facility Projections County population is as especially important variable to study the relation to jail admissions. Tracking population growth rates helps anticipate future demands on the jail; average daily population per 100,000 county population (i.e., the number of persons in jail per 100,000 residents of the county) provides a rate that allows for the examination of trends in ADP. As a county’s population grows, the average daily population most likely will increase. Following a ten-year decline from 1970-1980, the population of Jackson County has grown consistently since 1980; since 1990, population has increased steadily at an average annual rate of 0.6%. According to state of Missouri estimates,190 the County’s population is expected to grow at an annual rate of 0.4% to the year 2040. Table 34: Historical Population Change, Jackson County, MO Source: US Census Table 35: Projected Population Change, Jackson County, MO 31 Jackson County Facility Needs Assessment Capacity and Facility Projections Average Daily Population ADP is a general indicator of jail bed need. ADP is a direct function of admissions and length of stay and all factors and variables that contribute to admissions and length of stay. From 2012 to 2017 (See Table 36), ALOS in JCMO increased by 13%. Over that time period, ADP increased most from 2014 and 2015, when there was a sharp increase in ALOS and admissions was relatively flat. Overall during the 2012-2017 time period, ADP trended up by 25.8 inmates year over year. Table 36: Historic Average Daily Population Source: Jackson County, MO D. ARREST DATA Rates of arrest generally do not correlate with jail bed use, but they are sometimes used to provide context. Consistent with this approach, members of the consultant team interviewed Jackson County criminal justice stakeholders from agencies relevant to each Intercept to explore agency operations, policies and practices, interactions with and use of the county jail, extant alternatives to traditional criminal justice processing, the challenges facing the Jackson County justice system, and system successes (i.e., what’s working well). In some cases, the consultant team interviewed stakeholders multiple times to clarify polices or procedures or to obtain additional information. More than four dozen interviews were conducted between May and August. Information from across these interviews was synthesized to compile the descriptions below and to identify common themes and inform recommendations. The “front-end” of the criminal justice system includes the agencies whose policies and practices shape decisions regarding how to define and respond to certain actions and behaviors, within the larger context of state and federal laws details rates of violent crime and property crime in Jackson County from 2007 to 2017. As it shows, property crime has been on a downward trend over the past decade has declined 28% since 2007. 32 Jackson County Facility Needs Assessment Capacity and Facility Projections Violent crimes too were trending down over a 7-year period from 2007 to 2014 but have risen sharply, 41.4%, since 2014. This increase in violent crimes tracks the increase in the average daily population of the JCDC (Table 37 shows an increase of 16.7% from 2014 to 2017) where persons arrested for violent crimes are likely held. Since violent crimes typically take longer to adjudicate, as expected, there was a corresponding increase in average length of stay (Table 37 shows an increase of 17.6% from 2014 to 2017). It would seem that violent crime arrests are driving up capacity demand even though other nonviolent arrests and overall jail admissions are trending downwards. Table 37: Rates of Violent Crime and Property Crime E. INCARCERATION RATE A jurisdiction’s incarceration rate (IR) is calculated by dividing the average number of people held in a jail facility each day (the Average Daily Population, or ADP) divided by the jurisdiction’s overall population and multiplied by 100,000, to produce a per capita ratio of 1:100,000. Using this metric, Jackson County had a local incarceration rate of 136.3 in 2016. By comparison, the national incarceration rate for local jails in 2016 was 229; in the same year, Missouri’s incarceration rate for jails was 240.191 Thus, when compared to both national and state trends, Jackson County’s incarceration rate is substantially lower than the national (-41%) and state (-43%) rates. But it should also be noted that while the national incarceration rate increased an average of 4% per year between 1995 and 2007, national rates have declined steadily since then,192 reflecting both state level and federal policies to reduce the use of incarceration; in contrast to this national decline, however, the incarceration rate for Jackson County increased by an annual rate of 2.03% over the last six years. 33 Jackson County Facility Needs Assessment Capacity and Facility Projections Table 38: National and Jackson County: Comparative Incarceration Rates F. PROJECTED JAIL CAPACITY NEEDS: TWO SCENARIOS To estimate projected jail capacity needs for Jackson County for the year 2040, we outline two scenarios: An ADP Trend Projection and an Incarceration Rate Projection. As detailed in Table 39, the ADP analysis uses the jail’s historic annual average daily population data (20122017) and linear regression to develop an ADP trend line, which is then extrapolated to the year 2040. Note that this projection includes a 15% peaking/classification factor to provide bed capacity need at 5-year increments through 2040. Using this method, the projected jail capacity need is calculated at 1,779 beds. Table 39: Method 1, ADP Trend Projection As shown in Table 40, the second method utilizes historic incarceration rates. A trend line was applied to the incarceration rates from 2012-2017 and extrapolated to the year 2040. The incarceration rate is then multiplied times the forecast County population. A 15% peaking/classification factor has been applied to provide bed capacity need at 5-year increments through 2040. 34 Jackson County Facility Needs Assessment Capacity and Facility Projections Table 40: Method 2, Incarceration Rate Trend Projection Using the second method, the projected jail capacity need is calculated at 1,758 beds. Notwithstanding the two differing approaches, the methods produce capacity projections for the year 2040 that vary by only 21 beds–a difference of just over one percent. G. JAIL PROJECTIONS: ADDITIONAL FACTORS As indicated in Section III - Jail Population Analysis/Profile, the number of people incarcerated in Jackson County’s jails has consistently exceeded the facilities’ functional capacity. When a jail is crowded, counties typically seek ways to reduce overcrowding by evaluating characteristics of the population and recommending opportunities to reduce unnecessary incarceration (for example, by eliminating or reducing money bond), increasing case-processing expediency to reduce avoidable delays, and implementing more robust and standardized pretrial release protocols. Reflecting this intention, about 20 years ago Jackson County’s established a Population Control Group, a committee of criminal justice stakeholders whose purpose is to identify opportunities to reduce unnecessary incarceration and relieve overcrowding. With representatives from the Office of the County Executive, County Counselor, Prosecuting Attorney, Public Defender, Presiding Judge, Criminal “A” Judge, Associate Judge, Probation and Parole, Director of the Department of Corrections, the DOC’s Population Control Unit, Court Administrator, Sheriff, and County Legislature, the Population Control Group continues to meet bi-weekly to discuss and attempt to resolve issues within the Criminal Justice system that delay moving of cases. Participants in the Population Control Group consistently report that the group’s meetings have come to have little productive value; while various statistics are reported, there seems to be little or no capacity or methods for the group to engage in meaningful analysis or determine specific decisions of either policy or practice. Given the uncommonly high levels of aging cases (including cases in which people are held in pretrial custody for years; see Section III), this is both noteworthy and an urgent opportunity for immediate improvement. In our study and analysis, the consultant team has identified multiple opportunities to reduce unnecessary incarceration, which are discussed and noted as recommendations in Section III. For the purposes of the jail capacity projects, the consultant team has identified and analyzed three of these opportunities, which we offer here as examples that illustrate the potential quantifiable impact of systemic reform on the jail’s average daily population. 35 Jackson County Facility Needs Assessment Capacity and Facility Projections Moreover, these three changes could be immediately implemented as part of whole-system reform, immediately reducing the jailed population while increasing efficiency, improving procedural justice and equity, and without diminishing public safety: 1. Reduce time in custody for people granted Release on Own Recognizance (ROR). Our examination of release data release data from January 1 through June 30, 2018 revealed that during this time, 1,328 people were granted ROR; on average, they had spent 12.83 days in jail; this is an unacceptably protracted period in custody for people who prove to be of so little risk that, when released, it is without restriction or supervision. These protracted delays are costly, inconsistent with equity and justice, and detrimental to public safety, since using the jail this way limits bed availability for people who are deemed to pose a higher risk. To accomplish this, a good pretrial risk assessment tool and universally accepted decision-making process to inform pretrial decision-making could assist in lowering the time in jail before release. In terms of quantifiable impact, this population of 1,328 people, each held for 12.83 days, represents 17,038 detention days, for an ADP effect of 94.5 beds (17,083 detention days/180 days). If the time period between admission and release on ROR were reduced from 12.83 days to three days (a reasonable and readily achievable goal), the ADP would be reduced by 72.4 beds, reducing jail capacity need by 83.3 beds. 2. Reduce the time before a person is granted release on cash bond. The review of the release data revealed that 796 individuals were released on cash bond after having been held in custody for an average of 9.25 days. Again, a good pretrial risk assessment process could expedite release on cash bond, reduce the bond imposed, or eliminate cash bond, thereby reducing unnecessary incarceration. This population represents 7,363 detention days and an ADP of 40.9 (7,363 detention days/180days). If the time period between admission and release on cash bond were reduced from 9.25 days to 3 days, the ADP could be reduced by 27.6 beds, reducing jail capacity need by 31.7 beds. 3. Expand the use of Courtesy Supervision and County House Arrest, which includes electronic monitoring. Because the JCDOC limits the number of people placed on House Arrest (due to the number of electronic monitoring units it budgets), individuals who are eventually released on pretrial House Arrest remain in custody an average of 57 days. A review of release data revealed that 188 people were assigned to House Arrest represented 10,716 detention days and an ADP of 59.5 (10,716 detention days/180days). If House Arrest were expanded and the wait period in jail reduced to 7 days from 57 days, the ADP would be reduced by 52.2, reducing jail capacity need by 60.0 beds. Taken together, just these the three preceding modifiers could potentially reduce ADP by 152.2 and necessary jail capacity by 175 beds. Projected forward, such modifications could reduce the necessary jail bed capacity in 2040 by over 200 beds. Table 41: Potential Reforms and Effect on ADP and Capacity 36 Jackson County Facility Needs Assessment Capacity and Facility Projections Table 42: Projected Implication of Such Potential Reforms If Jackson County’s criminal justice system continues operating at its current status quo, we estimate that by the year 2040, Jackson County will require an estimated 1,700 to 1,800 jail beds. If Jackson County chooses to make systemic commitments to examining and addressing policies and practices such as those analyzed here, the County could both improve the jail’s current utilization and reduce future bed capacity needs to approximately 1,600 beds if not less for the year 2040. H. JAIL PROJECTIONS LESS THE PARTICIPATION OF KANSAS CITY AND KANSAS CITY POLICE DEPARTMENT On June 22, 2018 (during the course of this study), Jackson County gave notice to terminate an agreement whereby the County processes and houses Kansas City arrestees arrested on municipal charges. As mentioned previously, these arrestees held on municipal charges are held at the JCDC Annex and the Regional Correctional Center. From 2015 through mid-2018, the City’s use of jail beds on average was 17% of the average daily population of the Jackson County jail system. With the removal of inmates held on municipal charges, the jail population projections for Jackson County are revised downward by 17% as seen in Table 43. The jail capacity need for the year 2040 is 1,328 beds. Table 43: Jail Population Projections 37 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons VI. PHYSICAL PLAN OPTIONS AND LIFE CYCLE COST COMPARISONS A. A NEW FACILITY VERSUS REUSE OF THE EXISTING FACILITIES As noted in Section V, Capacity and Facility Recommendations, approximately 1,800 beds are needed to meet the County’s future capacity needs for the year 2040 if no changes are made to the criminal justice system. During the County’s Fact-Check review, it was requested that the consultant team consider projections if KCMO/municipal violation inmates are not included. The following section analyses the construction and operational cost of new facility options that would be built on a yet to be determined green site and would fully comply with current codes, standards, and modern jail design and compare these options to renovation and expansion of the current facility. The following options were explored: Option 1 is to build a new 1,328-bed facility with a core sized to support a 1,828-bed jail on a green site. This option predicts the implementation of some of the system adjustments and alternative program recommendations identified in this study. It also assumes that this facility will not house inmates accused of Kansas City municipal violations. Option 2A (1,578 bed capacity) is the recommended capacity if KCMO municipal violation inmates are not housed by the County or the County adopts system changes and develops alternatives to incarceration. Option 2B (1,828 bed capacity) assumes no changes to the criminal justice system or the adoption of alternatives to incarceration and also assumes the County will house KCMO municipal violation inmates. Option 3 is an option that looks to renovate the existing jail complex and build an 828-bed expansion to bring the total capacity of the complex to approximately 1,828 beds. In addition to analysis of capital costs and on-going staffing costs, pros and cons for each option are presented. B. NEW FACILITY OPTIONS 1, 2A AND 2B: KEY ASSUMPTIONS A new jail facility presents opportunities that are difficult to achieve by re-using the existing jail physical plants. Such missed opportunities include enhanced staff efficiencies (lower staff to inmate ratios), the ability to match housing with current inmate risk characteristics and classifications, the ability to provide enhanced inmate behavior management (that lowers incidents of violence and increases safety for inmates and staff), the ability to provide better medical and mental health care, and provide more robust rehabilitation and treatment programming to inmates. In modern, large (+1,000 beds) local jails, inmate housing is distributed between Special Needs housing and General Population housing to best fit the needs of today’s jail population. From a gross square footage point of view, housing represents 65% of the square footage and support space such as Intake/Release, Administration, Food Service, Laundry, and Centralized Programming. 38 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons Housing Special Needs Housing is set aside for acute medical and transition, acute mental health and step down, and restrictive housing for behavior management. Generally speaking Special Needs housing represents approximately 20% of a jail’s overall bed capacity. From a supervision point of view, Special Needs housing uses indirect supervision (sometimes called podular-remote or indirect supervision). Within the housing units, program rooms such as multipurpose rooms and individual counseling rooms are provided to give inmates rehabilitative programming opportunities on the pod. In addition, access to visitation and recreation is provided at the pod as well. General Population housing for minimum, medium, and maximum security classifications is generally a mixture of dormitory and multiple occupancy cell housing with dormitories used for lower, minimum security housing and multiple occupancy cells (two-person and four-person) used for medium and maximum security classifications. General Population housing is typically 80% of a facility’s overall bed capacity. Direct supervision is the preferred method of supervision for these classifications as it offers the best opportunity of inmate behavior management. Housing units in General Population generally have programming rooms, visitation capabilities, and access to spaces for large muscle exercise. Support Spaces The Intake/Release area (sometimes called booking) is a key support space. It is very similar to and emergency room in a hospital. It is here that people first arrive at the jail and they are processed and triaged. A new consolidated Intake/Release area could not only be more staff efficient but it could support a new mission of care and behavior management of the inmates. Other jail support spaces include Administration, Food Service, Laundry, and Centralized Programming. Gross Square Footage Needs A large jail in the range of 1,000 to 2,000 beds requires approximately 275 to 325 Gross Square Feet (GSF) per bed to account for all jail housing, jail support space, circulation, and mechanical space assuming that it has one or two operational levels. Generally speaking the larger the capacity, less square feet per inmate is required. Table 44 shows the gross square feet rough order of magnitude (ROM) for the three options. Please note that the actual square footage will be refined during the Phase III Program / Planning Assessment phase, and further refined during the Programming Phase and then refined again in the Schematic Design Phase. Table 44: New Facility Options - Square Feet ROM Site Requirements The size of the site will greatly influence design. Site needs are a function of the size of the ground-level area of the building (including areas for non-jail functions) and other areas needed for expansion, parking, building access and roads, outdoor activities, landscaping buffers, and support elements such as outdoor equipment. In rural sites, non-building elements may comprise 80 percent of the site area. 39 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons Whereas small and medium sized jails tend to be most effectively developed as one-level structures, larger facilities (1,000+ beds) may require multiple levels because of their large size. Parking requirements are an important design consideration, jurisdictions should consider the number of facility staff, family and professional visitors for inmates, and other visitors when determining the amount of space allocated for parking. Moreover, many new jails are designed without consideration of the need to expand capacity in the future. With the many changes that have occurred and can occur in criminal justice philosophy, state law, and arrest rates, expansion planning must be part of any facility development process. Given the potential size of a new jail and allowing space for future expansion, if needed, a site with 40-45 acres would provide space for the necessary flexibility to design an efficient facility. Construction Cost Construction costs again will vary according to: the market conditions; timeframe to start of construction; mix of single-occupancy cells, multiple-occupancy cells, with a minimal number of dormitory beds is anticipated. Given the probable cost of construction materials based on industry standards and labor, the cost of a new jail with approximately 400,000 GSF (Option 1) to 475,000 GSF (Option 2B) would range in cost from $230,000,000 to $270,000,000 respectively if the project were to bid in the spring of 2020. Staffing Costs Table 45 shows staffing estimates for the new facility options. Staffing will range from approximately 427 civil and correctional staff for Option 1 (1,328-bed capacity) to 506 staff for Option 2B (1,828-bed capacity). The estimates are based on the following assumptions: a 1:64 staff to inmate ratio in a direct supervision model for all General Population housing; special needs housing will be made up of smaller housing units with indirect supervision; a single intake/release area will be used instead of the two (2) intake/release areas in the current facility. The staffing estimates will be refined as the nature and design of the facility is developed during Programming and Schematic Design. Table 45: Staffing Estimates for New Facility Options 40 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons Table 45 also shows the annual staffing cost for the new facility options based on today’s average salary and benefits of $48,634 annually. C. RENOVATION AND EXPANSION: OPTION 3 Option 3 looks to reuse and renovate the existing buildings of the jail complex–JCDC (tower), Annex, and RCC and add a building comprised primarily of 828 beds of housing to bring the capacity of the jail complex to 1,828 beds overall. Construction Costs The August 31, 2017 HOK Facility Condition Assessment report focused on physical plant deficiencies in all three jail buildings and concluded, “Based on our Assessment, the buildings are in POOR or FAILED condition based upon many factors including:  Age  Outdated detention design of buildings  Differed maintenance over 30 years  Long term lack of investment in the facilities  Safety and security  Changes to building Code/Life Safety  Outdated technology and data  Changes in ACA  PREA standards  Lacking adequate ADA overall cell county by classification  Outdated Mechanical/Electrical/Plumbing/Fire Protection systems” 193 The cost of full renovation, for the three buildings that make up the jail complex, was estimated at the time of the report, to be $140,686,977.194 The report goes on to conclude, “even if the county were to decide to accomplish the needed repairs, the buildings would have many design flaws, code compliance issues, inadequate intake-booking-housing, and be 30 years plus behind current detention standards.”195 If a building containing 828 beds of housing is added to the complex, such an addition will require a 275,000 GSF based solution when industry standards are applied. The square footage per bed multiplier in this scenario is higher to reflect the smaller capacity. The construction cost for such an addition will vary again according to: the market conditions; timeframe to start of construction; mix of single occupancy cells, multiple-occupancy cells and dormitories; and construction materials. In jail construction, the housing component is the most expensive of all the jail components thus a higher cost per square foot is used. In addition, the cost to build on the existing site may require phasing that will extend the construction time period and thus increase cost. The estimated cost of an 828-bed addition is estimated to be in the range of $150,000,000 to $165,000,000. This estimate will be refined in Phase 3 and schematic design. 41 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons Combining the cost of renovation of the existing facilities ($140,686,977) and an 828-bed expansion ($150,000,000-$165,000,000) it is estimated that such a project would cost approximately $290,686,977 to $305,686,977. Which represents a probable increase in costs of $35,686,977 over the cost of building a new 1,828 bed facility. The cost differential is even greater, if the alternative program recommendations in the report are fully implemented. Realistically, without a new facility the ability to fully implement the alternative program recommendations is extremely limited. Staffing Costs As noted in Section IV, Jail Operations and Staffing, the layout and design of the multiple facilities that comprise the Jackson County Jail present significant staffing challenges. If the existing buildings were fully renovated, it would be difficult to remedy the fundamental flaw that makes the jail on of the most staff intensive the consultant team has encountered and the primary flaw is that the jail has ten (10) floors, in three (3) buildings, with fifty-three (53) housing units and two (2) separate intake and release areas. Moreover, the staff to inmate ratios to supervise housing illustrates the staffing inefficiencies of the jail. While newer and modern jail facilities have staff ratios of between 1:48 to 1:64 for housing pods, the Jackson County Jail has the following inefficient staff to inmate ratios:  JCDC Tower: Ranges from 1:24 to 1:36.  Jail Annex: 1:32  RCC: 1:25 As noted in Section IV, 502 is the recommended staffing (correctional officers and civilian) for the existing three (3) buildings at an annual cost of $25,541,667. If an 800-bed building is added to the jail complex, the County would need to add at least 110 correctional officers (including sergeants) to cover the additional housing (assumes a 1:64 staff to inmate ratio for the housing). In addition, other staff would be duplicated between the new and old facilities including: Captains, Lieutenants, Master Control, Transportation officers, and administrative staff to name a few. Approximately 30 to 35 of additional support staff would be required bringing the total staff of an expansion to at least 140-145 overall. Combining the recommended staffing of the existing facilities (502) and the staff needs of an 828-bed addition (a minimum of 145 personnel), this will bring staffing to 647 with an annual staffing cost of approximately $31,466,198. Comparison between a New Facility (Options 1 &2) versus Renovation and Expansion (Option 3). Pros of the Renovation and Expansion Option  42 If the expansion could be situated on the current city block on County-owned property, then the time and expense of finding and buying a new site could be eliminated. Moreover, finding a site is often made difficult if there are surrounding neighbors who oppose the project. Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons Cons of the Renovation and Expansion Option  Construction Cost for Option #3 would be more compared to Options 1, 2a or 2b.  After renovation, the existing facilities would still not meet modern jail standards including clear sight-lines, the ability to use direct supervision, and the opportunity to provide more programming space.  Renovation will be extremely disruptive to the daily operation of the jail. It will require that floors be vacated during remodeling and inmates will likely need to be housed outside of the County and will be an added expense. The HOK remodeling estimate includes approximately $6 million for boarding inmates in other counties during the renovation.  Most importantly, re-use of the existing staff intensive jail facilities will cost about $5.5 million more annually compared to a new facility. Projecting the staffing costs to the year 2040 and assuming an annual inflation factor of 2.5%, staffing costs associated with reusing the jail facilities would cost the County approximately $168 million more compared to a new facility. Pros of the New Facility Option  Building a 1,328-bed facility now, expandable in increments of 250 to 1,828-beds in the future, provides great flexibility for future growth and options with regard to housing KCMO/municipal arrestees.  A new facility will be more staff efficient. An estimated 141 fewer staff will be required to manage and operate a new 1,328-bed facility; 175 fewer staff to manage and operate a new 1,578-bed facility and 141 fewer staff to manage and operate a new 1,828-bed facility, compared to the renovation and expansion option. Annual savings in staffing costs are estimated to be $9.72 million for a 1,328-bed facility; $7.53 million for a 1,578-bed facility and $5.88 million for a 1,828-bed facility. Overall savings on staffing would be over $117.6 million for a 1,328-bed facility; $150.6 million for a 1,578-bed facility and $117.6 million for a 1,828-bed facility by 2040.  There is no phasing required with a new facility. Inmates would not have to be boarded in other counties while the jail was renovated.  A new facility could be purpose built to match the risk and characteristics of today’s inmates.  A new facility would be in compliance with current American Correctional Association standards offering the County a measure of protection from litigation.  A new facility could incorporate the most current thinking with regard to jail design and behavior management including: o 43 Reduced use of Solitary Confinement and Restrictive Housing. In 2016 the US Department of Justice (DOJ) developed a list of “Guiding Principles” to guide limiting the use of restrictive housing across the American criminal justice system including jails. A primary emphasis of the principles is increasing time out of the cell. Current designs of restrictive housing utilize sub-dayrooms that surround a central dayroom. The smaller dayrooms allow inmates more time out of their cell. It also allows 2-3 inmates to be released in the subdayroom for socialization under the supervision of staff. Socialization opportunities can be part of an overall step-down strategy to return the inmate to general population. As the inmate progresses, he is permitted access to the main dayroom and with more Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons socialization opportunities and to amenities including recreation, board games, visitation, and programming. 44 o Creation of a Continuum of Housing to enhance Inmate Behavior Management. Restrictive housing should be part of an overall continuum of housing to enhance and support inmate behavior management. Under the continuum housing strategy, housing units/pods are differentiated by the amenities they offer. Minimum security classifications would have the most amenities and fewer amenities are available in higher classifications. Amenities can include movable furniture and access to ice machines and microwave ovens. Amenities can be operational such as greater access to television, more visitation opportunities, and special events like watching football and movie nights. The point of the continuum is to encourage good behavior and reward good behavior with less restrictive housing environments. The housing continuum works especially well with an effective behaviorbased classification system. o Expanded Medical and Mental Health Care. The most current best practices to support mental health treatment includes dedicated mental health housing where acute inmates can be stabilized under close observation and transition to specialized units that provide for supervised socialization with the goal of returning the individual to general population. o Response to the Opioid Epidemic. The opioid epidemic has impacted jail designs. Designs now include special housing units for detoxification. These units are dormitory designs with medical staff integrated with the correctional officers using direct supervision. In these setting close medical care is provided. o Response to More Women in Jail. Women are the fastest growing inmate cohort. According to a BJS report from 2016, women now make up 14.5% of jail populations throughout the country. In areas of the country where opioid use and addiction are high, the percentage of women in jail exceeds 30%. Women in jail tend to have experienced trauma in their lives and the design of their housing should utilize trauma informed design principles. These include: reduce or remove adverse stimuli; provide connectedness to the outside (this can be views to the outside as well as murals); and cool color palates such as blue, green, and purple. o The Creation of Treatment Programs. There are many treatment programs that could be utilized to help inmates reintegrate back into the community and reduce recidivism. A new facility would allow the design of the programming spaces to match programs that would be most effective to Jackson County Inmates.  A new facility would be more energy efficient as it would be built to more stringent modern energy codes and the County could seek LEED certification to increase energy efficiency even more and reduce long-term utility costs.  A new facility would be new with a life expectancy of materials, furnishings, and equipment in the range of 30 years. Maintenance requirements would be less in the early years compared to the reuse of an existing facility. Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons Cons of the New Facility Option  A new facility would require a new site. Site selection is sometimes a difficult process especially if the site under consideration is located near residential neighborhoods. Typically, acceptable areas for jails are rural areas or sites zoned for industrial use.  County will need to decide how they plan to reuse the existing facilities. D. COST AND LIFE CYCLE COST ANALYSIS SUMMARY Overview: Option #1: New 1,328-Bed replacement facility, has been used a Baseline to compare each of the other options to. We have included conservative Project Costs, in the Options shown here. Please note, Final Project Costs will be refined during the Phase III programming phase and then refined again in the schematic design phase. Option 1: New 1,328-beds (Core of Facility planned for 2,000 beds in LCC) Project Cost: 400,000 sf + FF&E + Project Soft Costs = Range $215 million to $230 million 130-Year Life Cycle Cost Analysis: 30-year capital, Utilities, Maint. trans., Medical and 427 FTE's = $1,588,828,000 Option 2a: New 1,578-beds (Core of Facility planned for 2,000 beds in LCC) Project Cost: 435,000 sf + FF&E + Project Soft Costs = Range $225 million to $250 million 130Year Life Cycle Cost Analysis: 30-year capital, Utilities, Maint. trans., Medical and 472 FTE's = $1,762,567,000 Option 2b: New 1,828-beds (Core of Facility planned for 2,000 beds in LCC) Project Cost: 475,000 sf + FF&E + Project Soft Costs = Range $240 million to $270 million 130Year Life Cycle Cost Analysis: 30-year capital, Utilities, Maint. trans., Medical and 506 FTE's = $1,920,202,000 Option 3: 2New 828-Beds (Core of Facility planned for 2,000 beds in LCC) and Remodel Existing Project Cost: New: 275,000 sf, include infrastructure for future beds = Range $150 million to $165 million 3 Remodel (100% of CMR estimate in HOK study) = $140,686,977 TOTAL = Range $291 million to $306 million 1 30-Year Life Cycle Cost Analysis: 30-year capital, Utilities, Maint., trans, Medical, 3647 FTE’s 45 = $2,168,277,000 ($579,449,000 - $248,075,000 differential) Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons 46 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons 47 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons 48 Jackson County Facility Needs Assessment Physical Plan Options and Life Cycle Cost Comparisons    E. 1 Life Cycle Cost Analysis assume 2% Inflation Rate / Year The existing facilities capacity will not meet the county needs, therefore when considering the option to remodel, we must also include construction of a fourth building to accommodate Jackson County’s full bed needs. 3 More FTE’s due to inefficiency of existing facilities 2 Summary of Capital and Life Cycle Cost Findings A new jail facility would be the best option for Jackson County. A new facility would save the County over $168 million over the next 22 years in staffing costs and a new facility would be more energy efficient and have lower utility costs. Moreover, a new facility could be designed using the most current thinking in justice design including–direct supervision, inmate behavior management, gender and trauma informed design, and robust programming opportunities to reduce recidivism. A new jail facility could also be built in phases. The consultant team has estimated that 1,800 beds are required if no modification recommendations are adopted. If recommendations are adopted then initial bed capacity can be reduced and more beds “plugged in” when needed. This would not be the case if an addition is built next to the jail complex as it would be difficult to expand the addition. 49 Jackson County Facility Needs Assessment Reference List of All Specific Recommendations VII. REFERENCE LIST OF ALL SPECIFIC RECOMMENDATIONS Recommendation # 1: Reduce Avoidable Jail Intakes ................................................................................ 16 Recommendation # 2: Expedite Pretrial Case Processing to Reduce Pretrial Lengths of Stay ................... 16 Recommendation # 3: Strengthen Pretrial Releases Practices ................................................................... 16 Recommendation # 4: Resolve Aging Cases; Reinstate Limits on Continuances ........................................ 16 Recommendation # 5: Expand Capacity for Diversion................................................................................ 17 Recommendation # 6: Address Data-Quality Issues in Jail Information Processes .................................... 17 Recommendation # 7: Engage in System-Wide Data Analysis ................................................................... 17 Recommendation # 8: Examine and Address Racial and Ethnic Disparities ............................................... 17 Recommendation # 9: Review and Address Role of Money Bond ............................................................. 17 Recommendation # 10: Address Chronic Overcrowding ............................................................................ 24 Recommendation # 11: Improve Operations and Activities ....................................................................... 24 Recommendation # 12: Improve Policies, Procedures, and Training ......................................................... 25 Recommendation # 13: Reduce Vacancies and Turnover .......................................................................... 25 Recommendation # 14: Calculate Net Annual Work Hours ........................................................................ 26 Recommendation # 15: Examine Overtime Usage ..................................................................................... 26 Recommendation # 16: Develop Informed Staff Coverage Plan ................................................................ 26 Recommendation # 17: Commit to Data-Driven Whole-System Improvement ......................................... 26 50