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					Juvenile Justice Training
      Institute for
   State JJ Specialists

      (300 Slides)
JJDP Act
   When was it passed?
   Why was it passed?
   What does it say?
   What does it say about Compliance Monitoring?
   What are the Core Requirements?
   What do States receive when in compliance with
    the Core Requirements?
                                                     2
Formula Grants Award

   Access to your full Formula Grants allocation is
    contingent on meeting all four Core Requirements
    and maintaining an adequate system for
    Compliance Monitoring.



                                                   3
JJDP Act Core Requirements

   Deinstitutionalization of Status Offenders—1974
   Separation—1974
   Jail Removal—1980
   Disproportionate Minority Confinement—1988


                                                      4
Deinstitutionalization of Status
Offenders (DSO)
Section 223(a)(11)
Juveniles who are charged with or who have
committed offenses that would not be criminal
if committed by an adult… or such non-offenders
as dependent or neglected children shall not be
placed in secure detention or correctional facilities.
                                                         5
Separation
Section 223(a)(12)

Juveniles alleged to be or found to be delinquent
[and status offenders and non-offenders] will not
be detained or confined in any institution in which
they have contact with adult inmates.


                                                      6
Jail Removal
Section 223(a)(13)

No juvenile shall be detained or confined in any jail
or lockup for adults.




                                                        7
Disproportionate Minority
Contact (DMC)
Section 223(a)(22)
States are to ―address juvenile delinquency
prevention efforts and system improvement efforts
designed to reduce, without establishing or requiring
numerical standards or quotas, the disproportionate
number of juvenile members of minority groups, who
come into contact with the juvenile justice system.‖
                                                    8
         Core Requirements
          of the JJDP Act
Deinstitutionalization of Status Offenders
Sight and Sound Separation
Jail Removal
Disproportionate Minority Contact

                                             9
DSO
Sec. 223 (a)(11)
   A status offender is a juvenile offender who has been
    charged with or adjudicated for conduct that would not be
    a crime if committed by an adult.
   A non-offender is a juvenile who is subject to the
    jurisdiction of the juvenile court, usually under abuse,
    dependency, or neglect statutes, for reasons other than
    legally prohibited conduct of the juvenile.
   Status Offenders and non-offenders cannot be placed in
    secure detention or correctional facilities.
                                                               10
DSO—Sec. 223 (a)(11)
Status Offenses/Examples
   Runaway
   Ungovernable/incorrigible
   Curfew violation
   Truancy
   Possession of alcohol as a minor
   Possession of tobacco as a minor
   Traffic violations civil in nature   11
DSO—Section 223(a)(11)
Non-Offenses/Examples

   Child abuse and neglect
   Immigration violations (aliens)
   Danger to self or others (mental health)
   Abandonment


                                               12
DSO—Sec. 223 (a) (11)
Four exceptions for the placement of status
  offenders in secure juvenile facilities:
      I. 24 hours prior to and after initial
      court appearance (exclusive of
      weekends and holidays).

      II. Youth found to have violated a
      Valid Court Order (VCO).

                                               13
DSO—Sec. 223 (a) (11)
Four exceptions for the placement of status
  offenders in secure juvenile facilities (cont’d):
      III. Out-of-State runaways (when
      Interstate Compact is used).

      IV. Handgun exception.




                                                      14
DSO—Sec. 223 (a)(11)
I. The 24-hour exception may be used for
   limited purposes:
     For the purposes of identification,
      investigation, release to parents, or transfer to
      a nonsecure program.
     Applies only to accused status offenders, not
      adjudicated status offenders and not non-
      offenders.
                                                          15
    DSO— 223(a)(11)
    II. VCO Exception
    What States Must Do to Use the VCO
    Exception:
     State must have State Law allowing secure detention of kids
      who violate VCOs.
     The State must train court and facility staff to ensure that all
      VCO standards are met (i.e. due process is afforded, interviews
      occur within 24 hours, hearing within 48 hours).
     State must annually review a minimum of 10 percent of all VCO
      cases to ensure they meet VCO standards.
     State must project and report as DSO violations those cases
      that do not meet VCO standards.
                                                                         16
    DSO—223(a)(11)
    III. Out-of-State Runaways

     Interstate Compact—State must be a member.
     Out-of-State runaway may be securely detained in a juvenile
      facility indefinitely.




                                                                    17
    DSO—223(a)(11)
    IV. Youth Handgun Safety Act

     Prohibits possession of a handgun by a minor under age18.
     Youth who violate the Youth Handgun Safety Act or a similar law
      are considered delinquent offenders.
     Such youth can be placed in secure detention or correctional
      facilities.




                                                                        18
De Minimis Standards

How many violations can a State have
and still remain compliant with DSO?
Please see 1981 Federal Register for further details.



                                                        19
De Minimis Standards—DSO

   0 Violations/100,000 juveniles—the State has
    demonstrated full compliance,

   0.1 to 5.7 Violations/100,000 juveniles—the State
    has demonstrated full compliance with de minimis
    exceptions.
                                                        20
De Minimis Standards—DSO (cont’d)

   5.8–17.6 Violations/100,000 juveniles—the State
    is eligible for a finding of compliance with de
    minimis exceptions if it adequately meets the
    following criteria:


                                                      21
        De Minimis Standards
           Criteria—DSO
   Criterion B—instances of noncompliance were in
    apparent violation of State law or established
    executive or judicial policy.
   Criterion C—an acceptable plan has been
    developed to eliminate the noncompliant
    incidents.
                                                     22
De Minimis Standards—DSO (cont’d)

   17.7 to 29.4 violations/100,000 juveniles—the
    State is eligible for a finding of compliance with de
    minimis exceptions if it fully satisfies the following
    criteria:



                                                         23
         De Minimis Standards
         Criteria—DSO (cont’d)
   Criterion B—instances of noncompliance were in
    apparent violation of State law or established
    executive or judicial policy.
   Criterion C—an acceptable plan has been
    developed to eliminate the noncompliant
    incidents.
                                                     24
De Minimis Standards—DSO (cont’d)

   29.5 Violations and Above/100,000 juveniles—the
    State is presumptively ineligible for a finding of full
    compliance with de minimis exceptions unless…
         Out-of-State runaways
         Federal wards
         New State law

                                                          25
De Minimis Standards—DSO (cont’d)


Any rate above 29.4 violations is considered
to be an excessive and significant level of
status offenders and non-offenders held in
juvenile detention or correctional facilities.



                                                 26
                   Note!
   States found out of compliance with the DSO
    Core Requirement lose 20 percent of their
    Formula Grants allocation.
   The remaining 50 percent of the Formula Grants
    allocation must be spent to bring the State back
    into compliance with DSO.


                                                       27
De Minimis Standards—DSO (cont’d)

How many DSO violations is California
 allowed?
   Juvenile Population in 2005 = 9,452,391
   94.5 X 5.7 = up to 539 DSO violations
   94.5 X 17.6 = up to 1,663 DSO violations
   94.5 X 29.4 = up to 2,778 DSO violations
                                               28
         Core Requirements
          of the JJDP Act

Deinstitutionalization of Status Offenders
Sight and Sound Separation
Jail Removal
Disproportionate Minority Contact

                                             29
 SEPARATION
 Section 223(a)(12)


Juveniles alleged to be or found
to be delinquent [and status
offenders and non-offenders] will
not be detained or confined in
any institution in which they have
contact with adult inmates.
                                     30
SEPARATION
Sec. 223 (a)(12) [cont’d]

Contact is defined to include any physical or
sustained sight and/or sound contact between
juvenile offenders in secure custody status
and incarcerated adults, including inmate
trustees.



                                                31
SEPARATION
Sec. 223 (a)(12) [cont’d]
Inadvertent or Accidental Contact:
   Instances need not be reported if they occur in secure
    areas of a facility that are not dedicated to use by
    juvenile offenders and which are nonresidential.
   Any contact in a dedicated juvenile area, including
    residential area of a secure facility, would be a violation.


                                                                   32
Transferred, Certified, Waived,
and Direct File Youth
A juvenile who has been transferred to the jurisdiction of a
criminal court, may be detained or confined in a juvenile
facility with other juveniles who are under the jurisdiction of
the juvenile court. This is not a violation of separation since
the youth is not a juvenile ―alleged to be or found to be
delinquent‖ and the youth is not an ―adult inmate.‖ Once the
youth reaches the State’s age of majority, he/she must be
separated from the juvenile population within six months.
                                                                  34
Scared Straight, Shock
Incarceration, Jail Tours…
 No juvenile shall enter under public
 authority, for any amount of time, into a
 secure setting or section of an adult jail,
 lockup, or correctional facility as a
 disposition of an offense or as a
 means of modifying his or her behavior.

                                               35
De Minimis Standards—Separation
   0 Violations/100,000 Juveniles—the State has
    demonstrated full compliance.
   1 and Greater Violations/100,000 Juveniles—the
    State is eligible for a finding of compliance if the
    instances of noncompliance do not indicate a
    pattern or practice but rather constitute isolated
    incidences and one of the following criteria is
    satisfied:
                                                           36
           De Minimis Standards
           Criteria—Separation
   Violation of State law.
   Did incidents of noncompliance indicate a pattern
    or practice?
   Are there existing mechanisms for enforcement?
   Describe the State’s plan to eliminate the
    noncompliant incidents.
                                                    37
        De Minimis Standards—
          Separation (cont’d)

How many Separation Violations is California
 allowed?
        0

                                               38
CORE REQUIREMENTS OF THE JJDP ACT


 Deinstitutionalization of Status Offenders
 Sight and Sound Separation
 Jail Removal
 Disproportionate Minority Contact


                                              39
Jail Removal
Section 223(a)(13)

No juvenile shall be detained or confined in any jail
or lockup for adults.



                                                        40
JAIL REMOVAL
Section 223(a)(13)

Does not apply to juvenile facilities or adult prisons.




                                                          41
JAIL REMOVAL
Section 223(a)(13)
               Adult Jail:

               A locked facility, the purpose of which
               is to detain adults charged with
               violating criminal law, pending trial.

               Also those facilities used to hold
               convicted adult criminal offenders
               sentenced for less than one year.    42
JAIL REMOVAL
Section 223(a)(13)

Adult Lockup:
Similar to an adult jail,
except that an adult
lockup is generally a
municipal or police facility
of a temporary nature
which does not hold
persons after they have
been formally charged.         43
 JAIL REMOVAL
 Section 223(a)(13)

 Jail Removal Exceptions:
I.    Six-Hour Rule
II.   Court Appearance Hold
III. Rural Exception
IV. Transferred, Certified, Waived, or Direct File Youth

                                                      44
  JAIL REMOVAL
  Section 223(a)(13)

I. Six-Hour Rule of Reason
 An alleged delinquent may be detained for up to six
 hours, while separate from adults, for the purposes
 of identification, processing, and arranging for
 release to parents or transfer to juvenile court
 officials or juvenile shelter or detention facilities.

                                                          45
 JAIL REMOVAL
 Section 223(a)(13)

II. Six-Hour Court Appearance Hold

  An alleged or adjudicated delinquent may be
  detained, while separate from adults, for up to six
  hours before and after a court appearance.

  This hold must be related to a court appearance.

                                                        46
JAIL REMOVAL
Section 223(a)(13)

III. Rural Exception

   An accused juvenile criminal-type offender may
    be detained up to 48 hours (excluding weekends
    and holidays) in an adult jail or lockup, if certain
    conditions are met.
   This hold must be related to a court appearance.
                                                           47
JAIL REMOVAL Section 223(a)(13)
IV. Transferred, Waived,
Certified and Direct File Youth
   Juveniles who have been transferred to adult
    court and against whom criminal felony charges
    have been filed do not fall under the auspices
    of the JJDP Act for jail removal and separation
    requirements within jails and lockups.
   These juveniles are subject to State law.
                                                      48
De Minimis Standards—
Jail Removal
   0 Violations/100,000 juveniles—the State has demonstrated
    full compliance.


   0.1 to 9.0 Violations/100,000 juveniles—the State is eligible for
    the numerical de minimis exception if it has developed an
    acceptable plan to eliminate the noncompliant incidents
    through the enactment or enforcement of State law, rule or
    statewide executive or judicial policy, education, the provision
    of alternatives or other effective means.
                                                                        49
De Minimis Standards—
Jail Removal (cont’d)
   9.1 and greater Violations/100,000 juveniles—the State is
    eligible for the substantive de minimis exception if it meets five
    criteria:
             – Recently enacted changes in State law that are
               expected to have significant impact on the State’s
               achieving full compliance
             – All instances of noncompliance were in violation of
               State law

                                                                         50
De Minimis Standards—
Jail Removal (cont’d)
   9.1 and greater Violations/100,000 juveniles—the State is
    eligible for the substantive de minimis exception if it meets five
    criteria:
             – Instances of noncompliance do not indicate pattern
               or practice but rather constitute isolated instances.
             – Existing mechanisms to enforce State law.
             – Acceptable plan has been developed to eliminate
               noncompliant incidents.
                                                                         51
De Minimis Standards—
Jail Removal (cont’d)

   How Many Jail Removal Violations Is California
    Allowed?

   Up to 9 = 850 Jail Removal Violations
              (94.5 x 9 = 850)

                                                     52
 Adequate System of
Compliance Monitoring
              Presented by

            Elissa Rumsey,
Compliance Monitoring Coordinator, OJJDP

             Susan Davis,
      Compliance Monitor, Colorado

                                           53
Adequate System
of Compliance Monitoring (cont’d)

Section 223(a)(14) of the JJDP Act:
         ―Participating States must provide for an adequate
system of monitoring jails, detention facilities, correctional
facilities, and nonsecure facilities to ensure that the
requirements of paragraph (11), paragraph (12), and
paragraph (13) are met, and for the annual reporting of the
results of such monitoring to the [OJJDP] Administrator.‖

                                                                 54
     The 10 Compliance
     Monitoring Elements
1. Policies and Procedures
2. Monitoring Authority
3. Monitoring Timetable
4. Violation Procedures
5. Barriers and Strategies
                             55
    The 10 Compliance
Monitoring Elements (cont’d)
 6. Definitions
 7. Identification of the Universe
 8. Classification of the Universe
 9. Inspection of Facilities
 10. Data Collection and Data Verification

                                             56
The Elements

   In the OJJDP Guidance Manual, Audit Guideline
    Manual, and Formula Grants Regulations.
   On the OJJDP Web site under Compliance
    Monitoring.
   Disc provided contains all documents.


                                                    57
Policies and Procedures

   Critical!
   Policies and procedures serve multiple purposes:
       Desk manual.
       Document your Compliance Monitoring system in
        detail.
       Basis for your OJJDP audit.

                                                        58
Monitoring Authority

   Each State should have authority to inspect
    facilities and collect data.
   Your authority should be documented in your
    training materials and available to facilities.
   Optimal authority is legislation.
   Minimum authority is an Executive Order.
                                                      59
Monitoring Timetable
   Each State should
       Have a written timetable detailing how you will
        accomplish the Four Compliance Monitoring Tasks.
   This Monitoring Timetable should
       Detail who will do what, when, for what period of time,
        what the product will be.
       Can be in chart or written format.
                                                                  60
Violation Procedures
   Each State must have a procedure to handle violations.
   Authority to deal with violations is essential.
   Written policies should be available to all concerned
    parties.
   At a minimum, States should be able to cite a facility and
    request that the facility correct the noncompliant
    situation.

                                                             61
Barriers and Strategies
   Barriers = obstacles to either your monitoring
    efforts or compliance with the Core Requirements.
   All States have barriers.
   Strategies = what the Designated State Agency
    (DSA) and the State Advisory Group (SAG) are
    doing to overcome the barriers.
   Examples.
                                                   62
Definitions of Terms
   States MUST use OJJDP definitions when
    monitoring.
   These definitions should be in all your materials:
    policies, manuals, training materials.
   Preferably, the OJJDP definitions should be in
    State statutes; if not, make sure all facilities know
    what the federal definitions are.
                                                            63
Important Definitions:

   Secure
   Lockup
   Status Offender/MIP
   Separation



                          64
The Four Compliance
Monitoring Tasks
   These tasks are annual.
   The annual completion of these tasks should be in
    your timetable.
   The tasks are
       Identification of the Universe.
       Classification of the Universe.
       Inspection of Facilities.
       Data Collection and Data Verification.
                                                    65
Identification of the
Monitoring Universe

   The State must identify all facilities which might hold
    juveniles pursuant to public authority.

   Facilities must be classified to determine if each should
    be included in the monitoring effort.


                                                                66
Identification (cont’d)

   The list should include all jails, lockups, detention
    centers, juvenile correctional facilities, halfway
    houses, group homes, prisons and any other
    secure or nonsecure public or private facilities in
    which juvenile might be detained or placed.


                                                        67
Identification (cont’d)
   Key phrases: ―might hold,‖ ―public authority,‖ ―public and
    private,‖ ―full list.‖
   Necessary first step.
   Every facility that has the ―potential‖ to house juveniles,
    regardless of the purpose, comes under the purview of
    the monitoring requirements and must therefore be
    included in identification.

                                                                  68
Identification (cont’d)
   Statutes which prohibit placement of juveniles in specific
    facilities do not exempt them from the universe.
   Not all facilities that are identified in this step will be
    transferred to the inspection list! Do not get
    overwhelmed!
   All of the facilities identified must also be classified.
   However, not all will need an inspection or be subject to
    data collection/verification.

                                                                  69
Identification (cont’d)
   Sources for identifying your universe include
       State oversight/regulatory agencies
           Social Services
           Mental Health
           Public Health
           Associations
           Department of Corrections
           Others?
                                                    70
Classification of the
Monitoring Universe
   Each facility identified needs to also be classified.
   Classification will assist you in determining which
    facilities will need to be inspected.
   Classification has four elements:
       Secure or nonsecure
       Public or private
       Residential or nonresidential
       For juveniles only, for adults only, or for both juveniles and
        adults
                                                                         71
Classification (cont’d)
   Classification may be completed in conjunction with
    identification.
   States must confirm initial classification while onsite.
   Remember to use federal definitions.
   Query the State Oversight and/or Regulatory Agencies
    on statutes, regulations, standards, policies, violation
    procedures.

                                                               72
Organizing Your Monitoring
Universe Information
   Organize once, update annually.
   Organize as it makes sense to you.
   One example:
       By facility type (jails)
           ID and Classification List which shows the jails in State by address,
            contact name, phone, classification, and date of last inspection
           Rules, statutes, regulations as they pertain to this type of facility
           Violation procedures for this type of facility
           Very helpful during OJJDP audits
                                                                                    73
Inspection of Facilities
   Three reasons to inspect facilities:
       To confirm your classification (secure or nonsecure and who is
        being held there)
       To assess the separation levels at all points in the facility
       To determine if their record keeping system is adequate for you
        to collect the necessary data to determine compliance with the
        Core Requirements


                                                                         74
Inspection of Facilities
(cont’d)
   Confirm your classification:
       Is this facility secure or nonsecure? Is it for juveniles
        only, adults only, or juveniles and adults? Is it
        residential or nonresidential? Public or private?
       Once you answer these, and perhaps more, questions
        you will know how to classify it pursuant to federal
        definitions of terms.
                                                                75
Inspection of Facilities
(cont’d)
   Assess separation levels.
       Walk through the facility as if you were a juvenile.
       Ask lots of questions:
           When are adults in this area?
           When are trustees used?
           May I have a copy of your policies on separation?
           Enter a cell and ask the Deputy to walk into an adjoining cell to test sound
            separation (where juveniles are held securely in the vicinity of adults).

                                                                                      76
Inspection of Facilities
(cont’d)
   More questions:
       How are juveniles processed?
       Where do they enter facility?
       Who escorts them?
       Is time-phasing used?
       Where are nonsecure areas?
       Is there a nonsecure booking area?
                                             77
Inspection of Facilities
(cont’d)
   Record keeping system required to collect the following information on all
    juveniles held securely
       Name or ID
       Date of birth
       Race, sex, ethnicity
       Offense (most serious)
       Date and time IN secure setting
       Date and time OUT of secure setting
       Time out for court appearance (if applicable)
       Time back in for court appearance (if applicable)
       Person released                                                      78
Organizing Facility Information

   Create ―Facility Files‖
   All information on this facility is contained in one
    file
       Taken onsite and updated.
       Example.
   Very helpful to the next person who takes your job!

                                                           79
Inspection of Facilities
(cont’d)
   Many other reasons to inspect!
   Building relationships with your contact people.
   Sharing information about your agency.
   Problem solving solutions to juvenile justice issues.
   Serving as the eyes and ears for your SAG.
   Others?
                                                            80
Inspection of Facilities:
Pre-Visit Activities
    Schedule an appointment with Administrator so there
     is buy-in.
    Explain what you will be doing there and how long it
     will take
        Sight and sound.
        Classification.
        Record keeping.
                                                            81
Inspection of Facilities:
Onsite
    Walk through the facility as if you were a juvenile.
    Review sight and sound separation, records, security
     levels.
    Obtain a layout and sample of log.
    Obtain copies of any policies.


                                                            82
Inspection of Facilities:
Exit Interview
    Provide training materials.
    Explain how you have classified them and their separation
     levels.
    Fully explain the Core Requirements as they relate to their
     facility.
    Recommend changes if needed.
    Explain your violation policy.
    Ask what their needs are.
    Make sure you have all the information you need for your facility
     file.                                                           83
Inspection of Facilities:
Exit Interview (cont’d)

   If you don’t know the answer, research it and get back.
   Provide information on programs that might be
    relevant—you may be the only eyes and ears for your
    agency.
   Always thank people for their time and efforts.


                                                              84
Data Collection and
Data Verification
   Two parts: collect and verify.
   Collect data on all juveniles held securely in the State for
    the year.
   Must use OJJDP definitions of terms not only for offenses
    but for facilities:
       Jail, lockup, court holding, JDC, JCF, collocated.
       For example, if a facility isn’t ―behaving‖ like a court holding
        facility then it is a lockup.
                                                                           85
Data Collection and Data
Verification (cont’d)
   Twelve months of data is necessary.
   All facilities that hold juveniles securely must report.
   If data isn’t complete, the OJJDP/Excel Spreadsheet will
    project it for you.
   Please include a chart or table showing the facilities that
    held and the number of violations for each facility.

                                                                  86
Data Collection/Verification
(cont’d)
   Facilities Self-Report Admissions Data.
   Data collected by an agency other than the DSA needs to
    be verified onsite by the DSA.
   Verification process should be in your policies and
    procedures.
   Verification is an annual process at all facilities that hold
    juveniles securely.

                                                                87
Data Collection/Verification
(cont’d)
   At minimum, 10 percent of all VCOs must be
    verified; however, if you find violations in that 10
    percent sample you must project those numbers
    for the remaining 90 percent.
   Please verify 100 percent of VCO cases if the
    number is under 50 per facility.
                                                           88
Data Collection/Verification
(cont’d)
   Look over the OJJDP Excel Spreadsheet to see
    what data you will need at the end of the year so
    you are collecting them all year.
   Youth in possession of a handgun is not a
    violation of DSO.
   Title V funds linked to compliance.
                                                        89
    Data Collection/Verification:
    Title V
   Title V is the Community Prevention Grant Program.
   Title V money must be passed through to units of
    local governments.
   Compliance Monitors must demonstrate and SAGs
    must certify that units of local government are in
    compliance with the Core Requirements to receive
    Title V funding.
                                                    90
Data Collection/Verification
(cont’d)
   Once data are collected and verified, summarize
    for the OJJDP Compliance Monitoring Report.
   Data will need to be described in the narrative
    section of this report.
   The OJJDP Compliance Monitoring Report will be
    covered in more detail at a later time during this
    training.
                                                     91
 Adequate System of
Compliance Monitoring


    QUESTIONS?



                        92
Adequate System of
Compliance Monitoring:
Part 2
Compliance Monitoring Written
Products/Reporting Responsibilities
     —Mark Ferrante, Juvenile Justice Specialist, New Jersey
     —Wandra Simmons, TCAP Coordinator, OJJDP
     —Susan Davis, Compliance Monitor, Colorado
     —Julie Herr, State Representative, OJJDP
                                                           93
Formula Grants
Plan/Performance Measures
Presented by

Mark Ferrante,
Juvenile Justice Specialist, New Jersey

Wandra Simmons,
TCAP Coordinator, OJJDP


                                          94
Formula Grants (FG):
Three-Year Plan and Application

   FG Application must include plan for
    Compliance With the First Three Core
    Requirements of the JJDP Act and the State’s
    Plan for Compliance Monitoring.


                                               95
FG Three-Year Plan

   The plan must be data-based and program
    specific, including the necessary ―who, what,
    where, how, and when‖ to provide clear plan of
    action.


                                                     96
FG Three-Year Plan (cont’d)

   The Compliance Monitoring plan should include a
    detailed description of monitoring tasks and
    identify the specific agency or agencies
    responsible for each task.



                                                  97
FG Three-Year Plan (cont’d)
   This section should describe the legislative and
    administrative procedures and sanctions that the
    State has established to receive, investigate, and
    report compliance violations. If an agency other
    than the designated State agency is responsible
    for monitoring, describe how that agency
    maintains accountability for compliance with this
    requirement.
                                                         98
FG Three-Year Plan (cont’d)

   For each of the requirements, the State should
    describe:

    a. Strategy, specific activities, timetable covering the
       three-year planning cycle, and resources to support
       the implementation of the plans.


                                                               99
FG Three-Year Plan (cont’d)
 b. Barriers the State faces in achieving full compliance,
    and how it will overcome them.
 c. Role of the SAG in monitoring for compliance with the
    DSO, separation, and removal requirements.
 d. If the State has been found to be in full compliance
    with these requirements, provide an assurance that
    indicates:

                                                             100
FG Three-Year Plan (cont’d)
(1) Adequate plans are on file and available for
  review.
(2) Resources to maintain compliance are identified,
  on file, and available to review.
(3) The State will notify OJJDP if circumstances
  arise or if resources are lost that would jeopardize
  the State’s capability of maintaining compliance
  with the requirements.                             101
         FG Three-Year Plan:
        Performance Measures

   What are performance measures?
   Why do we need them?
   How do we implement them?
   How do we report on them?


                                     102
FG Three-Year Plan:
Performance Measures (cont’d)
 Three-Year Plan must include performance
  measures.
 Compliance monitoring program areas include
        – Compliance monitoring (Program Area 6 ).
        – DSO (Program Area 8).
        – Jail removal (Program Area 17).
        – Separation (Program Area 28 ).
                                                     103
FG Three-Year Plan: Performance
Measures (cont’d)
   Compliance Monitoring (Program Area 6)
    performance measures include:
     — Funds allocated (output).
     — Submission of annual CM Report (outcome).



                                                   104
         FG Three-Year Plan:
    Performance Measures (cont’d)
   DSO (Program Area 8) performance measures
    include:
     — Funds awarded for DSO (output).
     — # Site visits Conducted (output).
     — # of programs implemented (output).
     — # program youth served (output).
     — Changes in the # of violations of DSO requirement
       (outcome).                                          105
         FG Three-Year Plan:
    Performance Measures (cont’d)

   Jail Removal (Program Area 17) performance
    measures include:
     — Funds Awarded for Jail Removal (output).
     — # of programs implemented.
     — # program youth served.
     — Changes in the # of violations per Jail Removal Core
       Requirement (outcome).
                                                              106
         FG Three-Year Plan:
    Performance Measures (cont’d)
   Separation (Program Area 28) performance
    measures include:
     — Funds for Separation (output).
     — # of programs implemented (output).
     — Changes in the # of violations per Separation Core
       Requirements (outcome).


                                                            107
FG Three-Year Plan

   Questions?
   Thank you!




                     108
Policies and Procedures
Presented by

Susan Davis,
Compliance Monitor, Colorado

Julie Herr,
State Representative, OJJDP



                               10
                               9
Why a Policies and Procedures Manual?

   Required element of ―Adequate‖ Compliance
    Monitoring System
   OJJDP audits
   Desk manual for your position
       When you get promoted, provides guidance to your
        replacement.

                                                           110
Content
   Compliance Monitoring Plan/
    Policies and Procedures
       Monitoring authority
       Monitoring timetable
       Violation procedures
       Barriers/strategies
       Definition of terms
                                  111
Content (cont’d)

   The Four Monitoring Tasks

       Identification of the monitoring universe
       Classification of the monitoring universe
       Inspection of facilities
       Data collection/data verification


                                                    112
Content (cont’d)
   Should Also Include
       Core Requirements by facility type with a
        discussion/comparison of your State law
       Secure and nonsecure custody
       Policies on collocated facilities
       Exceptions that your State uses
       Title V certification
       Process for facilities to request an OJJDP opinion
       Frequently asked questions                           113
Content (cont’d)
   You want your policies to contain information on
       Who, what, where, when, why.

   If someone were to pick up and read your policies,
    they would understand your job.

   The more information you have, the fewer
    questions auditors will have.
                                                       114
Recommendations
   Set aside a good amount of undistracted time to write
    your policies.
   Before you start writing, really think about
       How you do your job.
       What steps you take.
       How you document your work.
   Surround yourself with all the OJJDP materials and
    regulations you have and read them before you start, so
    you understand their intent.
                                                              115
OJJDP Materials

   OJJDP Guidance Manual.
   OJJDP Audit Guideline Manual.
   Federal Regulations
   Formula Grants Manual, Volume 1.
       Provides a great deal of background information on
        why we do what we do.

                                                             116
State Materials
   Your State’s children’s code and penal code
   Web sites and relevant information for Department of
    Health and Human Services, Department of Corrections,
    PH, Mental Health, and other State agencies
   Your agency’s policies
   Forms you use in monitoring
   Agreements you have with other agencies for monitoring
   Monitoring authority documents (your Juvenile Justice
    Specialist should have these)
                                                         117
After It Is Written
   Have your Juvenile Justice Specialist look over
    the first draft.
   Once it is finalized, provide copies to all persons
    involved in monitoring.
   Update it once a year.


                                                          118
Discussion
   Questions?
   Comments?
   Experiences?
       Barriers
       Strategies



                     119
   Monitoring for the Core
Requirements of the JJDP Act by
        Facility Type
Sharon Harrigfeld,
Juvenile Justice Specialist, Idaho

Rich Case,
Compliance Monitor, New Jersey

Elissa Rumsey,
Compliance Monitoring
Coordinator, OJJDP                   12
                                     0
Why Monitor Facilities?

Section 223(a)(14) of the JJDP Act:
   Participating States must provide for an adequate
   system of monitoring jails, detention facilities,
   correctional facilities, and nonsecure facilities to insure
   that the requirements of paragraph (11), paragraph
   (12), and paragraph (13) are met, and for the annual
   reporting of the results of such monitoring to the
   [OJJDP] Administrator…


                                                                 121
             Note!

Section 223(a)(14) requires that States
     monitor NONSECURE facilities.




                                          122
How Is Adequate Defined?

1. See OJJDP’s Newly Revised Compliance
   Monitoring Guidance Manual.

2. Refer back to slides from earlier today.



                                              123
How Frequently Must Facilities
   Be Monitored Onsite?
 1. 100 percent of secure facilities in your universe must be
    inspected onsite at least one time every three years. A
    minimum of 10 percent per year must be inspected.
        Exception: Lockups (even those believed to be
        nonsecure) must be subject to inspection
        one time every three years.
 2. This is a minimum standard.
 3. Best practice dictates that States monitor 100 percent
    of secure facilities annually.
                                                                124
Why Is 100 Percent a Best Practice?

 1. A State is 100 percent certain of its
    compliance data.
 2. Ability to train new facility staff in a timely
    fashion.
 3. Facilities enjoy the benefit of the State
    presence.
 4. You are it.
                                                      125
Monitoring Juvenile
    Facilities
        Sharon Harrigfeld,
 Juvenile Justice Specialist, Idaho




                                      12
                                      6
       What Juvenile Facilities
        Need Monitoring?

1.   Juvenile Detention Center
2.   Juvenile Training School
3.   Group Home
4.   Youth Mental Health Facilities



                                      127
                 Note!

1. Juvenile Detention Centers and Juvenile
   Training Schools are the primary youth
   facilities needing monitoring.
2. This is where the majority of juveniles are
   detained and thus where the majority of
   the data will be.

                                                 128
Federal Definition of Juvenile
 Detention Center/Juvenile
      Training School

     A secure juvenile detention or
correctional facility is any secure public
  or private facility used for the lawful
   custody of accused or adjudicated
           juvenile offenders.
                                             129
                 Note!

1. Know federal de minimis allowances in
   advance.
2. Know approximately how many
   Deinstitutionalization of Status Offenders
   (DSO) violations are allowed in your State.


                                                 130
 Which Core Requirements Apply to
 Juvenile Detention Centers/Training
              Schools?
Deinstitutionalization of Status Offenders
Jail Removal
Sight & Sound Separation
Disproportionate Minority Contact

                                             131
           DSO Refresher
               Sec. 223 (a)(11)

                                Exceptions for Juvenile
                                Detention
                                Centers/Training Schools
                                only:
                                24 hours prior to and after
                                 initial court appearance
Status offenders and non-        (exclusive of weekends and
offenders cannot be              holidays)
placed in secure                If youth is found in contempt
                                 of a valid court order (where
detention or correctional        State law allows)
facilities.                                                  132
How to Monitor for DSO in Juvenile
Detention Centers/Training Schools

  1. Facilities self-report Admissions Logs.
  2. Compliance monitor verifies potential
     violations over the phone.
  3. Compliance monitor conducts onsite
     inspection to verify violations and visually
     confirm sight and sound separation.
  4. Violations are factored into the annual
     Compliance Monitoring Report to OJJDP.
                                                    133
           Sight and Sound
         Separation Refresher

Juveniles shall not have sight and/or sound
contact with adult inmates while in a secure
custody setting.




                                               134
How to Monitor for Separation in
  Juvenile Detention Centers/
       Training Schools
1. Determine whether adult inmates (including adult
   inmate trustees) are on site.
2. If adult inmate trustees are on the premises, they
   must be sight and sound separated from juveniles
   at all times.
3. Best practice dictates that adult inmates not be
   present at juvenile facilities, period.

                                                        135
  How to Monitor for Separation in
    Juvenile Detention Centers/
     Training Schools (cont’d)

4. Where Transferred, Certified, Waived or Direct-File youth
   are present, they also must be sight and sound separated
   from juvenile delinquents six months after reaching the
   State’s age of majority.
5. Violations must be factored into the annual Compliance
   Monitoring Report to OJJDP.


                                                               136
    How Frequently Must Juvenile
     Detention and Correctional
      Facilities be Monitored?

   100 % of secure facilities must be inspected every
    three years.
   A minimum of 10% of secure facilities must be
    visited per year.

                                                     137
Monitoring Adult Facilities
             Rich Case,
    Compliance Monitor, New Jersey




                                     13
                                     8
What Adult Facilities Need
      Monitoring?

1. Adult jails
2. Adult lockups—police departments,
   substations, sheriff’s departments
3. Court holding facilities
4. Adult prisons

                                        139
              Note!

1. Adult lockups are the primary adult
   facilities needing monitoring.

2. An adult lockup is often the first stop for
   youth upon arrest and thus where the
   majority of the data will be.

                                                 140
Federal Definition of Adult Jail

   An adult jail is a locked facility, the purpose of
    which is to detain adults charged with violating
    criminal law, who are pending trial.
   Also considered are those facilities used to hold
    convicted adult criminal offenders sentenced for
    less than one year.

                                                         141
Federal Definition of Adult
Lockup
 Similar to an adult jail, except that an adult lockup
  is a temporary-hold facility which does not hold
  persons after they have been formally charged.

 Law enforcement facilities without cells but
  containing cuffing rails or cuffing benches.
                                                      142
                 Note!

1. Know federal de minimis allowances in
   advance.
2. Know approximately how many DSO and
   Jail Removal violations are allowed in
   your State.



                                            143
Which Core Requirements Apply to
    Adult Jails and Lockups?
Deinstitutionalization of Status Offenders
Jail Removal
Sight & Sound Separation
Disproportionate Minority Contact


                                             144
Deinstitutionalization of Status
 Offenders (DSO) Refresher
                Status offenders and non-
                offenders may not be
                securely detained in an
                adult jail or lockup for any
                length of time.


                                           145
      Jail Removal Refresher

1. No juvenile shall be detained or confined in any
   jail or lockup for adults.
2. Status offenders and non-offenders securely
   detained for any length of time in jails/lockups
   equal two violations: DSO and Jail Removal.


                                                      146
Jail Removal Refresher (cont’d)

Jail Removal Exceptions
  • Six-Hour Rule
  • Court Appearance Hold
  • Rural Exception
  • Transferred, Waived, Certified, or Direct File Youth

                                                           147
         Sight and Sound
       Separation Refresher
Juveniles shall not have sight and/or
sound contact with adult inmates while
in a secure custody setting.




                                         148
How to Monitor Adult Jails and Lockups
 for DSO, Jail Removal, and Separation
1. Facilities self-report admissions logs.
2. Compliance monitor verifies potential violations over
   the phone.
3. Compliance monitor conducts onsite inspection to
   verify violations and visually confirm sight and sound
   separation.
4. Compliance monitor knows de minimis allowances.
                                                            149
                    Note!

No juvenile shall enter under public authority, for any
amount of time, into a secure setting or section of an
adult jail, lockup, or correctional facility as a
disposition of an offense or as a means of modifying
his or her behavior—this means no Scared Straight
Programs.


                                                      150
                    Note!

   Juveniles who have been transferred to adult
    court and against whom criminal felony charges
    have been filed do not fall under the auspices
    of the JJDP Act for jail removal and separation
    requirements within jails and lockups.
   These juveniles are subject to State law.

                                                      151
Questions?

Thank you!



             152
How Frequently Must Adult Jails
  and Lockups be Monitored?

   100 % of secure facilities must be inspected every
    three years.
   A minimum of 10% of secure facilities must be
    visited per year.

                                                     153
Monitoring ‘Other’ Facilities

            Elissa Rumsey,
Compliance Monitoring Coordinator, OJJDP




                                           15
                                           4
     What Is an ‘Other’ Facility?
   A ―nontraditional‖ facility not historically known
    to hold juveniles securely; or
   One that holds an extremely low number of
    juveniles or that almost certainly does not hold
    juveniles at all; or
   A facility that is unique in structure and physical
    grounds.
                                                          155
Monitoring Other Facilities

   Collocated Facilities
   Court Holding Facilities
   Adult Prisons
   Group Homes
   Mental Health Facilities


                               156
          Collocated Facility
   A juvenile facility located in the same building as an
    adult jail or lockup, or is part of a related complex of
    buildings located on the same grounds as an adult
    jail or lockup.
   Juvenile facilities collocated with adult facilities are
    considered adult jails or lockups absent compliance
    with certain criteria.

                                                               157
    Collocated Facility (cont’d)

Collocated Facility Criteria
   Juveniles and adults must be sight and sound separated.
   There must be separate juvenile and adult residential
    areas (time phasing is allowed for program areas).
   State must approve facility to operate as a collocated
    facility and must monitor annually.


                                                             158
    Staffing of Collocated Facilities
   Section 223(a)(12) allows for use of the same staff for
    adults and juveniles, given a State policy that
    requires staff training and certification to work with
    juveniles.
   At a minimum, training must include youth
    development, adolescent physical and mental health,
    and nonviolent crisis intervention.

                                                         159
Which Core Requirements Apply
    to Collocated Facilities?
   Juvenile Side:
       Deinstitutionalization of Status Offenders (DSO)
       Separation
   Adult Side:
       Deinstitutionalization of Status Offenders (DSO)
       Separation
       Jail Removal
                                                           160
How Frequently Must Collocated
   Facilities Be Monitored?

   Annually. One hundred percent of all collocated
    facilities in your State must be monitored every
    year.


                                                       161
    Monitoring Other Facilities

   Collocated Facilities
   Court Holding Facilities
   Adult Prisons
   Group Homes
   Mental Health Facilities


                                  162
      Court Holding Facilities
A court holding facility is a
secure facility, other than
an adult jail or lockup, that
is used to temporarily
detain persons
immediately before or
after detention hearings or
other court proceedings.




                                 163
Court Holding Facilities (cont’d)
   Court holding facilities must
        Meet the definition of a court holding facility.
        Not detain individuals overnight (i.e., nonresidential).
        Not be used for punitive purposes or other purposes
         not related to a court appearance.
        Provide for sight and sound separation in all secure
         areas.
   If the facility does not meet this criteria, it must be
    monitored as an adult jail or lockup.
                                                                    164
Court Holding Facilities (cont’d)
   A status offender may be held in a court holding
    facility if the facility meets the requirements of a
    court holding facility.
   A delinquent offender may be held in a court
    holding facility if the facility meets the
    requirements of a court holding facility.
   Sight and sound separation must be provided at
    all times.
                                                           165
Which Core Requirements Apply
 to Court Holding Facilities?

    Separation




                            166
  How Frequently Must Court
Holding Facilities Be Monitored?

   100 percent every three years.




                                     167
    Monitoring Other Facilities
   Collocated Facilities
   Court Holding Facilities
   Adult Prisons
   Group Homes
   Mental Health Facilities



                                  168
Adult Prison

   State or federally funded institution to house
    convicted offenders under continuous custody on
    a long-term basis




                                                      169
              Adult Prisons
   Status offenders and non-offenders are prohibited
    from being placed in adult prisons.
   Holding delinquent offenders in an adult prison is
    not a violation of jail removal; however, delinquent
    offenders must be separated at all times from
    adult inmates.
   The JJDP Act does not prohibit transferred,
    waived, or certified youth from being held in an
    adult prison. The separation requirement does not
    apply.
                                                           170
    Which Core Requirements
     Apply to Adult Prisons?

   Deinstitutionalization of Status Offenders (DSO)
   Separation




                                                       171
            How Frequently Must
            Prisons Be Monitored?
   Spot-check.
   Should you discover that status offenders and delinquent
    offenders are being securely detained, monitoring
    frequency should be increased.
   Annual certification should be provided by adult prisons
    certifying they do not hold juveniles in violation of the
    JJDP Act and specifically that Scared Straight type
    programs are not in operation.
                                                                172
Monitoring Other Facilities

   Collocated Facilities
   Court Holding Facilities
   Adult Prisons
   Group Homes
   Mental Health Facilities


                               173
Group Home
   A nonsecure, community-based, residential
    program or facility
   Includes residential treatment centers,
    shelter care, residential child care facilities



                                                      174
          Group Homes (cont’d)

   Nonsecure facilities should be monitored to verify
    that the facility continues to be nonsecure.
   If a facility’s status changes to have the capacity to
    hold offenders securely, data on youth detentions
    must be collected and verified onsite.



                                                             175
        Which Core Requirements
        Apply to Group Homes?

 ???




                                  176
     How Frequently Must Group
       Homes Be Monitored?
   OJJDP onsite audit observations.
   To date standard has been ―spot check.‖
   States must provide a plan to OJJDP with the 2007
    Compliance Monitoring report detailing number and
    security level of group homes in the State.
   OJJDP will review information provided and make a
    decision about what the future monitoring standard
    should be.                                           177
    Monitoring Other Facilities

   Collocated Facilities
   Court Holding Facilities
   Adult Prisons
   Group Homes
   Mental Health Facilities


                                  178
Mental Health Facility

   A juvenile facility governed under separate State
    law pursuant to civil commitment of juveniles for
    mental health treatment or evaluation.




                                                        179
Mental Health Facilities (cont’d)
   A juvenile committed to a mental health facility
    under a civil commitment for mental health
    treatment may be placed in a secure mental health
    facility.
   Status offenders and non-offenders may not be
    placed in a secure mental health facility where the
    court is exercising only its juvenile status offender
    or non-offender jurisdiction.
                                                            180
Which Core Requirements Apply
  to Mental Health Facilities?

 Deinstitutionalization of Status Offenders (DSO)




                                                     181
 How Frequently Must Mental
Health Facilities Be Monitored?

   10 percent per year




                                  182
Compliance Monitors are not simply
bean counters. Rather, they…
    Ensure that children and youth are treated in
     accordance to the Act.
    Serve as the authority in the State on Compliance
     Monitoring issues.
    Assist facilities in meeting liability with regards to
     how children can be detained.
    Other?
                                                              18
                                                              3
Wednesday, January 24, 2007
OJJDP National Compliance
   Monitoring Training
Ensuring Data Reliability and Validity
           __________
             Day 2

                                         18
                                         4
Building an Adequate System
 of Compliance Monitoring:
    Small Group Exercise
Presented by
Elissa Rumsey,
Compliance Monitoring Coordinator, OJJDP

Susan Davis,
Compliance Monitor, Colorado
                                           18
                                           5
Refresher:
Adequate System
of Compliance Monitoring
Section 223(a)(14) of the JJDP Act:
Participating States must provide for an adequate system of
monitoring jails, detention facilities, correctional facilities, and
nonsecure facilities to insure that the requirements of
paragraph (11), paragraph (12), and paragraph (13) are met,
and for the annual reporting of the results of such monitoring
to the [OJJDP] Administrator…


                                                                       18
                                                                       6
       The 10 Compliance
    Monitoring System Elements

   Policies and Procedures
   Monitoring Authority
   Monitoring Timetable
   Violation Procedures
   Barriers and Strategies
                                 187
    The 10 Compliance Monitoring
      System Elements (cont’d)

   Definitions
   Identification of the Universe
   Classification of the Universe
   Inspection of Facilities
   Data Collection and Data Verification

                                            188
Instructions for
Small Group Breakouts
   In your small group, discuss which of the 10 elements
    you have been assigned. Your element is included in
    your handout folder.
   15 minutes to get into groups.
   30 minutes to discuss/share ideas in group.
   75 minutes to report back (each group has 7 minutes).
   15 minutes to summarize.
   See further instructions in your handout folder.
                                                            189
Building an Adequate System
 of Compliance Monitoring




   QUESTIONS?


                              19
                              0
     The Valid Court Order
       (VCO) Exception

Presented by

Susan Davis,
Compliance Monitor, Colorado

Elissa Rumsey,
Compliance Monitoring Coordinator, OJJDP
                                           191
I. The JJDP Act on the VCO

   Section 103(16) of the JJDP Act:
    VCO means a court order given by a
    juvenile court judge to a juvenile.




                                          192
I. The JJDP Act on the VCO
     Section 103(16)(A):
      Juvenile must be brought before the court and made
      subject to the VCO

     Section 103(16)(B):
      Juvenile must have received, before the issuance of
      the VCO, the full due process rights guaranteed to
      such juvenile by the Constitution of the United
      States.

                                                            193
I. The JJDP Act on the VCO
Section 223(a)23
 Requires States to provide specific protections for

  juveniles when taken into custody for violating a
  Valid Court Order.




                                                    194
II. The VCO in Practice?


Where State law allows, States may exclude
as DSO violations those children securely
detained pursuant to the violation of a VCO.




                                               195
II. The VCO in Practice:



                    A juvenile commits
                     a status offense.




                                          196
II. The VCO in Practice

   The Juvenile cannot be held
      In an adult jail or lockup for any length

       of time.
      In juvenile detention past the standard

       24 hours for status offenders.
   The Juvenile must be brought before a
    court of competent jurisdiction for the
    issuance of a VCO.

                                                   197
II. The VCO in Practice

 A VCO is issued
 Must include a guarantee that the juvenile has
  been advised of all due process rights.



                                               198
                  II. The VCO in Practice

   Due Process Rights include
       Adequate notice of charges
       Assistance of counsel
       Privilege against self-incrimination
       Privilege to confront and cross-examine witnesses



                                                            199
II. The VCO in Practice

                   The Juvenile violates the Valid
                    Court Order.




                                                      200
II. The VCO in Practice

When a VCO Is Violated:
 A juvenile who violates a VCO may be held in a juvenile facility
  but must…
 Be interviewed by an appropriate public agency within 24
  hours.
 Have a reasonable cause hearing within 48 hours of being
  placed in detention.
 Have an assessment report presented to the court at this hearing
   to determine placement pending the violation hearing.
                                                                     201
III. What States Must Do to Use the
     VCO Exception:

   State must have State law allowing secure detention of kids who
    violate VCOs.
   The State must train court and facility staff to ensure that all
    VCO standards are met (i.e., due process is afforded, interviews
    occur within 24 hours, hearing within 48 hours).
   State must review a minimum of 10 percent of all VCO cases to
    ensure they meet VCO standards.

                                                                       202
III. What States Must Do
to Use the VCO Exception:
   State must project and report as DSO violations those cases
    that do not meet VCO standards.
   State must provide as part of its annual Compliance Monitoring
    report a copy of the State legislation that allows the VCO
    exception to be utilized.




                                                                     203
Stay Tuned…
for the VCO skit at lunch!
Starring:
Bob Miller (Louisiana Compliance Monitor) as ―Bobby‖
Laura Whitlock (South Carolina JJ Specialist) as ―Deputy Whitlock‖
Rich Case (New Jersey Compliance Monitor) as ―Court Staff‖
Barb Murray (Alaska JJ Specialist) as ―Bobby’s Mother‖

And a host of other JJ Specialists and Compliance Monitors!

                                                                     204
Questions?


Thank you!




             205
Federal Wards/Immigrant Youth
Presented by

Laurie Elliot,
Compliance Monitor, Illinois

Larry Fiedler,
State Representative, OJJDP

Allison Ganter,
Compliance Monitor, California

                                 20
                                 6
         Federal Wards

As defined by the Office of Juvenile Justice
and Delinquency Prevention, a federal ward is
a juvenile who is under the care and custody
of the federal government. Such juveniles
would include undocumented immigrant youth
and those youth in the custody of the Bureau
of Indian Affairs.

                                                20
                                                7
              The JJDP Act on
         Federal Wards/Alien Youth

Section 223(a)(11)(B)(ii)
  ―Juveniles. . . who are aliens shall not be placed in secure
  detention facilities or secure correctional facilities.‖


  Undocumented alien youth securely detained in juvenile
  facilities may violate the DSO Core Requirement.

                                                            208
                  The JJDP Act on
             Federal Wards/Alien Youth

   OJJDP Policy allows aliens to be securely held in juvenile
    facilities for 24 hours for the following purposes:
           Jurisdictional transfer
           Appearance as a material witness
           Return to lawful residence or country of citizenship
   Does not include those undocumented immigrants who
    are also delinquent.
                                                                   209
                        Note!
   States agree to participate in the JJDP Act and, as a
    result, receive federal Formula Grant funds.
   States must convince public and private facilities that
    undocumented immigrant youth held securely violate
    the JJDP Act.
   OJJDP is working with other federal agencies to
    increase cooperation and adherence to JJDP Act
    requirements.
   Bottom line is that, because the State is accepting these
    funds, it is up to the State to achieve compliance.
                                                                210
    That said, where the presence of
     federal wards exceeds 29.4…

   Federal Wards held under Federal statutory authority in a
    secure State or local detention facility may be considered
    an ―exceptional circumstance‖ if excluding them from final
    DSO calculations brings the State’s DSO rate below
    29.4/100,000.



                                                            211
    Federal Wards─The Indiana
            Experience
   Indiana has one of two secure facilities in the
    nation that contracts to hold federal wards.
   Average federal ward population is 30–35 a day.
   Average length of stay is roughly 45 days.
   Outcome for youth: 60 percent to 70 percent
    deported.
                                                      212
          Federal Wards─The Indiana
              Experience (cont’d)
       Initiation of the Compliance Monitoring Function
           Facility identification: discovery of the federal ward issue
            occurred only with the last 18 months after an onsite visit.
           Data collection and verification:
                Previous data collection method insufficient to identify
                 this issue.
                Indiana has initiated a Web-based reporting system
                 that will easily identify federal wards.
       Site visit and data verification will occur at this facility annually.
                                                                                 213
      Federal Wards─The Indiana
          Experience (cont’d)
   Maintaining compliance with the DSO mandate:
      Given the number of federal wards held securely in
       Indiana, the State will not be able to maintain compliance
       with the DSO mandate without the backing out of the
       federal wards, as allowed by the Juvenile Justice and
       Delinquency Prevention Act.


                                                                    214
     Federal Wards─The Indiana
         Experience (cont’d)
 General strategies used in Indiana to encourage compliance with
  the JJDP Act Core Requirements:
     Provision of training and technical assistance
     Withholding or restricting funding to counties that house
       noncompliant facilities or counties that use noncompliant
       facilities.
 Primary barrier for change of practice with regard to
  federal ward issue:
     This is a private facility with a great financial interest in
      maintaining this federal ward program.                          215
            Federal Wards –
        The California Experience
   We survey the field annually.
   In 2005, San Diego and Imperial County contracted with
       Border Patrol.
       Immigration and Customs Enforcement.
       U.S. Marshals.




                                                             216
   In California (cont’d)

In 2005, there were 332 federal wards
held, with 133 for more than 24 hours.




                                         217
             In California (cont’d)
   We verify each violation.
       Many times, a juvenile also has a delinquent charge and will be
        deported within 24 hours after the commitment has been
        completed.
       Facility personnel are not always aware of this exception.
       We are looking for straight federal holds for illegal entry.
   Compliance Monitor makes phone call upon submission
    of report.
   Compliance Monitor reviews and verifies data during
    onsite inspection.
                                                                      218
             California DSO
              Rates for 2005
   2.88
     De minimis compliance.

     133 of our 219 violations were federal wards

      held over 24 hours (61 percent).

   This is an area of ongoing technical assistance
    and improvement.
                                                      219
    Rural Exception

            Thomas Murphy,
      State Representative, OJJDP

            Elissa Rumsey,
Compliance Monitoring Coordinator, OJJDP



                                           22
                                           0
What Is The Rural Exception?

   The JJDP Act allows States to implement a
    statutory rural exception, allowing the temporary
    detention beyond the 6-hour time limit of juveniles
    accused of delinquent offenses who are awaiting
    an initial court appearance within 48 hours
    (excluding weekends and holidays).

                                                      221
What Is the Rural Exception?

   OJJDP requires that States seek prior written approval
    before implementing the Rural Exception.
   If you cannot find such written documentation granting
    approval from OJJDP in your files, you need to request
    approval in writing.
   Please submit this request along with your FY 2007
    Formula Grants application.
   This approval is not statewide; rather it applies to specific
    facilities that meet Rural Exception criteria.
                                                                222
                      Note!
   The Rural Exception does NOT apply to status offenders
    or non-offenders.
   There are specific conditions that must be met in order
    for an accused juvenile criminal-type offender who is
    awaiting an initial court appearance, to be detained in a
    jail or lockup under the Rural Exception.
   All of the following conditions must be met….

                                                                223
Rural Exception Conditions

1. The geographic area having jurisdiction over the
   juvenile must be outside a metropolitan
   statistical area (non-MSA) as defined by the
   Office of Management and Budget.



                                                  224
Rural Exception Conditions

2. A determination must be made that there is no
   existing acceptable alternative placement for the
   juvenile pursuant to criteria developed by the
   State and approved by OJJDP.
3. The jail or lockup must be certified by the State
   to provide sight and sound separation.

                                                   225
Rural Exception Conditions

4. The State must have a policy that requires
   individuals who work with both juveniles and
   adults in collocated facilities to have been trained
   and certified to work with juveniles.



                                                          226
Rural Exception (cont’d)
   The State must provide documentation that the
    conditions have been met.
   The State must have received prior approval from
    OJJDP to use it.
   OJJDP strongly recommends youth admissions
    screening and continuous visual supervision.

                                                   227
Rural Exception Rules

   An accused juvenile criminal-type offender may be
    detained for the following time periods: (all times exclude
    weekends and holidays).
       Up to 48 hours; or
       If the facility is located where conditions of distance to be
        traveled or the lack of highway, road or other ground
        transportation does not allow for court appearances within 48
        hours so that a brief (not to exceed 48 hours) is excusable; or

                                                                          228
Rural Exception Rules

    If the facility is located where conditions adverse to
     safety exist (e.g., severe, life threatening weather
     conditions), the time for an appearance may be
     delayed until 24 hours after the time that such
     conditions allow for reasonably safe travel (no
     weekend or holiday exception here).


                                                              229
                        Note!
   Extended time periods do not apply after the initial
    court appearance. The six-hour exception after a
    court appearance applies.
   In the CM report you must report on each use of
    the exception over 48 hours, and provide
    supporting documentation.


                                                       230
Court Holding Facilities
Presented by

Susan Davis,
Compliance Monitor, Colorado

Julie Herr,
State Representative, OJJDP

Andrew Polk,
Compliance Monitor, Massachusetts
                                    23
                                    1
What Is a Court Holding
Facility?
   A secure facility other than a jail or lockup.
   Used to temporarily detain persons immediately
    before or after a court proceeding.
   Does not detain individuals overnight.
   Is not used for punitive purposes.

                                                     232
How Do You Monitor These
Facilities?
   If the court holding facility meets the criteria, then
    you monitor for sight and sound separation only.
   If the court holding facility does not meet the
    criteria, it is not ―classified‖ as a court holding
    facility, and is monitored as either a jail or
    lockup—which means you monitor for all three
    Core Requirements.
                                                             233
Monitoring (cont’d)

   What types of juveniles can be held there,
    provided it is a court holding facility?
       Delinquents
       Status offenders
       Accused and adjudicated



                                                 234
Monitoring (cont’d)

   What would be considered a violation?
       If the facility is not sight and sound separated, it is not a court
        holding facility, and is monitored as a jail or lockup.
       If the juvenile is sentenced to the facility, or placed in the facility
        for punitive purposes, then it is no longer a court holding facility,
        and is monitored as a jail or lockup.
       If the juvenile is held overnight, then it is no longer a court
        holding facility, and is monitored as a jail or lockup.


                                                                             235
Examples
   Facilities in compliance are
       Sight and sound separated, either environmentally—or
        with extensive policies and procedures
       Not staffed at night (unless court is held at night)
       Do not allow judges to use the facility for punitive
        purposes


                                                               236
Examples (cont’d)

   Problems you may encounter:
       Old buildings where separation is difficult
       Judges who use the facilities because juvenile
        detention are overcrowded
       Facilities that are used for ―overflow‖ when the jail gets
        too crowded

                                                                 237
Possible Solutions

   For separation issues:
       Time phasing with policies.
       Hospital curtains.
       One-way glass.
       Separate court days for juveniles and adults.
       Others?

                                                        238
Possible Solutions (cont’d)

   Recommend that you ask for their ideas on
    solutions before you impose your ideas.
   Talk to chief, sheriff, judge to gain their approval.
   Discuss methods that other facilities have used as
    possible solutions for their situation.


                                                        239
Discussion

   Massachusetts

   Your State




                    240
Data Analysis, Data
Verification, and Reporting
Susan Davis
Compliance Monitor, Colorado

Elissa Rumsey
Compliance Monitoring Coordinator, OJJDP



                                           24
                                           1
Compliance Monitoring (CM) Data:
 Ensuring Reliability and Validity

 1.   Why collect data?
 2.   What kinds of data should be collected?
 3.   How should data be analyzed?
 4.   How should data be verified?
 5.   How should data be reported?
 6.   How does OJJDP verify data?

                                                24
                                                2
     1. Why Collect CM Data?

   Data collection and reporting are required to
    determine if facilities are in compliance with DSO,
    Jail Removal, and Separation.
   As part of the CM system, each State must report
    on the barriers it faces in implementing and
    maintaining a monitoring system.

                                                      243
1. Why Collect CM Data (cont’d)?

   Data can be a powerful tool to help you
    understand problems in your CM system.
   Data provide powerful evidence where
    compliance problems exist and can be used to
    demonstrate to State and local officials where
    changes must be made.

                                                     244
2. What Kind of Data Should Be
          Collected?
    Self-reported facility admissions logs
    Monthly, quarterly, semiannually, or annually
    Admissions logs should include
      Name or case identifier
      Age
      Race
      Most serious offense
      Time in/time out
      Held securely or nonsecurely
      Held sight/sound separated
      Where/who released to                         245
    2. What Kind of Data Should Be
              Collected?

   If facilities refuse to self-report any data by fax, email,
    or mail, the CM must attempt to collect data onsite.
   Review can be done monthly, quarterly, or annually.
   Review admissions logs for pertinent information.




                                                             246
    2. What Kind of Data Should Be
               Avoided?
   Self-reported violations from facilities are inadequate.
   Expecting State, local, and private facilities to understand the
    distinctions between State and federal detention requirements and
    to report accurately creates significant room for error.
   Compliance Monitors should ask facilities to maintain juvenile
    admissions logs and self-report them to the State; absent that, the
    State must collect admissions logs onsite.
   If the facility self-reports admissions logs, the CM must review
    them for violations and then follow up with the facility by phone
    and, ultimately, onsite.
                                                                      247
                         Note!
   The DSA must verify compliance data provided by
    another agency.
   If you have a memorandum of understanding with
    another State agency (e.g., Adult DOC), whereby it
    provides relevant data it has already collected, then you
    are still responsible to verify, onsite, whatever data it
    provides to you.
   If you are paying for that agency to monitor specifically
    for JJDP Act Core Requirements, then this does not
    apply.
                                                                248
3. How Should Data Be Analyzed?

   Admissions logs should be reviewed for accuracy and
    completeness.
   Suspect entries and entries that appear to include
    violations of the Core Requirements should be promptly
    followed up.
   Data must be analyzed and verified onsite before
    submitting final annual report to OJJDP.

                                                             249
4. How Should Data Be Verified?

   Data can first be verified over the phone.
   Data must ultimately be verified onsite. If facilities submit
    self-report admissions logs, ask to see the actual
    admissions logs onsite to verify that they match.




                                                                250
         5. How Should Data Be
           Reported to OJJDP?
   Verified data must be reported to OJJDP on an annual
    basis.
   Calendar-year monitoring period is strongly encouraged.
   12 months of data ideal; minimum of six months required.
   Data should be reported via the Excel spreadsheet,
    recently updated and available at
    www.ojjdp.ncjrs.org/compliance/.
                                                           251
5. How Should Data Be Reported
       to OJJDP (cont’d)?
   The data sets that you need to collect are in the OJJDP
    Guidance Manual.
   Make sure you understand the data sets before you start
    collecting data so you do not need to go back and collect
    additional data.
   Compliance de minimis standards were reviewed
    yesterday and are in the OJJDP Guidance Manual.

                                                            252
6. How Does OJJDP Verify State
      Compliance Data?

   Annual review of State’s Compliance Monitoring
    Report to determine eligibility for Formula Grant
    Award
   Onsite audit—at least once every five years


                                                        253
          Reminder: Data Tied to
          Formula Grant Funding
   The annual Compliance Monitoring Report shows
    compliance with DSO, Jail Removal and Separation.
   If in compliance with all three, 60 percent of Formula
    Grant funds are awarded.
   If out of compliance with one Core Requirement, 20
    percent of funding lost and 50 percent of remaining funds
    must be spent on that Core Requirement.

                                                             254
                  And Finally…
   Data collection is critical
   If OJJDP determines that a State is out of compliance
    with Section 223(a)(14) then Formula Grants funds can
    be frozen or not awarded.
   If you have a reluctant facility, stress
    Accountability
    Risk of civil litigation
    Fact that the requirements are now standards of
       professional conduct.
   Build relationships! Work as a team towards compliance.
                                                          255
 Compliance Monitoring Data:
Ensuring Reliability and Validity

 1.   Review of OJJDP Compliance Monitoring
      Report/Technical Assistance Tool
 2.   Form recently updated
 3.   Minor changes you should be aware of
 4.   Troubleshooting common errors

                                              25
                                              6
        San Diego
Onsite Facility Inspections
            Presented by
     Allison Ganter, California
       Elissa Rumsey, OJJDP




                                  25
                                  7
                   Six Facilities
1.   Kearny Mesa Juvenile   4.   San Diego City Police
     Hall                        Department, Mid-City Station

2.   Coronado Police        5.   San Diego County Sheriff’s
     Department                  Department

3.   National City Police        5a. Imperial Beach
     Department                      Substation
                                 5b. Lemon Grove
                                     Substation
                                                                258
     Kearny Mesa Juvenile Hall

   OJJDP Definition

    Secure Juvenile Detention Center:
    A secure juvenile detention center is any secure
    public or private facility used for the lawful custody
    of accused or adjudicated juvenile offenders.

                                                             259
     Kearny Mesa Juvenile Hall
Classification per Federal Definitions

    Secure
    Juvenile only
    Residential
    Public

                                     260
         Kearny Mesa Juvenile Hall
                2005 Data
   Rated capacity = 359.
   Total number of beds = 517.
   Facility reported 132 status offenders securely detained
    in violation of DSO.
   Status offenders are held in intake. They are not housed
    with other juveniles in housing units.
   Facility reported 43 federal wards held in violation of
    DSO.                                                       261
Onsite Inspection: 1/25/07
Kearny Mesa Juvenile Hall

   Self-reported data review
   Facility tour
   Applicable Core Requirements
         DSO
         Separation
   Verification of data
                                   262
     Coronado Police Department
   OJJDP Definition

    Lockup:
    A lockup is similar to an adult jail except that
    an adult lockup is generally a municipal or
    police facility of a temporary nature that does
    not hold persons after they have been formally
    charged.
                                                   263
    Coronado Police Department
Classification per Federal Definitions

   Secure
   Adult and Juvenile
   Nonresidential
   Public

                                         264
    Coronado Police Department
            2005 Data
   Four cells: each with varying capacities based on size.
   Facility reported five juvenile delinquents held in secure
    detention in 2005.
       None over six hours.
       All sight and sound separated from adults
   17 juvenile delinquents held in nonsecure detention.

                                                                 265
Onsite Inspection: 1/25/07
Coronado Police Department

     Self-reported data review
     Facility tour
     Applicable Core Requirements
           DSO
           Separation
           Jail Removal
     Verification of data
                                     266
National City Police Department
   OJJDP Definition
    Lockup:
    A lockup is similar to an adult jail except that an
    adult lockup is generally a municipal or police
    facility of a temporary nature that does not hold
    persons after they have been formally charged.


                                                          267
National City Police Department
Classification per Federal Definitions

   Secure
   Adult and juvenile
   Nonresidential
   Public

                                         268
    National City Police Department
               2005 Data
   12 cells: each of varying rated capacities based on size.
       One is a ―juvenile holding cell.‖
   Facility reported four juvenile delinquents held in secure
    detention in 2005.
       None over six hours.
   Facility reported 153 juvenile delinquents in nonsecure
    detention.
                                                                 269
Onsite Inspection: 1/25/07
National City Police Department

   Self-reported data review
   Facility tour
   Applicable Core Requirements
         DSO
         Separation
         Jail Removal
   Verification of data
                                   270
San Diego City Police Department
        Mid-City Station
   OJJDP Definition
    Lockup:
    A lockup is similar to an adult jail except that an
    adult lockup is generally a municipal or police
    facility of a temporary nature that does not hold
    persons after they have been formally charged.
                                                          271
 San Diego City Police Department
          Mid-City Station
Classification per Federal Definitions

    Secure
    Adult and juvenile
    Nonresidential
    Public
                                         272
    San Diego City Police Department
            Mid-City Station

   Two holding cells that are not locked.
       Hardware has been removed.
       Facility provided certification that they are nonsecure
        and do not hold juveniles securely.


                                                                  273
Onsite Inspection: 1/25/07
San Diego Police Department Mid-City Station

   Self-reported data review
   Facility tour
   Applicable Core Requirements
         DSO
         Separation
         Jail Removal
   Verification of data
                                               274
     San Diego County Sheriff’s
            Department:
      Lemon Grove Substation
   OJJDP Definition
    Lockup:
    A lockup is similar to an adult jail except that an
    adult lockup is generally a municipal or police
    facility of a temporary nature that does not hold
    persons after they have been formally charged.
                                                          275
      San Diego County Sheriff’s
             Department:
       Lemon Grove Substation
       Classification per Federal
              Definitions
   Secure
   Adult and Juvenile
   Nonresidential
   Public
                                    276
          San Diego County Sheriff’s
                 Department:
           Lemon Grove Substation
                  2005 Data
   Three holding cells: each with a rated capacity of three.
   Facility reported four juvenile delinquents held in secure
    detention in 2005.
       Two over six hours
   Facility reported 251 juvenile delinquents.
                                                                 277
Onsite Inspection: 1/25/07
San Diego County Sheriff’s Department:
Lemon Grove Substation
   Self-reported data review
   Facility tour
   Applicable Core Requirements
         DSO
         Separation
         Jail Removal
   Verification of data                 278
       San Diego County Sheriff’s
              Department:
       Imperial Beach Substation

   OJJDP Definition
    Lockup:
    A lockup is similar to an adult jail except that an
    adult lockup is generally a municipal or police
    facility of a temporary nature that does not hold
    persons after they have been formally charged.
                                                          279
    San Diego County Sheriff’s
             Department:
     Imperial Beach Substation
Classification per Federal Definitions

    Secure
    Adult and juvenile
    Nonresidential
    Public
                                     280
            San Diego County
           Sheriff’s Department:
         Imperial Beach Substation
                 2005 Data
   Two holding cells.
   Facility reported five juvenile delinquents held in
    secure detention in 2005.
     None over six hours.


   Facility reported 127 juvenile delinquents held in
    nonsecure detention.                                  281
Onsite Inspection: 1/25/07
San Diego County Sheriff’s Department:
Imperial Beach Substation
   Self-reported data review
   Facility tour
   Applicable Core Requirements
         DSO
         Separation
         Jail Removal
   Verification of data                 282
OJJDP Audits of State
Compliance Monitoring
Systems
Presented by
Julie Herr, State Representative, OJJDP
Ron Smith, Compliance Monitor, Illinois


                                          28
                                          3
Session Overview

   What is a compliance audit, and why do we do
    them?
   The audit process: planning, execution, and
    follow-up.
   Common audit findings.
   Illinois: A review of one State’s audit experience.
                                                          284
Pursuant to Section 223(a)(14) of the
JJDP Act of 2002, States shall:

         ―Provide for an adequate system of monitoring jails,
detention facilities, correctional facilities, and nonsecure
facilities to ensure that the requirements of paragraph (11),
paragraph (12), and paragraph (13) are met, and for annual
reporting of the results of such monitoring to the [OJJDP]
Administrator….‖

                                                                285
Pursuant to Section 204(b)(6) of the
JJDP Act of 2002, OJJDP shall:

    ―Provide for the auditing of monitoring systems required
under… this title to review the adequacy of such systems….‖




                                                           286
What Is a Compliance Audit?
   An in-depth review and evaluation of a State’s system for
    monitoring and reporting on its compliance with the Core
    Requirements.

   Audits occur a minimum of once every five years.

   OJJDP will determine whether a State’s system is ―adequate‖ or
    ―not adequate.‖ Additional findings and recommendations will
    also be provided.

   The result of a ―not adequate‖ finding is that access to Formula
    Grants funds will be frozen. Future eligibility as a ―Participating‖
    State with the Formula Grants program is also jeopardized.             287
Pre-Audit Planning
   State Rep provides informal notification that an audit is
    due for the coming year.

   Specialist, Compliance Monitor and State Rep work
    together to select mutually convenient dates.

   Specialist, Compliance Monitor and State Rep work
    together to identify an appropriate sample of facilities to
    be visited.
                                                                  288
Pre-Audit Planning (cont’d)
An appropriate sample of facilities will include the following:
   One juvenile detention facility
   One juvenile corrections facility/training school
   One adult jail
   One adult lockup
   One court holding facility
   One nonsecure group home
Facilities should ideally represent a mix of urban, rural, and suburban
  communities and include geographic areas beyond the capital region.
                                                                     289
Pre-Audit Planning (cont’d)

   Compliance Monitor contacts facilities to arrange a date
    and time for each audit visit, emphasizing that it is the
    State—not the facilities themselves—that is being
    audited.

   State develops a tentative agenda.


                                                                290
Pre-Audit Planning (cont’d)

   The State ensures that each of the selected
    facilities will have original data available onsite.

   The State agency has all required data available
    for review and ready to carry into the field.


                                                           291
Pre-Audit Planning (cont’d)
   30 days out, an official notification letter is mailed with information
    on required pre-audit materials.

   14 days in advance, pre-audit materials are provided to OJJDP.

   State Rep reviews pre-audit materials as well as the Compliance
    Monitoring section of the State’s Three-Year Plan.

   State Rep attempts to answer questions from Appendix 3 of the
    Audit Guideline Manual. A list of areas requiring additional
    clarification is compiled.
                                                                              292
Audit Execution
1) Entrance interview.
2) Discussion of the State system. Clarification of any
   issues that arose in the State Rep’s review of pre-
   audit materials. Key issues include

     Policies and Procedures        Definitions
       Monitoring authority         Identification
       Monitoring timetable         Classification
       Violation procedures         Inspection
       Barriers and Strategies      Data collection/verification
                                                                     293
Audit Execution (cont’d)
3) Facility visits.
     Introduction.
     Tour of facility and verification that physical plant,
      policies, procedures are sufficient to facilitate
      compliance with Core Requirements.
     Verification of data.

4) Exit interview.
                                                               294
Audit Follow-Up
   OJJDP completes official findings letter and audit
    report, with both findings and recommendations.
       Findings can be positive or negative.
       Findings  must be addressed or the State risks
        having its Formula Grants funds frozen.
       Recommendation  OJJDP strongly recommends
        that the State take action, such that the issue does
        not at a later date rise to the level of a ―finding.‖
                                                                295
Audit Follow-Up (cont’d)

   State prepares official response to report and
    findings letter, delineating how it will address audit
    findings and recommendations.

   OJJDP provides a ―response to the response,‖
    designating audit as officially closed or indicating
    the need for further action.
                                                           296
    Common Audit Findings
   The State is not performing onsite data verification prior
    to submission of Compliance Monitoring reports to
    OJJDP.
   The State has classified a facility, (e.g. a Lockup) as
    nonsecure yet during the OJJDP Audit the onsite
    inspection reveals a cuffing bench or cuffing rail.
   The State is not inspecting facilities believed to be
    nonsecure (e.g., lockups, group homes) to verify
    nonsecure status.
                                                                 297
Common Audit Findings (cont’d)
   The State is not inspecting secure facilities at a rate of
    100 percent every three years.
   The State is not monitoring its juvenile correctional
    facilities/training schools to ensure compliance with DSO
    and sight and sound separation requirements.
   Facilities are self-reporting violations and the DSA is not
    adequately verifying such self-reports for accuracy (e.g.
    comparing self-reported violations against
    admissions/booking logs).
                                                                  298
Common Audit Findings (cont’d)

   The State does not provide adequate documentation that
    VCO process requirements have been met.
   The State has not included law enforcement facilities that
    exist in airports, shopping malls, and sports stadiums in
    its monitoring universe.




                                                             299
    Thank You to
OJJDP for Sharing this.
                (




      Global Youth Justice
 www.GlobalYouthJustice.org
“Making the Time for Juvenile Crime”

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