Policy Number

Applicability
DOC

STATE OF IOWA
DEPARTMENT OF CORRECTIONS

AD-GA-23

POLICY
AND PROCEDURES

Policy Code

Iowa Code Reference

Public Access

N/A

Related DOC
Policies

Administrative Code
Reference

AD-GA-01
IO-RD-01
IO-RD-02
IO-RD-03
WR/OWI-38

N/A

ACA Standards

Responsibility

N/A

Michael Savala
Steve Dick

Effective Date

Authority

Chapter 1
ADMINISTRATION &
MANAGEMENT

Subject

Sub Chapter
GENERAL
ADMINISTRATION

RACIAL DISPARITY

CBC

April 2019
I.

PURPOSE
The purpose of this policy is to address issues of disparity and to ensure respect
and fair treatment by implementing correctional procedures and practices that
rely on equitable and relevant criteria rather than on the basis of an individual’s
identity.

II.

POLICY
It is the policy of the Iowa Department of Corrections (DOC), both for
Institutions and Community Based Corrections (CBC) to respond to and mitigate
racial disparities so as to practice fair and equitable distribution of benefits and
burdens in the assignment of incarcerated individuals/clients to custody levels,
institutional/residential jobs, vocational program opportunities, preparation and
support for parole/work release and community based supervision and
programing. It is the responsibility of the department to provide an environment
for incarcerated individuals/clients that is free from harassment or disparate
treatment based on their race, color, or national origin. Moreover, it is our policy
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AD-GA-23

 that any administrative processes associated with custody and classification,
discipline and grievances are conducted fairly, and that decisions are not
influenced by stereotypes or bias based on race, color or national origin. The
Department shall provide ongoing staff education and training, monitoring, and
auditing systems to provide continuous quality improvement and compliance with
all provisions of this policy. Likewise, the Department shall develop programs to
help incarcerated individuals/clients work and live together regardless of their
identity and backgrounds. The goal is to deliver supportive services based on
equality and respect for all individuals. All DOC/CBC staff, volunteers and
contractors shall adhere to this policy.
III.

DEFINITIONS
A.

Classification - A comprehensive process of an incarcerated
individual/client assessment, placement, and management designed to
optimize public safety, allows the most efficient use of correctional
resources, optimize safe and orderly operations, and addresses
incarcerated individual/client needs.

B.

Custody Level - An assessment of an incarcerated individuals/clients
threat to institutional safety and security that determines the level of
supervision, circumstances of program or job assignment(s), and the
requirements for escort and restraints during movement inside as well as
outside the institution/facility.

C.

Grievance Process - A formal written complainant process using
established procedures in IS-OR-06, Incarcerated Individuals/Client
Grievance Procedures, filed by an incarcerated individual/client.

D.

Discipline - System for governing an incarcerated individual/client conduct
that specifies prohibited acts and the penalties that may be imposed, if
institutional or CBC rules are violated.

E.

Institutional/Residential Job - Assignment of an incarcerated
individual/client to a particular work or task for which he/she is
compensated monetarily or otherwise, or is not compensated in any way.

F.

Racial Disparity - Disparate treatment influenced by stereotypes or bias
based on race, color or national origin.

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 IV.

PROCEDURES
A.

Leadership in Central Office, Institutions, and CBC shall be responsible for
ensuring that this Racial Disparity Policy is fully and consistently
implemented.

B.

Periodic aggregate and individual case reviews shall be made by the
Diversity/Disparity Advisory Board, to ensure that policies are
implemented in a manner that does not result in disparate treatment or
effects based on race, color or national origin. These reviews shall strive
to minimize and discourage that one group of incarcerated
individuals/clients does not bear a disproportionate burden in the areas
outlined in this policy.

C.

Classification
1.

Each incarcerated individual/client under the custody or purview of
the Department shall be classified/assessed to the most appropriate
assignment for security supervision, and re-entry/treatment needs
to promote safety and security and to prepare the individual for
success in the community.

2.

The classification system shall consider objective risk factors
associated with future conduct and management, and thus, help to
identify the types and level of risk likely to be presented by the
incarcerated individual/client.

3.

The classification methods employed should aim to eliminate
disparities based on race, color and national origin. Thus, factors
to be considered and reviewed may include, but are not limited to:
a.

The individual’s current and prior criminal history,

b.

Escape history,

c.

History of disciplinary behavior,

d.

Demonstrated current involvement with a security threat
group,

e.

Current age.

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 4.

D.

When monitoring procedures outlined in this policy identify
disparities in the incarcerated individual/client classification process,
steps shall be taken to mitigate those disparities as much as
possible without negatively impacting safety and security.

Housing Assignments
Assignment of an incarcerated individual/client to an institution or
residential facility, shall be made on the basis of criteria that is validated
and dynamic, and reflects an incarcerated individual’s/client’s security and
custody levels, as well as any special need (e.g., medical, mental health,
physical health, ability, safety, etc.)

E.

F.

Work Assignments
1.

All incarcerated individual/client job assignments shall be made
consistent with the need to promote racial equality.

2.

The process of assigning incarcerated individuals/clients to jobs
shall rely on objective criteria that takes into consideration their
abilities and rehabilitative/re-entry needs as well as any risk to
safety and security.

3.

Consideration shall be given to the skills needed for jobs, including,
but not limited to, academic level, and vocational skills, in addition
to physical and medical requirements.

4.

Job assignments shall include a variety of work that affords
incarcerated individuals/clients an opportunity to earn wages, learn
job skills, develop good work habits, and/or foster positive attitudes
that may be applied after release. These opportunities may
include: community based work opportunities, correctional
industries, institutional maintenance, institutional support, public
works, and work in the community based upon eligibility
requirements.

Program Assignments
1.

All program assignments shall be made in accordance with the
needs of incarcerated individuals/clients, the programs, and the
facility. The assignments shall further be based on reasonable,
objective criteria that reflect incarcerated individual’s/clients
abilities and security/risk levels.

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 G.

H.

2.

Assignments shall be made on identified criteria that are relevant to
the program.

3.

Assignment of an incarcerated individual/client to a specific
program shall be based on a current objective assessment of the
incarcerated individual’s/client’s rehabilitative/re-entry needs, risks,
and the specific goals of the program or service.

4.

While risk to safety and security as well as an incarcerated
individual’s/client’s medical and mental health needs may direct the
structure and/or setting for the program delivery, all program
assignments shall be made in accordance with individual and
program needs, and tailored, to the extent possible, to enable the
participation of a diverse group of incarcerated individuals/clients.

Discipline
1.

The IDOC provides for the orderly conduct of incarcerated
individuals/clients through the Disciplinary processes established in
IDOC Policies IO-RD-01, Overview and Philosophy of Incarcerated
Individual/Client Discipline, IO-RD-02, Informal Corrective Action
and Minor Disciplinary Reports, IO-RD-03, Major Discipline Report
Procedures, and WR/OWI-38 Rule Violations, Disciplinary
Process, Time Loss and Appeals which define acts of misconduct,
the process for adjudicating allegations of misconduct, and the
sanctions for misconduct.

2.

Disciplinary actions are based on credible evidence of misconduct,
and shall be timely, impartial and consistent across all incarcerated
individuals/clients.

3.

Sanctions are proportionate to the severity of the offense and the
incarcerated individual’s/client’s disciplinary record.

4.

Disciplinary actions are intended to change behavior, teach
consequence(s) of the misconduct, enforce staff authority, and
maintain safety, security, and order. Disciplinary rules aim to
generate a climate of respect among both staff and incarcerated
individuals/clients.

Grievances

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 I.

1.

It is the Department’s policy to maintain a written grievance
process that is available to all incarcerated individuals/clients
without regard to their race, color or national origin.

2.

All incarcerated individuals/clients shall have the opportunity to
attempt to resolve issues and/or incidents in an informal setting
prior to utilizing the formal grievance process as well as access to
appeal.

3.

All incarcerated individuals/clients are entitled to invoke this
grievance procedure for a broad range of complaints including, but
not limited to:
a.

Policies and procedures
individual/client;

that

affect

the

incarcerated

b.

Actions by employees, volunteers, contract employees
and/or other incarcerated individuals/clients;

c.

Incidents or conditions occurring within the corrections
system that affect the incarcerated individual/client
personally; and/or

d.

Issues relating to health care and other concerns.

4.

All grievances shall be processed and reviewed according to the
written grievance procedures as outlined in IDOC Policy IO-OR06, Incarcerated Individual/Client Grievance Procedures or local
policy for CBC.

5.

The Diversity/Disparity Committee shall periodically review all
incarcerated individual/client grievances considered to be
discriminatory due to race, color, or national origin to minimize and
address immediately, any known disparate treatment occurring
based on the identity of the incarcerated individual/client.

Monitoring
1.

IDOC will ensure all new employees read and understand the
disparity policy as well as complete annual diversity training as
assigned by institution and CBC guidelines. This includes tracking
and addressing compliance with the components delineated in this
policy regarding the racial categories of: White, African American,
Hispanic, Asian, and Other. Each Warden and District Director will
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AD-GA-23

 yearly compile the following data and provide its contents to the
respective Deputy Directors.
2.

The following data will be compiled each fiscal year on incarcerated
individuals served to review (a thru g provided by
Dashboard/Central
Office
Research
(exception
d:
IPI
Apprenticeship)):
a.

Classification: Distribution of incarcerated individuals/clients
by race for custody classification, administrative segregation
and protective custody status, Iowa Risk Revised levels,
Iowa Risk Revised overrides, Institution admission types (i.e.
probation/parole/work release/special sentence revocations),
Institution releases by closure types (i.e. parole/work release
granted, etc.).

b.

Work Assignments: Distribution of incarcerated individuals
by race and state-wide work assignment categories (ALL)
within the institution/facility.

c.

Intervention
Programs/Intervention
Assignments:
Distribution of incarcerated individuals by race per core
program
interventions
(i.e.
waiting/started/closed
interventions) provided at the institution/facility.

d.

Educational
Services:
Distribution
of
incarcerated
individuals/clients by race per highest education level at the
institution/district. IPI Apprenticeship numbers provided by
IPI.

e.

Discipline: Total number of disciplinary reports (hearing
held and pled guilty) broken out by race and type of
infraction by institution/district.

f.

Grievances: Total number of formal grievances submitted;
and broken out by race and grievance type, i.e., property,
food services, commissary, medical, etc. (provided by ATG)

g.

Violations:
Total number of revocations to prison by
technical violations vs. new arrests by race. Total number on
electronic monitoring by race.

h.

Training and Development: Number of staff, contractors
and volunteers who completed the diversity training prior to
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 independently commencing a job assignment. Number of
employees, contractors, and volunteers who signed off on
the policy during the intake/orientation. Number of staff who
completed the annual diversity training as required.
3.

J.

If the components data suggests racial disparity a review of its
practices shall be done by the Deputy Directors and their respective
Directors/Wardens to assess potential disparities, and if racial
disparity is identified, a compliance report shall include an action
plan to address and eliminate the disparity.

Review
The State-wide Diversity/Disparity Advisory Board shall conduct an annual
department-wide review of compliance with the respective components of
this policy.

Originated: Oct. 2018.
Revised: Oct. 2018, March 2019, April 2019.
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