PREA Cost Impact Analysis

Contents
Executive Summary ....................................................................................................................................... i
Introduction ................................................................................................................................................... 1
Compliance Analysis .................................................................................................................................... 4
Primary Cost Impacts and their Underlying Causes ................................................................................... 11
Background and Scope of Study ................................................................................................................. 61
Study Methodology ..................................................................................................................................... 63
Assumptions................................................................................................................................................ 75
Appendix A: Underlying Causes of Cost Impacts by Sector .................................................................... A-1
Prisons ................................................................................................................................................... A-1
Jails ..................................................................................................................................................... A-20
Juvenile ............................................................................................................................................... A-34
Community Corrections ...................................................................................................................... A-47
Lockups ............................................................................................................................................... A-58
Appendix B: Site by Site Characteristics and Cost by State ..................................................................... B-1
Prisons ................................................................................................................................................... B-1
Jails ..................................................................................................................................................... B-31
Juvenile ............................................................................................................................................... B-66
Community Corrections ...................................................................................................................... B-88
Lockups ............................................................................................................................................. B-100
Appendix C - Approach to Questionnaire Development and Data Gathering ......................................... C-1
Appendix D – Questionnaires ................................................................................................................... D-1
Adult Prisons and Jails .......................................................................................................................... D-1
Juvenile Facilities................................................................................................................................ D-13
Community Corrections ...................................................................................................................... D-26
Lockups ............................................................................................................................................... D-40
Appendix E – Data Reports ...................................................................................................................... E-1
Jails and Prisons .................................................................................................................................... E-1
Juvenile Facilities................................................................................................................................ E-16
Community Corrections ...................................................................................................................... E-32
Lockups ............................................................................................................................................... E-48
Appendix F - Standards Summary ............................................................................................................ F-1
Adult Prisons and Jails .......................................................................................................................... F-1
Community Corrections ...................................................................................................................... F-15

PREA Cost Impact Analysis
Juvenile Facilities................................................................................................................................ F-26
Lockups ............................................................................................................................................... F-37

PREA Cost Impact Analysis

Executive Summary
Table E-1: Standards with Negligible or Non-Existent Costs
This document is the final report of the Prison
Rape Elimination Act (PREA) Cost Impact Standards with a negligible or non-existent cost impact Compliance
Analysis, an effort to assist the Bureau of Justice RE1 Inmate reporting
96%
94%
Assistance (BJA) in the review of the standards DC4 Data storage, publication, and destruction
90%
MM2 Access to emergency medical and mental health
published by the National Prison Rape
services
88%
Elimination Commission (NPREC) on June 23, DI1 Disciplinary sanctions for staff
86%
OR4 Coordinated response
2009. This document assesses the costs specific IN2 Criminal and administrative agency investigations
86%
71%
to each standard, assesses variations within the RE4 Third-party reporting
69%
OR2 Reporting to other confinement facilities
cost estimates, and addresses a comprehensive OR3 Staff first responder duties
69%
67%
view of implementation and compliance on a OR1 Staff and facility head reporting duties
65%
DI2
Disciplinary sanctions for inmates
national level.
It covers five sectors of MM1 Medical and Mental Health Screenings - history of
55%
sexual abuse
correctional operations: state prison systems,
state and local juvenile facilities, community corrections, and local/county jails, police lockups.

Overall Cost Impacts

Table E-2: Standards with a Minimal or Modest Cost

Total Costs ($K)
Among the 41 PREA standards, 12 have Standard
Upfront On-Going
negligible or non-existent cost impacts as
Ongoing medical and mental health care for sexual
$12
$5,773
victims and abusers
shown in Table E-1. The majority of the sites MM3 abuse
Contracting with other entities for the confinement of
$0
$5,695
visited during this project, approximately 8 out PP2 inmates
AU1 Audits of standards
$0
$5,167
of 10, demonstrated compliance with these TR1 Employee training
$4,484
$4,375
PP1
$48
$3,768
Zero tolerance of sexual abuse
standards. For the sites not in compliance with
Agreements with outside public entities and
$33
$1,611
these standards, there was no indication that RP2 community service providers
SC2
$170
$1,605
Use of screening information
meeting the PREA standards would result in RP1 Evidence protocol and forensic medical exams
$25
$1,396
IN1
$18
$1,264
Duty to investigate
any measurable cost. Twenty-six standards ID6 Supplement to SC-2
$9
$746
Screening for risk of victimization and abusiveness
have anywhere from a very minimal to
SC1
$530
$677
$4
$284
modestly sizable cost impact most often PP6 Hiring and promotion decisions
Agreements with outside law enforcement agencies
affecting numerous sites and sectors but with RP3
$21
$258
$21
$250
some variability.
Table E-2 lists these RP4 Agreements with the prosecuting authority
DC3 Data review for corrective action
$352
$176
$458
$161
standards organized, from highest-to-lowest TR3 Inmate education
Specialized training: Medical and mental health care
according to ongoing costs.
These 26 TR5
$1,462
$153
$572
$142
Volunteer and contractor training
standards have varying degrees of compliance. TR2
DC1 Sexual abuse incident reviews
$2
$126
$6
$105
Some are compliant with relatively more RE2 Exhaustion of administrative remedies
Evidence standard for administrative investigations
standards than others. To illustrate this, Table IN3
$1
$79
$17
$72
Data Collection
E-3 shows that seven out of the 26 standards DC2
PP5
$2
$47
Accommodating inmate with special needs
$316
$15
have a compliance rate of 70% or higher. This TR4 Specialized training: Investigations
OR5 Agency protection against retaliation
$500
$0
means that for each standard in that list, at least
Inmate access to outside confidential support services
$98
$0
70% of the sites in this study demonstrated RE3
compliance. For example, Evidence Standard for Administrative Investigations (IN6) shows a 96%
compliance rate. In other words, 96% or 47 sites out of 49, in this study exhibited compliance with this
standard. This standard, therefore, has a relatively low cost and a high compliance.

Executive Summary

i

PREA Cost Impact Analysis
This contrasts with the remaining 19
standards, Table E-4, that show relatively
low compliance rates. In this case, Audits
of Standards (AU1) can be seen to have a
0% compliance rate whereby no sites
demonstrated compliance. This should
come to no surprise since there are no
audits currently available.
A similar
conclusion can be made for Zero
Tolerance of Sexual Abuse where only
four sites (or 8% of the 49 total sites) have
a PREA Coordinator on staff.

Table E-3: Standards with Compliance Less than 70%
Standard

RP3

Evidence standard for administrative
investigations
Agreements with outside law enforcement
agencies

PP5

Accommodating inmate with special needs

RP4
DC2
PP2

Agreements with the prosecuting authority
Data Collection
Contracting with other entities for the
confinement of inmates

DC3

Data review for corrective action

IN3

Table E-4: Standards with Compliance Less than 70%
Standard
RP1
SC2
DC1
RE3
OR5
MM3
ID6
TR2
TR5

Evidence protocol and forensic medical
exams
Use of screening information
Sexual abuse incident reviews
Inmate access to outside confidential
support services
Agency protection against retaliation
Ongoing medical and mental health care for
sexual abuse victims and abusers
Supplement to SC-2
Volunteer and contractor training
Specialized training: Medical and mental
health care

RP2

Specialized training: Investigations
Duty to investigate
Screening for risk of victimization and
abusiveness
Employee training
Exhaustion of administrative remedies
Inmate education
Agreements with outside public entities and
community service providers

PP6

Hiring and promotion decisions

PP1
AU1

Zero tolerance of sexual abuse
Audits of standards

TR4
IN1
SC1
TR1
RE2
TR3

Total Costs ($K)
Upfront
On-Going
$25
$1,396

Overall
Compliance
69%

$170
$2
$98

$1,605
$126
$0

69%
59%
59%

$500
$12

$0
$5,773

59%
57%

$9

$746

51%

$572
$1,462

$142
$153

43%
43%

$316

$15

41%

$18
$530

$1,264
$677

41%
45%

$4,484
$6
$458
$33

$4,375
$105
$161
$1,611

37%
33%
31%
24%

$4

$284

22%

$48

$3,768

8%

$0

$5,167

0%

Total Costs ($K)
Upfront
On-Going
$1
$79

Overall
Compliance
96%

$21

$258

88%

$2

$47

88%

$21

$250

88%

$17
$0

$72
$5,695

80%
73%

$352

$176

73%

Three standards (PP3, PP4, and PP7) account
for 99% of all upfront costs, and one, PP7,
accounts for 96% of all upfront costs, seen in
Table E-5. This finding is attributed primarily
to undefined and misinterpreted requirements
based on the current language of the standard.
Two standards (PP3 and PP4) account for
76% of all ongoing costs, solely driven by
increased staffing required to meet the intent
of the standards as they are written. This table
also shows that two of the three (PP4 and
PP7) have relatively low compliance rates
meaning that few sites exhibit compliance.
Inmate Supervision (PP3) on the other hand,
shows a combination of a high cost and high
compliance rate, indicating that of the few
sites noncompliant with the standard, the cost
impacts are very high.

Table E-5: Standards with the Highest Costs

Standard
PP3
PP4

Inmate supervision
Limits to cross-gender viewing and searches

PP7

Assessment and use of monitoring technology

Total Costs ($K)
% of Total Costs
Upfront On-Going Upfront On-Going
$1,665
$88,848
0%
38%
$21,293
$89,974
3%
39%
$770,634

$20,354

96%

9%

Overall
Compliance
73%
39%
31%

Another means to determine the relative cost impact and its magnitude is to compare a site's overall cost
impact to its annual operating budget. This can provide a measure of the relative impact on a site's daily
operations and whether they can or cannot absorb the additional costs as a result of PREA. Tables E-6
and E-7 (one for annual, ongoing costs and another for one-time, upfront costs) depict the cost impacts by
standard across each of the five sectors. The Harvey Balls™ represent an order of magnitude
distinguishing between relatively low and high costs. They are based on a percentage of the annual
Executive Summary

ii

PREA Cost Impact Analysis

standards that do not result in
any cost impact. A quartershaded ball 1 represents an
overall impact on annual
operating budget between 0%
and 0.25%, and a half-shaded
ball 2 represents an impact
between 0.25% and 0.50%. A
4
fully-shaded
ball

ups

Lock

Com
m.
Corr.

ile

Juven

Jails

ns

Priso

Prior

Stan
d

ity

ard

aggregate operating budget for each sector. Standards that do not result in any cost impact for any sector
are not depicted in the tables. The degree to which each Harvey Ball is shaded indicates the magnitude of
the cost impact, or percentage of
Table E-6: Yearly Cost Impacts as % of Annual Operating Budget
the overall operating budget.
An empty ball E represents
1

PP4

Limits to cross-gender
viewing and searches

4

1

1

4

1

2

PP3

Inmate Supervision

4

4

r

1

0

3

PP7

1

1

1

n/a

0

4

MM3

1

1

1

0

n/a

5

AU1

1

1

1

1

1

1

1

r

1

1

1

1

1

1

0

1

1

0

1

1

6

Assessment and use of
monitoring technology
Ongoing medical and mental
health care
Audits of standards

TR1 - TR5 Training and education

Contracting with other entities
for the confinement of
inmates
Accomodating inmates with
8
PP5
special needs
Zero tolerance of sexual
9
PP1
abuse
Screening for risk of sexual
10 SC1/SC2
abuse
RP2-RP4, Contract modifications for
11
RE3
outside services
Evidence protocol and
12
RP1
forensic medical exams
7

PP2

represents any percent impact
1
1
1
1
1
on annual operating budget
1
1
1
0
1
that is greater than 0.50%.
For
example,
Inmate
1
0
1
1
0
Supervision for prisons is
1
1
1
1
0
represented by a fully-shaded
1
1
1
0
0
Harvey Ball. The aggregate 13 IN1/IN3 Investigations
to SC-2: Use of
0
1
n/a
n/a
n/a
costs of all the prison systems 14 DC6 Supplement
screening information
Hiring and promotion
in this study is 0.51% of their 15
1
1
1
1
1
PP6
decisions
aggregate operating budget.
Gathering, reviewing, and
1
1
1
1
0
Meanwhile, the upfront costs 16 DC1-DC3 reporting data
Exhaustion of administrative
1
1
0
0
0
in Table E-7 on the next page 17
RE2
remedies
shows a full Harvey Ball for
Agency protection against
0
0
0
0
0
18
OR5
retaliation
Assessment and Use of
Monitoring Technology (PP7), representing an upfront percent impact of 4.83% for prisons. The primary
reason for the significantly higher percentage is attributed to the investment required for technical
modernization and retrofits. Thus a site could theoretically be compliant with 99% of the standards with
the exception of PP7 and still exhibit a large cost impact.
Appendix A includes similar tables with additional detail for each site categorized by sector.

Executive Summary

iii

PREA Cost Impact Analysis
Overall Compliance

ups
Lock

Com
m.
Corr.

ile
Juven

Jails

Priso
ns

Stan
d

Prior
ity

ard

Table E-7: Ongoing Cost Impacts as % of Annual Operating Budget

1

PP4

Limits to cross-gender
viewing and searches

1

r

1

1

1

2

PP3

Inmate Supervision

1

1

1

1

0

4

4

4

n/a

0

0

1

0

0

n/a

0

0

0

0

0

1

1

1

1

1

0

0

0

0

0

0

0

0

1

0

1

1

1

1

1

1

1

1

1

0

1

1

1

1

0

1

1

1

0

0

Investigations

1

1

1

0

0

Supplement to SC-2: Use
of screening information

0

1

n/a

n/a

n/a

Hiring and promotion
decisions
Gathering, reviewing, and
16 DC1-DC3
reporting data
Exhaustion of
17
RE2
administrative remedies
Agency protection against
18
OR5
retaliation

1

1

0

0

0

1

1

1

1

1

1

1

1

0

0

1

0

0

0

0

3

PP7

4

MM3

5
6

AU1

Assessment and use of
monitoring technology
Ongoing medical and
mental health care
Audits of standards

TR1 - TR5 Training and education

Contracting with other
entities for the confinement
of inmates
Accomodating inmates
8
PP5
with special needs
Zero tolerance of sexual
9
PP1
abuse
Screening for risk of sexual
10 SC1/SC2
abuse
RP2-RP4, Contract modifications for
11
outside services
RE3
Evidence protocol and
12
RP1
forensic medical exams
7

PP2

13

IN1/IN3

14

DC6

15

PP6

Sites have varying degrees
of compliance with the
standards ranging from a
high of 88% to a low of
38%.
The site with the
highest
ranking
(MA
Department
of
Youth
Services) is compliant with
88% of the standards. The
average compliance is 63%.
Table E-8 on the next page
shows the compliance rates
for each site in the study.
On average and collectively,
lockups have the highest
compliance rate at 74%,
while jails have the lowest
rate at 61%. The higher
compliance rates among
lockups may be a reflection
of the fewer number of
standards, their relative small
size, and the low number of
samples in this study (four).
The other four sectors in this
study all have relatively
close compliance rates;
between 67% and 61%.

A general correlation exists between lower compliance rates and higher costs, however this is just a
general pattern and there are several exceptions. Nine of the 41 standards have compliance rates under
40%. Two of these standards, the PREA Audit (AU1) and the PREA Coordinator (PP1), would not be
expected to have any compliance because the NPREC standards have not been officially promulgated
although four sites already have staff assigned as PREA Coordinator.

Executive Summary

iv

PREA Cost Impact Analysis
Table E-9 at the bottom of the page shows each of the 29 standards with a notable cost impact and their
underlying causes for the cost impact. The standards are organized according to magnitude of the
ongoing cost impact from
Table E-8: Compliance Rates by Site
highest to lowest. Although
Compliance
Percent
Site
Sector
Site
Sector
% of
Compliance
there are clearly some
Standards
MA DYS
Juvenile
IN DYS
Juvenile
88%
63%
relatively significant upfront
MA DOC
Prison
OYA
Juvenile
85%
63%
AR JA
Juvenile
Middleton PD
Lockups
85%
63%
costs that overshadow the
Denver County
Jail
Albany County
Jail
84%
61%
82%
61%
Seattle PD
Lockups
Norfolk City
Jail
ongoing costs (e.g., PP7),
OR DOC
Prison
MO PP
Community Corrections
80%
61%
prioritizing the standards by
MO DYS
Juvenile
Aiken County
Jail
78%
59%
CA DOC
Prison
Marion County
Jail
76%
59%
ongoing costs emphasizes
MA OCC
Community Corrections
Sacramento County
Jail
74%
56%
Peumansend Creek
Jail
Hennepin County
Jail
73%
56%
the long-term cost impact as
DCPA
Lockups
WA Pierce County
Jail
73%
56%
a result of the NPREC
Rocklin PD
Lockups
NY DOC
Prison
73%
54%
MN DOC
Prison
VA DOC
Prison
71%
54%
Standards. Some standards
Essex County
Jail
Pulaski County
Jail
70%
54%
AR DOC
Prison
Jefferson County
Jail
68%
53%
are bundled together: the
RI DOC
Prison
WA DOC
Prison
68%
51%
training standards (TR1
Ada Juv
Juvenile
MO
DOC
Prison
68%
49%
CA DJJ
Juvenile
SC DOC
Prison
68%
49%
through TR5); the Screening
IN DOC
Prison
Alachua County
Jail
66%
49%
WI Pierce County
Jail
Anoka County
Jail
66%
49%
Standards (SC1 and SC2);
AR DCC
Community Corrections
IN DOR
Community Corrections
66%
48%
Gathering, Reviewing and
Miami-Dade
Jail
WA CC
Community Corrections
63%
47%
SC PPP
Community Corrections
CO DOC
Prison
63%
41%
Reporting Data Standards
CO DYC
Juvenile
FL DJJ
Juvenile
63%
40%
38%
IDJC
Juvenile
(DC1
through
DC3);
Contract Modifications for Outside Services (RP2 though RP3 and RE3); and Investigations (IN1 and
IN3). Booz Allen believes that they are either dependent upon each other (such as data reviewing, or
screening standards) or are logically tied to each other because of their similarities in breadth and scope
(such as the training, investigations, and contract modification standards) and any attempt to decouple one
will either diminish the value of the others or jeopardize the collective objective of the set.
Table E-9: Major Cost Drivers and Underlying Causes
Cost Impact
Rank
1
PP4
2

PP3

3

PP7

4

MM3

5
6

AU1
TR1 - TR5

7

PP2

8
9
10

12
13

PP5
PP1
SC1 and
SC2
RP2 - RP4
and RE3
RP1
IN1 and IN3

14

ID6

11

15
16
17
18

Standard

Underlying Cost Driver

Limits to cross-gender viewing and The prohibition of cross-gender pat down searches results in major workforce realignments given the current
searches
male/female staffing ratios relative to inmate male/female ratios.
Inmate Supervision
With a level of subjectivity based upon one's definition of what is considered adequate, many sites perceive a need
to hire more staff as a means of preventing sexual abuse.
Assessment and use of monitoring Agencies are required to utilize video monitoring systems to eliminate sexual abuse with little to no guidance on the
technology
extent, quality, and specifications of this technology as it relates to their site's characterics and operations.
Ongoing Medical and Mental Health
Care
Audits of standards
Training and Education

Agencies must provide medical and/or mental health treatment to all known abusers of sexual violence, greatly
expanding the number of offenders served.
Agencies must conduct a triennial audit of all facilities.
Agencies are required to expand or modify current training programs to cover all employees (including non-sworn
officers and administrative assistants), contractors and volunteers, offenders, and ensure specialized training is
provided to investigators and the medical and mental health care staff.
Contracting with other entities for Contracted facilities must comply with all NPREC standards, passing any increased costs over to agencies in the
the confinement of inmates
form of increased fees.
Accommodating inmates with
Agencies must implement new policies and procedures to provide interpretive services.
Zero tolerance of sexual abuse
Evey site requires a PREA Coordinator requiring hiring additional staff.
Screening for Risk of Sexual Abuse Agencies are required to modify existing tools or implement procedures where one does not exist.
Contract modifications for outside
services
Evidence protocol and forensic
Investigations

Supplement to SC-2: Use of
Screening Information
PP6
Hiring and promotion decisions
DC1 - DC3 Gathering, Reviewing and Reporting
Data
RE2
Exhaustion of Administrative
Remedies
OR5
Agency protection against
retaliation

Executive Summary

Agencies must enter or attempt to enter into contractual agreemenst with outside entities to provide confidential
emotional support, tranistion services, and at times, investigative and law enforcement services
Agencies must provide a victim advocate during the medical exam process.
Agencies will see and increased volume of investigations as a result of more reports of sexual abuse
Agencies are required to house immigrant detainees separate from the general inmate population, resulting in
physical plant investments or increase personnel.
Agencies are required to conduct criminal background checks on employees considered for promotion.
Agencies are required to enhance existing processes for gathering, reviewing and reporting of sexual abuse data,
resulting in addition personnel costs as a level of effort.
Agencies are reqiured to modify existing policies or accompanying a victim to federal court. In addition, this
contradicts with PLRA.
Agencies are required modify existing inmate tracking systems to accommodate additional data characteristics.

v

PREA Cost Impact Analysis
Table 1: Site Legend

Introduction
The Prison Rape Elimination Act (PREA) of
2003 (P.L. 108-79) established the National
Prison Rape Elimination Commission
(NPREC) to develop and implement national
standards for the detection, prevention,
reduction and punishment of prison rape1.
The Bureau of Justice Assistance (BJA)
tasked Booz Allen to assist in the review
process of the standards published by NPREC
on June 23, 2009 to assess their cost impact at
correctional institutions across the country.
This report provides an analysis of the cost
impact based on data from 49 sites2
representing 13 prisons, 16 jails, 10 juvenile
facilities, 6 community corrections, and 4
lockups. Geographically, 12 sites are in the
Midwest, 8 are in the Northeast, 13 are in the
South, and 16 are in the West. Table 1 lists
the sites included in this study along with the
acronyms used throughout the report.
Methodology
The Booz Allen team, consisting of
criminal/juvenile justice subject matter
experts (SME) and cost estimating specialists,
conducted on-site face-to-face meetings with
representatives from each of the 49 sites. The
objective of these meetings was to obtain a
cost impact of implementing new policies and
procedures as a result of the NPREC
standards. To provide guidance for the
discussions and data gathering, the Booz
Allen team developed and used a
questionnaire based on the Standards for the
1

Prisons
State
Midwest
Minnesota Department of Corrections
MN
Indiana Department of Corrections
IN
Missouri Department of Corrections
MO
Northeast
New York State Department of Correctional Services
NY
Rhode Island Department of Corrections
RI
Massachusetts Department of Corrections
MA
South
Virginia Department of Corrections
VA
Arkansas Department of Corrections
AR
South Carolina Department of Corrections
SC
West
Washington Department of Corrections
WA
Oregon Department of Corrections
OR
California Department of Corrections and Rehabilitation
CA
Colorado Department of Corrections
CO
Jails
Midwest
Hennepin County Adult Detention Center
MN
Anoka County Jail
MN
Pierce County Jail
WI
Marion County Jail
IN
Jefferson County Jail
MO
Northeast
Albany County Correctional Facility
NY
Essex County Jail
MA
South
Aiken County Detention Center
SC
Peumansend Creek Regional Jail
VA
Norfolk City Jail
VA
Miami Dade County
FL
Alachua Regional Jail
FL
Pulaski County Region Detention Center
AR
West
Sacremento County Jail
CA
Denver County Jail
CO
Pierce County Jail
WA
Juvenile Detention
Midwest
Indiana Division of Youth Services
IN
Missouri Division of Youth Services
MO
Northeast
Massachussetts Department of Youth Services
MA
South
Florida Department of Juvenile Justice
FL
Arkansas Juvenile Assesment
AR
West
Oregon Youth Authority
OR
California Department of Juvenile Justice
CA
Colorado Division of Youth Corrections
CO
Ada County Juvenile Court Services
ID
Idaho Department of Juvenile Corrections
ID
Community Corrections
Midwest
Indiana Office of the Deputy Commissoner of Reentry
IN
Missouri Division of Parole & Probation
MO
Northeast
Massachussetts Office of Comm. Corrections
MA
South
South Carolina DOC- Dept. of Probation, Parole & Pardon Services
SC

Acronym

Arkansas Department of Community Corrections
West
Washington Department of Corrections, Community Corrections

AR

AR DCC

WA

WA CC

MA

Middleton PD

WA
CA
CO

Seattle PD
Rocklin PD
DCPA

Lockups
Northeast
Middleton Police Department
West
Seattle Police Department
Rocklin Police Department
Denver County Pre-arrangement Detention Facility

MN DOC
IN DOC
MO DOC
NY DOC
RI DOC
MA DOC
VA DOC
AR DOC
SC DOC
WA DOC
OR DOC
CA DOC
CO DOC

Hennepin County
Anoka County
WI Pierce County
Marion County
Jefferson County
Albany County
Essex County
Aiken County
Peumansend Creek
Norfolk City
Miami-Dade
Alachua County
Pulaski County
Sacramento County
Denver County
WA Pierce County

IN DYS
MO DYS
MA DYS
FL DJJ
AR JA
OYA
CA DJJ
CO DYC
ACJCS
IDJC

IN DOR
MO PP
MA OCC
SC PPP

Public Law 108-79, 108th Congress. "Prison Rape Elimination Act of 2003." September 4, 2003.

2

The participating state prison systems, community correction jurisdictions, juvenile correction agencies, jail and
lockup facilities are collectively referred to as "sites" throughout the document. Independently, however, they will
retain their respective titles.

Introduction

1

PREA Cost Impact Analysis
Prevention, Detection, Response, and Monitoring of Sexual Abuse by NPREC. The purpose of the
questionnaire, discussed in Appendixes C and D, was to solicit data, tailored to the appropriate sector,
concerning the cost impact for each site and standard.
The primary role of the SMEs was to provide context behind the discussions during the interviews and
background of the operating environments for each of the sites. Each SME brought a considerable
amount of knowledge about PREA (a couple of SMEs having participated in the NPREC standards
development) and many years of employment in the corrections industry or significant academic work in
the corrections field. Balanced with Booz Allen analysts, the study's methodology ensured objectivity
and independence when determining and estimating costs. Every cost for every site went through
rigorous tests and verification. At no time did Booz Allen accept a site's cost estimate as final without
further scrutiny, validation, and at times adjustments. This process often times resulted in prolonged
communications for many weeks after the initial visit.
It is also noted that there was a wide degree of varying interpretations of certain standards despite every
effort to baseline our assumptions for each of the standards during each site visit. To the greatest attempt,
Booz Allen maintained open lines of communications to ensure that each site understood our questions
and we subsequently understood and agreed with their response. Nevertheless, a number of costs were
either subject to wide variations, unobtainable, or fraught with so much uncertainty that an approximation
based on sound principles and logic was difficult to estimate. To resolve this issue, Booz Allen
developed specific standard costs that were used in such instances. Each of these costs is based on the
overall findings and/or reasonable assumptions in the field of corrections.
Booz Allen determined compliance based on a discussion about current practices, policies, and
procedures with the site's themselves. Any claim of compliance was validated and tested by subject
matter experts, policy documentation, or sufficient evidence of said claim. The scope of this project did
not entail audits of their operations or whether they met any yet-to-be defined audit requirements for
PREA. For example, the scope of this project did not include a workforce analysis to determine if
security staff are providing inmate supervision necessary to protect inmates from sexual abuse per
Standard PP3. Such an analysis would require clear auditing requirements, benchmarks, and target
staffing levels for each type of facility that does not exist. Instead, the Booz Allen team relied upon the
qualitative assessment of the individual site's compliance relative to reported sexual abuse incidents.
When feasible, the Booz Allen team would conduct a facility tour and obtain staffing and facility plans;
however, this was not possible during the majority of the site visits because many represent multiple
facility systems throughout their state. For more detailed information about the Methodology,
Questionnaire Development, and the actual questionnaires used in this study, see Appendixes C through
E.
Organization of Document
The results of the study are captured in two sections of the document: 1) Compliance Analysis and 2)
Primary Cost Impacts and their Underlying Causes. The Compliance Analysis section is a discussion
about the compliance of each site, sector, and standard. It highlights the compliance of each of the
standards, the relative compliance rankings of the sites included in this study, and assesses compliance
ranges relative to their cost estimates captured in this study. It provides a quick assessment to determine
which standards are problematic and which are considered relatively easy to implement. The Primary
Cost Impacts and their Underlying Causes section is a presentation of each standard that exhibits a cost,
Introduction

2

PREA Cost Impact Analysis
its impact on each of the sectors, and the reasons for the cost and whether such costs are common or rare
occurrences.
The Background and Scope section provides a brief history of PREA, the development of the standards,
and Booz Allen's role in the review and analysis of the standards. The Methodology section details the
approach of the study and the site selection criteria, followed by the Assumptions section that documents
general assumptions and standard cost calculations used throughout the study.
Appendix A (Underlying Causes of Cost Impacts by Sector) presents the same findings discussed in the
Primary Cost Impacts and their Underlying Causes but with additional detail. It is organized by sector so
that domain/sector experts can easily glean the cost impact in their sector. Appendix B serves as a
reference section for specific site-by-site characteristics and costs. The data therein is the same as
Appendix A and the Primary Cost Impacts and their Underlying Causes section but organized by site with
additional detail on a site's demographics, background, and characteristics.
The standards discussed in this report refer to standards as they are written for the adult jails and prisons
sector in the NPREC standards. However, some variations exist among the juvenile agency, community
corrections and police lockup standards. For purposes of this study, the reader can assume that each of
the adult jails and prisons standards maps to their related standards in juvenile facilities, community
corrections, and police lockups. For example, PP5 in adult jails and prisons maps to PP6 in police
lockups; PP7 maps to PP8; PP-1 to TR2; TR-4 to TR-3; PP6 to PP7; and both SC1 and SC2 to PP4. For
juvenile agencies, SC1 in adult jails and prisons maps to AP1 and SC2 maps to AP2. Likewise for
community corrections, MM3 in adult jails and prisons maps to MM2 in community corrections. One
standard, PP7, is not in community corrections however, so that standard does not apply to them.

Introduction

3

PREA Cost Impact Analysis

Compliance Analysis
Booz Allen began this study with
the hypothesis that a site's
compliance rating (i.e., how
compliant a site is with the
collective standards) would be a
measure of its cost impact. For
example, a site with a relatively
low compliance rating would have
higher costs than a site with a
relatively higher rating.
This
section explores this theory by
diving into the compliance rates of
each site and the compliance of
each standard (i.e., how many sites
are compliant with each standard).
The analysis indicates some
general trends and correlations
between a site's compliance and its
costs but numerous anomalies
suggest that the theory is
inconclusive.
Compliance by Standard

Table 2: Percent of Sites Compliance with Each Standard

Stand.
DI1
IN3
RE1
MM2
DC4
OR4
ID6
PP5
RP3
RP4
IN2
DC2
OR2
OR3

Description
Disciplinary sanctions for staff
Evidence standard for administrative investigations
Inmate reporting
Access to emergency medical and mental health services
Data storage, publication, and destruction
Coordinated response
Supplement to SC-2
Accommodating inmate with special needs
Agreements with outside law enforcement agencies
Agreements with the prosecuting authority
Criminal and administrative agency investigations
Data Collection
Reporting to other confinement facilities
Staff first responder duties

Contracting with other entities for the confinement of inmates
Data review for corrective action
Inmate supervision
Staff and facility head reporting duties
Ongoing med & mental health care for sex abuse victims and
MM3 abusers
RE4 Third-party reporting
DI2 Disciplinary sanctions for inmates
RP1 Evidence protocol and forensic medical exams
SC2 Use of screening information
Medical and Mental Health Screenings - history of sexual
MM1
abuse
OR5 Agency protection against retaliation
RE2 Exhaustion of administrative remedies
DC1 Sexual abuse incident reviews
TR5 Specialized training: Medical and mental health care
SC1 Screening for risk of victimization and abusiveness
TR2 Volunteer and contractor training
TR4 Specialized training: Investigations
IN1 Duty to investigate
PP4 Limits to cross-gender viewing and searches
TR1 Employee training
RE3 Inmate access to outside confidential support services
PP7 Assessment and use of monitoring technology
TR3 Inmate education
Agreements with outside public entities and comm. ser.
RP2 Providers
PP6 Hiring and promotion decisions
PP1 Zero tolerance of sexual abuse
AU1 Audits of standards
PP2
DC3
PP3
OR1

%
Comp.
98%
96%
96%
96%
94%
93%
90%
88%
88%
88%
88%
80%
76%
76%
73%
73%
73%
73%
72%
71%
71%
69%
69%
63%
62%
59%
59%
47%
45%
43%
41%
41%
39%
37%
36%
35%
33%

From
a
standard-by-standard
perspective, there are some in
which 100% of the sites included
in this study are compliant and
others in which no sites are
compliant. Several standards have
requirements that are common or
best practice in most correctional
facilities today and thus have high
compliance rates. Other standards
27%
require policy changes, the
20%
adoption of new policies altogether
8%
and/or the enhancement of existing
0%
practices.
These standards
generally have moderate to low compliance rates. Some standards (such as the PREA Coordinator and
PREA audits) are specific to the adoption of PREA and have very low compliance rates.

Compliance Analysis

4

PREA Cost Impact Analysis
The compliance rates for each standard, as shown in Table 2, vary from 0% to 98%. A majority of the
standards, 27 in total, have compliance rates between 41% and 88%. Nine of the 41 standards have
compliance rates under 40%. Two standards, the PREA audit (AU1) and the PREA Coordinator (PP1),
Table 3: Site by Site Overall Compliance
would not be expected to have any compliance since the
Percent
standards have not been promulgated yet, although four Site
Sector
Compliance
sites do have staff assigned to PREA Coordinator duties. MA DYS
Juvenile
88%
Training and education also have low compliance rates MA DOC
Prison
85%
Juvenile
85%
and relatively high costs. The training and education AR JA
Denver County
Jail
84%
standards, TR1 - TR5, all have compliance rates below Seattle PD
82%
Lockups
OR
DOC
Prison
80%
48%. Most sites provide some form of training and
MO DYS
Juvenile
78%
education; however many will be required to enhance their CA DOC
Prison
76%
Community Corrections
74%
programs to include PREA specific issues. Other sites will MA OCC
Peumansend Creek
Jail
73%
be required to expand the training to cover all employees, DCPA
Lockups
73%
Rocklin PD
Lockups
73%
contractors, and volunteers.
Six of the 41 standards have compliance rates of 90% or
above. As mentioned above, several of the standards
include requirements that were found to be common
practice in most of the sites visited and thus have very
high compliance rates. These include subjecting staff to
disciplinary sanctions when Violating Agency Sexual
Abuse Policy (DI1), Substantiating Sexual Abuse
Allegations if Supported by a Preponderance of the
Evidence (IN3), Ensuring that Offenders Have Multiple
Internal ways to Report Sexual Abuse (RE1), Providing
Access to Emergency Medical and Mental Health Services
(MM2), Securely Storing Sexual Abuse Data (DC4), and
Coordinating a Response to Sexual Abuse Allegations
(OR4). No costs are associated with any of the above six
standards.
Compliance by Site

MN DOC

Prison

Essex County

Jail

AR DOC

Prison

RI DOC

Prison

Ada Juv

Juvenile

CA DJJ

Juvenile

IN DOC

Prison

WI Pierce County

Jail

AR DCC

Community Corrections

Miami-Dade

Jail

SC PPP

Community Corrections

CO DYC

Juvenile

IN DYS

Juvenile

OYA

Juvenile

Middleton PD

Lockups

Albany County

Jail

Norfolk City

Jail

MO PP

Community Corrections

Aiken County

Jail

Marion County

Jail

Sacramento County

Jail

Hennepin County

Jail

WA Pierce County

Jail

NY DOC

Prison

VA DOC

Prison

Pulaski County

Jail

Jefferson County

71%
70%
68%
68%
68%
68%
66%
66%
66%
63%
63%
63%
63%
63%
63%
61%
61%
61%
59%
59%
56%
56%
56%
54%
54%
54%
53%
51%
49%
49%
49%
49%
48%
47%
41%
40%
38%

Jail
Although NPREC standards have yet to be formally WA DOC
Prison
promulgated, every site included in this study has already MO DOC
Prison
SC DOC
Prison
exhibited policies and procedures to meet compliance,
Alachua County
Jail
several demonstrating compliance with more than 80% of Anoka County
Jail
Community Corrections
the standards. Many of these sites began implementing IN DOR
WA CC
Community Corrections
changes soon after PREA legislation was signed in 2003 CO DOC
Prison
Juvenile
and subsequently have been aided in their effort with FL DJJ
IDJC
Juvenile
PREA grant funding to cover implementation of new
training or screening procedures. A few sites even have a salaried PREA Coordinator on staff. Despite
some of the PREA policies in place however, several other sites are compliant with less than 50% of the
standards.

Compliance Analysis

5

PREA Cost Impact Analysis
As shown in Table 3, compliance among individual sites varies greatly, ranging from a high of 88% to a
low of 38%. The median compliance among all sites is 63%. Collectively, lockups have the highest
compliance rate, at 74%, while jails have the lowest rate at 61% illustrated in Table 4. The higher
compliance rates among lockups may be a reflection of the fewer number of standards, their relative small
size, and the low number of samples in this study (4). The other four sectors in this study all have
relatively close compliance rates; between 67% and 61%.
MA DOC and OR DOC have the highest compliance rate among prisons, 85% and 80%, respectively.
Among jails, the highest compliance rates are for Denver County and Peumansend Creek, 88% and 73%,
respectively. MA DYS and AR JA have the highest compliance rates in the juvenile sector, 88% and
85%, respectively. MA OCC and the Seattle PD have the highest compliance rate for community
corrections and lockups, 74% and 82%, respectively.
Table 4: Compliance by Sector

In regard to compliance by region of the country, the data shows
that in general jurisdictions in the Northeast and West tend to
Average
Sector
have higher compliance rates, but here too, there is only a loose
Compliance
correlation with several exceptions. Among the 10 jurisdictions
Lockups
74%
Juvenile
65% with the highest compliance rates, 7 are located in the Northeast
Prisons
62% or West, while among the jurisdictions with the 10 lowest
Community Corrections
61% compliance rates; 6 are located in the Midwest or South.
Jails
60% Exceptions include AR JA, MO DYS, and Peumansend Creek
(located in the South and Midwest), which have relatively high compliance rates and WA DOC, WA CC,
CO DOC, and IDJC (located in the West), which have low compliance rates. Among individual states,
Massachusetts fares best in regards to the number of sites with high compliance rates; three of the four
Massachusetts sites in this study have compliance rates that fall within the top 10.
Compliance in Relation to Costs
This section shows the relation between compliance levels and the cost impact for each sector. They
categorize a sector's compliance level into bands and show the cost impact for each site within its
respective band (e.g., 40% - 49% compliant). It is a means to validate the hypothesis whereby sites with
lower compliance levels face generally higher costs to meet the PREA standards.
This study found that a loose correlation exists between compliance levels and costs, however it is
inconclusive as there are a few anomalies and caveats. Generally, as the rate of compliance declines,
costs increase. In other words, a site that is not compliant with many standards will exhibit a greater cost
impact as opposed to a site that is compliant with relatively more standards. The primary caveat is that it
depends on which specific standards a site is compliant. For example, a site that is not compliant with
Assessment and Use of Monitoring Technology (PP7) will usually exhibit higher costs because of the
investment required for technical modernization and retrofits. Thus a site could theoretically be
compliant with 99% of the standards except PP7 yet still exhibit a significant cost impact. Technical
Supervision (PP7), with a compliance rate of 35%, has the greatest upfront cost among all standards
(collectively across all sites). The upfront cost is primarily associated with purchasing and installing
cameras and other video technology. Prisons accounted for the vast majority of the technical supervision
costs, followed by juvenile facilities and jails. Another standard with a low compliance rate that carries
major costs is the Limits to Cross-Gender Viewing and Searches (PP4). This is because most prisons do
Compliance Analysis

6

PREA Cost Impact Analysis
not currently prohibit cross-gender pat downs. The costs associated with this standard are primarily
related to hiring more male staff to more closely match the higher proportion of incarcerated men, without
compromising security.
The same can be said for jurisdictions that are not compliant with inmate supervision (PP3) and Limits to
Cross-Gender Viewing and Searches (PP4) both of which are driven by the cost of labor. This is due to
the high unit cost of the standard, driven by personnel salaries, ranging from $35,000 - $70,000 per
person per year for those sites that do not believe they have an adequate number of staff to prevent sexual
abuse. Large jurisdictions with many facilities that are under-staffed may require a significant number of
additional full time equivalents (FTEs) to reach an adequate level, leading to a substantial increase in
yearly costs.
Prisons
Among prisons costs are generally higher for the jurisdictions that have lower to moderate compliance
rates. Falling in the 50% to 59% compliance range, NY DOC is estimated to have the highest upfront
costs, while the MO DOC, in the lowest compliance range, is estimated to have the highest ongoing cost.
The large upfront costs for NY DOC are primarily associated with Assessment and Use of Monitoring
Technology (PP7), consisting of the purchase and installation of video surveillance equipment. The large
ongoing costs for MO DOC are primarily associated with Inmate Supervision (PP3) and Limits to CrossGender Viewing and Searches (PP4), where costs consist of salaries for additional personnel. As noted
earlier, PP7, PP3, and PP4 have the highest costs for prisons, among all the NPREC standards; indicating
that the level of costs may be more strongly associated with the standards in which the jurisdictions are
compliant with rather than the overall compliance rate.
The prison systems with the highest compliance rates generally have lower costs, except for IN DOC and
CA DOC, which have relatively high upfront costs and ongoing costs, respectively. Falling in the 60% to
69% compliance range, the IN DOC has the third highest upfront cost, among all prison systems in the
study while the CA DOC, falling in the 70% to 85% compliance range, has the third highest ongoing cost.
Similar to NY DOC and MO DOC, the large upfront costs for IN DOC are entirely associated with PP7
and PP4 while the large ongoing costs for CA DOC are primarily associated with Limits to Cross-Gender
Viewing and Searches (PP4).
Table 5: Prisons – Compliance Level and Cumulative Cost ($K)

40% - 49% Compliant
Upfront
Ongoing

CO DOC MO DOC SC DOC
$3,505
$3,227 $4,273
$2,879 $63,867 $3,322

60% - 69% Compliant
Upfront
Ongoing

IN DOC AR DOC RI DOC
$20,055
$286
$803
$5,365 $12,520
$265

50% - 59% Compliant
Upfront
Ongoing

WA DOC NY DOC VA DOC
$3,206 $627,096 $30,998
$12,256 $37,411 $16,246
70% - 85% Compliant

MN DOC CA DOC MA DOC OR DOC
Upfront
$11 $8,761
$4,278
$258
Ongoing
$433 $30,428
$710
$774

Jails
Among jails costs generally do not correlate closely with level of compliance. Miami-Dade, falling in the
60% to 69% compliance range is estimated to have the highest upfront and ongoing costs. But there are
Compliance Analysis

7

PREA Cost Impact Analysis
some similarities with prisons. Miami-Dade's very large upfront costs are almost entirely associated with
PP7, consisting of the purchase and installation of video surveillance equipment. The modestly large
upfront costs for Pulaski County are primarily associated with Limits to Cross-Gender Viewing and
Searches (PP4), where costs consist of a severance payout after laying off female staff. Sacramento
County has a relatively low compliance rate and also among the highest costs. Sacramento County's
upfront cost is primarily associated with PP7 and Specialized Training (TR4 and TR5), and its ongoing
costs result primarily from Inmate Supervision (PP3).
The jails with the highest compliance rates, ranging from 70% to 88%, do generally have low costs,
except for Peumansend Creek’s upfront cost, which is relatively high. This again is associated with the
Assessment and Use of Monitoring Technology (PP7) and Limits to Cross-Gender Viewing and Searches
(PP4).
Table 6: Jails – Compliance Level and Cumulative Cost ($K)

Aiken
County
Upfront
Ongoing

$507
$29

Alachua Anoka
County County
$205
$797

49% - 59% Compliant
Hennepin Jefferson Marion Pulaski Sacramento WA Pierce
County
County County County County
County

$52
$312

$148
$118

$175
$598

$130 $1,874
$124
$124

60% - 69% Compliant
Albany Miami- Norfolk WI Pierce
County Dade
City
County
Upfront
Ongoing

$20 $25,144
$1,057 $7,281

$20
$124

$433
$433

$1,047
$5,972

$101
$309

70% - 88% Compliant
Denver Essex
Peumansend
County County Creek
Upfront
Ongoing

$134
$1

$13
$101

$642
$58

Juvenile
Among juvenile corrections agencies a stronger correlation exists between compliance and costs, where
costs are generally higher for the jurisdictions that have lower compliance rates; however, much of this is
still attributed to the specific standards with which the jurisdictions are noncompliant. The FL DJJ, which
has the second lowest compliance rate among all jurisdictions in this study, has the highest upfront cost
and second highest ongoing cost among the juvenile sites. The FL DJJ’s upfront costs are almost entirely
associated with the Assessment and Use of Monitoring Technology (PP7) while its ongoing costs are
mostly related to employee training (TR1). Because FL DJJ is a large jurisdiction and much of its staff
does not currently receive training specific to PREA issues; roughly 4,800 staff will require additional
training.
The CO DYC and the IN DYS, both with roughly average compliance rates, also have relatively high
costs. CO DYC has the second highest upfront cost, while IN DYS has the highest ongoing cost. The
CO DYC’s upfront costs are almost entirely associated with the Assessment and Use of Monitoring
Technology (PP7); while IN DYS’s ongoing costs are largely associated with Inmate Supervision (PP3).
Juvenile corrections agencies with the highest compliance rates generally have the lowest costs relative to
the other sectors. The AR JA, MA DYS, and MO DYS all have compliance rates in the top 10 of all 49
jurisdictions, and have generally low costs. These costs are primarily associated with the Assessment and
Use of Monitoring Technology (PP7), Training (TR1 - TR5), and Audits of Standards (AU1). It should
not be a surprise that Training and Audits of Standards are within this list because they typically have
lower costs relative to other standards. However, with Monitoring Technology in the list, it is noteworthy
Compliance Analysis

8

PREA Cost Impact Analysis
that it does not result in higher costs since this is one of the biggest cost drivers of all the standards. With
such a low cost, it suggests that juvenile agencies with high compliance rates do not require major
investments in surveillance technology (among to juvenile agencies in this study).
Table 7: Juvenile – Compliance Level and Cumulative Cost ($K)

38% - 48% Compliant
IDJC
FL DJJ
Upfront
$38,066
$353
Ongoing
$4,165
$1,266
64% - 77% Compliant
ACJCS
CA DJJ
Upfront
$3
$1,193
Ongoing
$115
$3,041

Upfront
Ongoing

Upfront
Ongoing

49% - 63% Compliant
CO DYC IN DYS
$17,781
$2,607
$3,383
$4,965

OYA
$4,138
$473

78% - 88% Compliant
AR JA
MA DYS MO DYS
$7
$933
$310
$85
$574
$310

Community Corrections
Among community corrections jurisdictions costs also do not generally correlate closely with level of
compliance. IN DOR has the lowest compliance rates in the study but also has relatively low costs. IN
DOR is compliant with many standards associated with the highest costs such as Inmate Supervision
(PP3) and Limits to Cross-Gender Viewing and Searches (PP4). Note that the standard for the
Assessment and Use of Monitoring Technology (PP7), a major cost driver for many jurisdictions in other
sectors, does not apply to community corrections.
The AR CC and MO PP, both falling in the 59% to 69% compliance range, have the highest ongoing
costs in community corrections; the costs for both jurisdictions are primarily associated with Limits to
Cross-Gender Viewing and Searches (PP4). The WA CC, in the lowest compliance range, has the highest
upfront costs. Unlike many other jurisdictions the upfront costs for WA CC are not concentrated in any
one standard rather, they are spread across numerous standards, including Employee Training (TR1),
Specialized Training (TR4 and TR5), Screening (SC1 and SC2), and Gathering, Reviewing and Reporting
Data Standards (DC1 - DC3).
Table 8: Community Corrections – Compliance Level and Cumulative Cost ($K)

48% - 58% Compliant
IN DOR
WA CC
Upfront
$33
$184
Ongoing
$50
$1,267

Upfront
Ongoing

59% - 69% Compliant
AR DOC
MO PP
SC PPP
$49
$47
$53
$1,997
$1,757
$88

70% - 75% Compliant
MA OCC
Upfront
$129
Ongoing
$315

Lockups
Among the four lockups in this study, costs do not correlate at all with the compliance level most likely
because there is simply a smaller sample. In fact, the lockup with the highest level of compliance, Seattle
PD, also has the highest costs. Seattle PD’s major cost is for Accommodating Inmates with Special
Needs (PP5)3. Standard PP5 is unique in that it is only a major cost factor for lockups. In addition to the
Seattle PD, the Rocklin PD and the DCPA also have relatively high costs associated with PP5. This is
unique to the lockup sector because only three other jurisdictions across all other sectors are not
compliant with this standard; the overall compliance rate for the standard is 88%. The Seattle PD has by
3

PP5 maps to PP4 in the standards for lockups

Compliance Analysis

9

PREA Cost Impact Analysis
far the largest cost associated with PP5 among all lockup facilities in this study. As a whole, 99.7% of all
ongoing costs associated with standard PP5 are in the lockups sector while 92% of the upfront costs for
PP5 are also in lockups.
Table 9: Lockups – Compliance Level and Cumulative Cost ($K)

60% - 69% Compliant
Middleton PD
Upfront
$5
Ongoing
$81

Compliance Analysis

70% - 79% Compliant
DCPA Rocklin PD
Upfront
$65
$19
Ongoing
$77
$802

80% - 89% Compliant
Seattle PD
Upfront
$28
Ongoing
$3,051

10

PREA Cost Impact Analysis

Primary Cost Impacts and their Underlying Causes
This section discusses the standards exhibiting
a notable cost impact based on the 49 sites
included in this study. This discussion covers
29 standards listed according to magnitude of
the ongoing cost impact from highest to lowest.
Although there are clearly some relatively
significant upfront costs that overshadow the
ongoing costs (e.g., PP7), prioritizing the
standards by ongoing costs emphasizes the
long-term cost impact as a result of the
standards and the belief that significant
adjustments to annual base funding allocations
are more difficult to secure than one-off
investments, particularly in today's economy
where state and local budgets are under
increased scrutiny. Table 10 shows the 29
standards with notable costs sorted from
highest-to-lowest ongoing costs. These are total
costs across all sectors and do not take into
account unique sector characteristics and
resulting cost impacts that this narrative will
address. The following pages only address the
standards that have a notable cost impact.

Table 10: Standards with Notable Costs and the % of Total Costs

Standard
PP4
PP3
PP7

Limits to cross-gender viewing and searches
Inmate supervision
Assessment and use of monitoring technology
Ongoing medical and mental health care for sexual
MM3 abuse victims and abusers
Contracting with other entities for the confinement of
PP2
inmates
AU1 Audits of standards
TR1 Employee training
PP1
Zero tolerance of sexual abuse
Agreements with outside public entities and
RP2
community service providers
SC2
Use of screening information
RP1
Evidence protocol and forensic medical exams
IN1
Duty to investigate
ID6
Supplement to SC-2
Screening for risk of victimization and abusiveness
SC1
PP6
Hiring and promotion decisions
Agreements with outside law enforcement agencies
RP3
RP4
Agreements with the prosecuting authority
DC3 Data review for corrective action
TR3 Inmate education
Specialized training: Medical and mental health care
TR5
TR2 Volunteer and contractor training
DC1 Sexual abuse incident reviews
RE2 Exhaustion of administrative remedies
Evidence standard for administrative investigations
IN3
DC2 Data Collection
PP5
Accommodating inmate with special needs
TR4 Specialized training: Investigations
OR5 Agency protection against retaliation
Inmate access to outside confidential support services
RE3

Total Costs ($K)
Upfront On-Going
$21,293
$89,974
$1,665
$88,848
$770,634
$20,354
$12

$5,773

$0
$0
$4,484
$48

$5,695
$5,167
$4,375
$3,768

$33
$170
$25
$18
$9

$1,611
$1,605
$1,396
$1,264
$746

$530
$4

$677
$284

$21
$21
$352
$458

$258
$250
$176
$161

$1,462
$572
$2
$6

$153
$142
$126
$105

$1
$17
$2
$316
$500

$79
$72
$47
$15
$0

Table 10 also shows the standard's relative
$98
$0
proportion of total costs. This is calculated by
dividing the total costs for each standard divided by the grand total (separately for ongoing and upfront).
This pinpoints very quickly which standards are the largest cost drivers, highlighting three in particular
(PP4, PP3, and PP7). These three standards account for 99% of all upfront costs and PP7 accounts for
96% of all upfront costs. This is attributed primarily to undefined and misinterpreted requirements based
on the current language of the standard. Two standards (PP3 and PP4) account for 76% of all ongoing
costs, solely driven by increased staffing required to meet the intent of the standards as they are written.
Another means to determine the relative cost impact and its magnitude is to compare a site's overall cost
impact to its annual operating budget. This can provide a measure of the relative impact on a site's daily
operations and whether it can or cannot absorb the additional costs as a result of PREA. Tables 11 and 12
(one for annual, ongoing costs; another for one-time, upfront costs) depict the cost impacts by standard
across each of the five sectors. The Harvey Balls™ represent an order of magnitude distinguishing
between relatively low and high costs. They are based on a percentage of the annual aggregate operating
budget for each sector. Standards that do not result in any cost impact for any sector are not depicted in
the tables. The degree to which each Harvey Ball is shaded indicates the magnitude of the cost impact, or

Cost Impacts and Their Underlying Causes

11

PREA Cost Impact Analysis
percentage of the overall operating budget. An empty ball
any cost impact. A quarter-shaded ball

1

ball

represents standards that do not result in

represents an overall impact on annual operating budget

between 0% and 0.25%, while a half-shaded ball
fully-shaded

E

2

represents an impact between 0.25% and 0.50%. A

4

Limits to cross-gender
viewing and searches

s
Loc
kup

Com
m
Cor .
r.

n ile
Juv
e

Jail
s

ns
Pris
o

Prio
r

ity

Table 11: Ongoing Cost Impacts as % of Annual Operating Budget

represents
any
percent
impact on annual operating
budget that is greater than
0.50%. For example, Inmate
Supervision for prisons is
represented by a fully-shaded
Harvey Ball. The aggregate
costs for this standard is
0.51% of the aggregated
sites' operating budget. In
Table 11, the same fullyshaded symbol for prison has
an upfront percent impact of
4.83%
on
prisons’
Assessment and Use of
Monitoring
Technology
(PP7). The primary reason
for the significantly higher
percentage is attributed to the
investment required for
technical modernization and
retrofits. Thus a site could
theoretically be compliant
with 99% of the standards
with the exception of PP7 but
would still exhibit a large
cost impact.

4

1

1

4

4

4

4

r

1

0

1

1

1

n/a

0

1

1

1

0

n/a

5 Audits of standards

1

1

1

1

1

6 Training and education

1

1

r

1

1

1

1

1

1

0

1

1

0

1

1

1

1

1

1

1

1

1

1

0

1

1

0

1

1

0

1

1

1

1

0

1

1

1

0

0

0

1

n/a

n/a

n/a

1

1

1

1

1

1

1

1

1

0

1

1

0

0

0

1

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

Contracting with other entities
7 for the confinement of
inmates
Accomodating inmates with
8
special needs
Zero tolerance of sexual
9
abuse
Screening for risk of sexual
10
abuse
Contract modifications for
11
outside services
Evidence protocol and
12
forensic medical exams
13 Investigations
14
15
16

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

As shown in these tables, 17
only three standards have 18
0
0
0
0
0
fully filled Harvey Balls, the
same referenced earlier (PP4, PP3, and PP7). These are considered the most problematic in terms of both
compliance and cost impact.

Cost Impacts and Their Underlying Causes

12

PREA Cost Impact Analysis

Limits to cross-gender
viewing and searches

s
kup
Loc

Com
m
Cor .
r.

n ile
Juv
e

Jail
s

ons
Pris

Prio
r

ity

Table 12: Upfront Cost Impacts as % of Annual Operating Budget

1

r

1

1

1

1

1

1

1

0

4

4

4

n/a

0

0

1

0

0

n/a

5 Audits of standards

0

0

0

0

0

6 Training and education

1

1

1

1

1

0

0

0

0

0

0

0

0

1

0

1

1

1

1

1

1

1

1

1

0

1

1

1

1

0

1

1

1

0

0

1

1

1

0

0

Supplement to SC-2: Use
of screening information

0

1

n/a

n/a

n/a

Hiring and promotion
decisions
Gathering, reviewing, and
16
reporting data
Exhaustion of
17
administrative remedies
Agency protection against
18
retaliation

1

1

0

0

0

1

1

1

1

1

1

1

1

0

0

1

0

0

0

0

1

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and
4
mental health care
3

Contracting with other
7 entities for the confinement
of inmates
Accomodating inmates
8
with special needs
Zero tolerance of sexual
9
abuse
Screening for risk of sexual
10
abuse
Contract modifications for
11
outside services
Evidence protocol and
12
forensic medical exams
13 Investigations
14
15

With a few exceptions, this
section addresses each standard
with an ongoing cost percentage
greater than zero, presented in
order of the greatest cost impact
to the least. The exceptions
include the Training Standards
(TR1 through TR5); the
Screening Standards (SC1 and
SC2); Gathering, Reviewing and
Reporting Data Standards (DC1
through DC3), Investigations
(IN1 and IN3) and Contract
Modifications
for
Outside
Services (RP2 though RP3 and
RE3). Each is bundled together
because Booz Allen believes that
each is either dependent on the
other (e.g., data reviewing or
screening standards) or is tied
logically to the other based on its
similarities in breadth and scope
(e.g., training, investigations,
and the contract modification
standards). As such, the cost
impact for these standards is first
presented as an aggregate cost
followed by specific standard
detail in the narrative.

Each standard or cost impact is first described in context of our overall findings, regardless of sector.
However, because of the relatively significant variations between the sectors, this is followed by a brief
summary of the cost impact on each of the five sectors. Finally, all costs are presented in thousands of
dollars.

Cost Impacts and Their Underlying Causes

13

PREA Cost Impact Analysis
Cost Impact #1 – Limits to Cross-Gender Viewing and Searches (PP4)
Limits to Cross-Gender Viewing and Searches (PP4) exhibits one of the lowest compliance measures
(39% overall) combined with one of the highest cost impacts, accounting for 38% of the total ongoing
cost impact across all sites in the study. The following chart underscores the magnitude of this standard,
which affects every sector but most prominently, from an ongoing cost impact perspective, prisons,
community corrections, and lockups.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$14,985
$ 1,762
$
85
$
48
$
24

Low
$
48
$
2
$
85
$
34
$
6

Yearly Range
High
$33,920
$ 384
$ 680
$ 1,849
$ 3,043

Percent
Low Compliant
$ 2,573
8%
$
38
38%
$ 680
70%
$ 1,656
67%
$ 698
25%

The underlying cause of this impact is attributed solely to the prohibition of cross-gender pat down
searches within the standard.
The NPREC standard PP4 states, “Except in the case of emergency or other extraordinary or
unforeseen circumstances, the facility… restricts cross-gender pat down searches.”
Every sector expressed a significant amount of consternation about this standard highlighting numerous
obstacles mostly around major workforce realignments given the current male/female staffing ratios
relative to inmate male/female ratios. Specifically, every sector has relatively more female correctional
officers than female inmates, resulting in females frequently conducting pat downs on male inmates as
part of normal operating procedures.
Cross-gender pat down searches are a common practice for all sectors but juvenile corrections agencies.
For most it is institutionalized in policies and procedures and has been practiced for many years with a
fundamental belief that frequent and surprise pat downs are a critical component to ensuring a safe
environment. Specific pat down procedures differ from site-to-site. Sites appreciate the control they have
to manage pat down procedures without gender constraints. Some have pat downs at certain posts while
others use pat downs randomly so as avoid establishing any patterns for the offender to exploit. Few sites
consider pat downs during hiring decisions with the majority being gender agnostic. There was a
common sentiment that pat downs were equally effective by either gender and potentially equally abused
by either gender.
Some sites (19 of the 49) are selective regarding their cross-gender pat downs having policies that are
nearly compliant such as prohibiting pat downs of female offenders by male officers while not restricting
female officers from cross-gender pat downs. Similarly, some prison systems prevented male officers
from working in all-female facilities, effectively prohibiting cross-gender pat downs. These few sites
employ bona fide occupational qualifications (BFOQ) based on gender when making their decisions
regarding the hiring and retention of employees. It was only seen at sites that have not been legally
challenged on the merits of equal employment or Federal statutes, specifically at sites that did not have
union representation or past litigation. This unique hiring practice results in a workforce where the
gender balance is much more in line with the U.S. workforce than is the inmate population.

Cost Impacts and Their Underlying Causes

14

PREA Cost Impact Analysis
Pat downs do not appear to be as common at juvenile corrections agencies. Given a higher offender-toofficer ratio, it is more likely that an officer of the same gender would be available to conduct pat downs.
Two additional economic or environmental drivers support such practices: 1) labor market factors that
supply proportionally more female correctional officers than female inmates compounded by the
disproportionate scale of available resources for large facilities in relatively remote locations and 2) local
or state laws that mandate equal opportunity employment, which create a barrier to removing crossgender pat down searches.
Prisons
The NY DOC reported the need to hire female correction officers to eliminate cross-gender pat downs at
female facilities, estimated at a cost of $33.9 million for 620 female corrections officers at their five
female facilities. Likewise, the MO DOC would accrue a cost of over $18.3 million in annual costs and
$362,000 upfront to hire 381 additional male staff. This level of support would provide three additional
posts per institution and supervision to provide on-call same gender pat search capability. Similarly, the
VA DOC estimated 50 additional male staff resulting in a $2.6 million annual salary cost impact. Some
systems on the other hand, would have to reduce their staff to balance their gender ratio. The IN DOC for
example, reported the need to reduce their female staff by 639 officers (replacing them with male staff),
none of which could be absorbed in other custody positions resulting in a one-time, upfront severance
payout of $15 million. Likewise, MA DOC anticipates having to replace 69 female staff with male staff
resulting in approximately $2 million in severance pay. CO DOC, on the other hand, believes female
officers could be absorbed by a female only facility, but would cost $650,000 in moving expenses.
Sites

Upfront Yearly

NY DOC

$

589

$33,920

CA DOC

$

479

$26,313

MO DOC
VA DOC
IN DOC
MA DOC

$ 362
$
48
$14,985
$ 1,974

$18,254
$ 2,573

CO DOC

$

650

Notes
Increase number of CO staffing at female facilities by
50%.
500 additional female FTEs would be required to
supervise women's facilities.
Male staff will need to be hired to supplement current
staff.
50 additional male FTEs (BFOQs) are required.
Severance pay for 639 female officers.
Severance pay for 69 female officers.
Moving expenses associated with transferring male and
female posts.

RI DOC was the only state system that reported full compliance with this standard. This anomaly
attributed to a low percentage of female officers (13%), a relatively small system, and a culture that does
not face any Federal, State, or union challenges when it comes to equal employment hiring practices.
These legal challenges were frequently brought up by most of the sites asserting that Federal and equal
employment statues would prevent them from complying with PREA, particularly if it resulted in any
gender-based hiring decision. Many of them (AR DOC, CA DOC, MN DOC, OR DOC, SC DOC, and
WA DOC,) have already faced considerable legal challenges and made an attempt to include these costs
in this study. AR DOC for example, expressed a need to fully double its current staff of 3,247 officers to
avoid violating state and local statutes. Booz Allen on the other hand did not include this cost as it is
deemed speculative and distracts from the primary reason for their noncompliance which is Federal and
state statutes.

Cost Impacts and Their Underlying Causes

15

PREA Cost Impact Analysis
Jails
Of the 16 jails, 10 reported noncompliance, of which 6 reported cost impacts ranging from $2,000 to $1.8
million for upfront costs and $38,000 to $384,000 for ongoing costs as shown in the table below. The
majority of jails in this study have proportionately more female correctional officers than female inmates.
This results in females frequently conducting pat downs on male inmates as part of normal operating
procedures, often times out of necessity. Of the 10 noncompliant facilities the average percentage of
female officers is 32% and the average percentage of female inmates is 16%.
Sites
WI Pierce County
Albany County
Anoka County

Upfront
$
5
$
5
$
5

Peumansend Creek
Pulaski County
Sacramento County

$ 233
$ 1,762
$
2

Notes
Yearly
$ 384 5 additional FTEs to create one full-time post.
$ 309 5 additional female FTEs.
$ 259 5 additional FTEs to create one full-time post.
Severance pay for 13 female officers, and salary matching
$
38 for new hires.
Severance pay for 82.5 female FTEs.
Fees associated with a policy change.

To meet this standard, demonstrating a few examples, WI Pierce County anticipated a need to add one
additional post (24/7) with five additional FTEs at a total annual cost of $384,000. Albany County
expressed a concern that the labor market is not producing enough female candidates, stemming from a
NY State Agility Test applied equally to all male and female officers. As a result, fewer women can pass
the test, resulting in a unique case where they do not have enough female officers to be available to
conduct female pat downs. In order to comply, Albany County will need to institute a more concerted
and aggressive recruitment of five additional female officers (those able to pass the agility test) resulting
in an annual cost impact of $309,000. Due to facility constraints, Anoka County would need to install a
24 hour male deputy rover position (5 FTEs) with an estimated annual cost impact of $259,000 per year.
Peumansend Creek would need an increase of 13 male officers and an equal decrease in female officers
resulting in an estimated $233,000 in severance costs along with an 8% wage premium to attract qualified
male applicants resulting in an ongoing cost impact of $38,000. To balance its ratio, Pulaski County
would need to replace 85 female FTEs, resulting in a one-time severance payout of $1.7 million.
Juvenile
Compliance with this NPREC standard is substantially easier for juvenile facilities for two reasons; (1)
juvenile facilities have a higher staff to resident ratio allowing for increased supervision; (2) most juvenile
facilities have policies that prohibit cross-gender pat downs. Of the ten juvenile sites in this report, three
reported noncompliance with only the CA DJJ reporting a cost as represented in the table below.
Sites
CA DJJ

Notes
Upfront Yearly
$
85 $ 680 Annual cost of 4 male FTEs to perform additional patdowns, costs for policy writing and HR support.

The CA DJJ estimated $680,000 for the addition of four male staff to assist with an anticipated 40%
increase in pat downs for male staff.

Cost Impacts and Their Underlying Causes

16

PREA Cost Impact Analysis
Community Corrections
Of the six community correction jurisdictions, four reported noncompliance and only two reported a cost.
The average percentage of male staff is 36% while the average percentage of female inmates is 16%. The
two jurisdictions (AR DCC and MO PP) and their respective costs are presented in the table below.
Sites
AR DCC

Upfront Yearly
Notes
$
48 $ 1,849 50 additional male FTEs and associated operations cost.

MO PP

$

34

$ 1,656 36 additional FTEs and associated operations cost.

The AR DCC has estimated the need to redeploy female staff (moving them from male to female
facilities) and hiring 50 additional male staff (ensuring each post in the male facilities has a male present)
for a net impact on its budget of $1.8 million annually. Furthermore, because the local labor pool in AR
simply does not provide enough qualified male applicants, AR DCC would need to increase its average
salary by 33% to ensure that enough male applicants are available. MO PP would run against federal
regulations making any gender-related workforce adjustment potentially illegal. Therefore, the path of
least resistance is obtaining additional FTE authority to hire more male officers, specifically three per
shift at the CRC and one per shift at the CSC resulting in an annual cost impact of $1.7 million to cover
36 FTEs including salary, expenses, and benefits.
Lockups
As it relates to lockups, prohibition of cross-gender pat downs falls under standard PP5. Similar to other
sectors, the lockups sector expressed great difficulty with prohibiting cross-gender pat downs. The
primary reason for the difficulty is that law enforcement officers not corrections officers manage the
lockups, and the rules and laws of offender treatment in the field differ from offender treatment in a
correctional institution. Law enforcement officers simply do not consider their detention, temporary
holding, and pre-arraignment facilities in the same light as jails and prisons. Their mission is law
enforcement, not incarceration, whereby the temporary custody of an offender is simply a transition from
the point of offense to longer -term incarceration at a county jail. Subsequently, police departments view
this standard as contradictory to existing case law, which upholds the rights of officers to conduct crossgender pat downs in the field with most officers assuming that those rights and procedures apply to the
holding facility as well. Of the four lockup facilities, three were noncompliant with two having a
relatively high cost estimate as a result of this standard. The primary cause of the cost impact is increased
staffing, primarily female officers on call at all hours in the event of a pat search.
Sites
Seattle PD
Rocklin PD

Notes
Upfront Yearly
$
24 $ 3,043 25 additional FTEs to staff 5 lockup facilities 24/7.
$
6 $ 698 5.5 additional FTEs to staff the lockup facility 24/7.

To become compliant with this standard, the Seattle PD would be required to hire a substantial number of
female officers requiring a minimum of 25 FTE female officers at a cost of $3 million per year. Rocklin
PD estimates a need for 5.5 additional female officers to staff the lockup facility 24/7 at an annual cost of
$698,000. This would allow for a female officer to always be on duty with a male officer at the lockup
facility. The DCPA facility allows female officers to conduct cross-gender pat downs on male inmates
but does prohibit male officers from cross-gender pat searches. To meet the PREA standard, DCPA will
need to realign its workforce, redeploying its female officers out of the male facility. Initially this will
result in a shortage of male officers suggesting a cost impact. However, because the Denver County Jail
Cost Impacts and Their Underlying Causes

17

PREA Cost Impact Analysis
and DCPA are merging under one roof, it is Booz Allen's assertion that there are male resources from
Denver County Jail to cover for the open positions in the pre-arraignment facility. This is clearly a
unique case where meeting this standard does not result in a cost impact.

Cost Impact #2 - Inmate Supervision (PP3)
Inmate Supervision (PP3) exhibits a relatively high compliance measure (73% of all the sites are
compliant) yet accounts for 38% of the total ongoing cost impact across every sector in the study. This
suggests that the majority of the sites have policies and procedures in place that they feel are adequate to
minimize sexual abuse. However, for those that do not the cost barrier is rather significant. As shown in
the chart below, the ongoing costs are most prominent for prisons yet still considerably significant for
jails and juvenile and nonexistent for lockups.
Sector
Prisons
Jails
Juvenile
Community Corrections

Upfront Range
High
Low
$ 878 $
91
$ 112 $
10
$
74 $
24
$
16 $
16

Percent
Yearly Range
High
Low Compliant
$44,273 $ 4,940
46%
$ 6,723 $ 393
81%
$ 3,703 $ 1,250
80%
$ 884 $ 884
83%

There are significant variations in costs among the few sites that do require additional supervision. The
variability in costs is due to multiple interpretations regarding the level of staff that is considered adequate
to prevent sexual abuse combined with the characteristics (age and design) of the physical plant. Although
sites may have a desire to increase staff to generally minimize all disruptive behavior, the level that is
adequate to prevent sexual abuse is often subjective with crude industry standards (e.g., staff to offender
ratios) as a measurement to determine the adequate level of staff. These measurements frequently do not
take into account the varying permutations of physical, environmental and operational characteristics.
With this in mind, the underlying cause of the cost impact for Inmate Supervision is the need to hire more
staff as a means of preventing sexual abuse.
The NPREC standard PP3 states, “Security staff provides the inmate supervision necessary to
protect inmates from sexual abuse.”
The supervision of inmates lends itself to a certain level of subjectivity based upon one's definition of
what is considered adequate. The level of staff employed at correctional institutions is often dictated by
state and local budgets conditions. The sites that have inadequate levels of staff generally cited state or
local budget constraints as the primary reason.
In order to report the cost impact consistently across varying types of supervision and population sizes,
sites were encouraged to use the number of sexual abuse incidents confirmed over the past several years
to identify any trends that might signal a problem. Because trends associated with the majority of the
sites studied suggest a flat or declining number of incidents reported and confirmed, there were few
compelling reasons to justify an increase in inmate supervision suggesting that a basis for cost cannot be
determined solely on the number of incidents confirmed.
It is generally understood, and was frequently discussed during the site visits, that increased supervision
will help deter and prevent sexual abuse before it ever happens but it should not be considered to be the
most effective means of deterrence/prevention. For example, contrary to logic, OR DOC believes the
majority of incidents occur when staffing levels are highest. Additionally, many sites expressed an
Cost Impacts and Their Underlying Causes

18

PREA Cost Impact Analysis
interdependence of physical and technical supervision, sometimes relying on one or the other depending
on the culture and environment of the site/system. Nevertheless, increased supervision has a major cost
impact on sites with numerous underlying reasons.
Prisons
Among the prisons where cost is estimated for physical supervision, all feel that they are operating at
staffing levels lower than their target levels. Of the 13 prisons in this study, only four are estimated to
have costs associated with physical supervision. Due to the sheer size of prison systems, costs for inmate
supervision are greatest in this sector. Annual costs ranged from $4.9 million for VA DOC to $44 million
for MO DOC, whereas upfront costs ranged from $91,000 for VA DOC and $878,000 for MO DOC.
Site
MO DOC
AR DOC
WA DOC
VA DOC

Upfront Yearly
Notes
$ 878 $44,273 Increase number of COs by 20% above current level.
$ 285 $11,791 Additional rounds are needed in older facilities. Increase
in salaries to attract additional staff.
$ 157 $10,531 Staffing cost to eliminate self-relieving posts.
$
91 $ 4,940 Increased LOE related to adding a post to 3 dormitory
housing units in 6 dormitory facilities.

Although cost for physical supervision is high, it represents a small portion of the operating budget of the
state prison systems; with the exception of MO DOC, where the cost represents 9% of the operating
budget. MO DOC is estimated to need 924 additional correctional officers placed throughout its 21
facilities, a 20% increase above its current staff level. Among prisons, AR DOC has the second highest
cost among prisons, associated with inmate supervision. AR DOC notes that a few of its older facilities
will require additional staff to cover blind spots, based on the original construct of its facilities,
suggesting that the physical layout of facilities can impact the number of staff required to provide
adequate supervision.
Jails
A majority of the jails in this study considered themselves in compliance with this standard and most
attributed their low levels of incidents of sexual abuse to their supervision models, commonly direct
supervision. As shown in the chart below, only three out of the 16 facilities believed that they needed to
hire additional staff to minimize the incidence of sexual abuse and work towards eliminating it altogether.
The three jails that have a cost impact are Miami-Dade, Sacramento County, and Jefferson County, each
of which has physical supervision as one of the greatest cost impacts on their operations.
Site
Miami-Dade
Sacramento County
Jefferson County

Upfront Yearly
Notes
$ 112 $ 6,723 Increased LOE to adequately provide supervision.
$
17 $ 4,360 Additional 6 FTEs required per shift.
$
10 $ 393 Additional 10-12 FTEs to adequately supervise inmates.

Miami-Dade, the largest jail in this study, is estimated to have $112,000 in upfront costs and $6.7 million
in yearly costs associated with hiring additional correctional officers. Miami-Dade identifies a need to
hire 89 Officers, 21 Corporals, six Sergeants, and two Lieutenants. Sacramento County is estimated to
have $4.4 million in annual costs to increase the number of officers per shift from 38 to 44. Sacramento
County has witnessed numerous staff reductions as a result of a very tight squeeze on state funding, which
has been very common throughout the public sector in California as the state grapples with unprecedented
Cost Impacts and Their Underlying Causes

19

PREA Cost Impact Analysis
budget issues. Over the past couple of years, there have been multiple positions cut and several positions
demoted including an 80% cut back of medical staff. Similarly, Jefferson County has witnessed a 25%
reduction in their staff over the past few years, dropping from 40 officers to 30 officers. Although it has
had only two sexual abuse incidents in the past 2 years, it believes that the risk of abuse has increased and
there is greater potential for abuse than ever before. Jefferson County Jail requires 10 to 12 additional
staff to adequately supervise inmates with a cost impact of $393,000 per year.
Juvenile
Most juvenile corrections agencies in this study reported very few substantiated incidents of sexual abuse.
A few agencies did report increases over the past few years but these are believed to be related to an
increase in awareness and a subsequent increase in reporting. Booz Allen understands that this seemingly
contrary to the BJS Special Report: Sexual Victimization in Juvenile Facilities Reported by Youth, 2008094 finding that an estimated 12% of incarcerated youth experienced some sort of sexual victimization in
the past year. There are some possible explanations for the diverging results. The BJS Study is based on
self - reporting whereas the data that Booz Allen received from sites is based on "reported" incidents,
suggesting that many incidents are simply not reported. Our study represents many fewer sites and is not
considered to be a statistical sampling of incarcerated juveniles. Nevertheless the BJS Special Report
merits further review relevant to the prevalence of sexual abuse at sites not included in this study.
As shown on the following table, only the IN DYS and CO DYC are estimated to have costs for inmate
supervision.
Site
IN DYS
CO DYC

Upfront Yearly
Notes
$
74 $ 3,703 78 additional FTEs required.
$
24 $ 1,250 25 additional FTEs to bring staffing to 5.2 shift-relief
factor.

The IN DYS believes that staffing ratios at its facilities need to reach one staff per 10 residents to be
considered adequate and identifies the need to hire 78 additional FTEs to reach this ratio, at an estimated
cost of $3.7 million in yearly wages and benefits and operational expenditures. The CO DOC is
estimated to require 25 additional staff members to provide adequate supervision at a yearly cost of $1.3
million.
Community Corrections
Inmate supervision was not viewed as an issue for most community corrections jurisdictions. As depicted
in the table below, only one of the six community corrections jurisdictions in this study, WA CC, is
estimated to have costs associated with physical supervision.
Site
WA CC

Upfront Yearly
Notes
$
16 $ 884 1 additional FTE for each of the 13 work release centers.

WA CC is estimated to require 13 additional staff, 1 FTE at each of its 13 work release centers, to provide
adequate supervision; a yearly cost of $884,000. The WA CC has seen an increase in reported incidents
4

Allen J. Beck, Ph.D., Paige M. Harrison, and Paul Guerino, BJS Special Report: Sexual Victimization in Juvenile
Facilities Reported by Youth, 2008-09. January 2010. US Department of Justice. Office of Justice Program, Bureau
of Justice Statistics.

Cost Impacts and Their Underlying Causes

20

PREA Cost Impact Analysis
of sexual abuse, but not necessarily an increase in substantiated cases. This is likely due to recent efforts
to better educate and train offenders on reporting policies that make it easier for offenders to make claims,
but most of which are found to be unsubstantiated after investigations. Nevertheless, WA CC
administrators believe that additional correctional officers are required to address the increased reports if
this signals any underlying causes of heightened risk factors associated with sexual abuse. One additional
officer at each of the 13 work release centers appears to be a reasonable assumption to address the
increased reporting.
Lockups
None of the lockups in this study are estimated to have costs associated with inmate supervision.

Cost Impact #3 - Assessment and Use of Monitoring Technology (PP7)
Assessment and Use of Monitoring Technology (PP7) has the greatest upfront cost impact of all standards
accounting for 96% of all upfront costs. This impact is attributed to the significant investment costs
required to procure and install monitoring technology. Maintaining such IT systems in the out-years is
also expensive with the resulting ongoing cost impact accounting for 8% of total ongoing costs across all
sites. This rather large cost impact is relatively widespread with the majority of sites noncompliant (69%)
suggesting that it is not just a few isolated cases driving the cost but a common finding among the 49 sites
in this study.
For those sites with a cost impact, this standard also has the most variation with costs to retrofit or
enhance monitoring technology from a few hundred thousands of dollars to investment costs approaching
a billion dollars. Such variation is burdened by multiple interpretations of what is deemed to be "cost
effective" and "appropriate" monitoring technology along with an overwhelming recognition of the merits
of technology to respond to sexual abuse. As the table below shows, upfront costs for prisons ranged
from $221 million to $621.5 million, whereas yearly costs ranged from $86,000 to $8.1 million. This
represents a variation in upfront cost of approximately $621.3 million and a variation in yearly cost of
almost $8 million. Meanwhile upfront jail and juvenile costs varied by approximately $25 million and
$38 million, respectively. Community Corrections are exempt from this standard and lockups did not
exhibit any costs.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$621,500
$ 25,000
$ 38,000
n/a

Low
$ 221
$ 116
$
6
n/a

Yearly Range
High
$ 8,143
$ 179
$ 2,163
n/a

Percent
Low
Compliant
$
86
8%
$
2
50%
$
1
20%
n/a
n/a
100%

The cost variability within sectors is mostly attributable to the number of facilities in a jurisdiction,
explaining the large variance in the prisons and juvenile sectors that each have instances whereby systems
are composed of numerous facilities across the state. For example, the RI DOC consists of only eight
facilities requiring updates and technical modification while NY DOC is responsible for 67 facilities. For
juvenile corrections agencies, the FL DJJ provided a cost impact associated with 101 facilities spread
throughout the entire state. The greater number of facilities analyzed typically results in a larger cost
Cost Impacts and Their Underlying Causes

21

PREA Cost Impact Analysis
impact. Other factors such as the age and physical design of the infrastructure can also contribute to a
certain degree of variation.
The fundamental, underlying cause of this cost impact is due to the requirement for agencies to utilize
video monitoring systems and other technology to eliminate sexual abuse.
The NPREC standard PP7 states, “The agency uses video monitoring systems and other costeffective and appropriate technology to supplement its sexual abuse prevention, detection, and
response efforts.”
As a testament to the variation in costs, there was a significant degree of varying interpretations of this
standard without any clear benchmarks or technical standards to target. Because every facility is
essentially starting from a different degree of technical modernization and has a different opinion of what
is "appropriate," there will continue to be considerable challenges in adopting this standard. Sites
frequently asked if there is any more specific guidance to technical requirements to clarify this standard.
Technical requirements suggested included a benchmark on video quality (e.g., number of mega pixels,
analog versus digital), archiving standards (e.g., number of days), staff monitoring ratios (e.g., number of
staff per cameras monitored), or coverage requirements (e.g., core areas that require surveillance taking
into account a wide array of physical and facility designs). This last example could include standards on
certain locations that must have video surveillance or specific quantity of cameras utilized based on
supervision practices and facility characteristics.
Prisons
As shown in the chart below, 12 agencies found an increased level of video monitoring was necessary to
supplement sexual abuse prevention, detection, and response efforts. AR DOC was the only site that
thought it had adequate monitoring technology; therefore, Booz Allen considered AR DOC compliant for
this study.
Site
VA DOC

Upfront
$ 30,080

Yearly
Notes
$ 8,143 Additional cameras, monitoring staff, and maintenance.

CA DOC
CO DOC
SC DOC
NY DOC
IN DOC
MN DOC
OR DOC

$ 8,281
$ 2,675
$ 4,050
$621,500
$ 5,048

$
$
$
$
$
$
$

WA DOC

$ 2,642

MA DOC
MO DOC
RI DOC

$ 2,294
$ 1,915
$
800

$

221

2,381
2,312
2,128
1,750
450
135
86

Upgrade video monitoring in 33 facilities and personnel
Additional cameras and monitoring staff are required.
Additional cameras, installation, and monitoring staff are
Increased video monitoring coverage in 39 facilities and
Upgrade video monitoring, new equipment cost, and
Cost to conduct annual security audit.
Purchase and installation of cameras in one facility and
cost to conduct yearly assessment.
Upgrade video monitoring, new equipment cost, and
standardizing video storage.
Upgrade video monitoring and new equipment cost.
Additional cameras and monitoring staff are required.
Additional camera equipment in minimum security
facilities.

The primary cost driver for monitoring technology is upfront investments costs associated with the
purchasing and installing equipment. The NY DOC estimates nearly $622 million to install video
surveillance in 35 of its male facilities and four of its female facilities. This cost includes $220 million
Cost Impacts and Their Underlying Causes

22

PREA Cost Impact Analysis
for 11 large maximum security facilities, $360 million for 24 medium-security facilities, $15 million for
four female facilities, plus additional building space at $27 million to handle the video monitors and
related equipment necessary to manage the systems and extra staff that would provide real-time
monitoring of surveillance. Whereas NY DOC cost estimate is based on the costs associated with one
large camera project for each of its medium and maximum security prisons, costs would be significantly
higher if NY DOC were required to undergo a process of adding supplemental cameras as often as every
year. Each annual project would require a new procurement, camera system redesign and construction at
significant cost.
A building’s age poses numerous obstacles to install a camera system resulting in significant increases to
the cost. Retrofitting old buildings with modern technology requires significant construction and
demolition costs. Older construction also requires much greater camera density to achieve similar
coverage than a modern facility built to maximize visibility. The facility at Bedford Hills, NY for
example, opened in 1901 as a reformatory for women. Today the facility consists of 57 buildings in a
variety of styles and ages totaling 585,740 square feet. In 2004, a project to design and install video
surveillance was completed after 2 years at a cost $3.6 million to install a modern system consisting of
300 cameras.
As is the case with all technology, recurring costs in the form of equipment maintenance and upgrades
must be considered. Additional recurring costs to consider include labor. An additional level of effort is
required to monitor an increased level of surveillance. The VA DOC, for example, anticipates requiring
an additional 24/7 post at each of its prisons resulting in an additional 84 FTEs. This results in nearly
$8.1 million in yearly operations and maintenance costs.
Jails
Generally, jails considered their facilities adequately equipped to provide technical supervision of its
inmates. Only seven out of 16 jurisdictions studied estimated a cost impact in order to comply with those
cost shown in the table below.
Site
Marion County
Jefferson County
WA Pierce County
Miami-Dade
Sacramento County
Aiken County
Peumansend Creek

Upfront
$
116
$
164
$ 25,000
$
684
$
500
$
400

Yearly
Notes
$
179 Additional cameras and monitoring staff are required.
$
143 Additional cameras and monitoring staff are required.
$
2 Cost to conduct yearly assessment.
Upgrade video monitoring coverage in 5 facilities.
Upgrade video monitoring and new equipment cost.
Upgrade video monitoring and new equipment cost.
Upgrade video monitoring and new equipment cost.

Aiken County's costs reflect its current plans to overhaul its existing surveillance system composed of 85
antiquated cameras of which only 16 have archiving capability. Similarly, Essex County is currently in
the process of adding 396 cameras along with archiving capabilities at a cost of $2.2 million. For this
study, the cost of $2.2 million was considered sunk, it provides a basis of comparison with the other
responses. Marion County and Peumansend Creek both do not consider their coverage adequate
throughout their facilities. In fact Peumansend Creek has a system that is no longer supported by its
vendor, making its current system obsolete and forcing it to replace its current system if and when they
system breaks or maintenance costs are untenable. The cost impact for both facilities includes additional

Cost Impacts and Their Underlying Causes

23

PREA Cost Impact Analysis
equipment to meet their monitoring needs while Marion County's costs also include additional resources
to monitor equipment.
Recent technical assessments at Miami-Dade have highlighted a need for additional video surveillance.
Consisting of five detention centers, Miami-Dade has a documented technical assessment recommending
a need for major video surveillance upgrades. Similar to concerns common in the state prison systems,
Miami-Dade is made up of older buildings requiring expensive retrofit designs and more cameras than
contemporary jails that have more visible space.
Juvenile
All juvenile corrections agencies in this study have at least some video monitoring in place however, all
(except MO DYS, which upgraded much of its video monitoring technology 2 years ago) believe that
some enhancements are required. Some facilities lack video monitoring coverage in vital common areas
while others lack archiving capabilities and still others have outdated equipment that is in need of
upgrades or replacement. The following table depicts the costs for the eight juvenile corrections agencies
that will have a cost impact for monitoring technology.
Site
CA DJJ
CO DYC

Upfront
$
904
$ 17,753

Yearly
Notes
$ 2,163 Additional cameras and monitoring staff are required.
$
192 Upgrade video monitoring, new equipment cost,
maintenance cost, and cost to conduct a yearly assessment.

IN DYS
FL DJJ

$ 2,500
$ 38,000

$
$

OYA
IDJC

$ 4,001
$
174

$
$

AR JA
MA DYS

$
$

$

6
925

140 Additional cameras and maintenance.
86 Upgrade video monitoring and new equipment cost for
101 facilities and cost to conduct yearly assessment.
58 Additional cameras and monitoring staff are required.
5 Upgrade video monitoring, new equipment cost, and cost
to conduct yearly assessment.
1 Additional cameras and maintenance.
Upgrade video monitoring and new equipment cost.

FL DJJ estimates $38 million necessary to adequately equip its 101 residential and detention facilities
with the necessary technical equipment. Similar to prisons and jails, FL DJJ's cost considers size,
physical structure of their facilities, and whether a facility is pre-wired for surveillance.
The CO DYC has the second largest cost associated with technical supervision among the nine juvenile
systems studied. Unlike the FL DJJ, the CO DYC based their estimate off of square footage; estimating
$27 per square foot to upgrade its facilities to provide adequate coverage. The CO DYC has 10 facilities
in need of upgrades, encompassing 657,526 square feet of space; the estimated cost to upgrade these
facilities is roughly $18 million.

Cost Impact #4 – Ongoing Medical and Mental Health Care (MM3)
This standard accounts for 2.5% of the overall costs across all sectors and has a compliance rate of 57%.
Isolated sites across varying sectors anticipate a significant cost impact associated with providing ongoing
care and mental health care particularly as it relates to care for all known abusers. Most sites provide
such care for victims but stop short of providing commensurate care for abusers. In addition, some sites

Cost Impacts and Their Underlying Causes

24

PREA Cost Impact Analysis
shared a concern about providing such care to all known abusers particularly with a relatively high
proportion of sex offenders entering their jurisdiction or site. As shown in the table below, these costs are
distributed across all sectors (excluding lockups) with a predominately large impact on ongoing costs
since these services are not considered one-time investments.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$

Low
7

n/a

$

1

n/a

Yearly Range
High
$ 3,000
$ 1,209
$ 750
n/a

Percent
Low Compliant
$ 293
69%
$
56
69%
$
59
80%
100%
n/a
n/a

For most sites, inmates labeled as sex offenders are required to attend a sex offender program. This
labeling is determined from the nature of the criminal offense, not from a screening instrument at intake.
This process likely misses many abusers who might be incarcerated for an unrelated offense. Discovery
of past sexual abuse incidents (via an enhanced screening tool) will add to the number of offenders in the
program. Often, this treatment is not provided on an ongoing basis. Annual costs for prisons to comply
range from $3 million to $293,000. Jail facilities that recognize a cost impact have provided an annual
range between $1.2 million and $56,000, while juvenile facilities anticipate a range anywhere between
$750,000 and $59,000. Significant variances in costs are due to different views on what providing
ongoing care may do to a system's current treatment program and/or the increased level of effort that will
be required to provide the appropriate care to not only inmates who have been abused or are know sex
offenders, but all known abusers or perpetrators of sexual abuse.
The underlying cause of this impact is due to the need to provide medical and/or mental health treatment
to all known abusers of sexual violence. The NPREC standard MM3 states the following:
”The facility conducts a mental health evaluation of all known abusers and provides treatment,
as deemed necessary by qualified mental health practitioners..
Prisons
Many prison jurisdictions such as the NY DOC and MA DOC provide evaluations and ongoing treatment
at any time as needed within the system. In the case of IN DOC, all known abusers are not currently
provided with ongoing treatment. Predators labeled as sex offenders by the court system are not
necessarily automatically sent to the sex offender treatment program. IN DOC anticipates a significant
increase in the number of inmates who will require treatment. An annual cost of $3 million to increase
the current treatment program by 75% has been provided. In addition to providing service to all known
abusers, the WA DOC anticipates a significant burden associated with providing ongoing mental health
treatment to inmates. An annual estimate of $293,000 has been provided to ensure ongoing care to
approximately 30 cases.
Site
IN DOC
WA DOC

Upfront

Yearly
Notes
$ 3,000 3/4 cost of full sex offender treatment program due to
increase in number of participants.
$ 293 On-going treatment to approximately 30 inmates on
average per year.

Cost Impacts and Their Underlying Causes

25

PREA Cost Impact Analysis
Jails
Three jail jurisdictions, Sacramento County, Alachua County, and Norfolk City anticipate an increased
level of effort associated with providing ongoing medical and mental health treatment to its inmates. In
the case of Sacramento County, current medical and psychiatric staffing levels are not sufficient to
conduct ongoing medical and/or mental health evaluations and treatment to all known abusers of sexual
abuse. Meeting such a requirement would require hiring six additional FTEs to provide care on a 24/7
basis. The annual cost impact would be approximately $1.2 million with upfront new hire costs of
approximately $7,000. Similarly, Alachua County would be required to hire an additional four FTEs at
$406,000 annually and Norfolk City would be required to hire one additional FTE at $56,000 annually.
Site
Sacramento County
Alachua County
Norfolk City
Miami-Dade

Upfront Yearly
Notes
$
7 $ 1,209 6 additional FTEs to provide on-going treatment of
inmates.
$
4 $ 406 4 additional FTEs to provide on-going treatment of
inmates.
$
1 $
56 1 additional FTE to provide on-going treatment of
inmates.
$
<1 Cost to provide on-going care to one inmate per year
based on most recent recorded number of proven
incidents.

Juvenile
Juvenile facilities express similar concerns as that of the prison and jail sectors. The IN DYS and the
IDJC anticipate an increase in the number of residents included in sex offender treatment programs. This
would include those who have not been adjudicated but exhibit signs of sexually abusive behavior. As
shown in the chart below, additional treatment would require an increase in level of effort amounting to
$750,000 annually for IN DYS and $59,000 annually for the IDJC.
Site
IN DYS
IDJC

Upfront

Yearly
Notes
$ 750 3/4 cost of full sex offender treatment program due to
increase in number of participants.
$
59 On-going treatment of approximately 15 residents who
have sexually abusive behaviors but have not been
adjudicated.

Cost Impact #5 - Audits of Standards (AU1)
Without any audit process available or practiced across the country, this was the only standard that has a
0% compliance yet it will impact every site uniformly with ongoing costs as shown in the table below.
Any yearly cost variation realized within a sector was due solely to a variation in the number of facilities.
All together this standard accounts for just over 2% of the overall impact on total ongoing costs without
any upfront costs.

Cost Impacts and Their Underlying Causes

26

PREA Cost Impact Analysis

Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

Upfront Range
High
Low

Percent
Yearly Range
High
Low Compliant
$ 724 $
86
0%
$
41 $
8
0%
$ 574 $
6
0%
$ 119 $
6
0%
$
3 $
3
0%

Lacking definitive guidelines regarding what a PREA audit might entail, Booz Allen has elected to
standardize the cost impact of a triennial audit. The cost impact of an audit consists of an auditor’s fee
and an internal level of effort cost realized by a facility's audit-related duties and activities. The auditor’s
fee is composed of labor costs and travel expenses (e.g., meals and incidental expenses, lodging, air fare,
and mileage) and is dependent on the complexity of the audit (i.e., its sector and number of facilities
within a system). Prisons for example, were assumed to require 4 days to audit, jails were assumed to
take 3 days, juvenile and community corrections facilities were assumed to take 2 days, and lockups were
assumed to be 1 day audits. More information regarding the detail behind our audit-related assumptions
can be found in the Assumptions section below.
The underlying cause of this cost impact is due to the need to conduct a triennial audit of all facilities,
including those that are contracted. The NPREC standard AU1 states the following:
“The public agency ensures that all of its facilities, including contract facilities, are audited to
measure compliance with the PREA standards. Audits must be conducted at least every three
years by independent and qualified auditors.”
Prisons
As previously mentioned, prisons are assumed to be subjected to a 4-day audit per facility. Based on this
assumption, yearly cost impacts vary from $724,000 to audit 67 facilities at NY DOC to $86,000 to audit
eight facilities as part of the RI DOC. The following table shows the audit cost for each prison in this
study.
Site
NY DOC
CA DOC
SC DOC
VA DOC
CO DOC
AR DOC
IN DOC
MO DOC
MA DOC
OR DOC
WA DOC
MN DOC
RI DOC

Upfront

Yearly
$ 724
$ 356
$ 324
$ 302
$ 259
$ 227
$ 227
$ 227
$ 194
$ 151
$ 140
$ 108
$
86

Notes
Cost to conduct an audit at 67 facilities.
Cost to conduct an audit at 33 facilities.
Cost to conduct an audit at 30 facilities.
Cost to conduct an audit at 28 facilities.
Cost to conduct an audit at 24 facilities.
Cost to conduct an audit at 21 facilities.
Cost to conduct an audit at 21 facilities.
Cost to conduct an audit at 21 facilities.
Cost to conduct an audit at 18 facilities.
Cost to conduct an audit at 14 facilities.
Cost to conduct an audit at 13 facilities.
Cost to conduct an audit at 10 facilities.
Cost to conduct an audit at 8 facilities.

Jails
Jails are assumed to be subjected to a 3-day audit process per facility. The cost to conduct a triennial
audit on Miami-Dade’s five jail facilities results in a yearly cost impact of $41,000. Sacramento County
Cost Impacts and Their Underlying Causes

27

PREA Cost Impact Analysis
and WA Pierce County both have two facilities at an annual cost of $16,000. The remaining jails analyzed
consisted of only one facility each. Therefore in each instance, their yearly cost impact equates to $8,000.
The following table shows the audit cost for each of the jails in this study.
Site
Miami-Dade
Sacramento County
WA Pierce County
Aiken County
Alachua County
Albany County
Anoka County
Denver County
Essex County
Hennepin County
Jefferson County
Marion County
Norfolk City
Peumansend Creek
Pulaski County
WI Pierce County

Upfront

Yearly
$
41
$
16
$
16
$
8
$
8
$
8
$
8
$
8
$
8
$
8
$
8
$
8
$
8
$
8
$
8
$
8

Notes
Cost to conduct an audit at 5 facilities.
Cost to conduct an audit at 2 facilities.
Cost to conduct an audit at 2 facilities.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.

Juvenile
Juvenile facilities are assumed to be subjected to a 2-day audit process per facility. Based on this
assumption, yearly cost impacts vary from $574,000 to audit 101 FL DJJ facilities to $6,000 to audit
ACJCS. The following table shows the audit cost for each of the juvenile corrections agencies in this
study.
Site
FL DJJ
MA DYS
MO DYS
CO DYC
OYA
AR JA
IN DYS
CA DJJ
IDJC
ACJCS

Upfront

Yearly
$ 574
$ 324
$ 182
$
62
$
62
$
45
$
40
$
34
$
17
$
6

Notes
Cost to conduct an audit at 101 facilities.
Cost to conduct an audit at 57 facilities.
Cost to conduct an audit at 32 facilities.
Cost to conduct an audit at 11 facilities.
Cost to conduct an audit at 11 facilities.
Cost to conduct an audit at 8 facilities.
Cost to conduct an audit at 7 facilities.
Cost to conduct an audit at 6 facilities.
Cost to conduct an audit at 3 facilities.
Cost to conduct an audit at 1 facility.

Community Corrections
Community corrections are assumed to be subjected to the same 2-day audit as juvenile facilities. Based
on this assumption, yearly cost impacts vary from $119,000 to audit 21 facilities as part of the MA OCC
to $6,000 to audit one facility as part of the IN DOR, MO PP, and SC PPP. The following table shows the
audit cost for each Community Correction jurisdiction in this study.

Cost Impacts and Their Underlying Causes

28

PREA Cost Impact Analysis
Site
MA OCC
WA CC
MO PP
AR DCC
IN DOR
SC PPP

Upfront

Yearly
$ 119
$
85
$
45
$
40
$
6
$
6

Notes
Cost to conduct an audit at 21 facilities.
Cost to conduct an audit at 15 facilities.
Cost to conduct an audit at 8 facilities.
Cost to conduct an audit at 6 facilities.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.

Lockups
Lockups are assumed to be subjected to a 1-day audit. Based on this assumption, each lockup studied
resulted in a yearly cost impact of $3,000 or the cost associated with conducting a triennial audit at one
Lockup facility. The following table shows the audit cost for each of the lockup in this study.
Site
DCPA
Middleton PD
Rocklin PD
Seattle PD

Upfront

Yearly
$
3
$
3
$
3
$
3

Notes
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.
Cost to conduct an audit at 1 facility.

Cost Impact #6 - Training and Education (TR1 through TR5)
Almost every site included in this study was noncompliant with one if not all the training standards with
Employee Training (TR1) alone accounting for nearly 2% of the overall cost impact across all sectors. A
vast majority of sites require some additional training and education to comply with NPREC standards
and subsequently have associated costs. The table below bundles all the training costs together because
training and education for employees, offenders volunteers, and contractors (in Booz Allen's assessment)
are intricately related to one another and there can be some cross-pollination of curriculum between
standards. Although there is some consistency in noncompliance, the costs associated with this standard
are not relatively high but they do vary considerably among sites. In total, 39 of the 49 sites in this study,
or 80%, have costs associated with training and education.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$ 4,504
$ 328
$ 163
$ 128
$
64

Low
$
30
$
4
$
1
$
8
$
4

Yearly Range
High
$ 226
$ 261
$ 3,417
$ 123
$
16

Percent
Low Compliant
$
14
63%
$
1
20%
$
24
48%
$
2
33%
$
1
33%

The fundamental, underlying cause of this cost impact is due to the requirement for agencies to train all
employees (including non-sworn officers and administrative assistants), train all contractors and
volunteers, provide education to inmates and offenders, and ensure specialized training is provided to
investigators and the medical and mental health care staff.
The NPREC standard TR1 states, “The agency trains all employees to be able to fulfill their
responsibilities under agency sexual abuse prevention, detection, and response policies and
procedures…..”

Cost Impacts and Their Underlying Causes

29

PREA Cost Impact Analysis
TR2 states, “The agency ensures that all volunteers and contractors who have contact with
inmates have been trained on their responsibilities under the agency’s sexual abuse prevention,
detection, and response policies and procedures….”
TR3 states, “During the intake process, staff informs inmates of the agency’s zero-tolerance
policy regarding sexual abuse and how to report incidents or suspicions of sexual abuse. Within
a reasonably brief period of time following the intake process, the agency provides
comprehensive education to inmates regarding their right to be free from sexual abuse and to be
free from retaliation for reporting abuse, the dynamics of sexual abuse in confinement, the
common reactions of sexual abuse victims, and agency sexual abuse response policies and
procedures……”
TR4 states, “……the agency ensures that agency investigators conducting sexual abuse
investigations have received comprehensive and up-to-date training in conducting such
investigations in confinement settings…….”
TR5 states, “The agency ensures that all full- and part-time medical and mental health care
practitioners working in its facilities have been trained in how to detect and assess signs of
sexual abuse and that all medical practitioners are trained in how to preserve physical evidence
of sexual abuse……”
Although many sites have begun implementing processes and changes to their training procedures, most
do not meet the intention of the standard as it is written, particularly Appendix B of the NPREC
standards. Additional training costs arise from the need to provide training specific to confinement
settings for investigators and to provide training on preserving physical evidence of sexual abuse to
medical and mental health care practitioners. In many instances curriculum and training material will
need to be developed to include all aspects of PREA and additional level of effort from trainers will be
required; these often encompass large upfront costs. In some cases non-medical care contractors do not
receive any training on sexual abuse, which will require a large increase in level of effort to remedy.
Annual costs are also incurred from the additional effort required to provide refresher training and to train
new staff.
Prisons
Of the 13 prisons in this study, eight are estimated to have costs associated with training and education.
Most costs are relatively modest, given the size of prison systems, with the exception of NY DOC's
upfront training costs of $4.5 million. While employees at NY DOC receive training on sexual abuse,
current training does not meet expectations defined by the NPREC standards. Additional training will be
required for 27,000 staff including direct employees, contractors, volunteers, and medical staff. All other
DOCs have training and educations costs of less than $1 million as depicted in the table below.

Cost Impacts and Their Underlying Causes

30

PREA Cost Impact Analysis
Site
MO DOC
NY DOC

MN DOC
VA DOC
RI DOC
WA DOC
SC DOC
OR DOC

Upfront Yearly
Notes
$
51 $ 226 Refresher training for employees and training for
investigators.
$ 4,504 $ 115 Training for employees, contractors, volunteers, and
medical staff, and to develop a lesson plan and provide
appropriate materials for inmate education.
$
77 Additional employee training and refresher education for
inmates.
$ 550 $
63 Train contractors, investigators, and mental and medical
health staff, and provide inmate education.
$
$ <1 29 Updated training module for employees.
$
47 $
20 Curriculum development and materials cost.
$ 155 $
14 Costs for developing materials.
$
30
Training for medical and mental health staff.

For many prisons, the cost impact associated with Training Employees, Volunteers and Contractors (TR1
and TR2) was limited to developing PREA-related material and delivering refresher training. When
practical, the curriculum to train employees is shared with contractors and volunteers to minimize the cost
impact. Typically any cost impact associated with the Training of Agency Investigators Conducting
Sexual Abuse Investigations (TR5) is due to current curriculum lacking information regarding
investigations in confinement settings. The SC DOC, VA DOC, WA DOC, and MO DOC each
acknowledged that their current curriculum lacked training in confinement settings. In regards to the
Training of Medical and Mental Health Staff (TR4), the main issue was curriculum related to preserving
physical evidence of sexual abuse.
Jails
All 16 jails included in this study require additional training and/or education to comply with this
standard. Upfront costs for jails ranged from $328,000 for Sacramento County to $4,000 for Marion
County. Yearly costs for jails ranged from $261,000 to less than $1,000. Much of Miami-Dade's large
yearly costs are associated with refresher training for its employees and to provide education to its
inmates. Sacramento County’s large upfront costs are primarily a result of the need to train its 100
medical and mental health care staff.

Cost Impacts and Their Underlying Causes

31

PREA Cost Impact Analysis
Site
Miami-Dade
Albany County

Pulaski County

Upfront Yearly
Notes
$
28 $ 261 Additional employee training and refresher training and for additional inmate education.
$
5 $ 122 Additional training to staff, volunteers, and medical and mental health staff and for inmate
education.
$ 132 $
33 Training of staff to include refresher training.
$ 170 $
25 Training for contractors, investigators, and medical and mental health staff.
$
6 $
21 Costs to train employees, contractors, investigators, health care staff, and to develop material for
inmate education.
$
31 $
20 Costs are to train employees and volunteers and to provide sexual abuse education to inmates.

WA Pierce County

$

97

$

Peumansend Creek
Hennepin County

$
$

9
125

$
$

Anoka County

$

28

$

Norfolk City

$

17

$

Sacramento County
Marion County
Aiken County
Jefferson County
Essex County

$
$
$

Denver County
Alachua County
WI Pierce County

$

328 $
4 $
6 $
$
8

16 Costs to provide initial training to all staff required under the standard and to provide refresher
training to employees.
11 Yearly cost for refresher training and upfront cost to train investigators.
7 Upfront cost to develop curriculum and train employees, investigators and medical/mental health
and yearly cost for refresher.
5 Yearly cost for refresher training and upfront cost for inmate education and to train investigators.
3 Costs to develop material for inmate education and to train investigators and medical/mental
health staff.
1 Cost to train medical staff and volunteers and to provide inmate education.
1 Cost to train investigators and volunteers.
<1 Cost to train employees and develop an orientation video.
<1 Cost to provide refresher training to 30 employees.
Material to educate inmates and train investigators and medical/mental health staff.

Primary costs drivers include modifications to current curriculum and training to an expanded set of
employees, contractors, and volunteers in order to cover PREA material. Because of their smaller size
relative to prisons, it is assumed in this study that jails can leverage the PREA Coordinator to assist in
curriculum development and even training delivery when feasible. This assumption was applied to each
jail on a case-by-case basis depending on its size. The costs to Train Employees (TR1) are by far the
largest of the training cost estimates. Although training in some form is provided to most staff, it often
excludes training on PREA related issues. Specialized Training for Investigations (TR4) and Medical and
Mental Health Care (TR5) had a significantly less of a cost impact. For most jails in this study, the
investigators are employed by the sheriff's office that manages the jail and are accustomed to conducting
investigations in confinement settings. Medical and mental health staff on the other hand typically are
employed by the county health department and receive their training on sexual abuse through individual
medical and professional licensure requirements. This training is conducted outside the jail and external
to its own training operations. Inmate education has a relatively low cost impact, much of it consisting of
costs to develop educational materials.
Juvenile
As shown in the table below, 9 of 10 juvenile corrections agencies require additional training and/or
education, with upfront costs ranging from $163,000 for CA DJJ to $1,000 for ACJCS and yearly costs
ranging from $3.4 million for FL DJJ to $24,000 for MO DYS. FL DJJ has by far the largest yearly costs
as a result of the need to train 4,800 employee. All other jurisdictions have lower training costs, much of
it associated with enhancing current training to include PREA issues, extending the training to contractors
and volunteers, and including specialized training for investigators and medical and mental health care
staff.

Cost Impacts and Their Underlying Causes

32

PREA Cost Impact Analysis
Site
FL DJJ
CO DYC

IDJC

OYA
MO DYS
CA DJJ
IN DYS
MA DYS
ACJCS

Upfront Yearly
Notes
$
65 $ 3,417 Cost to train employees and all other personnel under this
standard and to provide resident education
$
1 $
61 One FTE to train employees, on-going site training at the
facilities, and the quality assurance process (audit) at each
facility.
$ 129 $
60 Cost for employee training, including refresher, investigators
and medical staff, and to develop materials for resident
education
$ 133 $
35 Cost to train contractors and medical staff
$
98 $
24 Cost to train employees, including refresher, and to train
contractors, volunteers, and medical staff
$ 163
Cost to train investigators and medical staff
$
25
Cost for external investigators, Correctional Peace Officers
curriculum and confinement-specific training material.
$
5
Cost to train 2 investigators, at $2.5K each
$
1
Refresher education for residents

Similar to jails, Training of Employees (TR1) represents the largest cost impact. Primary costs drivers
include modifications to current training curriculum and training to an expanded set of employees,
contractors, and volunteers to cover PREA material. It is assumed in this study that some of the smaller
juvenile correctional agencies can leverage the PREA Coordinator to assist in curriculum development
and even training delivery when feasible. Training for Contractors and Volunteers (TR2) is relatively low
assuming that the curriculum from TR1 can be leveraged. Specialized Training for Investigations (TR4)
and Medical and Mental Health Care (TR5) are estimated to have the lowest cost impact. For some of the
juvenile correctional agencies in this study, local or state authorities not directly employed by the
jurisdiction conduct the investigations. These authorities, usually state and local police departments,
generally receive training on sexual abuse but do not receive training specific to conducting investigations
in confinement settings. All medical and mental health staff on the other hand are employed directly
and/or contracted by the juvenile corrections agencies in this study. The medical and mental health care
staff generally receive training on sexual abuse through individual medical and professional licensure
requirements; this training is conducted outside the juvenile facilities and external to their own training
operations. In these cases it is difficult to ensure that the training they receive is compliant with the
standard.

Cost Impacts and Their Underlying Causes

33

PREA Cost Impact Analysis
Community Corrections
As shown in the table below, five of six community corrections jurisdictions require additional training,
with MA OCC having the highest upfront and yearly costs, $128,000 and $123,000, respectively. MA
OCC ensures employees are trained on sexual abuse but the current curriculum is not comprehensive
enough to cover all PREA topics. To do so will require modifications to their training curriculum. The
ongoing costs reflect refresher training to be delivered on a regular basis to 99 Community Correction
staff, 879 probation officers, and 138 parole officers and all contractors. All other community corrections
training and education costs are modest in comparison.
Site
MA OCC
WA CC

Upfront Yearly
Notes
$ 128 $ 123 Cost of materials and staff time to implement training.
$
47 $
20 Cost to develop training materials and train employees

IN DOR

$

32

$

SC PPP

$

52

$

MO PP

$

8

$

11 Cost to develop training materials for employees and offender
education
3 Cost to train employees, volunteers, and investigators
2 Cost to provide education to offenders and to train investigators

Although most community corrections jurisdictions have costs associated with training, the costs are far
less than those estimated for prison, jails, and juvenile facilities. Most community corrections
jurisdictions require only modest modifications to existing curriculum and additional training time to
deliver the required material. Most jurisdictions offer some sort of sexual abuse training at orientation for
new hires (TR1 and TR2) but it is often not comprehensive enough to cover PREA and sometimes
excludes administrative staff (or un-sworn officers), volunteers, or contractors. As with the other
jurisdictions, training employees has the largest cost impact for community corrections, while Specialized
Training (TR4) and Medical and Mental Health Care (TR5) have a lower cost impact.
Lockups
As it relates to lockups, training falls under standards TR1 through TR3. As shown in the chart below,
none of the lockup facilities in this study conduct training in accordance with the NPREC standards and
each one has a cost impact. Costs are estimated to range from $64,000 to $4,000 for upfront costs and
$16,000 to $1,000 for yearly costs. The DCPA, the largest among the lockup facilities in this study, has
by far the highest costs. DCPA’s costs are associated with staff time required to update its current
training program to cover NPREC standards.
DCPA

Site

Upfront Yearly
Notes
$
64 $
16 Cost for updating training to cover PREA material, consisting
of staff time for both initial training and refresher training.

Middleton PD
Rocklin PD

$
$

4
6

Seattle PD

$

4

$
$

Cost Impacts and Their Underlying Causes

4 Cost to employee and volunteer train
1 Cost for employee and to renegotiate a contract with Lexipol to
develop and monitor this additional policy.
Cost to develop a 30 minute video on sexual abuse for
employees.

34

PREA Cost Impact Analysis
Cost Impact #7 - Contracting with Other Entities for the Confinement of Inmates (PP2)
Contracting with private and public (e.g., county jails) facilities for the confinement of offenders is a
practice seen at 13 of the 49 sites included in this study. It has no upfront costs and the ongoing costs
account for nearly 2% of the overall cost impact across all sectors with a compliance rate of 73%, which
is relatively high. With a high compliance and a modest impact on the costs, this suggests that costs are
isolated in a select set of sites but as the table below shows, these costs are scattered across the sectors
except for lockups since they typically do not contract out for such services.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High

Low

Yearly Range
High
$ 1,259
$ 755
$ 1,577
$
34

Percent
Low Compliant
$
41
62%
$ 755
94%
$ 1,018
70%
$
23
33%
100%

For those sites contracting with private facilities, some correctional agencies mandate that all contracted
facilities follow the same policies and procedure as the jurisdiction places on its own facilities, often
times having regulations codified in contracts. As for public institutions like county jails, it is assumed
that the institution is held to the same PREA standards as everyone else. Nevertheless as is seen
throughout the study, there is a cost impact on certain standards and it is very likely that the contracting
entity will pass those costs on as higher fees. Some sites however, have unique contracting agreements
with private entities that prevent any additional or higher fees regardless of whether requirements and
regulations change. Such cases are noted but are relatively rare. The tables in this section illustrate the
upfront and ongoing cost impacts by sector for those contracting for the confinement of offenders.
For this standard, the major underlying causes of costs are that contracted facilities must comply with all
NPREC standards. In many instances the costs accrued by contractors to comply are passed over to
jurisdictions in the form of increased fees. The NPREC standard PP2 states,
“….Any new contracts or contract renewals include the entity’s obligation to adopt and comply
with the PREA standards and specify that the public agency will monitor the entity’s compliance
with these standards as part of its monitoring of the entity’s performance.”
Prisons
Of the 13 prisons in this study, four are estimated to have costs associated with this standard, seen in the
table below. All costs are ongoing, assuming that the contractor will pass on any increased costs (whether
upfront or ongoing) to the contracting facility in the form of higher monthly or annual fees. Each of these
costs are essentially a proportion of a site's overall cost impact where the proportion is a factor of
contracted inmates to total inmates. Therefore a site with a relatively high overall PREA cost impact will
also have a high PP2 cost impact, assuming the contracted facilities are essentially at the same rate of
compliance, or lower, as the contracting facility.

Cost Impacts and Their Underlying Causes

35

PREA Cost Impact Analysis
Site
CA DOC

Upfront

IN DOC
AR DOC
SC DOC

Yearly
Notes
$ 1,259 Contracts out for the confinement of approximately 7,700
inmates.
$ 735 Contracts out for the confinement of 2,400 inmates.
$ 253 Contracts out for the confinement of 280 inmates.
$
41 Contracts out for over 300 inmates.

Of particular note, CA DOC suggested that their contracted facilities (all county jails) must abide by
California Code of Regulations (CCR) Title 15 with an implicate assumption that cost would not increase.
However, understanding the budget difficulties in California and elsewhere, it is reasonable to assume
that each of these contracted jails, all held to the same PREA standards, will themselves incur additional
costs that they could easily pass on to CA DOC in the form of higher inmate fees. AR DOC suggested
that they would need to re-house their inmates contracted out to their county and city jails under the
assumption that these entities may choose not to abide by PREA. This study assumes a greater likelihood
that these entities will ultimately adopt the PREA standards and pass on additional and increased costs to
AR DOC. The following table shows the cost impact of PP2 on the prisons included in this study.
Jails
Among the jails in this study only one, Marion County Jail, is estimated to have any cost impact
associated with this standard for contracting for the confinement of a significant number of their inmates
with an estimated yearly cost impact of $737,000.
Site
Marion County

Upfront

Yearly
Notes
$ 755 Contracts out for approximately 1,375 inmates.

Juvenile
Five of the 10 juvenile corrections agencies in this study contract with other entities for the confinement
of residents, but only two exhibit any cost impact shown in the table below.
Site
CO DYC
IDJC

Upfront

Yearly
Notes
$ 1,577 Contracts out for 748 youth.
$ 1,018 Contracts out for approximately one-half of all youth.

IDJC contracts with up to 19 facilities for the housing of its residents and the CO DYC contracts 48
facilities. CO DYC estimates yearly costs of $1.6 million with the vast majority of the costs associated
with needing to update the technological supervision of its contracted facilities; specifically the purchase
and installation of cameras. IDJC will have increased yearly costs of $1 million. Unlike the CO DYC,
these costs are not concentrated in any one standard, but rather is spread among several standards that the
contracted facilities will be required to comply with. Two jurisdictions that have rather extensive reliance
on contracting (FL DJJ and MA DYS) do not exhibit any costs here. The MA DYS has contracts with 37
providers throughout the state to house its residents in 57 facilities but believes that their contractors meet
the PREA standards. FL DJJ, on the other hand anticipates a significant cost impact since 84% of their
offenders are housed in a contracted facility. However, with so many offenders under contractor
supervision, their increased costs are embedded throughout all their standards and not isolated solely in
PP2.

Cost Impacts and Their Underlying Causes

36

PREA Cost Impact Analysis
Community Corrections
Three community corrections jurisdictions (IN DOR, WA CC, and MO PP) each have contracted
facilities under their jurisdiction. IN DOR reported two contracted facilities managed by their Duvall
Residential Center. As these are very small operations with close and integrated management by Duval
administrators, they do not anticipate any required contract modifications and/or cost increases. WA CC,
on the other hand contracts out 13 out of their 15 work release centers meaning that the vast majority of
their offenders are housed in contracted facilities, yielding an annual cost of $34,000. Finally, MO PP
contracts out with five facilities, covering 1.3% of their total offender population with an estimated cost
of compliance of $23,000 per year.
Site
WA CC
MO PP

Upfront

Yearly
Notes
$
34 Contracts out for approximately 642 offenders in work
release centers.
$
23 Contracts out for approximately 250 beds.

Lockups
None of the lockups in this study contract for the confinement of offenders so there are no reported costs.

Cost Impact #8 - Accommodating Inmates with Special Needs (PP5)
A majority of jurisdictions across all sectors are very cognizant of the need to ensure offenders are
provided the tools necessary to effectively communicate regardless of any handicap or illness, supporting
the relatively high compliance rate of 88% across all sites. Nevertheless this study does show that this
standard accounts for almost 2% of the total cost impact, largely isolated in the lockups sector shown in
the table below. This is primarily due to their small size and limited resources to provide interpretive
services that exist across all the other sectors.

Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

Upfront Range
High
Low

$

2

$

2

Percent
Yearly Range
High
Low Compliant
$
1 $
1
92%
$
8 $
8
94%
100%
$
1 $
1
67%
$
38 $
38
50%

The underlying cause of this impact is due to the need to ensure everyone has the ability to communicate
effectively and directly with staff. The NPREC standard PP5 states the following:
“The agency ensures that (inmates) who are limited English proficient [LEP] deaf, or disabled,
are able to report sexual abuse to staff directly, through interpretive technology, or through noninmate interpreters.”
Prisons
Nearly all, 92%, of jurisdictions studied were found to be in compliance with PP5. The lone exception,
CO DOC, requires approximately $1,000 annually to ensure sign-language interpreter services are
available for those inmates that require them. Remaining jurisdictions reported having multiple ways for
inmates with special needs to report incidents of sexual abuse, including TTY machines for the deaf,
language lines and staff for the LEP, and access to mental health care staff and sister agencies for the
Cost Impacts and Their Underlying Causes

37

PREA Cost Impact Analysis
mentally disabled. In each instance, providing access to these services is either written policy or court
ordered.
Site
CO DOC

Upfront

Yearly
Notes
$
1 Fees for sign-language interpreter services.

Jails
Similar to prisons, jails were compliant in almost every instance. In the case of Anoka County, additional
equipment and interpreter services are requested to accommodate inmates’ needs.
Site
Anoka County

Upfront

Yearly
Notes
$
8 Purchase of additional equipment for deaf and disabled
inmates. Increased use of on-site interpreters (LEF and
deaf), translation technology (language lines and video
relay), and increased LOE to provide security.

Juvenile
All juvenile facilities analyzed as part of our study were found to be in complete compliance with PP5.
Methods reported include: TTY machines for the deaf, language lines and staff for LEP residents, and
mental health care staff for the mentally disabled.
Community Corrections
Currently SC PPP does not have interpretive services available at their disposal. A cost of $1,000
annually was estimated based on 20 hours of service. While the WA CC has multiple translation services
available, their pamphlets and booklets are currently only provided in English and Spanish. With a very
diverse population consisting of Chinese, Cambodians, Koreans, Russians, Laotians, and Vietnamese,
additional materials are required to ensure offenders of all nationalities are able to interpret
communication properly with staff. As shown in the chart below, a cost impact has been provided in the
amount of $2,000 was provided. Remaining jurisdictions mentioned numerous services that are available
including interpreters, language telephone lines for nearly every language, Internet translation, university
foreign language students, TTY machines for the deaf, and mental health staff for the mentally
challenged.
Site
SC PPP
WA CC

Upfront
$

2

Yearly
Notes
$
1 Cost to contract out for interpretive services.
Cost to provide materials in numerous foreign languages.

Lockups
Relative to other sectors, lockups have a much smaller staff and far fewer resources at their disposal to
meet this standard. With fewer staff, there is a lower probability that an officer speaks a foreign
language. Because incarceration is not a police department's primary mission, it is likely that there are
insufficient funds to support interpretive services, particularly when offenders are infrequent and stay for
only a couple of hours. Rocklin PD demonstrated this scenario, in which the influx of Spanish-speaking
inmates has made it very difficult for them to meet the language demands of its detainees. Consequently,
Rocklin PD would like to incentivize bilingual staff who accepts a position with the PD by providing a
Cost Impacts and Their Underlying Causes

38

PREA Cost Impact Analysis
5% increase in salary. At a minimum six FTEs are required to make this initiative successful, Rocklin PD
estimates a yearly cost impact of $38,000.
Site
Rocklin PD

Upfront

Yearly
Notes
$
38 Incentives associated with hiring bilingual staff.

Cost Impact #9 - Zero Tolerance of Sexual Abuse (PP1)
Although the PREA standards are not formally promulgated, most sites have policies describing a zero
tolerance of sexual abuse. However the reason this standard is the ninth highest ranked in terms of cost
impact is due to the requirement of a PREA Coordinator which very few sites actually have. With
upfront costs limited to hiring and training a new employee, the primary cost driver is the annual salary of
a senior level position. Regional cost of living standards aside, this standard exhibits the most uniformity
and consistent cost among all the standards since the requirements are objective and clear. With a low
compliance across all sites (8% overall) this cost impact is just over 2% of the total cost. The following
tables show the distribution across each of the sectors. For most of the sites visited, the cost is the result
of one additional full-time staff member added to their management and operational budget requirements.
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

Upfront Range
High
Low
$
1 $
1
$
1 $
1
$
1 $
1
$
1 $
1
$
1 $
1

Percent
Yearly Range
High
Low Compliant
$ 145 $
9
23%
$ 199 $
20
6%
$ 140 $
34
0%
$ 113 $
33
0%
$
63 $
5
0%

As mentioned above, the underlying cause of this impact is solely due to the designated PREA
Coordinator position. The NPREC standard PP1 states the following:
“The agency employs or designates a PREA coordinator to develop, implement, and oversee
agency efforts to comply with the PREA standards.”
Prisons
As shown in the chart below, among the 13 prison systems, 10 were noncompliant each of which
provided a cost estimate. Nine out of those 10 require a full-time staff member to fill this position with
salary levels varying state by state as a factor of the cost of living and going wages.
Site
RI DOC
AR DOC
CA DOC
VA DOC
MN DOC
SC DOC
MO DOC
IN DOC
NY DOC
CO DOC

Upfront
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1

Yearly
$ 145
$ 121
$ 115
$ 112
$ 106
$
91
$
79
$
72
$
71
$
9

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
Salary increase to existing PREA Coordinator to cover
NPREC requirements.

The level of effort and cost of a senior level staff member is the sole cost driver associated with this
standard. To meet the intent of the standard, Booz Allen required that each system employ one seniorCost Impacts and Their Underlying Causes

39

PREA Cost Impact Analysis
level staff member to oversee the responsibilities of the PREA coordinator. Although the standard is
clear on what it requires, some prison systems thought that one senior-level FTE was either too much or
too little. RI DOC and the MN DOC, for example thought it unnecessary to hire a senior-level position
believing that that grade level was too high and unwarranted. Others such as the NY DOC and the VA
DOC, with a combined capacity of nearly 100,000 inmates, thought that the equivalent of one senior-level
position would not adequately meet the responsibilities of the position without providing additional
support. For these large systems, they would likely go above and beyond the standard particularly due to
the additional reporting and monitoring requirements (for which it can be assumed that supplemental
PREA staff might assume those roles and cover the costs of those standards).
Jails
Of the 16 jails participating in this study, 15 were noncompliant, each of which reported a cost estimate.
Site
Sacramento County
WA Pierce County
Miami-Dade
Alachua County
Denver County
Albany County
Hennepin County
Essex County
Marion County
Pulaski County
Norfolk City
Jefferson County
Anoka County
Aiken County
WI Pierce County

Upfront
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1

Yearly
$ 199
$ 163
$ 141
$ 136
$ 124
$ 101
$ 101
$
93
$
92
$
92
$
56
$
53
$
25
$
21
$
20

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
0.25 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.

Juvenile
All of the juvenile corrections agencies participating in this study reported noncompliance with this
standard, each of which reported a cost estimate.
Site
CA DJJ
MO DYS
OYA
CO DYC
FL DJJ
IN DYS
MA DYS
ACJCS
AR JA
IDJC

Upfront
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1

Yearly
$ 140
$ 101
$
92
$
86
$
76
$
72
$
71
$
59
$
38
$
34

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.

Community Corrections
All of the community corrections jurisdictions participating in this study reported noncompliance with
this standard, each of which reported a cost estimate.
Cost Impacts and Their Underlying Causes

40

PREA Cost Impact Analysis
Site
WA CC
AR DCC
SC PPP
MA OCC
MO PP
IN DOR

Upfront
$
1
$
1
$
1
$
1
$
1
$
1

Yearly
$ 113
$ 107
$
78
$
73
$
71
$
33

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.

Lockups
All of the lockup facilities participating in this study reported noncompliance with this standard, each of
which reported a cost estimate.
Site
Rocklin PD

Upfront Yearly
Notes
$
1 $
63 0.5 FTE salary, benefits and new hire operations costs.

DCPA

$

1

$

57 0.5 FTE salary, benefits and new hire operations costs.

Middleton PD

$

1

$

53 0.5 FTE salary, benefits and new hire operations costs.

Seattle PD

$

<1 $

5 Handled by the Audit, Accreditation, and Policy
department at minimal cost.

Cost Impact #10 - Screening for Risk of Sexual Abuse (SC1 and SC2)
Screening for Risk of Victimization and Abusiveness (SC1) and Use of Screening Information (SC2) are
treated as one cost impact in this study because they are considered dependent upon each other, one
standard or process logically supporting the other. Any attempt at decoupling the two would undermine
the intent of either one. Together, these two standards account for nearly 2% of the overall costs. In
terms of compliance, more sites are compliant with SC2 (63%) than SC1 (39%) mostly because they have
screening procedures in place but require upfront modifications to meet the standard. As shown in the
table below, the costs exhibit some significant variation from a low upfront cost of $1,000 to a high of
nearly $2.8 million. This variation is evident in the ongoing costs as well with a low of $1,000 to a high
of $1.5 million.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$ 226
$
80
$ 2,753
$
64

Low
$
$
$
$

1
1
1
64

Yearly Range
High
$ 804
$ 133
$ 1,530

$
$
$

Low
437
1
60

$

$

20

20

Percent
Compliant
62%
47%
60%
58%
75%

Most sites currently utilize a formal screening process, however the vast majority of the sites in this study
thought that they would need to update their screening instruments to include PREA-related questions
mostly because they fell short of meeting all the PREA criteria or were not gender-specific. Each site was
at a different degree of compliance, some requiring modest modifications with little or no costs and some
requiring significant modifications depending on the state of their current classification process and "gap"
between that and the PREA standard.

Cost Impacts and Their Underlying Causes

41

PREA Cost Impact Analysis
The underlying cause of this impact is solely due to screening requiring sites to modify existing tools or
implement procedures where one does not exist.
The NPREC standard SC1 states, “Employees must conduct this screening using a written
screening instrument tailored to the gender of the population being screened.”
The NPREC standard SC2 states, “Employees use information from the risk screening (SC1) to
inform housing, bed, work, education, and program assignments with the goal of keeping
separate those inmates at high risk of being sexually victimized from those at high risk of being
sexually abusive.”
Prisons
Among the 13 prisons participating in this study, eight reported noncompliance and seven provided a cost
estimate as described in the table below.
Site
MO DOC

Upfront

SC DOC

$

54

OR DOC

$

5

VA DOC
CO DOC

$
$

226
176

WA DOC
RI DOC

$
$

56
1

Yearly
Notes
$ 804 Additional LOE to administer the screening instrument at
intake.
$ 665 Development of new screening instrument and 1 additional
FTE at 17 facilities.
$ 437 Development of new screening instrument and 5 additional
FTEs for increased work load.
Integration of new screening instrument.
Increased LOE for programmer to modify existing
screening instrument.
Cost to upgrade system and train staff.
Increased LOE for programmer to modify existing
screening instrument.

A majority of the costs are the result of having instruments that are not gender-specific or screening
processes that are not conducted at all classification reviews. Therefore, there are upfront costs associated
with modifying the screening tool and ongoing costs to cover the increased workload of conducting more
screenings. Where modifications are needed, prison systems such as the VA DOC can expect an upfront
cost impact of approximately $50,000 associated with integrating the newly developed risk screening tool
into their current review process. CO DOC also considered the cost impact associated with integrating
modifications of the screening assessment tool into their offender management system, resulting in
upfront costs of $176,000 to update their Offender Release of Information to Law Enforcement (ORILE)
database. Unable to gather specifics regarding a cost impact of this standard on its offender management
system, a system similar to CO DOC, Booz Allen assumed an equal impact for VA DOC.
The OR DOC only screens offenders on an as-needed basis. With an increased workload as a result of
screening all offenders, they will be subject to a cost impact of $437,000 per year to cover five additional
staff to conduct screenings.
When a screening instrument is not currently utilized, the cost to develop an instrument and provide the
necessary level of effort to conduct screenings is expected to be considerable. Currently the SC DOC
uses a cell assignment form to match cell mates. This is not considered to be a screening instrument as
defined in the standard therefore SC DOC requires a new instrument and procedure to conduct its
screenings. To develop and implement a written screening instrument throughout its facilities, the SC
DOC estimates $35,000 in upfront costs. In addition, SC DOC will require 17 additional caseworkers at
Cost Impacts and Their Underlying Causes

42

PREA Cost Impact Analysis
$665,000 per year and $19,000 in operations costs to execute the screening process on all inmates in each
facility.
Jails
Among the 16 jails participating in this study, 12 reported noncompliance, of which nine provided a cost
estimate as described in the table below.
Site
Alachua County

WA Pierce County
Miami-Dade

Albany County
Pulaski County
Hennepin County
Anoka County
Denver County
Sacramento County
Aiken County

Upfront Yearly
Notes
$
2 $ 133 2 FTEs to meet the demand for increased level of
screening and to make informed decisions based on new
criteria.
$
1 $ 111 1 FTE for increased level of screening.
$
3 $ 111 1 FTE for increased level of screening. Additional LOE to
modify screening instrument. Yearly cost to separate
inmates and house separately.
$
1 Printing cost for new form to use during admission
process.
$
80
Cost to modify screening instrument for gender.
$
20
Cost to modify screening instrument in the electronic jail
management system.
$
10
Cost to modify screening instrument in existing jail
software.
$
1
Cost to modify screening instrument in existing jail
software.
$
1
Additional LOE to create and implement a new form.
$
<1
Cost to modify screening instrument.

Each site except WA Pierce County currently utilizes a formal screening process. However modifications
to existing screening instruments are required to include the requirements of SC1, primarily genderspecific questions. Each participating jail varied in degree of compliance, where some require modest
modifications with little or no costs and others require significant modifications at a steep cost. Alachua
County, WA Pierce County, and Miami-Dade seem to have a very large gap between current processes
and compliance. They require not only significant modifications but also additional employees to manage
and execute screening altogether, with Miami-Dade even requiring costs to house inmates separately.
Juvenile
As it relates to the juvenile sector, screening for risk of sexual abuse falls under standards AP1 and AP2.
Of the 10 juvenile corrections agencies participating in this study, four reported noncompliance, three of
which reported a cost estimate as described in the table below.
Site
IDJC

CA DJJ
ACJCS

Upfront Yearly
Notes
$ 2,753 $ 1,530 Additional LOE to develop screening instrument and to
administer the new tool. Additional space needed to
separate juveniles.
$
14 $
60 Increased LOE to develop a screening instrument and to
make informed decisions.
$
1
Cost to modify the screening instrument.

Cost Impacts and Their Underlying Causes

43

PREA Cost Impact Analysis
At the IDJC residents are screened during intake on a needs assessment, yet, there is not an instrument in
place to measure for predators and victims. The IDJC estimates $45,000 to develop a screening
instrument and an additional $24,000 in yearly administering costs. Further, IDJC indicates that 37% of
its juvenile offenders have a history of sexual offending, or 128 offenders. With only 113 beds available,
IDJC anticipates requiring a minimum of 15 additional beds. IDJC has provided an upfront cost for a 36bed expansion and an ongoing cost per day of $275 per offender.
Community Corrections
Of the six community corrections jurisdictions that participated in this study, only two reported
noncompliance and only WA CC has an associated cost impact as described in the table below.
Site
WA CC

Upfront
$
64

Yearly

Notes
Cost to develop screening instrument and train personnel.
Increased LOE to upgrade information system and train
staff on new procedures.

The Screening Standards are required of community correction facilities, not jurisdictions solely
governing probation and parole (SC PPP and MO PP). WA CC screens every offender who enters a work
release center and again when an offender is transferred, however WA CC asserts that their screening
instrument and process is not in compliance with SC1, leading to a one-time cost of $11,000 to develop a
written screening instrument and train personnel on administering procedures. The level of effort
associated with upgrading the information systems, training time, and documentation of new procedures
was estimated to cost $54,000 in upfront fees.
Lockups
Of the four lockup facilities participating in this study, only Middleton PD reported noncompliance seen
in the table below.
Site
Middleton PD

Upfront

Yearly
Notes
$
20 Additional LOE for booking based on updated screening
criteria.

The Middleton PD estimates that additional screening requirements would lengthen the booking
procedure and shorten the time that arresting officers can be in the field. The Middleton PD estimated that
the NPREC standards would result in an hour extra for each booking. To cover the cost of backfilling
occupied positions the Middleton PD estimated $20,000 to cover these additional hours

Cost Impact #11 - Contract Modifications for Outside Services (RP2 through RP4 and
RE3)
Agreements with Outside Public Entities and Community Service Providers (RP2), Agreements with
Outside Law Enforcement Agencies (RP3), Agreements with the Prosecuting Authority (RP4), and
Inmate Access to Outside Confidential Support Services (RE3) are treated as one cost impact in this study
because they share similar characteristics and each require establishing contracts or agreements for
external services (unrelated to the confinement of inmates) and for the case of RE3, ensuring that
offenders are aware of the victim advocate services available to them. Collectively, these three standards
account for just under 1% of the total cost impact across all sectors. Although most sites are compliant
with both RP3 and RP4 (88% compliance for each), the compliance rate for RP2 is considerably less at
Cost Impacts and Their Underlying Causes

44

PREA Cost Impact Analysis
24% due to the nature of the services. RP3 and RP4 rely upon services generally mandated by state and
county laws whereas RP2 is dependent on non-profit organizations that are not mandated by law and in
fact are often discouraged from supporting offenders resulting in lower compliance and higher costs.
Finally RE3 is somewhat related to RP2. When an agency decides to contract with or enter into an
agreement with a local or national non-profit to provide emotional or transitional support services, that
agency will need to ensure that offenders are aware of these services and have the knowledge of how to
contact them. This is seen as a one-time, upfront cost to capture printing and material expenses.

Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

$
$
$
$

Upfront Range

Yearly Range

High

High

20
26
46
4

Low
$
$
$
$

1
1
1
1

Low

$ 1,214

$

40

$
$

$
$

8
126

50
126

Percent
Compliant
56%
64%
60%
50%
100%

Contracting with outside entities for services is a practice that was seen at numerous sites in this study.
These include contracts with local non-profit organizations that provide Emotional Support Services
(RP2) and local law enforcement entities that provide Investigative Support (RP3) and Prosecutorial
Support (RP4). The vast majority of sites (76%) do not have existing contracts with emotional support
providers subsequently leading to the primary cost driver in this category. Booz Allen uncovered
instances where a rape crisis center would charge a fee when providing services to an offender due to
Victims of Crime Act (VOCA) funding restrictions. Many sexual assault service providers are funded in
whole or in part by the VOCA Victim Assistance formula grant program. These funds cannot be used for
―perpetrator rehabilitation and counseling." Sub-recipients cannot knowingly use VOCA funds to offer
rehabilitative services to offenders. Likewise, VOCA funds cannot support services to incarcerated
individuals, even when the service pertains to the victimization of that individual. Overall, this funding
restriction makes it difficult for non-profit agencies to provide their services free of charge to incarcerated
sexual assault victims if much of their funding comes from this formula grant program. Other sites cited a
lack of demand for such services in their community, with fewer providers to choose from resulting in
higher costs.
Of lesser consequence in terms of a cost impact was any agreement with law enforcement entities. Most
sites cited local regulations or state statues that enforced local law enforcement officials to investigate all
crimes and prosecute them with sufficient evidence. There were few occurrences in which a site
expressed difficulties with obtaining adequate service from their local law enforcement agencies requiring
them to enter into contract agreements if such services were not enforced or guaranteed by state or local
statute.
The major underlying causes for these standards are twofold: 1) jurisdictions must enter or attempt to
enter into a Memorandum of Understanding (MOU) with outside service providers to provide inmates
with confidential emotional support services related to sexual abuse and to help victims of sexual abuse
during their transition from incarceration to the community, and 2) some sites must actually pay for local
law enforcement services when it comes to providing services to inmates.

Cost Impacts and Their Underlying Causes

45

PREA Cost Impact Analysis
The NPREC standard RP2 states, “….The agency also maintains or attempts to enter into MOUs
or other agreements with community service providers that are able to: (1) provide inmates with
confidential emotional support services related to sexual abuse and (2) help victims of sexual
abuse during their transition from incarceration to the community...”
The NPREC standard RP3 states, “… the agency maintains or attempts to enter into a written
MOU or other agreement specific to investigations of sexual abuse with the law enforcement
agency responsible for conducting investigations…”
The NPREC standard RP4 states "… the agency maintains or attempts to enter into a written
MOU or other agreement specific to investigations of sexual abuse with the law enforcement
agency responsible for conducting investigations."
The NPREC standard RE3 states "…the facility provides inmates with access to outside victim
advocates for emotional support services related to sexual abuse. The facility provides such
access by giving inmates the current mailing addresses and telephone numbers, including tollfree hotline numbers, of local, State, and/or national victim advocacy or rape crisis organizations
and enabling reasonable communication between inmates and these organizations."
Prisons
Of the 13 prisons in this study, only six are estimated to have costs associated with standards RP2 through
RP4 shown in the table below.
Site
WA DOC

NY DOC
AR DOC
CO DOC
IN DOC
MO DOC
SC DOC

Upfront Yearly
Notes
$
4 $ 1,214 Development of MOUs with law enforcement agencies
and the DA's office. Cost to provide outside access to
services.
$
$ <1
500 Emotional support and transition services throughout the
state.
$
72 Development of MOUs with service providers.
$
1 $
60 Increased LOE to ensure coordinated process and and that
referrals are made.
$
10 $
40 Development of MOUs with service providers.
$
20
Cost to provide outside access to services.
$
4
Development of MOUs with service providers.

NY DOC's relatively large ongoing costs cover agreements for emotional services in each of the 32
counties with an institution and contracts for transition support services in all 62 NY counties. IN DOC's
cost estimate was calculated based on an assumption of the number of inmates requiring services
assuming a fixed hourly rate for a local service provider for both emotional and transitional support. The
annual cost impact at WA DOC is associated with numerous factors, the largest of which being the costs
associated with contracts to provide emotional and transitional services, $761,000 per year of the total
$1.2 million impact on this standard. Despite the prevalence of service providers in WA, a recent inquiry
into who could contract with WA DOC revealed numerous obstacles due to VOCA funding restrictions
meaning WA DOC would have to pay for these services that would otherwise (as found in most places
across the country) be provided free of charge. Making up the remainder of the cost impact, WA DOC
would have to develop agreements with law enforcement agencies throughout the state subsequent to a
recent discovery that one of the largest counties in Washington will no longer investigate crimes that are
not against county residents. Because there is no consistency in how counties handle investigations and
Cost Impacts and Their Underlying Causes

46

PREA Cost Impact Analysis
no state statute enforcing local law enforcement to conduct investigations, a formal agreement with all 39
counties in the state is required. WA DOC also believes that MOUs are necessary with DA Offices,
based on the inconsistent manner with which prosecutors move investigations through the court system.
Jails
Most facilities in this study have some sort of agreement in place with an external vendor or community
organization that provides emotional support and can help victims of sexual abuse transition from
incarceration to the community. These partnerships are arranged loosely and mostly are not codified with
an MOU or formal written agreement. Formalizing this partnership however, does not equate with a
significant or reportable cost for most facilities. On the other hand some facilities do expect costs mostly
due to administrative or legal feels to draft and formalize the agreement. These costs are all between
$500 and $2,000 and impact WA Pierce, Essex, Hennepin, Alachua, and Aiken counties shown in the
table below.
Site
Alachua County

Upfront
$
26

Marion County

$

9

Sacramento County

$

5

Anoka County

$

4

Essex County

$

2

Hennepin County
WA Pierce County

$
$

2
2

Aiken County

$

1

Yearly

Notes
Cost to provide inmates with outside access to support
services and development of MOUs.
Cost to provide inmates with outside access to support
services.
Cost to provide inmates with outside access to support
services.
Cost to provide inmates with outside access to support
services.
Development of MOUs with service providers and cost to
provide outside access to support services.
Development of MOUs with service providers.
Development of MOUs with service providers and cost to
provide outside access to support services.
Development of MOUs for the Cumbee Center.

Juvenile
A majority of the juvenile correction agencies in this study do not use MOUs or other agreements with
outside public entities for the provision of the services identified in this standard, which include support
services, investigative services and prosecuting procedures; only five believe that a cost will be incurred
to do so shown below.
Site
ACJCS
IN DYS
CA DJJ

IDJC
MO DYS

Upfront Yearly
Notes
$
1 $
50 Development of MOUs with service providers.
$
3 $
30 Transitional services of residents and cost to provide
outside access to support services.
$
24 $
19 Development of MOUs with service providers and process
for receiving reports from a public entity, and for
transitional services.
$
46 $
8 Development of MOUs with service providers.
$
4
Cost to provide outside access to support services.

The costs are associated primarily with the Provision of Support Services (RP2) by outside entities and
community service providers. It is estimated that the IN DYS will accrue an annual cost of $30,000 to
contract with an outside entity to provide support service. ACJCS has a contract with a service provider
Cost Impacts and Their Underlying Causes

47

PREA Cost Impact Analysis
but it does not provide the specific services required by PREA, requiring them to look elsewhere and
establish a contract with a new entity costing approximately $50,000 per year. On the other hand, CA DJJ
expects to incur a one-time cost of $20,000 as a result of establishing a process for receiving reports from
public entities and coordination of the services to residents. This will be followed by an annual cost of
$19,000 for transition counseling services to victims of sexual abuse.
In regards to Conducting Criminal Investigations and Prosecuting Violations (RP3 and RP4,
respectively), most juvenile correction jurisdictions in this study noted that state and local police
investigate cases and local prosecutors, such as District Attorney’s, prosecute violation. Because these
entities operate under state and local statues, MOU’s would generally not be required. IDJC on the other
hand feels that MOUs would be required and if the state statute did not meet the standard, they would
have to develop MOUs with each of the state's 44 counties for both investigations and prosecutions
resulting in a one-time cost of $42,000.
Community Corrections
As for establishing MOUs with law enforcement, only one community corrections site has a modest
ongoing cost associated with these NPREC Standards, WA CC. Because WA CC is integrated with WA
DOC, they share the same, yet proportional to size, cost impact. The estimated cost associated with
contracts to provide emotional and transitional services is $79,000 per year for the same reason as WA
DOC, VOCA funding restrictions and the need to pay for services that would otherwise be free.
WA CC would have to develop agreements with law enforcement and prosecuting agencies at each of the
state's 39 counties to ensure investigations are conducted estimated at $47,000 per year. In addition, this
cost covers agreements with other agencies that do not receive VOCA funding.
Site
WA CC

Upfront Yearly
Notes
$
4 $ 126 Development of MOUs with outside service providers and
39 counties for investigation of crimes and prosecutions.
Costs to provide outside access to support services.

MO PP
IN DOR

$
$

3
1

Cost to provide outside access to support services.
Cost to provide outside access to support services.

Lockups
As it relates to lockups, contract modifications and/or policy updates fall under standards PP2, RP2, and
RP3. None of the lockups in this study are estimated to have costs associated with NPREC standards RP2
through RP4. Given the relatively few number of inmates housed in lockups and the short duration of
time they are confined, lockups generally do not contract with other facilities and do not provide services
as outlined in this standard.

Cost Impact #12 - Evidence Protocol and Forensic Medical Exams (RP1)
Evidence Protocol and Forensic Medical Exams (RP1) has a relatively minimal cost impact when
compared with the other standards, yet there are some sites and scenarios that suggest this could have a
sporadic impact nationwide. As shown in the chart below, upfront costs vary by a few thousand dollars
and are the result of two factors, upfront costs associated with hiring a new employee or maintaining and
developing an MOU. Yearly cost associated with prisons range anywhere from $842,000 to $6,000,
$61,000 to less than $1,000 for jails, and $230,000 to $1,000 for juvenile facilities. Any yearly costs
Cost Impacts and Their Underlying Causes

48

PREA Cost Impact Analysis
associated with community corrections result in less than $1,000, while a study of lockups revealed no
yearly cost impact.

Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

Upfront Range
High
Low
$
11 $
8
$
1 $
1
$
4 $
4

Percent
Yearly Range
High
Low Compliant
$ 842 $
6
62%
$
61 $
1
75%
$ 230 $
1
70%
67%
75%

The underlying cause of this impact is due to the requirement for agencies to make available a victim
advocate during the medical exam process. The NPREC standard RP1 states,
“The facility makes available a victim advocate to accompany the victim through the forensic
medical exam process.”
Prisons
Of the 13 prison systems analyzed, more than half responded that a victim advocate is made available by
the local hospital in coordination with the Sexual Assault Nurse Examiner (SANE), resulting in zero cost.
Others, such as the CA DOC, have MOUs in place between each of its 31 institutions and a local rape
crisis center. Shown in the table below, upfront costs range from a low of $8,000 for SC DOC to develop
an MOU and $4,000 for IN DOC for upfront costs associated with a new employee. The real impact
however, is seen in the ongoing costs. These costs are considerably higher, upwards of $843,000 per year
to cover the cost of maintaining agreements and/or contracts with victim advocacy services that provide
emotional and transitional support services.
Site
IN DOC
NY DOC
AR DOC
SC DOC

Upfront Yearly
Notes
$
11 $ 842 Part-time internal advocate at each facility.
$ 250 "Fee for Service" contract to provide services.
$
6 Designation of current FTE from victim response team to
serve as victim advocate.
$
8
Modification of current medical contract to provide
support.

The prison systems in this study shared various strategies to provide victim advocacy support in the event
it was not available free of charge at the local hospital. NY DOC, for example, must develop a contract
with local hospitals to accompany their victims of sexual assault. An estimate of $250,000 annually has
been recorded using Medicaid rates as a fee structure. To ensure availability of a victim advocate
throughout the process, others such as the IN DOC require that an internal position including overtime
and benefits be created, resulting in an annual cost of $842,000. AR DOC suggests designating a current
member of their victim response team as a victim advocate. An annual cost of $6,000 was provided for
training and any overtime associated with providing victim advocacy services.
Jails
Half of the facilities are currently providing victim advocacy services in coordination with the SANE at
the local hospital, medical center, or through other community-based groups such as the local Rape Crisis
Center or YWCA. Of the 16 jails studied, only three identified a cost impact associated with providing

Cost Impacts and Their Underlying Causes

49

PREA Cost Impact Analysis
victim advocacy services. Alachua County requires that an internal position including overtime and
benefits be created, resulting in an annual cost of $61,000. Peumansend Creek has identified a victim
advocacy support service within their community which provides these services at a nominal annual fee
of approximately $1,000. Aiken County will need $100 to cover the level of effort of a current staff
member not assigned to the security section to accompany a victim during the medical exam process,
assuming one incident per year.
Site
Alachua County
Peumansend Creek

Upfront Yearly
Notes
$
1 $
61 Additional LOE to provide advocacy services.
$
1 Fee charged by outside advocacy support group to provide
service.
$
<1 Per incident fee based on one incident per year.

Aiken County

Juvenile
In most cases, victim advocacy services are made available to juvenile facilities by an outside entity such
as a local hospital or a victim advocacy provider within the community. Two of the ten juvenile
corrections agencies analyzed however, have a cost associated with providing victim advocacy services to
its residents. In the case of the IN DYS, which consists of seven facilities, some of which are located in
rural areas of the state, victim advocacy services are not always provided by the local hospital. It may
also be difficult to find community-support services which are available when requested. For these
reasons, and to ensure an advocate is made available 24/7 in the event of an emergency, the IN DYS
requests an additional part-time FTE at each facility. This results in an annual cost estimate of
approximately $230,000. Based on a relatively low number of incidents confirmed over the past couple
of years, both the FL DJJ and the IDJC provided an estimate based off of a per incident fee. IDJC on the
other hand provided an estimate based on a cost per incident. This approach is considered more cost
effective especially for jurisdictions that encounter a relatively low number of incidents on a yearly basis.
Site
IN DYS
FL DJJ
IDJC

Upfront Yearly
Notes
$
4 $ 230 0.5 FTE at each of 7 facilities to provide internal victim
advocate.
$
4 Per incident fee based off of average number of incidents
annually.
$
1 Hourly fee of a victim advocate based off of number of
previous incidents.

Community Corrections
None of the community correction jurisdictions in this study are estimated to have any notable costs
associated with forensic medical exams.
Lockups
None of the lockups in this study are estimated to have costs associated with forensic medical exams.

Cost Impact #13 - Investigations (IN1 and IN3)
IN1 and IN3 account for just over 0.5% of total overall ongoing costs and have an average compliance
rate of 68% with IN1 having 41% and IN3 having 96%. Its primary impact is due to additional staff to
conduct more frequent investigations or ensure that investigations are conducted properly and thoroughly.
Cost Impacts and Their Underlying Causes

50

PREA Cost Impact Analysis
As the table shows below, the cost impact was not as widespread as the noncompliance rate would
suggest, impacting only six sites across prisons, jails, and juvenile facilities.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$
10
$
1
$
3

Low
$
$
$

1
1
1

Yearly Range
High
$ 516
$ 182
$ 227

Percent
Low Compliant
$
98
54%
$ 182
78%
$
64
55%
92%
75%

The primary underlying cause of this cost impact is dues to an increased volume of investigations as a
result of more reports.
The NPREC standard IN1 states, “The facility investigates all allegations of sexual abuse,
including third-party and anonymous reports...."
The NPREC standard IN-3 states, “Allegations of sexual abuse are substantiated if supported by
a preponderance of the evidence."
Prisons
Due to an anticipated higher number of investigations and reports as a result of PREA, primarily more
reports, MA DOC will require 11 additional investigators at an annual cost of $516,000 plus associated
one-time upfront hiring costs. Similarly, OR DOC anticipates a workload increase to carry out more
investigations requiring two part-time investigators in two parts of the state, resulting in one FTE or
$98,000 per year plus associated one-time upfront hiring costs.
Site
MA DOC
OR DOC

Upfront Yearly
Notes
$
10 $ 516 11 additional FTEs due to changes in grievance
regulations and third-party reporting.
$
1 $
98 Additional 0.5 FTE on both the east and west of state to
account for increased workload.

Jails
Only one jail, Sacramento County indicated a need for an additional investigator at a cost of $182,000 per
year plus associated one-time upfront hiring costs. They feel this would allow for every incident to be
investigated as well as notification of completed investigations.
Site
Sacramento County

Upfront Yearly
Notes
$
1 $ 182 1 additional FTE to ensure all reports are investigated and
notification of completed investigations is made.

Juvenile
IDJC does not have an investigation unit. With an anticipated increase in reporting, it is estimated that
IDJC will need to add at least one internal investigator to ensure that incidents are investigated by trained,
qualified staff. This would include responding to and reporting on all third-party reports and would result
in an annual cost of $64,000 per year plus associated one-time upfront hiring costs. Likewise, MA DYS
expects to hire at least two more investigators to comply with an expanded sexual abuse definition which
will lead to additional investigations and level of effort. Two investigators at MA DYS hired with this
Cost Impacts and Their Underlying Causes

51

PREA Cost Impact Analysis
specific expertise have an annual cost of $178,000 plus associated one-time upfront hiring costs. Finally,
OYA asserts it will need three additional investigators at a cost of $227,000 per year plus associated onetime upfront hiring costs
CO DYC relies upon their local Social Service Agency and/or law enforcement agencies to conduct all
investigations of sexual abuse but does not believe they are being administered adequately. With
anticipated increased sexual abuse reports as a result of PREA, CO DYC believes that the addition of an
Inspector General will support a better practice and Ensure Cases are Investigated when Substantiated by
a Preponderance of the Evidence (IN3). CO DYC is the only site among the 49 to have a cost for IN3.
This cost is $79,000 per year plus associated one-time upfront hiring costs.
Site
OYA
MA DYS
CO DYC
IDJC

Upfront Yearly
Notes
$
3 $ 227 3 additional FTEs would be required. OYA is currently
understaffed.
$
2 $ 178 2 additional FTEs required due to anticipated increase in
number of investigations.
$
1 $
79 1 additional FTE to ensure that proper investigations are
taking place based on standard.
$
1 $
64 1 additional FTE is required to ensure investigators are
conducted as the standard requires.

Cost Impact #14 - Supplement to SC2: Use of Screening Information (ID-6)
Accounting for a mere 0.3% of total overall ongoing costs, the use of screening information of immigrant
detainees is notable because of its low compliance rate (51%) and potential for its impact on the U.S.
Marshals Service (USMS) and Immigration and Customs Enforcement (ICE). Going into this study, it
was assumed that (primarily) jails would be unprepared for this standard because it requires housing
inmates separately subsequently requiring significant facility or physical infrastructure modifications if a
site chooses to take these detainees. If a site decides to no longer house detainees as a result of PREA, the
burden is passed back to USMS and ICE.
Prison and jail jurisdictions included in our study were asked to reveal any existing relationships with ICE
for the temporary housing of detainees. While no prison jurisdictions anticipate a cost impact associated
with compliance, several jail facilities revealed a cost impact related to the separate housing of immigrant
detainees.

Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

Upfront Range
High
Low
$

9
n/a
n/a
n/a

$

9
n/a
n/a
n/a

Percent
Compliant
100%
$
3
81%
n/a
n/a
n/a
n/a
n/a
n/a

Yearly Range
High
Low
$

515
n/a
n/a
n/a

The underlying cause of this impact is attributed to the need for immigrant detainees to be separated from
the general inmate population. The NPREC standard ID6 states,
“Any facility that houses both inmates and immigration detainees houses all immigration
detainees separately from other inmates...”

Cost Impacts and Their Underlying Causes

52

PREA Cost Impact Analysis
Jails
To house immigrant detainees separate from other inmates, jail facilities currently found to be
noncompliant would require either an increased level of effort or additional cell blocks. For example,
Albany County anticipates that nine additional FTEs will be required in order to ensure that ICE detainees
are housed separately from the rest of the population.
Although a formal agreement does not currently
exist, they mention that taking such measures to ensure separation would not be cost effective based upon
the current revenue generated. Therefore, Albany County would opt not to house these detainees going
forward. Although Marion County does not believe that any additional level of effort would be required,
they are concerned that if their jail facility were at capacity additional cell space would be required. For
10 inmates on average, this would equate to approximately $19,000 per month or $228,000 per year.
Site
Albany County
Marion County
Pulaski County

Upfront Yearly
Notes
$
9 $ 515 9 additional FTEs required to ensure ICE detainees are
housed separately.
$ 228 Additional cell block is required to house approximately
10 ICE detainees separately per month.
$
3 On average, 23 ICE detainees per year for up to 48 hours
would be required to be held separately.

Cost Impact #15 - Hiring and Promotion Decisions (PP6)
Hiring and Promotion Decisions (PP6) has a relatively low compliance rate (22% overall) yet relatively
low costs to meet compliance with this standard. As shown in the table below, upfront costs are limited
to only prisons and jails and average $1,000 whereas ongoing costs impact everyone but lockups with a
low of $1,000 and high of $80,000 per year. These costs are a direct correlation with the number of
employees for each site, roughly equating to the number of annual promotions. Therefore the costs are
most prominent at state prison systems where they might have staff counts in the thousands, and
occasionally, require an additional staff member dedicated to running background checks.
Background checks on new hires are a common practice among correctional institutions, however
background checks for employees being considered for promotion are not as common resulting in low
compliance rates among the sites included in this study with nominal costs to comply.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$
$

Low
1
1

$
$

1
1

Yearly Range
High
$
80
$
5
$
8
$
3

Low
$
$
$
$

4
1
1
3

Percent
Compliant
23%
6%
30%
33%
25%

The major underlying cause for the cost impact is the requirement to conduct criminal background checks
on employees considered for promotion. An additional, but far less frequent, cause for the cost impact
includes the requirement to contact all prior institutional employers. The NPREC standard PP6 states,
“…..Consistent with Federal, State, and local law, the agency makes its best effort to contact all
prior institutional employers for information on substantiated allegations of sexual abuse; must

Cost Impacts and Their Underlying Causes

53

PREA Cost Impact Analysis
run criminal background checks for all applicants and employees being considered for
promotion…...”
Many sites rely on periodic checks, often automatic and annual feeds, alerting them of criminal activity
among its employees. Increasing the frequency of this to include staff considered for a promotion yields
additional fees and/or a level of effort to conduct more criminal background checks. It was assumed that
even if employees are subject to annual criminal background checks, there was a small probability that
that background check synchronized with promotions meaning that an additional check would be required
to meet compliance. As a cost-saving measure, DOJ might want to consider adding language such that a
criminal background check would be required within a certain number of months from the date of
promotion. Therefore if an employee receiving a promotion recently had his/her automatic, annual
background check, that check could be used in the promotion assessment.
Prisons
A majority of costs for prison systems are associated with conducting background checks on employees
being considered for promotion, estimated at $50 per instance shown in the table below.
Site
CO DOC
SC DOC
AR DOC
VA DOC
WA DOC
MN DOC
RI DOC

Upfront Yearly
Notes
$
1 $
80 Cost based off of 713 promotions annually. Additional
LOE is also required.
$
1 $
58 Annual cost to conduct background checks and 1
$
50 Cost to conduct background checks for 1,000 promotions
$
1 $
41 1 additional FTE required to conduct background checks.
$
12 Cost to conduct background checks for 235 promotions.
$
6 Cost to conduct background checks for 122 promotions.
$
4 Cost to conduct background checks for 80 promotions.

A majority of prison systems conduct background checks internally, limiting the cost impact of such an
investigation to an additional level of effort, insignificant enough to note in this study. Where checks are
completed by an external agency, additional fees are accumulated. SC DOC will incur an additional cost
impact having to hire one FTE to support contacting prior institutional employers. Similarly, the VA
DOC requires one additional FTE at $41,000 annually, whose resources will be used to investigate
employees and potential new hires based on guidelines addressed in the standard. The CO DOC, with the
highest cost impact among prisons, is estimated to require one FTE in addition to the costs to conduct
background checks.
Jails
Every jail included in this study conducts criminal background checks on new hires but not for
promotions. Only the Norfolk City jail ensures that its contractors reach prior employers to verify past
employment breaches regarding sex violence. This results in an estimated cost of $1,000. All other costs,
shown in the table below, are associated with conducting background checks on employees being
considered for promotion, and are assumed to be $50 per background check.

Cost Impacts and Their Underlying Causes

54

PREA Cost Impact Analysis
Site
Marion County

Upfront

Yearly
Notes
$
5 Cost to conduct background checks for 100 promotions.

Sacramento County

$

3 Cost to conduct background checks for 63 promotions.

Miami-Dade
Alachua County
Hennepin County
Albany County
Pulaski County

$
$
$
$
$

2
2
1
<1
<1

$

<1 Cost to conduct background checks for 3 promotions.
Cost to modify contract to ensure contractor is contacting
previous employers.

Denver County
Norfolk City

$

1

Cost to conduct background checks for 45 promotions.
Cost to conduct background checks for 40 promotions.
Cost to conduct background checks for 25 promotions.
Cost to conduct background checks for 5 promotions.
Cost to conduct background checks for 4 to 5 promotions.

Juvenile
Similar to jails, all juvenile facilities conduct background checks for new hires but most do not conduct
the checks for promotions. None of the juvenile facilities are estimated to have a cost impact for
contacting prior employers, because most already do this or can at no additional cost. As shown in the
table below, all costs are associated with conducting background checks on employees being considered
for promotion.
Site
FL DJJ

Upfront

MO DYS
CO DYC
IDJC

Yearly
Notes
$
8 Cost to conduct background checks for 166 promotions.
$
$
$

3 Cost to conduct background checks for 60 promotions
3 Cost to conduct background checks for 53 promotions.
1 Cost to conduct background checks for 12 promotions.

Community Corrections
Only one community correction site is estimated to have a cost impact associated with conducting
background checks or contacting prior institutional employers. WA CC, with roughly 62 promotions per
year, will bear a yearly cost of $3,000 to conduct the additional background checks.
Site
WA CC

Upfront

Yearly
Notes
$
3 Cost to conduct background checks for 62 promotions.

Lockups
As it relates to lockups, background checks for hiring and promotions falls under standard PP7 and
estimates are less than $1,000.

Cost Impact #16 - Gathering, Reviewing and Reporting Data (DC1 through DC3)
Sexual Abuse Incident Reviews (DC1), Data Collection (DC2), and Data Review for Corrective Action
(DC3) are treated as one cost impact in this study because they are considered dependent upon each other,
one standard or process logically supporting another. Any attempt at decoupling the two would
undermine the intent of the others. This standard has some of the highest compliance rates and lowest
overall cost impact as shown in the table below. Of the sites not in compliance, a level of effort and
database automation/integration were found to be the primary cost drivers associated with the gathering,
Cost Impacts and Their Underlying Causes

55

PREA Cost Impact Analysis
reviewing, and reporting of sexual abuse data. The compilation of a review team consisting of upper
management officials with input from line supervisors, investigators, and practitioners, resulted in a wide
array of very subjective cost impacts.
Upfront Range

Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$ 301

$

1

$
$
$

$
$
$

1
50
6

15
50
6

Low

Yearly Range

High
$
85
$
1
$
72
$
1

Low
$
$
$
$

1
1
5
1

Percent
Compliant
69%
71%
87%
39%
83%

The underlying cause of this impact is solely due to enhancing existing processes for gathering, reviewing
and reporting of sexual abuse data.
The NPREC standard DC1 states, “The facility treats all instances of sexual abuse as critical
incidents to be examined by a team of upper management officials, with input from line
supervisors, investigators, and medical/mental health practitioners.”
The NPREC standard DC2 states, “The incident-based data collected includes, at a minimum, the
data necessary to answer all questions from the most recent version of the BJS Survey on Sexual
Violence.”
The NPREC standard DC3 states, “Using these data, the agency identifies problem areas,
including any racial dynamics underpinning patterns of sexual abuse, takes corrective action on
an ongoing basis, and, at least annually, prepares a report of its findings and corrective actions
for each facility as well as the agency as a whole.”
Prisons
Of the 13 prison systems participating in this study, nine reported noncompliance, resulting in a cost
estimate shown in the table below. The main cost driver among these four NPREC standards was the
review team found in DC1.

Cost Impacts and Their Underlying Causes

56

PREA Cost Impact Analysis
Site
CO DOC

NY DOC

VA DOC
WA DOC
MO DOC
CA DOC
OR DOC
SC DOC
MN DOC

Upfront Yearly
Notes
$
1 $
85 Cost of a review team based on a confirmed number of
incidents and 1 additional FTE to review, compile, and
report data.
$
1 $
81 Cost of a review team based on a confirmed number of
incidents and 1 additional FTE to prepare report for
facility head.
$
1 $
72 1 additional FTE to review, compile, and report data.
$ 301 $
46 Database improvements and 1 additional FTE to monitor
new database.
$
4 Cost of a review team based on a confirmed number of
incidents.
$
3 Cost of a review team based on confirmed number of
incidents.
$
1 Cost of a review team based on a confirmed number of
incidents.
$
1 Cost of a review team based on a confirmed number of
incidents.
$
10
Increased LOE to automate database.

The NY DOC, WA DOC, CO DOC, and the VA DOC found that the creation of report findings and
recommendations for improvement would require additional FTE support. In each instance, this
additional resource will be used to collect, review, and analyze an increasing flow of sexual abuse data
into the system. To accurately collect and report on the influx of data, it is estimated to cost the MN DOC
a one-time charge of $10,000 to automate its database. Similarly, the WA DOC requires upfront costs of
$301,000 to make necessary improvements to its current data collection system.
Jails
Among the 16 jails participating in this study, nine reported noncompliance but only three had a cost
impact shown in the table below.
Site
Sacramento County

Upfront

Hennepin County
WA Pierce County

$

Yearly
Notes
$
1 Cost of a review team based on a confirmed number of
incidents.
$
1 Cost of a review team based on a confirmed number of
incidents.
<1 $
<1 Cost of a review team based on a confirmed number of
incidents and cost to formalize a process.

Gathering, reviewing and reporting data was not a significant cost driver for the jail sector. Certain
evidence that was examined when looking at this standard included whether the facility was currently
reporting data (e.g., BJS survey on sexual violence), the volume of sexual abuse incidents, and the site's
current reporting and review processes and procedures. Few costs were expressed to comply with these
standards and it was found that most costs could be minimized by using the PREA Coordinator.
Hennepin County and Sacramento County believed that they would need to establish a multidisciplinary
review team as described in DC1.

Cost Impacts and Their Underlying Causes

57

PREA Cost Impact Analysis
Juvenile
Of the 10 juvenile correction agencies participating in this study, four reported noncompliance, with two
reporting a cost estimate indicated in the table below.
Site
CO DYC
CA DJJ

Upfront Yearly
Notes
$
1 $
72 1 additional FTE to gather data from contracted facilities
and prepare annual report.
$
15 $
5 Increased LOE to develop report and cost to maintain that
data for 3 extra years.

A majority of the juvenile corrections agencies in this study were found to be in full compliance with
these standards; the only exceptions being the CA DJJ and CO DYC. The CO DYC estimated $72,000 for
one FTE responsible for gathering data from contracted facilities and preparing an annual report. The CA
DJJ estimated $15,000 to upgrade files and existing servers to store data for an additional three years.
Community Corrections
The six participating community corrections jurisdictions all reported noncompliance, with only the WA
CC reporting a cost shown in the table below.
Site
WA CC

Upfront Yearly
Notes
$
50 $
1 Cost of a review team based on a confirmed number of
incidents.

WA CC uses Sierra, a newly deployed data tracking system that uses sexual abuse data to assess the
effectiveness of current procedure. However, it excludes the consideration of racial dynamics.
Modifying this system to meet the standard is estimated to cost $50,000 upfront. The WA CC does not
have a review team in place in accordance with the requirements of DC1. Booz Allen standardized the
costs associated with formalizing a review team based off of number of confirmed incidents.
Lockups
Of the four lockup facilities, only one reported noncompliance and a cost estimate. The Rocklin PD
estimates the need to update internal records management system to provide the functionality to aggregate
and report on sexual abuse incidents.
Site
Rocklin PD

Upfront
$
6

Yearly

Notes
Cost to update internal records management system.

Cost Impact #17 - Exhaustion of Administrative Remedies (RE2)
Although this standard had a negligible cost impact, it is noted in this assessment since most prison
jurisdictions were found to be noncompliant with an inmate’s exhaustion of administrative remedies after
a 48-hour time period. Several noted that this standard would directly contradict with the Federal Prison
Litigation Reform Act (PLRA) and expressed concern over its pending consequences to current grievance
procedures adopted throughout agencies. In most instances however, quantifying a cost impact as a result
of this change in policy was indeterminate or speculative at best.

Cost Impacts and Their Underlying Causes

58

PREA Cost Impact Analysis
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$
$

Low
1
3

$
$

1
2

Yearly Range
High
$
72
$
25

Percent
Low Compliant
$
72
0%
$
8
69%
90%
83%
100%

The underlying cause of this impact is solely due an offender having exhausted his/her administrative
remedies 48 hours after alerting the agency the need for protection and the contradiction with PLRA. In
terms of cost however, the underlying causes are modifications to existing policies or accompanying a
victim to federal court. The NPREC standard RE2 states,
“An inmate seeking immediate protection from imminent sexual abuse will be deemed to have
exhausted his or her administrative remedies 48 hours after notifying any agency staff member of
his or her need for protection..”
Prisons
CO DOC expressed a cost impact of an increased level of effort associated with a change in policy
restricting investigations to 90 days. A cost of $72,000 annually was provided to hire one additional
Grievance Officer to help meet a shortened deadline.
Site
CO DOC

Upfront Yearly
Notes
$
1 $
72 Additional FTE support in order to meet a reduction in
grievance policy deadline from 95 to 90 days.

Jails
Because of a shortened time frame of incarceration in jails, most did not believe that the 48-hour policy
would have a measurable cost impact on their facility. Where a cost impact was quantifiable, it was
limited to the level of effort attributable to documenting or modifying a policy and additional level of
effort to transfer inmates and provide them with appropriate supervision. Located close to federal court,
Alachua County determined an increased level of effort would be required to temporarily house federal
inmates being heard in federal court. Anoka County considered the cost that it would take to accompany
an increased number of inmates to court. Essex County and Sacramento County provided a cost
associated with the development and modification of facility policy.
Site
Alachua County

Upfront

Anoka County
Essex County
Sacramento County

$
$

3
2

Yearly
Notes
$
25 Additional LOE required to house Federal inmates being
heard in Federal court.
$
8 Increased LOE associated with accompanying inmates to
court.
Modification of policy for 48-hour rule.
Developing a policy for the 48-hour rule.

Cost Impacts and Their Underlying Causes

59

PREA Cost Impact Analysis
Cost Impact #18 - Agency Protection Against Retaliation (OR5)
OR5 does not have any ongoing costs but is included here due to the one-off upfront cost impact
identified at NY DOC. As shown in the chart below, overall, this standard has a compliance rate of 59%
however, with the exception of one site, can be met without any additional costs for all sites.
Upfront Range
Sector
Prisons
Jails
Juvenile
Community Corrections
Lockups

High
$ 500

Low
$ 500

Yearly Range
High

Low

Percent
Compliant
54%
71%
60%
40%
100%

With only one site reporting a cost for this standard, the underlying cause is the requirement to modify
existing inmate tracking systems to accommodate additional data characteristics. The NPREC standard
RE2 states:
"The agency monitors the conduct and/or treatment of inmates or staff who have reported sexual
abuse or cooperated with investigations, including any inmate disciplinary reports, housing, or
program changes, for at least 90 days following their report or cooperation to see if there are
changes that may suggest possible retaliation by inmates or staff."
Prisons
NY DOC does not have a formal monitoring system in place. Inmates and staff who believe they have
been subjected to retaliation for reporting any type of misconduct or for cooperating with an investigation
would typically contact the Office of the Inspector General. Modifications to NY DOC's inmate tracking
system to accommodate this data would cost approximately $500,000, a one-time expenditure.
Site
NY DOC

Upfront
$ 500

Yearly

Cost Impacts and Their Underlying Causes

Notes
Development of a system to permit Central Office
monitoring of inmate victims and witnesses.

60

PREA Cost Impact Analysis

Background and Scope of Study
On September 3, 2003, the Prison Rape Elimination Act of 2003 (P.L. 108-79), hereafter referred to as the
PREA, was enacted by the U.S. Congress to address the problem of sexual abuse of persons in the
custody of U.S. correctional agencies. PREA applies to all public and private institutions and
community-based agencies that house or supervise adult or juvenile offenders. This legislation
established NPREC charged with the mission to develop proposed standards to prevent, detect, respond
to, and monitor the sexual abuse of incarcerated and detained individuals throughout the United States.
On June 23, 2009, the Commission presented its final report to the President, the U.S. Congress, the
Attorney General, the Secretary of Health and Human Services, and other federal and state officials. The
final report (available online at http://nprec.us/publication/) includes the following major provisions:
Development of standards for detection, prevention, reduction, and punishment of prison rape.
Collection and dissemination of information on the incidence of prison rape.
Award of grant funds to help state and local governments implement the purposes of the PREA.
To assist in the review process toward publication of these standards, BJA, a component of the Office of
Justice Programs (OJP) within the U.S. Department of Justice (DOJ), is working with Booz Allen
Hamilton (Booz Allen) to address the costs of implementing these standards.
Scope
This cost impact study represents the second phase of a three-phased project. In Phase I, initial budgetary
cost projections were developed for the implementation of national standards under PREA for nine sites
and were submitted to the DOJ in February 2010. The document provided summary and detailed data of
nine locations identified by the BJA. Specifically, it provided preliminary cost projections for the
implementation of each standard as formulated by the NPREC. These standard-specific cost projections
took into account the assessed difficulty of implementation and the extent to which the existing facility or
jurisdiction does, or does not, have policies and procedures in place related to the standard. Costs
reflected startup, as well as ongoing operational costs on an annualized basis.
Phase II (this report) uses the lessons learned from Phase I and focuses on the standards that have highest
likelihood of a cost impact and the underlying causes. It represents a larger sample of up to, but no more
than, 50 sites across the country representing five sectors, including state prison systems, local jail
jurisdictions, police lockups, state and local juvenile facilities, and community corrections. Specifically,
this report will:
Determine costs specific to each of the proposed standards from a larger number of sites. Booz
Allen will determine the number of variations that are sufficiently distinctive to require separate
estimates and ensure the completeness of cost components for each variation within each sector.
The sectors include federal and state prison systems, local jail jurisdictions, police lockups, state
and local juvenile corrections agencies, and community corrections jurisdictions. Booz Allen
shall ensure the completeness of cost components for each sector and collect enough data to
estimate the cost components for each site type in each sector.

Background and Scope

61

PREA Cost Impact Analysis
Collect detailed cost data from up to 50 additional sites. The total number selected within each
sector shall be determined based on initial assessments of variability among cost components,
with greatest effort directed to sectors with the greatest variation.
Address a comprehensive view of implementation and compliance on a national level, and must
be completed in a time frame supportive of implementation required under the Act. The analysis
will present ―order of magnitude‖ estimates based on a viable number of sites that will achieve an
acceptable level of confidence in the results.
Assess the accounting methods of each jurisdiction or facility and adjust the data accordingly to
obtain more reliable/comparable cost estimates.
Cover additional activities to include:
-

Working with corrections authorities to acquire sufficient data to determine costs linked
to each standard;
Assessing site-level costs data to insure accuracy, completeness and comparability;
Conducting onsite meetings with correctional authorities, as needed, to complete work
tasks;
Producing site-level data files that contain aggregated data for each standard

During Phase III, Booz Allen will develop a cost model designed to facilitate the development of
financial and schedule guidelines for full implementation of the standards to facilitate monitoring of
ongoing financial viability of the NPREC standards and to support ongoing funding justification at the
state and local levels.

Background and Scope

62

PREA Cost Impact Analysis

Study Methodology
Overview
OJP/BJA contracted Booz Allen to complete a cost impact analysis of the NPREC standards on different
correctional facilities, including Adult Prisons & Jails, Juvenile Facilities, Community Corrections, and
Police Lockups. This section describes the study team and the data gathering and data analysis
methodologies that have guided the study thus far.
Study Team – To accomplish this task, Booz Allen assembled a team of qualified specialists in
cost analysis and estimating, criminal justice, and correctional operations. Booz Allen is
providing project management, cost analysis, cost estimating support and expertise, logistics and
planning support, and overall leadership and quality assurance for this effort. Our specialist in
criminal justice provides domain and academic knowledge on sexual violence and correctional
institutions and operations, including targeted expertise on criminal justice policies and programs
in the U.S. prison/jail system and sexual violence in correctional settings. Our specialists in
correctional operations are providing correctional operations domain experience with specific
experience in managing jails, prisons, and juvenile detention facilities across the U.S. They are
prominent members of correctional professional societies, many of whom have served in
leadership positions. They bring an extensive knowledge of the operational requirements of
correctional agencies and a deep understanding of the impact of policy and regulation impacts,
particularly the PREA, on operating budgets. Each of the specialists supporting this study has
extensive knowledge of and/or first-hand experience with NPREC and its mission, some of whom
participated in previous PREA studies and analyses of the standards.
Data Gathering – Data gathering took place in two phases. Phase I focused on gathering data
from 11 sites1 throughout the country with the objective to identify major findings that would be
further explored in Phase II.
The first step in the data gathering for Phase II was the modification of the Phase I questionnaire
(see Appendix C - Approach to Questionnaire Development and Data Gathering). Using the
results from Phase I, Booz Allen isolated questions about standards deemed to have the highest
potential for a cost impact. Those standards were then translated into questions that addressed the
level of detail found in the checklist items, as published in the Commission Standards, with
subsequent questions designed to understand the underlying cause of the cost impact (e.g., cost
drivers). The survey questions were categorized into two primary areas: Major Findings and
Minor Findings. The Major Findings and Issues focused on obtaining a deeper understanding of
common and frequent cost drivers in Phase I while the Minor Findings & Issues focused on
confirming or denying certain one-off findings in Phase I that may or may not have a real cost
impact yet warranted additional research.

1

Nine were required by contract but 11 actually participated.

Methodology

63

PREA Cost Impact Analysis
The questionnaire was imperative in guiding the discussions at each site and for ensuring that
data gathering could be completed within the 2 hours allotted for each meeting—a time
determined to be sufficient for data gathering while respecting the schedule constraints of the
survey participants and their primary function of managing their operations.
Booz Allen also developed a demographic form to obtain additional background information on a
site's unique characteristics such as the incidence and prevalence of sexual abuse; the size the
site/jurisdiction in terms of the number of facilities, staff and inmates; and other variables used in
the analysis such as whether or not the staff are unionized.
The questionnaires and demographic forms were sent in advance of each meeting, and most sites
reviewed the materials to familiarize themselves with the study and the specific data to be
gathered. It was not anticipated that the site would provide answers to the questionnaire upon our
arrival. Most did not, but a few did take time to fill out the questionnaire and demographic form
in advance, expediting the interview process tremendously. Whether filled out or simply reviewed
in advance, the questions were designed to facilitate an interactive, and sometimes spirited,
discussion on the NPREC standards, the extent of their compliance, and the challenges of
compliance from a financial perspective.
Each meeting was attended by, most frequently, four Booz Allen representatives to include an
interview facilitator, a primary note taker, and two subject matter experts with significant
experience in the field of correctional operations and management. Representatives from the site
included the director1 (for the majority of the sites) and members of the director's staff such as the
chief of operations, budget director, training lead, and at times medical and mental health care
professionals. Each meeting began with introductions, a description of the purpose of the cost
impact study, and instructions to facilitate the discussions and anticipated questions and answers.
All sites were familiar with PREA requiring very little background descriptions of the NPREC
standards. The mood of each meeting was amicable and the Booz Allen team received absolutely
no resistance from any of the sites about the inconvenience of participating.
To keep these meetings on track and on point, Booz Allen steered participants away from any
discussions about the merit, efficiency, or efficacy of the standards, focusing solely on the cost
impacts of the PREA standards on their particular site per the statement of work. At the
conclusion of each meeting, the Booz Allen team negotiated a date (typically 2–3 weeks out) to
expect responses containing specific cost data used in this report. To facilitate a response, Booz
Allen typed up the meeting notes and discussion and pre-populated a data template to be returned
to each site immediately after the interview.
The data template used throughout our study was divided into two parts. Part I included those
standards determined to be both major and minor findings and issues discussed in detail as part of
our site visits. Part II referenced specific qualitative aspects of standards addressed in Part I and
each of the remaining NPREC standards not considered to be a major cost driver. Part II gave
1

This could be the Secretary for state systems for prisons, community corrections, or juvenile systems; sheriff or
jail administrator for jails; and police chief for lockups.

Methodology

64

PREA Cost Impact Analysis
each site an opportunity to review the NPREC standards in their entirety, determine whether or
not they were compliant, and while a rare occurrence, provide any potential cost impact not
considered a major or minor finding or issue based on our Phase I study.
Data Analysis – After receiving the data, Booz Allen analyzed the results, which often required
extended and continued conversations with site personnel to clarify data and responses. The
analysis, primarily conducted in a Microsoft Excel-based cost model, segregated the data by
standard, site, and area and then divided the data into upfront and yearly maintenance costs,
defined as follows, in order to report immediate versus ongoing cost impact:
•

Upfront costs, as defined in this report, are any one-time costs required to bring a facility
into full compliance with the NPREC standards, without any implied
ongoing/maintenance costs.

•

Yearly maintenance costs, as defined in this report, are the ongoing operational costs
required to sustain PREA compliance on an annual basis.

Booz Allen neither aggregated the data with the intent of arriving at an analytical conclusion, nor
was the data used to represent a sample of a population for statistical purposes. This report simply
presents the cost impact data for the implementation of NPREC standards on the 49 selected sites.
Applying Lessons Learned from Phase I to Phase II
Phase I set the stage for Phase II, identifying specific standards that either have or do not have a cost
impact. Phase I also served as a logistical pilot phase for the much larger data collection effort in Phase
II. The data obtained during Phase I were analyzed and categorized into major issues and findings. These
issues and findings included an analysis of the data received and an interpretation of the results and
subsequent hypotheses of how the data should be understood. This particular analysis was not conducive
to gaining insight into the underlying causes of the costs associated with each of the issues and standards;
there were many instances where the data were isolated, incongruent, or inconclusive, mostly due to the
small sample size included in this study. This was expected with Phase II designed to remediate these
shortcomings.
The sites visited during Phase I included two local jails, three statewide prison systems, two statewide
juvenile systems, two local juvenile facilities, and one statewide community corrections system. All sites
included in that report were selected by the OJP/BJA. Representation for a lock-up facility was not
accomplished during Phase I, however one site during the data collection, the Ohio Bureau of Community
Sanctions in Columbus, Ohio, returned data for jails and lockups throughout the state. Booz Allen
qualified these data results with the Ohio Department of Rehabilitation and Correction (ODRC) in
accordance with the PREA definition of ―lockup‖ and ―jail‖ and presents this data as such in this report.
Over 7 weeks in the fall 2009, Booz Allen conducted 2-hour meetings with each facility. Two Booz Allen
representatives and at least one specialist with functional expertise in the relevant correctional facility
sector attended each meeting. Attendees from the facilities ranged from 1 to 30, with an average of six
participants, representing directors, operational managers, medical staff, mental health staff, investigators,
and correctional officers. Each meeting began with introductions, a description of the purpose of the cost
impact study, and instructions to facilitate the discussions and anticipated questions and answers. The
Methodology

65

PREA Cost Impact Analysis
mood of each meeting was amicable, and the Booz Allen team received no resistance from the sites about
the inconvenience of participating.
The results of Phase I were a set of major findings. The list below highlights 12 major issues and findings
as they relate to cost impacts or difficulties with implementing the NPREC standards. They are arranged
by impact severity (highest to lowest), as determined by the amount of attention a particular standard
received during the data collection and/or its resulting cost impact. The questionnaire for Phase II was
based on these findings.
Phase I Major Finding #1 – Cross-Gender Pat Downs
The prohibition of cross-gender pat downs may result in significant operational,
workforce, and organizational impacts across the Adult Jails & Prisons, Community
Corrections, and Police Lockups sectors, leading to substantially increased costs that
stem from legal issues and the reorganization of staff. This finding will have less of an
impact on juvenile facilities due to generally higher staff to resident ratios and child
protection laws.
Phase I Major Finding #2 – Inmate/Resident Supervision – Physical Supervision
This issue reflects one of the widest variability in costs because of the varying
interpretations of how best to provide the supervision necessary to protect inmates from
sexual abuse. Responses varied in the costs associated with them—ranging from plans to
enhance staffing to adequate levels (as defined differently by each site) to direct
supervision models with significant staffing increases.
Phase I Major Finding #3 – Inmate/Resident Supervision – Technical Supervision
Similar to Issue #2, this issue reflects a very wide variability in costs from the sheer
number of technological alternatives available to sites —ranging from modest
enhancements of current surveillance equipment to full-blown installations of high-end
surveillance systems with complex data storage capabilities.
Phase I Major Finding #4 – PREA Coordinator
The requirement of a PREA Coordinator will continue to be a cost impact for every site,
resulting in a relatively large cost impact on the aggregate. This cost impact however, is
matter of jurisdiction, and it increases or decreases proportionately with the level of
decentralization versus centralization.
Phase I Major Finding #5 – Training and Education
Not surprisingly, there is a correlation between the training and education requirements
and the number of trainees, whether they are employees, volunteers, or contractors.
However, because of the many alternatives for delivering training, whether it be
classroom or computer based, and the varying frequency of delivering recurring training,
this finding resulted a relatively wide range in costs.
Phase I Major Finding #6 – Victim Advocacy
The requirement for a victim advocate will continue to be an issue and a cost driver in
Phase II, yet the costs associated with this requirement are relatively low when compared
to the other issues. We believe that, similar to the PREA Coordinator position, the victim
Methodology

66

PREA Cost Impact Analysis
advocate position will be a higher cost driver in locations where the administration is
decentralized and will vary depending on whether the site is in an urban versus a rural
setting.
Phase I Major Finding #7 – Gathering, Reviewing, and Reporting Sexual Abuse Data
Gathering, reviewing, and reporting data will likely be an issue throughout the country.
Variables that determine the impact of this issue include whether or not sites are currently
reporting data (e.g., BJS report), their volume of incidents, and the current state of their
information technology (IT) infrastructure.
Phase I Major Finding #8 – Background Checks for Hiring and Promotions
There is a correlation between the number of employees and the cost of conducting
background checks. What is less understood however, are the varying costs of
background checks from place to place; there appears to be no standard on the exact
criteria investigated in a background check.
Phase I Major Finding #9 – Triennial Auditing of the PREA Standards
The PREA specific audit will continue to be an issue throughout the country. Our
findings suggest that costs are relatively equal for prisons, jails, and community
corrections. Juvenile correction agencies, on the other hand appear to have more
stringent audit standards, yielding higher costs. In addition, the DOJ should not overlook
the cost burden of centrally managing and tracking audit data.
Phase I Major Finding #10 – Screening for Risk of Sexual Victimization and Abusiveness
While most sites were in full compliance with the screening process, we anticipate that
many sites will need to update their screening instruments to include PREA-related
questions, however the cost of such an upgrade is relatively small.
Phase I Major Finding #11 – Contract Modifications and/or Policy and Procedure Updates
Contract modifications and updates to policies and procedures will continue to be a cost
incurred from implementing the NPREC standards. However, there is a wide range in
results from doing so, and the costs are relatively small.
Phase I Major Finding #12 – Accommodating Special Needs
Smaller, more remote facilities
will see a greater burden on their
budgets
in
accommodating
special needs because fewer
services, such as interpretive
services, are available in rural
areas. Such services will likely be
sparse and, if attainable from
large metropolitan areas, they
will not be readily available at
crucial times.

Methodology

67

PREA Cost Impact Analysis
Site Selection Methodology
Driving the site selection for the PREA cost impact study were four objectives: 1) Investigate and analyze
variations from the results of the first phase of this study to determine common themes and outliers, 2)
Provide an equitable representation of cost impacts across sectors, regions of the country, and operational
demographics, 3) Identify sites that have a reasonable expectation that they can be willing and effective
participants in this study and 4) Develop a list of sites that facilitate efficient travel and logistics with the
ability to visit multiple sectors (prisons, jails, community corrections, etc.) on one site trip.
The map to above, and table below identify the sites included in the PREA cost impact study.
In addition to Phase I findings, the site selection for this final report was influenced by a number of
factors considered vital to assessing the cost impact of implementing the proposed PREA standards issued
by the PREA commission. These factors include the following:
Geographic location
Size/capacity of the
system/facility
Number of staff
Average daily population (ADP)
ADP to staff ratio
Number of facilities
ADP to facilities ratio
Average cost of care per day
Union presence
Age limit of resident population
(juvenile)
States participating in
Performance Based Standards
(PbS) (juvenile)

SECTOR

Region/State

Adult
Prisons

Community Juvenile
Corrections Facilities

Jails

Lockups
TOTAL

Northeast

3

2

1

1

1

8

Rhode Island

1

-

-

-

-

1

Massachusetts

1

1

1

1

1

5

New York

1

1

-

-

-

2

Midwest

3

4

2

2

1

12

Minnesota

1

1

-

-

1

3

Missouri

1

1

1

1

-

4

Indiana

1

1

1

1

-

4

Wisconsin

-

1

-

-

-

1

South

3

6

2

2

-

13

Arkansas

1

1

1

1

-

4

Florida

-

2

-

1

-

3

South Carolina

1

1

1

-

-

3

Virginia

1

2

-

-

-

3

West

4

3

1

5

3

16

California

1

1

-

1

1

4

1
1
1
1
4
The statistics analyzed were provided Colorado
Idaho
2
2
by
the
American
Correctional Oregon
1
1
2
Association (ACA) 2009 Directory, the Washington
1
1
1
1
4
13
15
6
10
5
49
2009-2010 ACA National Jail and TOTAL
Adult Detention Directory, and the Council of Juvenile Correctional Administrators (CJCA) Yearbook
2009. A breakdown of counts by region, state and sector can be found in Appendix A.

Having visited nine locations and gathered data on 11 sites during the Phase I study, the Booz Allen
team’s objective was to (1) identify as many sites nationwide that mirrored the demographic composition
of Phase I; (2) identify new sites that broadened the diversity of the sites visited previously; and (3)
winnow down the list such that it provides an equitable and balanced representation of the wide variety of
correctional facilities and jurisdictions throughout the country (limited our selection to the lower 48
states). We aimed to cluster as many sectors into one site as feasibly possible to ease the financial and
time burden on travel logistics. Finally, we initially targeted more than 50 sites with the goal of securing
"no more than 50 sites" following the SOW under this contract. Although we were optimistic that we
would have 100% participation from all these sites, we understood a reality that a few sites would opt out

Methodology

68

PREA Cost Impact Analysis
of the study due to logistical/scheduling conflicts or, regrettably, an unwillingness to participate. Meeting
this expectation with a few last minute drop-outs, the study ultimately received full participation from 49
sites. The following paragraphs describe the justification for the sites selected in this study.

Adult Prison Systems
12 prison systems and one combined jail-prison system were selected as part of the Phase II study. More
adult prisons and jails were chosen over the other sectors simply due to their relative proportion (e.g., # of
inmates, # of employees, and budget), to the others. The location of these sites was dispersed evenly
throughout each of the four regions of the U.S. In general, adult prisons analyzed as part of the Phase I
study shed particular light on concerns associated with certain
SECTOR
standards such as PP4 – Limits to Cross-gender Viewing and Searches
and PP3 – Inmate Supervision. Both the Pennsylvania Department of
Adult
Prisons
Corrections (PA DOC) and the Connecticut Department of Corrections Region/State
(CT DOC) expressed grave concern over restrictions linked with cross- Northeast
3
Rhode
Island
1
gender pat down searches and federal and state statutes. By analyzing
Massachusetts
1
similar prison systems throughout the United States, we were better
New York
1
able to determine if these concerns and severe impacts to cost were Midwest
3
commonplace or merely an outlier to the norm.
Minnesota
1
Three prisons were selected in the Northeast. RI DOC was chosen
because it represents a combined jail-prison system. Similar to CT
DOC, RI DOC provided an opportunity to compare jail-prison systems,
while simultaneously, adding to the diversity of our selected sites.
Further, the RI DOC represented the smallest of the prison systems
being analyzed in terms of capacity, number of staff, ADP, and number
of facilities, while simultaneously accounting for one of the highest
amounts in terms of cost of care per day. The RI DOC allowed us to
determine what effect, if any, the size and average cost of care per day,
implementing PREA had on a prison system.

Missouri

1

Indiana

1

South

3

Arkansas

1

South Carolina

1

Virginia

1

West

4

California

1

Colorado

1

Oregon

1

Washington
TOTAL

1
13

The NY DOC has a capacity exceeding 66,000 inmates, third largest of the prison systems represented.
Further, with a total of 67 facilities, we have gained a better understanding of the cost impact PREA has
on implementing standards across one of the most complex and culturally diverse prison systems in the
nation.
Minnesota, Missouri, and Indiana provide a good representation of prison systems in the Midwest.
Capacities range from nearly 10,000 inmates in Minnesota to more than 31,000 inmates in Missouri, with
an ADP between approximately 9,600 in Minnesota and 31,000 in Missouri. Further, cost of care per day
ranges from $45/day in Missouri to nearly $90/day in Minnesota shedding light on which potential
economic factors affect a jurisdiction’s commitment to providing care to its inmates. Minnesota and
Missouri are represented by a union, but Indiana is not. This particular difference provided us to the
opportunity to study how a union’s presences impacts any potential staff changes associated with crossgender pat downs. The blend of small, medium, and large systems, with varying characteristics, allowed
the Phase II study to identify any potential cost drivers exhibited throughout the Midwest prison systems.

Methodology

69

PREA Cost Impact Analysis
Arkansas, South Carolina, and Virginia represented the South. Similar to the Midwest, the VA DOC, SC
DOC, and AR DOC, vary significantly on many factors considered important to the site selection process
referenced above. Each system’s capacity ranges from 13,000 inmates (AR DOC) to upwards of 32,000
inmates (VA DOC). Further, staff population ranges from 3,200 in AR DOC to just over 6,000 in VA
DOC. These discrepancies allowed us to analyze the impact a large variation in multiple factors has on
cost drivers.
In the West, prison systems included the states of California, Colorado, Oregon, and Washington. CA
DOC has an ADP of approximately 170,000 inmates, 33 state prison facilities, and a staff population of
approximately 63,000. CA DOC presented a major opportunity to identify significant cost drivers in one
of the largest and most complex prison systems in the country. Also, with an ADP to capacity ratio of
nearly 3:1, we were able to gain some insight into the cost impact overcrowding might have on
implementing PREA standards. CO DOC and WA DOC were chosen for their significant size and
geographical dispersion throughout the Western region of the U.S. OR DOC is recognized nationally
among correctional agencies for providing inmates with the cognitive, behavioral, and job skills they need
to become productive citizens. We were able to gain a better understanding of the effects implementing
PREA has on a model institution.

Jails
Fourteen jail facilities and one jail system were selected as part of the
Phase II study. The location of these sites was dispersed evenly
throughout each of the four regions of the United States. In general,
jails analyzed as part of the phase I study shed particular light on
concerns associated with certain standards such as PP4 – Limits to
Cross-Gender Viewing and Searches and PP3 – Inmate Supervision.
Kent County Jail (KCJ) initially responded that this standard was
impractical and that they would not be able to comply under any
circumstance. Louisville Metro Department of Corrections (LMDC)
budgeted $1.5 million yearly to adhere to policy standards associated
with Inmate Supervision.
By analyzing similar jail facilities
throughout the U.S., we were better able to understand the quantitative
and qualitative impact that the NPREC standards will have on jail
facilities.

SECTOR
Jails
Region/State
Northeast

2

Massachusetts

1

New York

1

Midwest

4

Minnesota

1

Missouri

1

Indiana

1

Wisconsin

1

South

6

Arkansas

1

Florida

2

South Carolina

1

Virginia

2

West

3

California

1

Colorado

1

In the Northeast, two jail jurisdictions were selected. The Albany Washington
1
County Correctional facility, originally opened in 1931, is one of the TOTAL
15
largest county correctional facilities in the State of New York. Classified as one of 12 mega facilities
(1,000+ beds) in New York, Albany County allowed us to consider the cost impact associated with one of
the larger and older jail facilities being analyzed which served as a good benchmark when further
investigating direct supervision and PP3.
Minnesota, Missouri, Indiana, and Wisconsin provided a good representation of jail facilities in the
Midwest. Similar to the uniqueness of each prison system represented by the Midwest, jail facilities were
represented by one mega facility (1,000+ beds), two medium facilities (50-249 beds), and one small
facility (1-49 beds). The Pierce County Jail in Wisconsin represented the lone small jail facility selected
Methodology

70

PREA Cost Impact Analysis
as part of phase II. Further, because none of the jails represented by the Midwest are ACA accredited, the
team was better able to determine whether ACA-accredited facilities are more or less likely to have less
of a cost impact than unaccredited (by ACA) facilities.
Arkansas, Florida, South Carolina, and Virginia represented the South. Categorized as mega facilities
(1000+ beds), KCJ and LMDC estimated a significant cost impact associated with PP7 – Assessment and
Use of Monitoring Technology and PP3 – Inmate Supervision. Miami-Dade’s five correctional facilities,
with a capacity of almost 6,000 and an ADP of over 6,300 inmates, allowed us to determine whether high
impact costs associated with certain standards are commonplace throughout large, integrated jail systems.
In order to maintain an accurate representation of different size jail facilities throughout the South, three
large jail facilities (250-999 beds) were selected; the Norfolk City Jail and the Peumansend Creek
Regional Jail in Virginia, and the Aiken County Detention Center in South Carolina, and one medium jail
facility (50-249), the Pulaski County Regional Detention Facility in Arkansas.
In the West, jail facility site selection included the states of California, Colorado, and Washington. The
Sacramento County Jail was the largest single jail facility analyzed as part of our Phase II study, with a
capacity of more than 4,000 beds. Two additional mega facilities (1000+ beds), the Denver County Jail
and the Pierce County Detention/Corrections Center in Washington State, were chosen as representative
jail facilities in the West region because of their size and potential for helping us to identify cost drivers
associated with implementing PREA. Additionally, the Pierce County Detention/Corrections Center has
expressed a keen interest in this study and was very willing to participate.

Juvenile Facilities
At 10, juvenile facilities represented the third most sites chosen in
SECTOR
the selection process. One of the primary reasons for selecting more
Juvenile
juvenile facilities over community corrections and lockups is due to
Facilities
Region/State
the recent publicity of the juvenile detention statistics released by
Northeast
1
BJS in mid-January. In addition, the placement of the juvenile
Massachusetts
1
correctional agency within the executive branch of state government Midwest
2
impacts the agencies’ jurisdiction, authority, scope of services, Missouri
1
Indiana
1
budgets, and leadership. This profile was taken into consideration
South
2
when making site selections and the team was conscientious of
Arkansas
1
selecting at least one representative juvenile facility from each of the Florida
1
four agency profiles in existence. Further, we understand the West
5
distinction associated with the different types of facilities and California
1
Colorado
1
programs categorized under each juvenile system. For the purposes
Idaho
2
of our Phase II cost study, the team included sites categorized as
Oregon
1
institution, secure treatment, and training school, detention, TOTAL
10
reception/assessment/diagnostic center, and other secure residential
facility (ranch, camp). Finally, we made our site selection based on PbS participation, a program to
improve the conditions, practices, and services in youth correction and detention facilities.
The Arizona Department of Juvenile Corrections (ADJC) and the Texas Youth Commission (TYC), both
free-standing programs, identified a high cost impact associated with PREA standards, PP3 – Resident
Supervision, RE-4 – Third-party Reporting, RP1 – Evidence Protocol and Forensic Medical Exams, TR1
Methodology

71

PREA Cost Impact Analysis
– Employee Training, and DC1 – Sexual Abuse Incident Reviews. By visiting additional free-standing,
secure facilities such as the IDJC in the West, Booz Allen was able to compare the high cost impact
realized as part of our Phase I study, with similarly organized juvenile systems while in different regions
of the country.
Florida Parishes Juvenile Detention Center budgeted for more than $900,000 in costs associated with
camera replacement and one server. Likewise, the TYC received $18.5 million in 2007 for installation of
video monitoring equipment and $1.5 million for 12 new FTEs to maintain the system. Assessing large
and complex systems such as the FL DJJ and the CA DJJ, both much larger than Florida Parishes and
TYC, we were able to gain a better understanding of how size can directly impact the implementation of
certain PREA standards.
While Phase I provided a great foundation to begin Phase II, we used Phase II as an opportunity to expand
our juvenile selection to other agency profiles and facilities/programs that captured a representative
sample of all juvenile systems/facilities throughout the United States, thus broadening our diversity of
selected sites.
The MA DYS represented an agency under human services, categorized by 57 institution, secure
treatment, and training school facilities. Categorized as a PbS, with a capacity of 1,000 beds, and an age
limit of 21 years, the MA DYS will served as a good representative sample of a juvenile system in the
Northeast with characteristics that had not yet been assessed upon completion of Phase I.
The Midwest was represented by the states of Missouri and Indiana. The MO DYS falls under the
Division of Child Welfare/Social Service and represented 32 facilities in total, with a capacity of 801.
MO DYS allowed us to analyze juvenile systems under the division of child welfare/social service, to
determine what cost effect, if any, this type of system might have in addition to other agency profiles.
The IN DYS, under the Division of Adult Corrections, represented seven facilities with a capacity of just
over 1,100 and an ADP of 805. The size of the system, coupled with yet another division not previously
analyzed as part of Phase I, made this juvenile system appealing.
The South was represented by two juvenile systems in the states of Arkansas and Florida. The FL DJJ is
a free standing system of 25 detention facilities and 76 residential facilities with the capacity to house
approximately 6,400 residents. At 101, the FL DJJ boasts 47 more facilities than its next largest
competitor, MA DYS, chosen as part of our study. The high number of facilities allowed us to examine
potential cost drivers associated with implementing PREA throughout a large, complex system.
Specifically, we were able to closely analyze those standards that have a direct correlation to large
facility, high capacity systems, such as PP7 – Assessment and Use of Monitoring Technology and AU1 –
Audits of Standards. Because the State of Florida does not participate in PbS, our team was able to
identify any additional cost impact associated with not participating in the PbS program. The AR JA falls
under the agency profile of Division of Child Welfare/Social Services. It is classified as a reception
facility, the only one of its kind chosen as part of our Phase II study. By analyzing the AR JA, we were
able to determine any significant cost impact associated with a juvenile reception facility, heretofore not
included in this study.
The West included three state run systems and one independent detention facility, located in California,
Colorado, Oregon, and Idaho. With a capacity of approximately 4,600 beds, the CA DJJ provided a great
Methodology

72

PREA Cost Impact Analysis
opportunity to examine the largest juvenile system chosen as part of our Phase II process. It was one of
two Division of Adult Correction profiles analyzed, consisting of six secure institutions. Furthermore, it
boasts the highest age limit at 25. We were given the opportunity to consider all of these factors when
analyzing a potential cost impact. The CO DYC is an agency under human services consisting of 11
secure facilities. Booz Allen considered Colorado a great opportunity to investigate a distinct agency
responsible for the management and oversight of state-operated and privately contracted residential
facilities in the Western region of the nation. Finally, the IDJC serves as a free-standing agency in the
executive branch, responsible for three state correctional centers. Also, in an effort to assist Idaho’s 44
counties with the development of the juvenile system under the Juvenile Corrections Act, the Department
has a District Liaison assigned to each of the seven judicial districts that are available to provide
assistance to county elected officials, the courts, probation, and contract placement providers. We
examined what benefits or drawbacks, if any, this relationship had on implementing PREA standards.

Community Corrections
Six community corrections facilities were chosen as part of the
SECTOR
Phase II selection process. During Phase I, the Ohio Bureau of
Community
Community Sanctions (OBCS) served as the lone representative of
Corrections
our cost impact study. The OBCS oversees the state’s subsidy
Region/State
programs, including halfway houses, Community Corrections Act, Northeast
1
and community-based facility programs. Accounting for more than Massachusetts
1
2
26 agencies and 159 probation agencies, the cost impact associated Midwest
1
with implementing PREA standards was high. In selecting sites for Missouri
Indiana
1
purposes of the Phase II study, our focus was on geographically
2
dispersed community corrections systems which capture the size and South
Arkansas
1
complexity of the OBCS. Doing so allowed us to examine the high
1
cost impact associated with standards such as Prevention Planning, South Carolina
West
1
Training and Education, Screening, Official Response, Medical and
1
Mental Health Care, and Data Collection and Review. Doing so, we Washington
TOTAL
6
were able to determine whether costs associated with the OBCS
were an anomaly or a growing trend of costs associated with implementing PREA standards throughout
all community corrections systems in the country.
The MA OCC encompasses over 20 adult community correctional centers spread throughout the entire
state. According to the Utilization of Community Corrections Centers Statistical Report, FY 2008, on
average, 1,147 offenders were participating in programs at the community corrections centers. The
community correction centers are community based, intensive supervision sites, delivering bundled
sanctions and services, including treatment and education. As the lone representative in the Northeast, the
size, complexity, and similar service offerings, made the MA OCC a prime candidate for comparison with
the OBCS.
The Midwest included community corrections systems in the states of Missouri and Indiana. The IN
DOR oversees both adult work release facilities and adult contract facilities and has realized a growth in
number of participating counties from 19 to 73. In addition, over 53,000 adults were being served during
FY 2008, 51% of which were felons. Their increase in growth and oversight of varying programs and

Methodology

73

PREA Cost Impact Analysis
contracted facilities throughout the state, made participation of IN DOR essential to the community
corrections section of our study.
The South included community corrections facilities in Arkansas and South Carolina. The AR JA and the
SC PPP prerelease centers provided a good geographic dispersion of the remaining portion of the
Southern region of the United States. SC PPP allowed us to focus our efforts on six specific prerelease
centers to determine any additional cost impact associated specifically with prerelease centers conforming
to standards set by the PREA commission. Similarly, the AR JA is responsible for parole and probation
services and community correctional facilities. With a vast array of programs including probation,
regional correctional facilities, education, and mental health services, AR JA provided further insight into
the high cost impact associated with OBCS.

Lockups
Unlike the other sectors, Phase I did not yield a clear strategy for
locating and identifying lockups, primarily because there was only
one lockup representative during that study, the Delhi Township
Police Department.

SECTOR
Lockups
Region/State
Northeast

1

Locating and arranging site visits with lockups remotely (via phone
Massachusetts
1
or email) posed several challenges because, as we learned, few
West
3
lockups have primary points of contact that are solely responsible for
California
1
the holding facility since they are run out of a police department and Colorado
1
officers are responsible for field duty and inmate supervision as an Washington
1
ancillary duty. To overcome these challenges, Booz Allen employed TOTAL
4
a strategy of locating candidates while on existing site visits for the
other sectors. To locate candidates we relied upon recommendations and referrals from jail
administrators under the assumption that most had professional relationships with lockups in their
respective counties, frequently obtaining transfers from these lockups. For example, the Essex County
Jail Director referred our team to Middleton PD and the same approach was used for Seattle PD, DCPA,
and Rocklin PD, having received recommendations from WA Pierce County Jail, Denver County Jail, and
Sacramento County Jail, respectively.
Overall, this study reflects four lockup sites including three from the West (Seattle PD, Rocklin PD, and
DCPA) and one from the Northeast (Middleton PD). The Rocklin PD has four holding cells within their
facility, an ADP of four, with a capacity of 10. The Middleton PD, has three holding cells, an ADP of
two, with a capacity of 12. The Seattle PD has five precincts each for a total of 18 cells. The DCPA, a
larger lockup facility more closely associated with a jail, has a capacity of 158 and an ADP of more than
200.

Methodology

74

PREA Cost Impact Analysis

Assumptions
Definition of Sexual Abuse
Booz Allen operated under a targeted definition of sexual abuse, specially addressing physical rape,
penetration, and contact. For the purposes of this report, Booz Allen did not include sexual harassment in
its definition of sexual abuse. This exclusion is noteworthy as sexual harassment is defined by the PREA
as ―repeated and unwelcome sexual advances, requests for sexual favors, verbal comments, or gestures or
actions of a derogatory or offensive sexual nature by one inmate directed toward another.‖ Furthermore,
the PREA glossary defines sexual abuse to ―encompass (1) inmate-on-inmate sexual abuse, (2) inmateon-inmate sexual harassment, (3) staff-on-inmate sexual abuse, and (4) staff-on-inmate sexual
harassment.‖ Although we understand the importance and impact of this broader definition, the inclusion
of sexual harassment and subsequent compliance with the NPREC standards was determined to be out of
the scope of this study. Specifically, the costs associated with eliminating all forms of sexual harassment
would be colossal in nature, if even possible. Therefore, the Booz Allen team defined sexual abuse
consistent with the BJS’s Survey on Sexual Violence, Form SSV-IA, with the exclusion of sexual
harassment under the belief that its inclusion is broader than the intent of PREA and NPREC.
Nonconsensual Sexual Acts: Contact of any person without his or her consent, or of a person who
is unable to consent or refuse; and contact between the penis and the vagina or the penis and the
anus including penetration, however slight; or contact between the mouth and the penis, vagina, or
anus; or penetration of the anal or genital opening of another person by the hand, finger, or other
object
Abusive Sexual Contact: (less severe) Contact of any person without his or her consent, or of a
person who is unable to consent or refuse; and intentional touching, either directly or through the
clothing, of the genitalia, anus, groin, breast, inner thigh, or buttocks of any person
Excludes incidents in which the intent of the sexual contact is to harm or debilitate rather than to
sexually exploit
Staff Sexual Misconduct: Any behavior or act of a sexual nature directed toward an inmate by an
employee, volunteer, contractor, official visitor, or other agency representative (exclude inmate
family, friends, or other visitors). Sexual relationships of a romantic nature between staff and
inmates are included in this definition. Consensual or nonconsensual sexual acts including
intentional touching of the genitalia, anus, groin, breast, inner thigh, or buttocks with the intent to
abuse, arouse, or gratify sexual desire; or completed, attempted, threatened, or requested sexual
acts; or occurrences of indecent exposure, invasion of privacy, or staff voyeurism for sexual
gratification
Presentation of Costs
For the purposes of simplification, all costs in this study are shown in 2010 dollars, and the ongoing
yearly costs do not reflect future or inflated costs that would be needed in any budget or funding
exercise. Costs for each standard are presented as upfront (one-time, initial investment costs) and
ongoing or yearly (annual recurring operational maintenance, expenditures, and/or refresh). This
study also assumes consistent services for the life of any contract entered upon by a site/jurisdiction
Assumptions

75

PREA Cost Impact Analysis
and that no further modifications or adjustments to current policies, procedures, or operations will be
necessary any time in the future. Although this is an unrealistic assumption, forecasting the many
permutations and variations of future services is outside the scope of this study.
Determination of Compliance and Validating Site Responses
Booz Allen determined compliance based on a discussion about current practices, policies, and
procedures with the site's themselves. Any claim of compliance was validated and tested by SMEs,
policy documentation, or sufficient evidence of said claim. The scope of this project did not entail
audits of their operations and whether they met any yet-to-be defined audit requirements for PREA.
For example, project scope excluded a workforce analysis to determine if security staff are providing
inmate supervision necessary to protect inmates from sexual abuse per Standard PP3. Such an
analysis would require clear auditing requirements, benchmarks, and target staffing levels for each
type of facility that do not exist. Instead, the Booz Allen team relied upon the qualitative assessment
of the individual site's compliance relative to reported sexual abuse incidents. When feasible, the
Booz Allen team would conduct a facility tour and obtain staffing and facility plans however this was
not possible during the majority of the site visits as many represent multiple facility systems
throughout their state.
Booz Allen received many responses that described different methods to comply with the same
standards. We do not assume to have the authority to determine which method is best in the spirit of
PREA. For example, one site may choose to comply with a training standard using computer-based
or IT-based delivery. Although this may cost more than a classroom based method, Booz Allen
cannot determine that one is better than the other for that particular facility.
Definition of Lockup
According to the NPREC definition, a lockup is ―a temporary holding facility of a Federal, State, or
local law enforcement agency. Lockups include locked rooms, holding cells, cell blocks, or other
secure enclosures under the control of a law enforcement, court, or custodial officer. Lockups are
primarily used for the temporary confinement of individuals who have recently been arrested or are
being transferred to or from a court, local jail, state prison, or other agency.‖ Booz Allen interprets
the NPREC definition of a lockup to include local police departments with temporary holding cells or
correctional facilities with temporary holding cells that are not administratively or operationally part
of the local jail at the county or state level.
This study employed this definition in its selection of lockups while it was not without its hurdles.
While exploring potential lockups to include in this study, Booz Allen identified a few jails that
operated stand-alone booking facilities that briefly housed detainees while they waited on processing,
a court summons, or a posted bond. Although, these facilities are within the scope of the NPREC
definition, they are an inseparable part of the jail, sharing the same resources, correctional officers,
and administrative staff. Booz Allen did not consider these booking units/facilities as part of this
study. Due to their close relationship (both by proximity and resources) these holding facilities have
access to all the functions and resources of the jail and thus do not portray a stand-alone lockup. In
addition, due to the shared responsibilities of the two entities, it is unclear who would be responsible
for compliance with the standards. Finally, the cost impact of the NPREC standards on the booking

Assumptions

76

PREA Cost Impact Analysis
unit/facility would be indeterminate from the entire jail because the holding facility is typically
considered a small component of the total cost of the jail's operations.
Inmate Supervision (PP3)
Staffing shortages can lead to many destabilizing acts and rectifying this goes far beyond protecting
inmates from sexual abuse to include all violent activities. One might argue that an increase in
staffing should not be fully attributable to PREA (providing inmate supervision necessary to protect
inmates from sexual abuse) however, for this study, PREA would be the only federal requirement to
increase staffing so it is assigned 100% of the cost impact.
Roles and Responsibilities of the PREA Coordinator
NPREC standards suggest a PREA Coordinator should develop, implement, and oversee agency
efforts to comply with PREA. It is also mentioned that the PREA Coordinator should have an
integral role in the design of a training program. Booz Allen considers the PREA Coordinator’s roles
and responsibilities to be more manageable in an environment consisting of one facility. For this
reason, Booz Allen assumes the responsibilities and any associated cost impact resulting from the
development and training of a PREA curriculum or the data collection and review process will be
provided for under the annual salary plus benefits of the PREA Coordinator position.
Immigrant Detainees
Immigrant detainees are detainees in the custody of Immigration and Customs Enforcement, (ICE) or
Customs and Border Protection (CBP) and do not include inmates that are arrested for breaking local
or state laws only to be determined after intake that they are illegal immigrates. This study assumes
that these inmates are not subject to the supplemental standards for immigrant detainees (ID-1
through ID -11). It should be noted however, that this study did not include any sites from the State
of Arizona. With recent enactment of Arizona Senate Bill 1070, it is very likely that such inmates,
otherwise arrested on violation of local law for an un-jailable offense, would now be incarcerated and
subject to these standards and required to be housed separately. Although the law requires that an
illegal alien be transferred immediately to the custody of ICE or CBP, it is very likely that the local
law enforcement officials will house the detainee until the Federal Government transfers them to
federal detention. If so, this could have a major cost impact on jails and lockups throughout the state
if incarceration rates of illegal aliens increase.
Litigation
The potential for litigation arose frequently during our site visits, particularly for prison systems
surrounding standard PP4, Limits to Cross-Gender Viewing and Searches, and RE2, Exhaustion of
Administrative Remedies. A common solution to meet standard PP4 is a workforce realignment
however, many sites expressed federal or state statutes that would prevent them from making any
gender based hiring or workforce decisions. Similarly, most prison systems expressed considerable
concern about RE2's contradiction with the PLRA, again an issue where PREA is running up against
a federal law. For both instances there was some discussions and evidence of past litigation and
source documentation but to consider any cost in the context of this study is speculative and,
arguably biased because the study does not investigate potential litigation in the event a correctional
institution is brought to court to defend itself in a sexual abuse case. Under the scope of this study
Assumptions

77

PREA Cost Impact Analysis
and contract, this is not a cost benefit analysis whereby such a study would then include these
intangible or qualified costs and benefits. Under these parameters, no litigation costs, whatsoever,
are included in the cost impact calculations of this report.
Labor Costs
All costs estimates for additional staff reflect salaries and benefits (retirement, medical, social
security, and paid time off). In addition, all new hires have associated operations cost to reflect the
cost of office furniture and supplies, office equipment, communications services, institutional
expenses (uniforms, badges, etc.), training, public safety supplies (weapons and ammunition) and
other expenses, other than salary and fringe benefits, associated with employing personnel. See
Operations Costs below for a standard cost calculation used throughout this study.
Recurring Training of Volunteers and Contractors
Though not required as part of TR2 – Volunteer and Contractor Training, analysis discovered a
certain level of turnover identified by jurisdictions when referring to training of their volunteers and
contractors. Booz Allen assumes that jurisdictions will realize a certain level of turnover yearly, and
that replacement volunteers and contractors will be required to receive training on PREA.
Consequently, Booz Allen assumes a 25% turnover ratio and has included a yearly maintenance cost
equal to 25% of upfront cost provided by each jurisdiction to ensure replacement volunteers and
contractors are trained accordingly.
Contracting for the Confinement of Inmates
Facilities that have contracts in place for the confinement of inmates will be required to ensure those
contractors have met the same PREA standards as is required of them. This will result in higher
costs for the contracted facilities as they must abide by the same PREA standards as the contracting
facility, incurring investment and higher ongoing costs. And these higher costs will likely be passed
on to the contracting facility in the form of higher annual or monthly fees. This study assumes that
these increased fees will be proportional to the increased costs of the contracting facility based on the
underlying assumption that the contracting facility holds the contractor to similar operating
standards, policies, and procedures. To determine this proportion, Booz Allen assumes these costs
are a portion of inmates confined by contractors to total inmates confined by the jurisdiction in
question. For example, if jurisdiction X contracted out 250 inmates, and housed 1,000 within their
own confines, a factor of .25 would be used to calculate the cost impact. This factor is multiplied by
the site's ongoing costs (excluding costs associated with the PREA coordinator and audits which are
solely the burden of the contracting facility) to reflect the contracted facility's ongoing cost impact.
The contractor will also have a financial incentive to recoup their investment costs as result of PREA.
Booz Allen assumes these upfront costs are amortized over a 10-year life cycle meaning that onetenth of the upfront cost impact is applied to the ongoing costs. That way, the contractor is
sufficiently recouping both their increased investment and ongoing costs by passing it on to the
contracting facility in higher fees.
Standard Costs
Numerous costs were subject to wide variations, unobtainable, or fraught with so much uncertainty
that an approximation based on sound principles and logic was difficult to estimate. To resolve this
Assumptions

78

PREA Cost Impact Analysis
issue, Booz Allen developed specific standard costs that were used in such instances. Each of these
costs is based on the overall findings and/or reasonable assumptions in the field of corrections. The
following standard costs are found throughout the analysis and noted when used. The basis of
assumptions for each standard cost is noted below.
Criminal Background Checks:
The cost to conduct criminal background
Assumptions:
checks is estimated by Booz Allen to be $50
Access fee = $18
per background check. This cost consists of
Time required = $1.5 hours
an $18 fee to access criminal records from
Average wage of staff conducting check = $21.33
government sources and $32 in level of
per hour (salary and benefits)
effort costs for staff to complete the
Formula:
Cost of background check = access fee + (No. of
background check process. The access fee
hours to complete check * Avg salary of staff
was identified in a prior Booz Allen study
conducting the check)
and represents the fee charged by the
Government to access individual records.
The level of effort cost assumes that the time required to conduct each background check is 1.5
hours and that the wage for staff conducting the check is $21.33 per hour.
Table 13: Costs per Criminal Background Check

Cost per check

Access fee
LOE
TOTAL
$
18 $
32 $
50

PREA Audit:
Since PREA audits have not been
Assumptions:
developed yet, it was necessary for Booz
Number of Auditors = 4
Allen to estimate a standard cost for these
Auditors fee per hour = $75
audits across each sector. The total costs
Hotel rate = $110 per night
for audits are shown in the table below.
Meals and incidentals = $66 per day
Air Travel = $270 round trip
Booz Allen estimated the cost of a PREA
Mileage = 300 miles per audit at .50 per mile
audit based on information collected from
Staff cost = $73,200 (salary + benefits) per year
the MO DOC on their estimated cost of a
PREA audit for prisons and from
information on past ACA audits conducted at LA DOC prisons. This information was then
benchmarked against cost data for ACA and other audits from all other jurisdictions in this study,
for consistency. The cost of an audit consists of the auditor’s fee and level of effort costs accrued
by the facilities for audit associates duties and activities. The auditors fee is made up of labor
costs and travel expenses (meals and incidental expenses, lodging, air fare, and mileage), shown
in the table below. The auditor’s fee costs are based on cost provided by MO DOC for a 4-day
audit of prison facilities. The auditor’s fee to audit a prison was estimated on a per-day basis and
applied to jails, juvenile corrections, and lockups. Prisons were assumed to require 4 days to
audit, jails were assumed to take 3 days, juvenile and community corrections facilities were
assumed to take 2 days, and lockups were assumed to be 1 day audits. The LOE costs for audits
are based on information from past LA DOC audits, where one FTE was required to support
audits for four prisons per year. The cost for one FTE is assumed to be $73,200 (salary +
Assumptions

79

PREA Cost Impact Analysis
benefits); this equates to an $18,300 LOE cost per for prisons. The LOE costs for jails, juvenile,
community corrections, and lockups is based on the costs for prisons adjusted for fewer days,
based on the proportion that auditors labor cost decline for each day.
Table 14: PREA Audit Costs per Facility

Auditors Fee
Auditors Labor (non-fixed cost)
Meals and Incidental Expenses (non-fixed)
Hotel (non-fixed
Air Travel (fixed costs)
Mileage (fixed cost)
Total Auditors fee
LOE Cost
TOTAL COST

Cost Per Day
$
2,400
$
264
$
440
$
1,080
$
600

Prisons
(4 day audit)
$
9,600
$
1,056
$
1,760
$
1,080
$
600
$
14,096
$
18,300
$32K

Jails
(3 day audit)
$
7,200
$
792
$
1,320
$
1,080
$
600
$
10,992
$
13,725
$25K

Juvenile &
Community
Corrections
(2 day audit)
$
4,800
$
528
$
880
$
1,080
$
600
$
7,888
$
9,150
$17K

Lockups
(1 day audit)
$
2,400
$
264
$
440
$
1,080
$
600
$
4,784
$
4,575
$9K

Operations Cost:
Operations costs include the cost of office furniture and supplies, office equipment,
communications services, institutional expenses (uniforms, badges, etc.), training, public safety
supplies (weapons and ammunition) and other expenses, other than salary and fringe benefits,
associated with employing personnel. Booz Allen standardized operations costs and applied them
to the cost associated with employing staff, where only salary and benefits are known. The
operations costs are estimated for office and medical staff and security staff on a yearly and onetime basis. The yearly cost is the recurring cost that is accrued each year while the one-time cost
is the cost of items that are only purchased once, upon hire. The office and medical staff
estimates are based on information provided by MO DOC on the cost to employ a PREA
Coordinator. Operations costs for security staff are based on the cost for office staff adjusted to
compensate for the different functions. Costs are calculated on a per FTE, per year basis and
include the following:
Table 15: Operations Cost Per FTE per Year
Institutional
Public Saftey
office equipment
Communications
expense
Supplies
Office (includes computer, expense (internet (uniforms,
other Training (weapons and
expense
phone, etc.)
and Phone service) badges, etc.) expenses expenses ammunition)
Office staff and Medical Staff
Yearly cost
one-time cost
Security Staff
Yearly cost
one-time cost

Total

300

48
792

100

600

100

300
300

$ 1,448
$ 1,092

100

100
50

100

800

100

300
300

200 $ 1,700
600 $ 950

Severance packages for potential lay-offs
In the event that a jurisdiction has declared that replacement of particular staff members is
necessary to comply with an NPREC standard, Booz Allen assumes a cost impact associated with
a severance package will be realized. Typically, severance packages include up to six months of
salary (usually depending on years of service), payment for unused vacation and/or sick leave,
medical, dental, and life insurance benefits, and any associated retirement benefits. All things
Assumptions

80

PREA Cost Impact Analysis
considered, Booz Allen assumes an accurate upfront cost impact associated with a severance
package to be 50% of current yearly salary including benefits.
Review team of upper management officials including input from line supervisors,
investigators, and practitioners
Sexual Abuse Incident Reviews (DC1) requires that a team of upper management officials, with
input from line supervisors, investigators, and medical and mental health practitioners, review the
details of every sexual abuse incident following each substantiated allegation. The associated
cost impact provided by jurisdictions was a result of inconsistent interpretation of the standard
and an unknown level of effort required to comply. And, while Booz Allen has made every effort
to document each jurisdictions interpretation and cost consideration in their respective narratives,
the team felt underlying assumptions were required to accurately and consistently report on a
potential cost impact.
Booz Allen interprets a review team of upper management officials to consist of four senior-level
staff and one junior analyst. A cost to conduct a 1-hour review with these five officials was
determined based on each jurisdictions senior and junior-level salary. Once calculated, this
hourly fee was multiplied by each jurisdictions average number of confirmed sexual abuse
incidents over the past several years.
Site Specific Assumptions
MO DOC and MO PP
MO DOC is a unified system covering probation and parole, community corrections, and adult
prisons. Booz Allen received duplicative training cost estimates for NPREC standard TR4:
Specialized training: Investigations from the MO DOC (prisons) and MO PP. Costs were split
proportionately between the two systems based on 2008 and 2009 confirmed sexual abuse incidents.
WA DOC and WA CC
The WA DOC provided cost for both its prison system and community corrections since the two
divisions are integrated under the responsibility of the DOC. For example, the WA DOC developed
a cost impact associated with the development and use of a screening instrument to dually serve its
prison and community corrections divisions. Booz Allen determined that an accurate breakout of
this cost could be estimated based on the capacity of its prison system versus its community
corrections division. Similarly, cost for RP2 – RP4, which includes agreements with outside public
entities, conducting or contracting for criminal investigations, and authorities that prosecute
violations, were divided based upon the number of sexual abuse incidents reported by each division.
Further, WA DOC reported that they currently employ one PREA coordinator. Booz Allen assumes
the majority of the PREA coordinator’s current responsibilities reside in the prison division.
Therefore, no additional cost impact has been estimated for a PREA Coordinator under WA DOC.
However, the salary including benefits for a senior-level PREA Coordinator to oversee the WA CC
has been estimated.

Assumptions

81

PREA Cost Impact Analysis
Denver Pre-Arraignment and Denver County Jail
Although Denver County Jail indicated that there would be a cost impact for standards TR1 and SC1,
officials were unable to facilitate the estimation of a quantifiable cost impact. As a result, Booz
Allen developed cost estimates based on information developed or retrieved from other sites with
comparable or relevant data. The cost estimate for TR1, for example, leveraged a per-person training
cost from DCPA, located just a few miles away with similar economic and labor characteristics.
With 145 staff receiving training at an approximate cost for TR1 of $64,000 upfront and $16,000
ongoing, the per- person cost of training at DCPA is roughly $441 upfront and $110 on going per
person. Multiplying these per-person costs with the number of staff at Denver County (302) yields
an upfront training cost of $133,000 and ongoing cost of $33,000. The cost estimate for SC1 mirrors
the response given by Sacramento County which expressed similar concern that their screening
instrument would require certain modifications to ensure it was gender-specific. Further, Sacramento
County based their estimate on staff time required to provide the necessary enhancements. During
our site visit, Denver County noted that the main contribution to an estimated cost impact would
indeed be labor. Therefore, Booz Allen has leveraged the cost impact provided by Sacramento and
incorporated it into SC1 for Denver County

Assumptions

82

PREA Cost Impact Analysis

Appendix A: Underlying Causes of Cost Impacts by Sector
Prisons
The study reflects 13 prison systems including the Rhode Island Department of Corrections (RI DOC),
Massachusetts Department of Corrections (MA DOC), and the New York State Department of
Correctional Services (NY DOC), in the North, the Minnesota Department of Corrections (MN DOC), the
Missouri Department of Corrections (MO DOC), and the Indiana Department of Corrections (IN DOC),
in the Midwest, the Arkansas Department of Corrections (AR DOC), South Carolina Department of
Corrections (SC DOC), and Virginia Department of Corrections (VA DOC), in the South, and the
California Department of Correction and Rehabilitation (CDCR), Colorado Department of Corrections
(CO DOC), Oregon Department of Corrections (OR DOC), and the Washington Department of
Corrections (WA DOC) in the West.
The ongoing and upfront tables highlighted with Harvey Balls, on the following two pages, represent an
order of magnitude signifying a cost impact in relation to overall budget for the prisons sector. The
degree to which each Harvey ball is shaded indicates the magnitude of the cost impact. An empty ball
represents standards that do not result in any cost impact. On the other hand, a fully-shaded ball
represents a percent impact on annual operating budget that is greater than 0.50%. A quarter-shaded ball
and half-shaded ball represent an overall impact on annual operating budget between 0% and 0.25% and
0.25% and 0.50%, respectively. For example, the MA DOC upfront cost impact as a percentage of annual
operating budget for assessment and use of monitoring technology is equal to 0.45% and therefore
represented by a half-shaded Harvey ball.

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-1

PREA Cost Impact Analysis

DO
C

WA
DO
C

SC
DO
C

RI
DO
C

DO
C

4

0

0

0

0

4

4

0

0

0

0

r

4

0

0

0

0

0

4

0

0

0

0

4

r

0

1

r

1

0

1

0

1

1

0

4

0

4

0

0

0

r

0

0

0

0

0

0

0

1

0

5 Audits of standards

1

1

1

1

1

1

1

1

1

1

1

1

1

6 Training and Education

0

0

0

0

0

1

1

1

0

1

1

1

1

1

1

0

1

0

0

0

0

0

0

1

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

1

1

1

1

0

1

1

1

0

1

1

0

1

0

0

0

0

0

0

1

0

1

0

1

0

0

1

0

1

1

0

0

0

1

0

0

0

r

0

1

0

0

1

0

0

0

1

0

0

0

0

0

0

0

0

0

1

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

1

0

0

1

0

0

0

1

1

1

1

0

1

1

0

0

0

1

1

1

0

1

1

1

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Limits to cross-gender
viewing and searches

2 Inmate Supervision
Assessment and use of
3
monitoring technology
Ongoing medical and mental
4
health care

7
8
9
10
11
12

Contracting with other entities
for the confinement of
inmates
Accomodating inmates with
special needs
Zero tolerance of sexual
abuse
Screening for risk of sexual
abuse
Contract modifications for
outside services
Evidence protocol and
forensic medical exams

13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

Appendix A - Underlying Causes of Cost Impacts/Prisons

0

VA

OR

DO
C
NY

DO
C
MO

DO
C
MN

DO
C
MA

0

1

AR

IN

DO
C

OC
CO
D

OC
CA
D

DO
C

Prio
rity

Table 16: Prisons Ongoing Cost Impacts as % of Annual Operating Budget

= > 0.5%

A-2

PREA Cost Impact Analysis

DO
C

WA
DO
C

DO
C

RI
DO
C

OC
OR
D

DO
C

1

4

r

0

1

1

0

0

0

0

1

0

0

0

0

0

1

0

0

0

0

1

1

0

1

r

4

r

0

r

4

1

r

4

4

4

0

0

0

0

0

0

0

0

0

0

0

0

0

5 Audits of standards

0

0

0

0

0

0

0

0

0

0

0

0

0

6 Training and Education

0

0

0

0

0

0

1

1

1

1

1

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

1

0

1

0

1

1

1

0

1

1

0

1

0

0

1

0

0

0

0

0

1

1

1

1

1

0

0

1

1

0

0

1

1

0

0

1

1

0

0

0

0

1

0

0

0

0

0

0

1

0

0

0

0

0

0

1

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

1

0

1

0

0

1

0

0

1

0

1

0

0

0

1

1

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

7
8
9
10
11
12

Contracting with other entities
for the confinement of
inmates
Accomodating inmates with
special needs
Zero tolerance of sexual
abuse
Screening for risk of sexual
abuse
Contract modifications for
outside services
Evidence protocol and
forensic medical exams

13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

0

VA

1

1

Limits to cross-gender
viewing and searches

SC

NY

DO
C
MO

DO
C
MN

DO
C
MA

DO
C

0

1

AR

IN

CO
DO
C

OC
CA
D

DO
C

Prio
rity

Table 17: Prisons Upfront Cost Impacts as % of Annual Operating Budget

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

Prison Cost Impact#1: Limits to Cross-Gender Viewing and Searches (PP4)
The ability of prison systems across the country to comply with a prohibition to cross-gender pat down
searches is marred in current gender staffing ratios relative to inmate gender ratios, many of which are
imbalanced with proportionately more male inmates than male officers. As a result, there simply are not
enough male officers available for same-gender pat down searches.
In order to comply, many systems feel the most appropriate solution is to either replace female staff with
additional male staff, or hire additional male staff and operate at a decreased utilization rate (to avoid
violating federal or state statues requiring equal opportunity hiring practices). However, many systems
including the VA DOC expressed concern over the ability to find qualified male staff, specifically in rural
areas, that possess the character necessary to pass a stringent background check and are willing to accept
the salary being offered. If able to locate appropriate male candidates, the MA DOC anticipates having to
replace 69 female staff with males resulting in approximately $1.9M in severance and $66K in upfront
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-3

PREA Cost Impact Analysis
operations costs associated with hiring additional staff. The VA DOC will hire 50 additional male staff at
$48K in upfront cost and approximately $2.6M annually. Similarly, it is estimated that the MO DOC
would accrue a cost of over $18M annually and $362K upfront to hire 381 additional male staff. This
level of support would provide three additional posts per institution and supervision to provide on-call
same gender pat search capability. Others, such as the NY DOC, estimate increasing the number of
staffing by 50% at its female facilities. This results in 620 additional female COs for an annual cost
impact including salary and benefits of approximately $33.9M and nearly $600K in upfront operations
costs. Some systems also expressed concerns about violating Federal and state statutes as they relate to
equal hiring practices. These systems were NYS DOC, MA DOC, OR DOC and MN DOC, and AR
DOC. Other systems such as MN DOC and WA DOC specifically cited union presences as a major
concern in adhering to this standard. On the other hand RI DOC suggested is ability to prohibit crossgender pat downs is partly due to a lack Federal/state statutes or union concerns.
The MN DOC, SC DOC, OR DOC, and AR DOC, recognized a potential cost impact, albeit
unquantifiable. In its largest facility, Faribault, the MN DOC noted as many as 50% of its COs are
female. Current staffing patterns at facilities such as Faribault make it difficult for an agency such as the
MN DOC to alter staffing patterns without anticipating the need for new hires, severance pay, etc.
Similarly, the SC DOC reports it would be nearly impossible to meet this standard given the mismatch
gender ratio of employees to inmates (45% female employees, 93% male inmates). The OR DOC cites
federal statute preventing them from complying with this standard. Due to Federal statute regarding Civil
Rights, AR DOC reported that termination of female staff is not an option. They suggested doubling staff
in order to have a CO of both genders at each post and restricting the opposite gender’s ability to secure
certain areas within the facility would provide the only suitable outcome. While the Booz Allen team felt
it necessary to document their suggested plan of action, we determined the cost estimated to implement
their plan of action to be unreasonable. However, we do note that the AR DOC does not feel any other
policies could be modified in order to meet this standard. In addition, AR DOC feels adhering to the
standard would not eliminate sexual misconduct, but rather limit it to the same sex.
One unique and cost-effective solution considered by the CO DOC is the transfer of female COs from
male facilities and male COs from female facilities. The associated cost impact is $5K per staff for 130
staff to transfer facilities for a total upfront cost of $650K.
Prison Cost Impact #2: Inmate Supervision (PP3)
The Physical Supervision of Inmates lends itself to a certain level of subjectivity based upon one's
definition of what is considered adequate. In order to report consistently across varying types of
supervision and population size, systems were encouraged to use the number of sexual abuse incidents
confirmed over the past several years to identify any trends that might signal a problem. Because trends
associated with the majority of the systems studied suggest a flat or declining number of incidents
reported and confirmed, there were few compelling reasons to justify an increase inmate supervision
suggesting that a basis for cost cannot be determined solely on the number of incidents confirmed.
Booz Allen understands that a basis for cost cannot be determined solely on the number of sexual abuse
incidents confirmed. Clearly, increased supervision will go to great lengths to deter and prevent sexual
abuse before it ever happens. Other factors were considered when identifying findings associated with
Inmate/Resident Supervision. For example, the OR DOC suggests the majority of incidents occur when
staffing levels are highest, contrary to logic. Additionally, many systems expressed an interdependence
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-4

PREA Cost Impact Analysis
of both physical and technical supervision, sometime relying on one or the other depending on the culture
and environment of the site/system. Nevertheless, it has a major cost impact on systems with a number of
underlying reasons.
The age and structure of prison facilities also plays a factor in the need for physical supervision. AR
DOC, for example, suggests a few of its older facilities will require additional staff to cover blind spots,
based on the original construct of its amenities. They estimate requiring an additional 250 COs and 50
Lieutenants, for a yearly salary including benefits and matching of approximately $11.8M annually.
Meanwhile, MA DOC reported that in its older facilities it has already increased its physical presence,
and therefore requires no additional increase in supervision in response to PREA.
Discussion with the VA DOC found that staff insubordination might have a direct effect on providing
inmates with adequate supervision on a consistent basis. When an employee is late to work or a no-show,
the need for additional FTEs is required. Having this backup available on hand in anticipation of an
unforeseen circumstance, could directly impact the safety and security of inmates from sexual violence.
It is estimated that adding a 24/7 post to each of three dormitory housing units in six dormitory facilities
will cost approximately $4.9M annually. Similarly, the WA DOC feels additional FTEs are required at
several posts throughout its facilities that are currently self-relieving. By providing additional resources
at these posts, WA DOC feels it is adequately providing physical supervision. It is estimated that such
action will result in a cost impact of $10.5M annually and $157K upfront for an additional 165.5 FTEs.
According to WA DOC, doing so will remove all self-relieving posts in its facilities and provide the
adequate supervision necessary to comply with the standard.
The SC DOC estimated one additional CO per wing per shift for its seventeen medium and maximum
security facilities. However, further analysis revealed that SC DOC relies more heavily on video
surveillance than physical supervision. An initial estimate upwards of $50M in physical supervision was
determined to provide an equivalent amount of supervision as approximately $4M in upfront camera
equipment and $2M in yearly maintenance. Further analysis regarding this estimate has been provided
under Prison Cost Impact #3: Assessment and Use of Monitoring Technology.
Prison Cost Impact #3: Assessment and Use of Monitoring Technology (PP7)
Use of technical supervision has a number of significant cost drivers. Foremost, the cost associated with
purchasing and installing equipment is the greatest investment cost to a system. The NY DOC discussed
its current plans to minimize sexual abuse in its female facilities through adequate use of monitoring
systems. It also mentioned four relatively new maximum security facilities that rely heavily on video
monitoring to assist in addressing all activity, including sexual abuse. DOCS' correctional facilities have
very different physical plants, sizes and functions. Furthermore NY DOC has several different types of
surveillance systems in place in a number of our medium and maximum security correctional facilities.
These systems can best be placed into three categories: limited coverage systems, expanded coverage
systems and full coverage systems. Limited coverage systems have surveillance cameras in specified
areas of the facility usually limited to Special Housing Units (disciplinary and/or segregation units),
reception or draft areas, mess halls and/or visiting rooms. Expanded coverage systems have recently been
added to several of NY DOC's female correctional facilities. These systems cover corridors, common
areas in housing units and program areas in addition to Special Housing Units, reception areas, mess halls
and visiting rooms. Full-coverage systems have extensive camera coverage of all areas in which inmates
are permitted.
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-5

PREA Cost Impact Analysis
Only two prisons in New York State, Upstate and Five Points, currently have full-coverage surveillance
systems. These facilities were opened in 1999 and 2000, respectively. These facilities were new
construction, designed and built as state-of-the-art correctional facilities with maximum visibility.
Because the video surveillance systems were part of the original design, the cost of the surveillance
systems in those two facilities represents a fraction of the cost of installing a similar system in an existing
correctional facility.
For comparison purposes, Five Points Correctional Facility is a modern maximum security facility. It has
ten primary interconnected buildings totaling 870,359 square feet with a capacity of 1,500 inmates in a
double-cell configuration. The complex covers an area of 72 acres and has approximately 1,200
cameras. The system cost $5.2M to install when the facility was built (and therefore unoccupied). On the
other hand Bedford Hills Correctional Facility is a maximum security facility for female inmates with a
capacity of 926 inmates primarily in single cells. The facility at Bedford Hills originated with an 1892
law providing for a reformatory for women. The reformatory opened in 1901 under the jurisdiction of the
State Board of Charities. Today, the facility consists of 57 buildings in a variety of styles and ages
totaling 585,740 square feet. NY DOC designed and installed a surveillance system in a two-year project
completed in February 2004. It cost $3.6M dollars to retrofit Bedford Hills Correctional Facility with a
modern surveillance system consisting of 300 cameras.
Typically, older facilities pose numerous obstacles for contractors to install a camera system and thus
construction in an existing, occupied correctional facility takes substantially longer resulting in significant
increases to the cost. Further, older construction requires much greater camera density to achieve similar
coverage than modern construction built to maximize visibility. NY DOC feels it is necessary to add
surveillance systems to an additional 35 facilities and increase coverage in four female facilities. The cost
impact associated with this investment is approximately $621.5M. This cost includes $220M for 11 large
maximum security facilities, $360M for 24 medium-security facilities, $14.8M for four female facilities,
additional building space to handle the video monitors and related equipment necessary to manage the
systems, and additional staff costs to provide real-time monitoring of surveillance.
It is estimated to cost $2.6M in upfront cost for the installation and purchase of DVR equipment and
monitors at the CO DOC. The VA DOC feels it is necessary to double its current amount of cameras at
each of its 28 major institutions, resulting in $30M upfront for equipment. Similarly, the SC DOC, RI
DOC, MA DOC, WA DOC, OR DOC, IN DOC, and MO DOC all provided a cost impact associated with
new and/or upgraded equipment ranging from $220K at the OR DOC, to approximately $5M at the IN
DOC. According to the CA DOC, a conservative estimate equates to $8.3M in upfront cost, or $250K per
facility for 33 facilities to install additional monitoring technology. The CA DOC voiced further concern
regarding the condition of its older facilities. Facilities with lead abatement and asbestos make it very
difficult to install cameras. And, while they feel increased technical supervision is necessary in these
facilities, extensive renovation costs will need to be incurred prior to installment or the increased
technical supervision will be rendered cost-ineffective.
Of course, as is the case with all technology, recurring costs in the form of equipment maintenance and
upgrades must be considered. Each prison system analyzed noted significant maintenance costs
associated with the upkeep of its technology. At the AR DOC, $4M has already been invested in video
technology upgrades. Meanwhile, the NY DOC currently spends $480K annually in maintenance fees
associated with its current technology. When you consider the increase in surveillance systems
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-6

PREA Cost Impact Analysis
mentioned above, the NY DOC estimates an additional cost impact of approximately $1.5M to $2M will
be incurred. Likewise, the VA DOC anticipates $250K annually to perform the necessary maintenance
required of surveillance equipment. In almost all instances, additional cost associated with the
maintenance of current technology will be realized.
Another cost driver associated with the technical supervision of inmates is labor. An additional level of
effort, or labor, is required to monitor additional cameras. CO DOC, for example, anticipates $2.3M
annually for additional staff to support increased technical supervision at each of its facilities, while the
VA DOC anticipates $7.9M annually for 28 new posts (one for each facility) to monitor surveillance and
perform maintenance. In addition, CA DOC estimates they will require the need for 33 additional
Program Technicians at a yearly impact of $1.6M.
Finally, in addition to video monitoring and surveillance, other forms of technology like radio frequency
bracelets and wands were considered in order to comply with this standard. However, based on the prison
systems included in this study, these forms of technology did not indicate much of an impact in reducing
sexual abuse misconduct. The general consensus is that video monitoring and surveillance is the most
effective technical solution in preventing sexual abuse and helping to aid in the resolution of
investigations,
By considering funds that have already been invested, it is easier to understand the projected cost impacts
provided above. NY DOC, for example, has currently committed $13.8M in technical supervision of its
female facilities and committed $10.2M to its last two maximum security facilities. The cost of
equipment can vary significantly depending upon the capability of the equipment being installed. As a
result, this standard yields the greatest variability among all the standards. MA DOC received an early
PREA grant to install between 200 – 225 cameras with archiving capabilities at a cost of $360K, or $2K
per camera. Likewise, MN DOC recently received an early PREA grant in the amount of $704K that was
partially used to purchase additional cameras. Similarly, current video monitoring at the RI DOC
includes 350 cameras, each with archiving capability. The cost per camera was $3.25K. By 2005, the
AR DOC had invested $1.1M in video technology upgrades and between 2005 and 2009 that amount had
increased to $1.9M. Upgrades included archival technology (≈ $200K to convert VHS to digital),
installing vision panels on doors, and converting cameras from black and white to digital and color
videos.
Prison Cost Impact #4: Zero tolerance of Sexual Abuse (PP1)
Several prison systems analyzed, including the MA DOC and OR DOC have already employed a PREA
Coordinator. Remaining systems struggle to gauge the level of effort required to successfully perform the
duties and responsibilities of a PREA coordinator as outlined. While a full-time PREA coordinator is
required for state prison systems, both the RI DOC and the MN DOC felt it unnecessary to hire a seniorlevel position. Others, such as the NY DOC and the VA DOC, with a combined capacity of nearly
100,000 inmates, felt the equivalent of one senior-level position would not adequately meet the
responsibilities of the position without providing additional support.
LOE, in the form of increased staff support is the sole cost driver associated with this standard. To meet
the intent of the standard, we required that each system employ one senior-level staff member to oversee
the responsibilities of the PREA coordinator. However, because a wide degree of variation in inmate

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-7

PREA Cost Impact Analysis
capacity and number of staff is present amongst state-wide prison systems, those that felt additional
support is necessary were provided the opportunity to document the number of personnel required and
their respective salaries. While Booz Allen did not consider the cost impact of these additional FTEs, we
felt it important to document DOCs concerns and the varying levels of staff that DOCs felt would be
required to adequately support the PREA Coordinator position. The NY DOC, for example, suggested
they would require a deputy commissioner, an assistant commissioner, two field auditors, and a clerical
position. The AR DOC initially requested the equivalent of twelve ACA Managers (one for each of its
facilities) and an ACA Coordinator. Further, the CA DOC estimated a cost impact for developing a
PREA Unit, to include an Associate Director, Associate Warden, and two Lieutenants. Again,
information provided above is informational and did not influence the overall cost impact.
The following table lists the budget requirements for an additional staff member assuming a senior level
position reporting directly to the agency head. All costs are annual and include salary plus benefits.
Operational costs have also been incorporated and include office furniture and supplies, office equipment,
communications services, training, and other expenses above and beyond salary and fringe benefits.
Jurisdiction
RI DOC
AR DOC
CA DOC
VA DOC
MN DOC
SC DOC
MO DOC
IN DOC
NYS DOCS
CO DOC
MA DOC
OR DOC
WA DOC

Upfront
$
$
$
$
$
$
$
$
$

1
1
1
1
1
1
1
1
1

$
$
$
$
$
$
$
$
$
$

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
Salary increase to existing PREA Coordinator to cover
9 NPREC requirements.
Senior-level position already funded
Senior-level position already funded
Senior-level position already funded

Yearly
145
121
115
112
106
91
79
72
71

Prison Cost Impact #5: Training and Education (TR1 through TR5)
Training, as outlined by the NPREC standards, must be provided to all employees, volunteers,
contractors, investigators, and medical and mental health care practitioners. In addition, periodic
refresher training must be provided to all employees. While the number of training hours and frequency
of refresher training may vary by jurisdiction, the cost drivers do not. Cost drivers associated with
training and education include instructor fees, labor hours, material cost, and academy/seminar fees.
For the most part, PREA Training of Employees (TR1) is already a common practice throughout prison
systems, resulting in minimal to modest costs to sharpen or modify curriculum and/or provide ongoing
training. MO DOC, for example, will need to modify their current policy mandating PREA refresher
training. This will require training 7,913 staff on a yearly basis for a total yearly cost impact of
approximately $214K. With less than 1/5 the number of staff, it is estimated to cost the RI DOC $29K
annually to provide its staff with the same level of in-service training.
The outlier to this analysis is the NY DOC. While employees at the NY DOC receive training on sexual
abuse, current training does not meet expectations defined by the NPREC standards. Labor hours to
develop a curriculum, along with overtime associated with providing 27,000 employees with four hours
of training, results in a cost impact of approximately $3.7M.
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-8

PREA Cost Impact Analysis
Notable mention belongs to MA DOC. It is a pioneer in the industry for adopting PREA into the training
curriculum7. Currently, all new recruits receive a four hour training session, while all employees receive
a two hour annual in-service training
Similar to employee training, most prison systems meet the training requirements associated with
volunteers and contractors (TR2). Where contact by contractors and volunteers with inmates is limited,
volunteers and contractors receive written information (such as a pamphlet) regarding the prevention of
sexual abuse of inmates. Where recurring or more frequent contact with inmates takes place, more
extensive training is warranted. The VA DOC, for example, has numerous contractor and volunteers that
receive training during orientation but the volunteer training, in particular, is not extensive enough to
cover the PREA topics, requiring modifications to the curriculum estimated at $250K for an upfront, onetime cost. This will also result in modifications of the training delivery to volunteers yielding an
additional ongoing cost of $63K. Likewise, NY DOC anticipates having to train approximately 200
contracted staff on PREA, a third of which are estimated to be replaced on an annual basis. Labor hours
associated with this required training is estimated at approximately $42K upfront and $10K annually.
Typically, any cost impact associated with the training of agency investigators conducting sexual abuse
investigations is due to current curriculum lacking information regarding investigations in confinement
settings. The SC DOC, VA DOC, WA DOC, and MO DOC each acknowledged that their current
curriculum lacked training in confinement settings. It is estimated to cost the SC DOC $5K in fees to the
Criminal Justice Academy to provide specialized training to 30 investigators. Similarly, it will cost the
VA DOC approximately $2K for its agents to receive training through the Department of Criminal Justice
Services, while costing the WA DOC approximately $20K which includes the cost of curriculum
development, materials, and student hours for a two-day training session. The cost impact for MO DOC
to provide outside training to its 47 investigators including instructor fees and per diem amounts totals
approximately $51K upfront.
Certain jurisdictions, such as the RI DOC, reported providing the same training to its medical and mental
health staff as it does to the rest of its employees. Instances where this training includes detecting signs of
sexual abuse as well as preservation of evidence, compliance is met. However, where training was
ignored or does not meet the threshold of PREA, cost associated with instructor hours, increased labor
hours of staff, and materials is borne. The cost impact associated with the SC DOC is $150K to train 575
practitioners in-house. Further, because certain medical staff at the VA DOC is not included in training
because of time and cost, $48K in salary is estimated. The NY DOC will be required to train 400 New
York State Office of Mental Health (OMH) staff. It is estimated that training will likely take 6 to 8
separate sessions and cost approximately $750K upfront. Further, NY DOC anticipates having to provide
a certain number of new full and part-time practitioners with similar specialized training. The yearly cost
impact to provide such training is estimated at $105K. It is estimated to cost the WA DOC approximately
$27K to provide training that includes preservation of physical evidence, while the OR DOC anticipates
similar training of 200 staff at approximately $30K. It should be noted, OR DOC is investigating the
availability of a crisis center which might be able to provide this training free of charge.

7

Janine M. Zweig, Rebecca L Naser, John Blackmore, and Megan Schaffer. "Addressing Sexual Violence in
Prisons: A National Snapshot of Approaches and Highlights of Innovative Strategies." Urban Institute, Justice
Policy Center. October 2006.

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-9

PREA Cost Impact Analysis
The MA DOC brought 10,000 inmates through a clinical training class on sexual abuse and PREA
standards. The trainers for this class were medical staff and investigators that supervised inmate groups
of 40-60. In addition, booths were setup to provide inmates with literature on PREA, and emotional
support services were made available. PREA pamphlets are regularly provided to inmates as a form of
refresher training, in addition to a 15-minute refresher training class for inmates that transition facilities.
For the most part, prison systems rely on informational videos, pamphlets, and orientation presentations
to educate inmates at intake. Staff is on hand to lend support and answer any questions. These services
are common practice and resulting in modest costs. In most instances, education of inmates is limited to
the intake process and as part of a transfer to a new facility. MN DOC, for example, plans on updating its
educational materials requiring additional labor and printing costs of $75K. The estimated cost of $14K
annually for SC DOC includes a caseworker and corrections officer for 20 minutes a week at each of its
17 facilities. Similarly, there is an anticipated cost from the WA DOC of approximately $20K annually
for training materials and staff time to ensure its inmates are provided the appropriate education. The RI
DOC on the other hand plans to make a copy of its orientation video for approximately $200 and play it
consistently throughout its facilities. Similarly, the CO DOC and IN DOC provide refresher training to
inmates through a DVD presentation. As evident above, multiple approaches to providing inmates with
recurring education are available. The preferred method of providing that recurring education can have a
significant impact on the underlying cost.
The following tables on the next couple of pages show the cost impacts by site according to the five
training standards.

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-10

PREA Cost Impact Analysis

Site

Employee Training (TR-1)
Upfront
Yearly

MO DOC

$

RI DOC

$

MN DOC

$

NY DOC

$

3,700

Notes
Modification of policy requiring two additional hours of PREA-related
226
training to approximately 8,000 staff yearly.
29 In-service training cost at ½ hour of overtime annually.
Training on PREA-related material is provided to all employees. Annual
2
cost of $2K associated with provided recurring training.
Approximately 20 hours of PREA curriculum development time and
overtime cost associated with four hour training of approximately 27,000
staff. Significant cost associated with recurring training is not anticipated.
Staff receives in-class training from 1-16 hours based on their level of
exposure to inmates. Recurring training is provided.
4 hour initial classroom training session and a 2 hour annual refresher
session is provided to all staff.
All new staff receives basic training. Annual refresher training is also
provided.
Classroom training is provided to all staff. Annual refresher training is also
provided.
All new recruits are required to attend a 4 hour class. Annual refresher
training is also provided.
PREA training to include an annual refresher course is provided to all
employees.
Training is provided as part of new employee orientation and one hour
mandatory training is provided to all employees annually.
All employees receive initial PREA training and in-service refresher
training.
Training is classroom-based and is offered during initial orientation and as
in-service training on a yearly basis.

AR DOC
CA DOC
CO DOC
IN DOC
MA DOC
OR DOC
SC DOC
WA DOC
VA DOC

Site

Volunteer and Contractor
Training (TR-2)
Upfront
Yearly

VA DOC

$

250

$

NY DOC

$

42

$

AR DOC
CA DOC
CO DOC
IN DOC
MA DOC
MN DOC
MO DOC
OR DOC
RI DOC
SC DOC
WA DOC

Notes
Training of jail staff at numerous contracted facilities. Recurring cost at
63
25% initial training impact.
4 hours of training to approximately 200 primary care contractors.
10
Recurring cost at 25% initial training impact.
Initial orientation training and annual refresher training is provided.
Classroom-based training is provided on a recurring basis.
Basic training is provided as well as on a recurring basis.
Training is provided to all volunteers and contractors.
Contractors are provided a 3-hour class on PREA-related material and are
required to get recertification. Volunteers are provided pamphlets.
Contractors receive training during their basis training. Training program
for volunteers is being revised to include PREA-specific material at no
additional cost.
Training on PREA-related material is provided to all volunteers and
contractors.
Classroom training is provided to all volunteers and contractors.
Classroom training is provided to all volunteers and contractors.
Training is provided by in-house coordinators.
1 hour of initial training and 30 minutes of recurring training provided
annually.

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-11

PREA Cost Impact Analysis

Site

Inmate Education (TR-3)
Upfront
Yearly

MN DOC

$

WA DOC

$

SC DOC

$

VA DOC

$

250

NY DOC

$

13

RI DOC

$

<1

AR DOC
CA DOC
CO DOC
IN DOC

Notes
A presentation and handbooks are provided at all intake centers. Cost
75
provided is for training existing inmates once every three years.
Inmates are provided comprehensive intake and transfer training. Cost
20 provided for training materials and staff time associated with refresher
training.
PREA orientation via video is provided to all newly committed inmates.
14 One caseworker and one CO for 20 minutes a week for all 17 institutions is
required to provide refresher education.
Training of inmates at numerous contracted facilities.
Development of a lesson plan and related training materials along with cost
to develop an education video for recurring training.
RI DOC anticipates a cost impact associated with development and
production of a DVD to be utilized for recurring training.
PREA education provided at diagnostic and intake. Refresher information
provided in the form of a DVD.
Inmate education and appropriate follow-up is provided.
Inmate orientation provided at intake and at time of transfer. Posters are
also displayed.
Education provided via inmate handbook and PREA brochure. A public
service announcement is periodically shown throughout the facilities.
Inmate attend orientation on sexual abuse. Literature on PREA is provided
and a Q & A session is audited by the PREA coordinator. 15-minute
refresher is provided during transfer.
Refresher training is not currently provided but any cost will be absorbed by
the department.
Inmates are provided education at intake and newsletters, handbooks, and
posters are utilized as refresher training.

MA DOC
MO DOC
OR DOC
Specialized Training:
Investigations (TR-4)
Upfront
Yearly

Site
MO DOC

$

51

WA DOC

$

20

SC DOC

$

5

VA DOC

$

2

AR DOC
CA DOC
CO DOC
IN DOC
MA DOC
MN DOC
NY DOC

OR DOC
RI DOC

Notes
Fees associated with providing 47 investigators with training on
confinement settings.
Estimate includes two-day training seminar on confinement settings.
Estimated cost to train 30 investigators through the Criminal Justice
Academy.
Estimate includes PREA-specific training provided by the Department of
Criminal Justice Services.
Investigative staff received specialized training.
Office of Correctional Safety provides appropriate training.
Training requirements are mandated by state law.
Correctional Peace Officer curriculum and confinement-specific training are
provided.
A 5-day training related to PREA standards was conducted by NIC.
Investigative staff are provided the appropriate level of training.
Members of the Sex Crimes are provided the Municipal Police Training
Council Peace Officer School, the Office of the Inspector General Basic
Investigations School, and the 40 hour NY Police Sex Offense Seminar.
Investigators are currently provided training from the AG’s Sexual Assault
Task Force.
RI DOC conducts internal training through staff assigned to the Special
Investigation Unit.

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-12

PREA Cost Impact Analysis
Specialized Training:
Medical and Mental
Health Care (TR-5)
Upfront
Yearly

Site
NY DOC

$

750

SC DOC
VA DOC

$
$

150
48

OR DOC

$

30

WA DOC
RI DOC

$

27

MO DOC
MN DOC
MA DOC
IN DOC
CO DOC
CA DOC
AR DOC

$

Notes
Training 400 OMH employees would take six to eight separate sessions.
Training on recognizing the signs of sexual abuse would need to be
105
developed in conjunction with OMH for this target audience.
Approximately 30 hours to develop curriculum.
Training of approximately 575 practitioners in-house.
Estimate includes daily contractual salary of medical staff.
Approximately 200 contract staff would have to be compensated at their
contract rate to attend training. Cost estimated is based on one-hour of
training.
Training for practitioners on how to preserve evidence.
Training is part of licensing and credentialing.
Full and part-time mental health care practitioners receive training on how
to detect and assess signs of sexual abuse through their annual training from
their company.
Medical and mental health care staff have the requisite training that covers
sexual abuse.
Medical and mental health care staff are required to attend specialized
training for nurses on preserving evidence.
Medical and mental health care practitioners are trained on how to detect
sexual abuse and on how to preserve the evidence.
Mental health and health service professionals receive specialized training
on sexual assault. They are also required to attend the PREA First
Responder training.
Practitioners are provided appropriate training through education and
license processes.
Medical staff receives training as part of their medical studies and through
medical organizations.

Prison Cost Impact #6: Evidence Protocol and Forensic Medical Exams (RP1)
Where applicable, advocates to accompany a victim through the medical exam process are provided by
local hospitals. Typically, these services have no cost impact on the jurisdiction responsible for providing
the inmate with an advocate. Of the thirteen prison systems analyzed, more than half responded that these
services were made available at the hospital. Others, such as the CA DOC, have MOUs in place between
31 of its institutions and a rape crisis center.
In the case of NY DOC, hospitals would require the state to enter into a funding source contract. NY
DOC would be forced to create a ―fee for service‖ contract with every hospital in proximity to one of its
facilities. The will cost the NY DOC approximately $250K annually.
In the case of the RI DOC and SC DOC, services will be provided by an outside entity. If requested by
an inmate, the RI DOC has already made available victim advocate services through Day One. SC DOC
on the other hand can anticipate a cost of approximately $8K to research and engage in a contract for
these services with an outside entity.
MA DOC believes that an internal full-time victim advocate is necessary to accompany a victim through
the entire process. However, because the local hospital has a rape crisis center and a well established
SANE program, MA DOC is considered to be in compliance with RP1. Similarly, AR DOC has a victim
response team that is responsible for working with victims internally. This team includes security, a
chaplain, and mental health practitioners. AR DOC feels they can designate a member from their victim
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-13

PREA Cost Impact Analysis
response team on a 24-7 basis, which would include staying with the victim throughout the forensic
medical exam process. This cost equates to $6K annually. At $842K annually, a much more significant
cost impact can be expected for the IN DOC to provide an internal 0.5 FTE including overtime and
benefits at each of its facilities.
In most cases, access to outside confidential support services is made available to inmates through a
hotline, mail, posters, and pamphlets. Because most advocacy services provide posters and pamphlets
free of charge, cost is typically limited to any contract fees associated with providing for the service,
materials cost, and any rate per minute fee associated with the hotline. Upfront costs associated with
providing access to support services range from $20K to less than $1K.
Prison Cost Impact #7: Gathering, Reviewing, and Reporting Sexual Abuse Data (DC1 through
DC3)
The majority of jurisdictions were found to be in compliance with DC1 – DC4, resulting in no cost
impact. Of those jurisdictions not in compliance, LOE and database automation/integration were found to
be the only cost drivers associated with the gathering, reviewing, and reporting of sexual abuse data. The
compilation of a review team consisting of upper management officials with input from line supervisors,
investigators, and practitioners, was resulting in a wide array of very subjective cost impacts. For
consistency, Booz Allen has decided to standardize the cost impact associated with this assessment.
Where a site determined a review team would need to be assembled, Booz Allen applied a cost estimate
based on several factors outlined above in the Assumptions section of the document.
The NY DOC, WA DOC, CO DOC, and the VA DOC found that the creation of report findings and
recommendations for improvement would require additional FTE support. In each instance, this
additional resource will be used to collect, review, and analyze an increasing flow of sexual abuse data
into the system. In order to accurately collect and report on the influx of data, it is estimated to cost the
MN DOC a one-time charge of $10K to automate its database. Similarly, the WA DOC requires an
upfront cost of $301K to make necessary improvements to its current data collection system.
The majority of systems analyzed found the gathering, reviewing, and reporting of sexual abuse data to be
common practice. Where viable, the PREA Coordinator will make efforts to help in the data collection
and review process. For example, the RI DOC suggests the PREA coordinator conduct audits as part of
the data collection process under DC2.
Major Issue and Finding #8: Hiring and Promotions Decisions (PP6)
Background checks on new hires were found to be commonplace throughout all jurisdictions studied.
Similar checks on promotional candidates were found to be done less frequency, however. By limiting
the number of background checks to contingency hires, as opposed to all promotional candidates, the cost
impact associated with conducting background checks is lessened. Similar to the cost impact associated
with assembling a review team, costs to conduct background checks have been standardized and factors
outlined above in the Assumptions section. The majority of prison systems conduct background checks
internally, limiting the cost impact of such an investigation to LOE. Where checks are completed by an
external agency, additional fees are accumulated. At a cost of $50 per background check, the MN DOC,
which averages approximately 122 promotions annually, will have a yearly cost impact of approximately
$6K. Similarly, with an average of 235 promotions and 291 promotions annually, the WA DOC and SC
DOC can anticipate a yearly cost impact of nearly $12K and $15K, respectively.
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-14

PREA Cost Impact Analysis
Departments such as the NY DOC and the AR DOC receive automatic feeds of criminal records for all
existing employees on a consistent basis. This process dissolves any need for agencies to conduct checks
on promotional hires, while also keeping agency heads informed of its existing employees that are not
being considered for a promotion.
Many departments make a conscious effort to contact prior institutional employers. Some, such as the
NY DOC, AR DOC, and the CA DOC suggest using these resources may not result in any added benefit.
NY DOC has made this effort in the past and states that the information obtained is limited to what
employers consider reasonable. In addition, the AR DOC feels most employers would not answer the
question as they are under strict data privacy restrictions, while CA DOC questions the legality of such a
request and do not feel it would yield actionable results. Nevertheless, where this action is not currently
being taken, jurisdictions feel it additional LOE is necessary. The SC DOC has estimated an additional
FTE at $43K annually to contact prior institutional employers. Similarly, the VA DOC requires one
additional FTE at $41K annually, whose resources will be used to investigate employees and potential
new hires based on guidelines addressed in the standard.
Prison Cost Impact #9: Audits of Standards (AU1)
Without a clear understanding of the elements that will be included as part of an audit on the NPREC
standards, jurisdictions were asked to use an audit that they currently participate in, such as the American
Correctional Association (ACA) audit or an internal DOC Policy Unit audit, as a baseline for estimating a
potential cost impact. To conduct an audit on the standards, Booz Allen anticipates similar cost drivers to
audits currently being conducted; audit fees, LOE, and travel expenses.
Because no formal audit process has been developed, Booz Allen has standardized the cost associated
with conducting an audit throughout the Prison sector. Factors included in our assumption have been
described above in the Assumptions section of the document. A cost per prison facility of $33K
triennially has been determined based on an auditor’s fee and an internal LOE.
Prison Cost Impact #10: Screening (SC1 and SC2)
The majority of the costs associated with screening are the result of having instruments that are not
gender-specific or screening processes that are not conducted at all classification reviews. Therefore,
there are upfront costs associated with modifying the screening tool and ongoing costs to cover the
increased workload of conducting more screenings. Where modifications are needed, systems such as the
VA DOC can expect an upfront cost impact of approximately $50K associated with integrating the newly
developed risk screening tool into their current review process. CO DOC also considered the cost impact
associated with integrating modifications of the screening assessment tool into their offender management
system, resulting in an upfront cost of $176K to update its Offender Release of Information to Law
Enforcement (ORILE) database. Unable to gather specifics regarding a cost impact of this standard on its
offender management system, a system similar to CO DOC, Booz Allen assumed an equal impact for VA
DOC.
The OR DOC only screens offenders on an as-needed basis. With an increased workload as a result of
screening all offenders, they will be subject a cost impact of $437K per year to cover five additional staff
to conduct screenings.
Where a screening instrument is not currently utilized, the cost to develop an instrument and provide the
necessary LOE to conduct screenings is expected to be considerable. Currently, the SC DOC uses a cell
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-15

PREA Cost Impact Analysis
assignment form to match cell mates. This is not considered to be a screening instrument as defined in
the standard therefore SC DOC requires a new instrument and procedure to conduct the screenings. In
order to develop and implement a written screening instrument throughout its facilities, the SC DOC
estimates $35K in upfront costs. In addition, SC DOC will require 17 additional caseworkers at $665K
per year to execute the screening process on all inmates in each facility.
Prison Cost Impact #11: Contracting with Other Entities for the Confinement of Inmates (PP2)
Contracting for the confinement of inmates is practice seen at a few of the prisons included in this study
but not all of them will incur a cost. In one instances, such as with the MA DOC, a contractual agreement
has already been made with a private entity forcing it to comply with the NPREC standards, resulting in
no additional costs. Booz Allen acknowledges that some contracts with private entities may be written in
a way that essentially places the cost burden on the contractor but it is assumed to be rare. Contracting
with public correctional institutions, on the other hand is considered different since they are subject to
stricter publicly-controlled budget constraints operating without profit as a financial incentive. They have
less budget flexibility to absorb higher costs and often have much looser contract requirements. CA
DOC, for example, suggested that their contracted facilities (all county jails) must abide by California
Code of Regulations (CCR) Title 15 with an implicate assumption that cost would not increase,
However, understanding the budget difficulties in CA and elsewhere, it is reasonable to assume that each
of these contracted jails, all held to the same PREA standards, will themselves incur additional costs that
they could easily pass on to CA DOC in the form of higher inmate fees estimated at $1.3Mper year
assuming nearly 8K inmates contracted out to the Correctional Corporation of America, or 4.2% of their
inmate population. Where formal agreements have not been reached, costs associated with modifications
to existing contracts are anticipated. The IN DOC has an agreement with GEO, in Newcastle, Indiana, to
house 2,400 inmates on their behalf, roughly 8.8% of their total inmate population. An annual cost of
$735K was estimated to bring contracted facilities into compliance with the NPREC standards. Similarly,
the SC DOC and AR DOC, contract out for the confinement of 300 and 280 inmates, respectively. The
SC DOC can expect an associated ongoing cost impact of approximately $41K while AR DOC will see a
cost impact of $253K annually. While not considered a reasonable cost impact to our study, several
jurisdictions expressed concern and a potential for exorbitant cost if contracted facilities did not agree to
comply with PREA. AR DOC, for example, suggested that they would have to re-house their inmates
contracted out to their county and city jails under the assumption that these entities may choose not to
abide by PREA, resulting in an annual cost of $4.9M. This study on the other hand assumes a greater
likelihood that these entities will ultimately adopt the PREA standards and pass on additional and
increased costs to AR DOC.
Prison Cost Impact #12: Contract Modifications for Outside Services (RP2 through RP4, and RE3)
Most jurisdictions have agreements in place with outside public entities to provide emotional support and
transition services. Where agreements do not exist, six out of the 13 prisons in this study, contracts need
to be established and for state systems, the cost impact can be significant as demonstrated by NY DOC
($500K per yea) and WA DOC ($761K per yea). NY DOC's relatively large ongoing costs cover
agreements for emotional services in each of the 32 counties with an institution and contracts for
transition support services in all 62 NY counties. The annual cost impact at WA DOC is associated with
a number of factors, the largest of which being the costs associated with contracts to provide emotional
and transitional services. Despite the prevalence of service providers in WA, a recent inquiry into who
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-16

PREA Cost Impact Analysis
could contract with WA DOC uncovered numerous obstacles due to VOCA funding restrictions meaning
WA DOC would have to pay for these services that would otherwise (as found in most places across the
country) be provided free of charge
Where investigations are not conducted internally, they are conducted by the State Police (RP3). The
State Police are typically bound by state statute to conduct investigations. Where necessary, a jurisdiction
has the opportunity to engage or modify a MOU to ensure investigations of all PREA-related incidents are
carried out. The WA DOC feels such action is necessary, having to develop agreements with law
enforcement agencies throughout the state subsequent to a recent discovery that one of the largest
counties in Washington will no longer investigate crimes that are not against county residents. Because
there is no consistency in how counties handle investigations and no state statute enforcing local law
enforcement to conduct investigations, a formal agreement with all 39 counties in the state is required
with an estimated cost of $226K per year.
Similarly, the local District Attorney typically handles criminal prosecutions of DOC inmates (RP4). In
most instances, agreements or state statutes with these authorities already exist. However, this study did
uncover on outlier. Similar to RP3, the WA DOC also feels that MOUs are necessary with DA Offices,
based on the inconsistent manner with which prosecutors move investigations through the court system,
yielding an estimated cost of $226K per year.
In most cases, Access to Outside Confidential Support Services (RE3) is made available to inmates
through a hotline, mail, posters, and pamphlets. Because most advocacy services provide posters and
pamphlets free of charge, cost is typically limited to any contract fees associated with providing for the
service, materials cost, and any rate per minute fee associated with the hotline. Upfront costs associated
with providing access to support services range from $20K to less than $1K
Prison Cost Impact #13: Accommodating Special Needs (PP5)
The CO DOC reported a yearly cost of $1K would be required in order to provide sign language
interpreter services. In every other instance, each jurisdiction studied reported having multiple ways for
inmates with special needs to report incidents of sexual abuse, including TTY machines for the deaf,
language lines and staff for the LEP, and access to mental health care staff and sister agencies for the
mentally disabled. In each instance, providing access to these services is written policy and in the case of
CA DOC, court ordered.
Prison Cost Impact # 14: Exhaustion of Administrative Remedies (RE2)
Multiple prison systems included in this study currently have policies in place which allow for longer
than 90 days before an inmate is determined to have exhausted his or her administrative remedies. In CO
DOCs case, a level 3 Grievance Officer would need to be hired in order to meet a shortened deadline.
Others such as the MO DOC, which currently has a 180-day policy, feel they could revise this policy at
no additional cost to the agency.
While the argument being made by NPREC in the discussion section under RP2 has been considered,
most agree that the 48-hour exhaustion of administrative remedies would have a significant impact on the
grievance process and directly violate the Prison Litigation Reform Act (PLRA).

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-17

PREA Cost Impact Analysis
“No action shall be brought with respect to prison conditions under section 1983 of this title, or any other
Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such
administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a)
State prison systems fear this could result in a significant amount of staff time to pull together
investigative reports, a legal team to draft responses, and the Attorney General’s office to defend any
claims. The OR DOC states this fails to allow for time to investigate allegations and could encourage
allegations that would undermine the purpose being addressed by this law. Further, it would tie up
institution, law enforcement, investigatory, prosecution, and judicial resources on potentially frivolous
cases instead of the substantive claims of actual survivors of sexual assault. In response, AR DOC stated
this would be a huge policy issue and cause serious damage to our grievance process. Under this
scenario, an inmate could file a report (verbal or written) and get much quicker access, under very
different circumstances, that those articulated in the PLRA regardless whether AR DOC did all the correct
things to ensure the inmate's safety. This would lead to systematic abuse. In addition, there are travel
costs and alternative housing costs for those inmates that have to relocate.
Prison Cost Impact # 15: Duty to Investigate (IN1)
All third party reports of sexual abuse are currently investigated throughout those DOCs analyzed as part
of our study. However, each DOC individually expressed concern over providing written notification of
the outcome of an investigation, including that of third party reports. A few in particular, the CO DOC,
WA DOC, OR DOC, and NY DOC, suggested that notifying victims of the outcome of investigations
exposes them to risk of retaliation, including physical hard. Others suggested that notification to nonvictim complainants violates states law protecting the confidentiality of victims of sexual abuse.
DOCs also expressed concern over notifying victims and/or other complainants of any disciplinary or
criminal sanctions. In particular, the RI DOC reported, per union policy and state law, it is not allowed to
notify any disciplinary sanctions for employees.
In each instance, DOC’s reported that each investigation is carried through to completion, regardless of
whether the alleged abuser or victim remains at the facility and that all allegations of sexual abuse were
substantiated if supported by a preponderance of the evidence. Certain jurisdictions, such as MA DOC,
suggest that due to proposed changes in grievance procedures and third-party reporting, the number of
investigations conducted will increase dramatically. Because of this, MA DOC has estimated the need for
eleven additional investigators at a yearly cost of approximately $516K. OR DOC, who currently has
many of the NPREC standards implemented, has seen a significant increase in workload required to carry
out investigations. They have requested one-half an additional FTE on both the east and west side of the
state to accommodate this increase. The resultant cost impact is $98K annually.
Prison Cost Impact # 16: Ongoing Medical and Mental Health Care for Sexual Abuse Victims and
Abusers (MM3)
In most cases, treatment of any type, including the effects of sexual abuse, is available at any time within
the system. In fact, only the WA DOC and IN DOC are not in compliance with the standard. In both
cases, the WA DOC and IN DOC do not provide ongoing treatment for all abusers. The current inmate in
WA DOCs Sex Offender Treatment Program costs approximately $10K annually. To provide an average
of 30 inmates with ongoing treatment is estimated to cost approximately $293K a year. The IN DOC
states that only adjudicated inmates labeled as sex offenders are required to attend the treatment program.
Appendix A - Underlying Causes of Cost Impacts/Prisons

A-18

PREA Cost Impact Analysis
Predators that have committed ―lesser‖ acts are not currently sent to the program. Based on the standard
as written, the IN DOC anticipates an increase of ¾ its current Sex Offender Treatment Program, or $3M
annually.

Appendix A - Underlying Causes of Cost Impacts/Prisons

A-19

PREA Cost Impact Analysis

Jails
The study reflects sixteen jail/detention sites including six from the South (Aiken County, Peumansend
Creek, Norfolk City, Miami-Dade, Alachua, and Pulaski Co), two from the Northeast (Albany County
and Essex County), three from the West (WA Pierce County, Sacramento County, and Denver County),
and five from the Midwest (MN Hennepin and Anoka County, WI Pierce County, IN Marion County, and
MO Jefferson County).
The ongoing and upfront tables highlighted with Harvey Balls represent an order of magnitude signifying
a cost impact in relation to overall budget for the jails sector. The degree to which each Harvey ball is
shaded indicates the magnitude of the cost impact. An empty ball represents standards that do not result
in any cost impact. On the other hand, a fully-shaded ball represents a percent impact on annual operating
budget that is greater than 0.50%. A quarter-shaded ball and half-shaded ball represent an overall impact
on annual operating budget between 0% and 0.25% and 0.25% and 0.50%, respectively. For example,
Anoka County’s ongoing cost impact as a percentage of annual operating budget for training and
education is equal to 0.05% and therefore represented by a quarter-shaded Harvey ball.

Limits to cross-gender
viewing and searches

(W
I)
Pie
rce

Pie
rce
(W
A)

ent
o
ram
Sac

ask
i

d
Pul

nse
n
Peu
ma

ade

No
rfol
k
Cit
y

mi
D
Mia

rion
Ma

n
rso
Jeff
e

Hen
nep
in

Ess
ex

er
Den
v

An
oka

any
Alb

a
chu
Ala

en
Aik

Prio
rity

Table 18: Jails Ongoing Cost Impacts as % of Annual Operating Budget

0

0

4

4

0

0

0

0

0

0

0

r

0

0

0

4

0

0

0

0

0

0

0

4

0

4

0

0

0

4

0

0

0

0

0

0

0

0

0

4

4

0

0

0

0

0

1

0

0

4

0

0

0

0

0

0

0

1

1

0

0

4

0

0

5 Audits of standards

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

6 Training and Education

1

1

r

1

1

0

1

1

1

1

1

1

1

1

1

1

0

0

0

0

0

0

0

0

4

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

r

4

1

r

r

r

r

r

r

1

1

0

r

4

4

1

0

r

1

0

0

0

0

0

0

1

0

0

0

0

4

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

1

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

4

0

0

0

0

4

0

0

0

0

0

4

0

0

0

1

0

0

0

0

1

1

0

1

0

1

0

1

1

0

0

1

1

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

1

1

0

0

1

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

2 Inmate Supervision
Assessment and use of
3
monitoring technology
Ongoing medical and mental
4
health care

7
8
9
10
11
12

Contracting with other entities
for the confinement of
inmates
Accomodating inmates with
special needs
Zero tolerance of sexual
abuse
Screening for risk of sexual
abuse
Contract modifications for
outside services
Evidence protocol and
forensic medical exams

13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

Appendix A - Underlying Causes of Cost Impacts/Jails

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

A-20

PREA Cost Impact Analysis

1

Limits to cross-gender
viewing and searches

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

Pie
rce
(W
I)

o

Pie
rce
(W
A)

ent
Sac
ram

ask
i
Pu l

end
ans
Peu
m

ade

No
rfol
kC
ity

Mia
mi
D

n
Ma
rio

Jeff
e

rso

n

n
epi
Hen
n

Ess
ex

Den
ver

An
oka

any
Alb

Ala
chu
a

en
Aik

Prio
r

ity

Table 19: Jails Upfront Cost Impacts as % of Annual Operating Budget

0

0

1

1

0

0

0

0

0

0

0

4

4

1

0

1

0

0

0

0

0

0

0

1

0

1

0

0

0

1

0

0

4

0

0

0

0

0

0

4

r

4

0

4

0

4

0

0

0

1

0

0

0

0

0

0

0

0

1

0

0

1

0

0

5 Audits of standards

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

6 Training and Education

1

4

1

r

r

1

r

0

1

1

1

1

1

4

r

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

1

1

1

1

1

1

1

1

1

1

0

1

1

1

1

1

1

0

1

1

0

1

0

0

1

0

0

r

1

1

0

1

1

0

1

0

1

1

0

1

0

0

0

0

1

1

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

1

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

7
8
9
10
11
12

Contracting with other entities
for the confinement of
inmates
Accomodating inmates with
special needs
Zero tolerance of sexual
abuse
Screening for risk of sexual
abuse
Contract modifications for
outside services
Evidence protocol and
forensic medical exams

13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

Jails Cost Impact #1: Limits to Cross-Gender Supervision (PP4)
The prohibition of cross-gender pat downs presents the most significant and consistent cost impact among
the jails included in this study. The most common reason for noncompliance, resulting in the greatest real
cost impact, is a staff gender ratio that is out of balance with the inmate gender ratio. It is a particular
challenge for many facilities where the rate of incarceration is much higher for men while hiring practices
are gender neutral. Many sites have policies in place that effectively balance the male/female staff ratio
and, in many places across the county, labor market factors supply proportionally more female
correctional officers than female inmates. In a system with a disproportionate number of male inmates,
there simply are not enough male officers to conduct pat downs.
Relative to the gender ratio of inmates, the majority of sites in this study have proportionately more
female correctional officers than female inmates, resulting in females frequently conducting pat downs on
male inmates as part of normal operating procedures, often times out of necessity. For example, In
Peumansend Creek’s facility, 54% of the staff is female while 83% of the inmate population is male.
There is concern that if this standard were implemented, they would need to implement a major
Appendix A - Underlying Causes of Cost Impacts/Jails

A-21

PREA Cost Impact Analysis
workforce realignment, moving more men into the male portion of the jail and moving female officers out
of the male jail ensuring that enough male officers are available for same-gender pat downs. Specifically,
this would result in an increase in 13 male officers and an equal decrease in female officers, a handful of
which could be placed in the control center or in the women's unit. In addition, finding qualified male
officers in rural areas, offering relatively low salaries, is often times difficult, with much of the male
applicant pool screened out due to past criminal histories. Peumansend Creek feels that they would either
have to lower their recruitment standards, loosening previous drug convictions and forgoing the
polygraph exam or increase wages (which would in turn have to be increased for the entire staff). The
cost impact to payout leave for the female staff being laid off is $22K. Assuming an 8% wage premium
to attract more qualified applicants Peumansend Creek would face an increased annual cost of $38K the
base salaries and benefits pay for the laid off female staff was the same as their male counterparts. In
addition, there will be incidental costs, upwards to $12K to cover expenses such as training, uniforms,
polygraph examination, medical exams and labs, and interviewing and processing for a total upfront cost
of $233K.
Albany County expressed a similar staffing concern but in the other direction, expressing a concern that
the labor market is not producing enough female candidates. This stems from a NY State Agility Test
applied equally to all officers, male or female. As a result, fewer women can pass the test, resulting in a
unique case where they do not have enough female officers to be available to conduct female pat downs.
In order to comply, Albany County will need to institute a more concerted and aggressive recruitment of
five additional female officers (those able to pass the agility test) resulting an annual cost impact of
$309K, or $60K per person for salary and benefits. Since these are new hires, there are additional upfront
operational costs of $5K for training, office supplies, and incidentals.
Pulaski County has a similar situation with nearly a perfect gender balance between their male and female
officers contrasted by a heavily weighted male inmate population. Female officers conducting crossgender pat searches are common and part of their routine practice. Any adjustment will have a major
impact on their workforce and the assigned roles and posts. In order to get their staff gender ratio in
proportion with the inmate gender ratio, they would need to eliminate up to 75% of their female staff, or
up to 82.5 FTEs, replacing them with male officers. Such an effort would result in a one-time severance
payout of $1.7M (assuming a 50% payout of an average salary for 82.5 FTE), followed by a multi-year
strategy to hire so many new officers. Assuming the cost of the new staff is equal to the cost of the
dismissed staff; the net cost impact is limited to the severance payout and the upfront costs of new hires
such as recruiting, training, office supplies, communications, security, and uniform resulting in a total
cost impact to Pulaski County of $78K. It is noted that Pulaski County believes their current operating
model functions very well and any modification could lead to greater risks (and potentially greater cost)
since their experience tells them they have more issues of women conducting pat searches on women as
opposed to men conducting pat searches on women.
Pierce County WI also has roughly a 50:50 split between their male and female officers contrasted by an
80% male inmate population. However, they are a very small jail, operating in a multi-functional county
sheriff's office where the dispatchers split their time between inmate supervision and the 911 call center.
At any given time, they have three people on duty always representing both genders (i.e., a duty shift is
prohibited from being staffed entirely by the same gender). Pierce County believes that they have
adequate staffing levels to comply with this standard under normal circumstances, but are not confident
Appendix A - Underlying Causes of Cost Impacts/Jails

A-22

PREA Cost Impact Analysis
their current operations would suffice during peak times of incarceration such as weekends, particularly
when two females are on duty, leaving them with only one male officer to conduct pat downs. To
mitigate this and fully comply with the standard, they would need to add one additional post with five
additional staff (FTE’s) members at a total annual cost of $384K.
At Anoka County, due to the configuration and design of their jail, only one person can cover a post at a
time. With a staff made up of 25% women in an environment overwhelmingly populated by male
inmates, this means that women would essentially be barred from working inside the jail, limited to work
in the control room, visiting room, or booking facility. Such work restrictions would potentially violate
state statutes on equal employment. The best option to meet this requirement would be to increase the
number of male officers and install a 24 hour male deputy rover position requiring five new staff at an
annual cost of $259K per year. In addition to providing added security, this position would be backup for
same gender (male) pat downs. Since these are new hires, there are additional upfront operational costs
of $5K for training, office supplies, and incidentals.
Lastly, it is important to note that some of the jails in this study are in compliance with this standard
having policies in place that prohibit cross-gender pat downs except in the case of an emergency.
Examples include Aiken County, Alachua County and Jefferson County. Neither of these sites has any
federal or state statutes dictating their staffing rations nor union representation for their officers despite
having gender spreads that would indicate an issue or potential cost impact. For example Aiken County
has a male/female officer ratio of 76:24 and a male/female inmate ratio of 85:15, yielding a ratio spread
of 9% (the difference between the male percentages) which is relatively low and closer to the gender ratio
of offenders.
Jails Cost Impact #2: Inmate Supervision (PP3)
A majority of the sites in this study considered themselves in compliance with this standard, most
attributing their low levels of incidents of sexual abuse to their supervision models, commonly direct
supervision. Only three out of the 16 sites felt they needed to hire additional staff in order to minimize the
incidence of sexual abuse and work towards eliminating it altogether. The three jails that have a cost
impact are Miami-Dade, Sacramento County, and Jefferson County, each of which having PP3 as one of
the greatest cost impacts on their operations. Miami-Dade feels like they are noncompliant with PP3 due
to insufficient workforce/security officer levels. Highlighted in a NIC study in 2006, Miami-Dade was
reported to be down 600 staff members below their target, a level set to maintain adequate security.
Despite hiring a few mental health care professionals in 2009, staffing levels have not rebounded and
have certainly not kept pace with the increased flow of inmates. In order to meet what they consider bare,
minimal standards to protect officers and inmates from all forms of violence to include sexual abuse,
Miami-Dade asserts a need to hire 89 Officers, 21 Corporals, six Sergeants, and two Lieutenants with an
annual cost of $6.7M. Since these are new hires, there are additional upfront operational costs of $112K
for training, office supplies, and incidentals.
Sacramento County expressed similar staffing issues, citing a historically high inmate ratio of 63:1,
something more typical of a direct supervision model and a ratio that is causing grave concerns among
jail administrators. Sacramento County has witnessed a number of staff reductions that are very common
throughout the public sector in California as the state grapples with unprecedented budget issues,
resulting in a very tight squeeze on state funding. Over the past couple of years, there have been multiple
Appendix A - Underlying Causes of Cost Impacts/Jails

A-23

PREA Cost Impact Analysis
positions cut and several positions demoted, including an 80% cut back of the medical staff.
Consequently, Sacramento County believes they are not providing enough physical supervision necessary
to protect the inmates and officers from abusive behavior (to include sexual abuse). In order to return
back to the level of supervision their operation was designed to handle, they would require an additional 6
deputies per shift resulting in an annual cost of $4.4M. Since these are new hires, there are additional
upfront operational costs of $17K for training, office supplies, and incidentals.
Similarly, Jefferson County jail has witnessed a 25% reduction in their staff over the past few years,
dropping from 40 officers to 30 officers. Although they have only had two sexual abuse incidents in the
past two years, they feel that the risk of abuse has increased and there is much more potential for abuse
than there ever has been. Coupled by an increasing inmate population, Jefferson County believe 10 - 12
additional staff are required to provide adequate supervision to mitigate violent behavior, or in their case,
the potential of such behavior. Hiring these additional FTE will cost approximately $393K annually.
Since these are new hires, there are additional upfront operational costs of $10K for training, office
supplies, and incidentals.
Jails Cost Impact #3: Assessment and Use of Monitoring Technology (PP7)
By and large, cost impacts for PP7 are due to an altogether absence of technical supervision or antiquated
systems deemed inefficient to meet the standard. Common throughout the study for all sectors, this cost
is the most variable representing significant cost impacts for many sites. For the jails sector, six out of the
16 sites have technology upgrades in flight or have a need for an upgrade of their current technology
capabilities in order to comply with this standard. Aiken County, for example, employs technical
supervision however, they feel it is antiqued and impractical with only 16 out of 85 cameras that even
record. With a very good understanding of their technical requirements, they already have a procurement
process in place to install 85 new cameras throughout the facility with a one-time cost of $500K.
The Marion County Jail has cameras in place in portions of its facility but it does not provide complete
coverage and efforts are already underway to install additional cameras. A total of $200K has already
been spent to purchase and install cameras in the common areas, supplemented by a $75K grant from the
State Criminal Alien Assistance Program (SCAAP). Despite these investments, the west side of the
facility does not contain any cameras due to lack of infrastructure necessary to support the technology.
This would require an estimated additional $113K investment. They also need 3 FTE to maintain the
equipment and monitor the video footage. This is estimated to cost an additional $179K per year plus
one-time operational costs for new employees estimated at $3K.
Similarly Peumansend Creek does not have full coverage throughout its facility and is also burdened with
a system that is no longer supported by its vendor, making it obsolete and preventing them from any
expansion because it is based on a technology that is not interoperable with current technology. An
upgraded system with ten additional cameras is estimated to cost $400K.
Recent technical assessments at Miami-Dade have highlighted a need for additional video surveillance.
With an antiquated system similar to Peumansend Creek but with a much larger facility requiring a full
retro fit, this is estimated at $25M. Although a seemingly high estimate, Miami-Dade assert that their
current video surveillance system is not effective in preventing and investigating sexual abuse. Some
facilities are altogether absent of any type of surveillance system and those with existing cameras do not
Appendix A - Underlying Causes of Cost Impacts/Jails

A-24

PREA Cost Impact Analysis
provide true surveillance capability because the technology is inferior. A full site assessment is still
required to determine specific requirements but the cost estimate is in line with past technology
investments such as a recent telecommunications upgrade costing $14M. That effort is considered less
complex and does not take into account major differences such as the physical infrastructure and
equipment required for five separate sites currently in operation, two future sites and construction of a
central operations, separate from control areas at individual facilities.
Essex County is the one site that has a fully funded upgrade in flight and is currently in the process of
adding 396 cameras along with archiving capabilities at a cost of $2.2M. This is not reflected as a cost
impact to PREA in this study as it is considered a sunk cost since it is already funded. These investments
cover the Male Release Center, (―the Farm‖), and the Women in Transition (―WIT‖) both having obsolete
video monitoring systems.
Jails Cost Impact #4: Zero Tolerance for Sexual Abuse (PP1)
The major issue in this standard is the requirement for an agency to employ or designate a PREA
coordinator to oversee the agency's efforts to comply with the NPREC standards. For most of the sites
visited, this resulted in the need for at least one additional full-time staff member added to their
management and operational budget requirements. One site, Peumansend Creek, already has a
designated, part-time PREA Coordinator and, so long as their bed space is below 500, can retain
compliance with this standard at no additional cost. The following table lists the budget requirements for
an additional staff member assuming a senior level position reporting directly to the agency head. All
costs are annual, fully loaded, including salary and benefits (e.g., healthcare, retirement). Operational
upfront costs are also includes office furniture and supplies, office equipment, communications services,
training, and other expenses above and beyond salary and fringe benefits.
Site
Upfront
Sacramento County$
1
WA Pierce County $
1
Miami-Dade
$
1
Alachua County $
1
Denver County
$
1
Albany County
$
1
Hennepin County $
1
Essex County
$
1
Marion County
$
1
Pulaski County
$
1
Norfolk City
$
1
Jefferson County $
1
Anoka County
$
1
Aiken County
$
1
WI Pierce County $
1
Peumansend Creek

Yearly
$ 199
$ 163
$ 141
$ 136
$ 124
$ 101
$ 101
$
93
$
92
$
92
$
56
$
53
$
25
$
21
$
20

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
0.25 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
Superintendent chooses to be PREA Coordinator

Jails Cost Impact #5: Training and Education (TR1 through TR5)
Training and education has a significant cost impact on the majority of jails included in this study.
Primary costs drivers include modifications to current curriculum and training to an expanded set of
Appendix A - Underlying Causes of Cost Impacts/Jails

A-25

PREA Cost Impact Analysis
employees, contractors, and volunteers in order to cover PREA material. Due to their smaller size relative
to prisons, it is assumed in this study that Jails can leverage the PREA Coordinator to assist in curriculum
development and even training delivery when feasible. This assumption was applied to each jail on a
case-by-case basis depending on their size. For example, a PREA coordinator at Miami-Dade, a very
large jail with five facilities, would have a much more complex set of duties than a PREA coordinator
Norfolk City, a considerably smaller jail. The following tables show the cost impacts by site according to
the three training standards:
Site

Employee Training (TR-1)
Upfront
Yearly

Miami-Dade

$

Albany County

$

Denver County

$

132

WI Pierce County

$
$

WA Pierce County

$

63

$

Pulaski County

$

15

$

Peumansend Creek
Hennepin County

$
$

48

$

Anoka County

$

Jefferson County

$

Norfolk City

$

1 $

Aiken County

$

4

Alachua County
Essex County
Marion County
Sacramento County

Notes
Cost reflects modifications to web-based training that does not include PREA content ($23K). Employees at Miami-Dade are
261 granted 40 hours of training annually and all training is considered overtime. PREA training would require an additional two
hours time from each employee, subject to overtime. Total cost for overtime is estimated at $238K/year.
Albany Co. provides sexual harassment training to all sworn officers in a classroom forum (and refresher training as their
budget permits) but does not cover PREA specific curriculum and their administrative staff does not receive the same training.
115
Assuming the curriculum can be obtained or developed by the PREA Coordinator, this cost reflects delivery of the additional
PREA content for sworn employees and full PREA training required for administrative staff.
The Denver Co. police provide training to all employees; however it does not cover PREA standards. Costs reflect four
33
additional hours for each employee to cover PREA topics during initial training and one additional hour to cover PREA topics
Training is provided but does not cover PREA. It is likely that WI Pierce Co could receive training through the state mandated
20 certification training program but that is uncertain. Assuming the curriculum can be obtained or developed by the PREA
Coordinator, and cannot leverage state training, this cost reflects delivery of the additional PREA content annually.
Training is provided but does not cover PREA. Assuming the curriculum can be obtained or developed by the PREA
16 Coordinator, costs reflect four additional hours for each employee to cover PREA topics during initial training and one
additional hour to cover PREA topics during refresher training.
PREA training is already provided to all new sworn employees but does not cover civilian employees. Upfront cost reflects
the estimated cost to teach PREA topics to the non-sworn staff ($3K) and the sworn employees hired before PREA training
11 was instituted. These employees are subject to overtime pay and have a training cost estimate of ($12K). The ongoing costs
reflects recurring training for these same individuals, non-sworn staff and employees hired before PREA training was
instituted. Those hired after PREA training was instituted already receive periodic refresher training and that is considered a
PREA training is covered for new employees but not during refresher training. Cost reflects an additional four hours of
11
training per employee every year.
Hennepin Co. provides training but it does not completely cover the PREA standards. Upfront costs reflect modifications need
7
to be made to their training curriculum in order to make the material more comprehensive on PREA. On-going costs cover
Anoka Co. provides training but it does not completely cover the PREA standards. Assuming the curriculum can be obtained
4
or developed by the PREA Coordinator, this cost reflects delivery of the additional PREA content annually.
All Corrections staff is given a 40 hour, Corrections Officer Certification course during the initial few months of their
<1
employment. A section of that class is dedicated to employee conduct, criminal investigations, PREA, Missouri State Statute,
PREA training is already provided to all sworn employees but does not cover 12 civilian employees. Cost reflects staff time to
<1
attend initial training and periodic refresher training. Delivery of training can be provided by PREA Coordinator at no
Training is provided to most employees but it does not cover PREA specific curriculum. It also does not cover the four
administrative clerks. Additional costs cover development of PREA materials/content and instructor cost. It is assumed that
the curriculum can be reused for on-going refresher training.
All employees are currently trained (to include sworn and civilian) on PREA topics. Method of training is a web-based module
with refresher training provided annually.
Orientation training for all employees is thorough, including 2 hours devoted to sexual abuse and PREA.
Marion Co. jail employees receive training on sexual abuse, consistent with PREA. Training is provided in a classroom
setting, a video loop, and through a handbook provided to all employees. Training is provided by staff and a 24-hour annual inSacramento Co conducts initial PREA training (covering domestic violence and sexual assault) for all employees and a 4 hour

Appendix A - Underlying Causes of Cost Impacts/Jails

A-26

PREA Cost Impact Analysis
Inmate Education (TR-3)
Notes
Upfront
Yearly
$
7 $
7 Costs reflect modification to orientation pamphlet (reprinting and binding) to incorporate PREA material.
Inmates are provided a sexual abuse orientation guide sheet which provides instructions on how to report any sexual abuse and
Norfolk City
$
2 $
2 policy on sexual abuse. The same information is included in the inmate’s handbook which all inmates receive. Nevertheless,
modifications are required to encompass PREA. Cost reflects development of a comprehensive PREA program with written
Inmates do not receive any PREA education. Hennepin Co believe the most cost efficient means is via video to be broadcast
Hennepin County $
50
throughout the jail. Costs reflect modifications to the television system, development of educational curriculum, production
costs, and modification of the jail's electronic inmate management system to document and track inmate participation in these
Miami-Dade
$
28
Costs reflect augmentation to inmate handbook, development of PREA orientation video, and monitors in intake and booking
Sacramento County $
25
Supplies and equipment cost to provide video loops and educational materials to all inmates.
Inmates do not receive any PREA education. Costs reflect revisions to orientation video to include PREA content (also done
Anoka County
$
13
in multiple languages), redeveloping the current orientation program, developing training materials and presenting classes on
WA Pierce County $
12
PREA education is not provided to inmates. Costs reflect development of materials and video.
Essex County
$
3
Essex Co. provides education on sexual abuse during the intake process but it does not cover PREA. Costs reflect material
All inmates receive training during their classification interview but it does not include PREA. Cost reflects production of new
Aiken County
$
1
orientation video to include PREA information.
WI Pierce County $
1
PREA education is not provided to inmates. Costs reflect development of handbook on PREA.
Alachua County
PREA education is not provided but can be covered by the PREA Coordinator at no additional cost.
Inmates receive a handbook at orientation but it does not include sexual abuse. Albany Co estimates that modifications can be
Albany County
made at minimal costs with labor provided by the PREA Coordinator.
Denver Co shows a video at booking on sexual abuse and provides a handbook with the PREA standards. They also have
Denver County
posters on PREA around the facility.
A prisoner handbook is given to each inmate at intake. The handbook explains the zero-tolerance policy of the Jail and
Jefferson County
discusses the procedures involved in reporting incidents.
Comprehensive education on sexual abuse is provided to all inmates at intake. Inmates are shown an orientation video and
Marion County
receive handbooks that cover PREA issues.
Peumansend provides all inmates with an orientation film and handbooks which are updated on an annual basis. The average
Peumansend Creek
stay of an inmate is 60 days so refresher training is not necessary. Monthly newsletter and television channel includes an
education on PREA (a video they obtained from DOJ).
Site
Pulaski County

Jurisdiction
Pulaski Co.

Norfolk City

Inmate Education (TR-3)
Notes
Upfront
Yearly
$
7 $
7 Costs reflect modification to orientation pamphlet (reprinting and binding) to incorporate PREA material.
Inmates are provided a sexual abuse orientation guide sheet which provides instructions on how to report any
sexual abuse and policy on sexual abuse. The same information is included in the inmate’s handbook which all
$
2 $
2 inmates receive. Nevertheless, modifications are required to encompass PREA. Cost reflects development of a
comprehensive PREA program with written material, a video education segment, and an instructor.

Hennepin Co.

$

50

Miami-Dade

$

28

Sacramento Co.

$

25

Anoka Co.

$

13

WA Pierce Co.

$

12

Essex Co.

$

3

Aiken Co.

$

1

WI Pierce Co.
Alachua Co.

$

1

Albany Co.
Denver Co.
Jefferson Co.
Marion Co.
Peumansend Creek

Inmates do not receive any PREA education. Hennepin Co believe the most cost efficient means is via video to be
broadcast throughout the jail. Costs reflect modifications to the television system, development of educational
curriculum, production costs, and modification of the jail's electronic inmate management system to document and
track inmate participation in these educational sessions.
Costs reflect augmentation to inmate handbook, development of PREA orientation video, and monitors in intake
and booking areas.
PREA education is provided to all inmates.
Inmates do not receive any PREA education. Costs reflect revisions to orientation video to include PREA content
(also done in multiple languages), redeveloping the current orientation program, developing training materials and
presenting classes on PREA to our existing inmates.
PREA education is not provided to inmates. Costs reflect development of materials and video.
Essex Co. provides education on sexual abuse during the intake process but it does not cover PREA. Costs reflect
material updates and reprinting,
All inmates receive training during their classification interview but it does not include PREA. Cost reflects
production of new orientation video to include PREA information.
PREA education is not provided to inmates. Costs reflect development of handbook on PREA.
PREA education is not provided but can be covered by the PREA Coordinator at no additional cost.
Inmates receive a handbook at orientation but it does not include sexual abuse. Albany Co estimates that
modifications can be made at minimal costs with labor provided by the PREA Coordinator.
Denver Co shows a video at booking on sexual abuse and provides a handbook with the PREA standards. They
also have posters on PREA around the facility.
A prisoner handbook is given to each inmate at intake. The handbook explains the zero-tolerance policy of the Jail
and discusses the procedures involved in reporting incidents.
Comprehensive education on sexual abuse is provided to all inmates at intake. Inmates are shown an orientation
video and receive handbooks that cover PREA issues.
Peumansend provides all inmates with an orientation film and handbooks which are updated on an annual basis.
The average stay of an inmate is 60 days so refresher training is not necessary. Monthly newsletter and television
channel includes an education on PREA (a video they obtained from DOJ).

Specialized training for investigations and medical and mental health care had a significant less cost
impact. For most of the jails in this study, the investigators are employed by the sheriff's office that
manages the jail and are accustomed to conducting investigations in confinement settings. Medical and
mental health staff on the other hand typically are employed by the county health department and receive
their training on sexual abuse through individual medical and professional licensure requirements. This is
Appendix A - Underlying Causes of Cost Impacts/Jails

A-27

PREA Cost Impact Analysis
done outside the jail and external to their own training operations. And for most, it is difficult to ensure
the training they receive is compliant with the standard. And if it were not, particularly in rural areas,
they have limited options of recourse because there simply are not many resources available in the
community. Most sites did express a need for training but the costs, by and large, were relatively low,
within a range of $1K - $5K with a few exceptions noted below. Although relatively low, all costs
however are deemed quite uncertain as most sites were not aware of available curriculum and training
programs.
Specific examples of Investigator training include Hennepin County's estimate at $8K and WA Pierce
County's estimate at $11K for their investigators, Anoka County at $13K, and Alachua with the highest
estimate at $50K while Peumansend Creek referenced an ACA course for their investigators that would
cost approximately $7K.
As for examples on training for medical and mental health staff, Hennepin County estimated $20K for
eight hours of training per nurse for 35 nurses, Albany County estimated $6K, and Alachua County
estimated $20K for their medical staff, depending on the length of training, number of trainers and travel
requirements if it was deemed the current level of training was not adequate to meet PREA standards.
Similar costs were estimated for Anoka County to send their nurses to Sexual Assault Response Team
(SART) training at an initial cost of $3K. Sacramento County however, provided the highest estimate at
$300K, also assuming a training course at $3K per person to cover their staff of 100 medical and mental
health professionals. Peumansend Creek referenced a NIC course made available via internet that they
could use as a one-day seminar.
Jails Cost Impact #6: Evidence Protocol and Forensic Medical Exams (RP1)
The costs associated with providing inmates a victim advocate during the medical examination are
relatively low in comparison to the other issues presented by the standards. It appears to be a more of a
cost driver in facilities that are located in rural locations and have fewer victim advocate services
available or different attitudes about victim's rights particularly if they are incarcerated. It was found that
eight out of the 16 sites currently are providing these services at local hospital, medical center or other
community based groups such as local Rape Crisis or Treatment Centers or the YWCA.
As for the sites that do have a cost impact, they include sites like Peumansend Creek that contacts with
the Rappahannock Council Against Sexual Assault. They charge approximately $1K for each victim they
work with. This includes crisis services, court accompaniment when victim seeks prosecution, one month
of individual counseling, and written materials for counseling and support.
Other sites, on the other hand, face a serious hurdle due to the constraints on VOCA funding, whereby
local service providers will not work with inmates. In Alachua County, for example, victim advocacy
services are not currently being provided because they are grant funded and will not deal with inmates.
Pat discussion between the jail and some service providers led to a retainer fee plus a per incident cost.
With such limitations, Alachua finds it easier to hire their own advocate at $61K per year plus one-time
upfront costs of $1K for office set up and training.
Although it did not result in a cost in this study it is noteworthy that the state of South Carolina does not
consider an inmate as a victim if he or she has been sexually abused, potentially further limiting services
Appendix A - Underlying Causes of Cost Impacts/Jails

A-28

PREA Cost Impact Analysis
available throughout the state8. This means that a publicly funded hospital is not obligated to provide a
medical exam free of charge in a scenario where the victim is an inmate. This law however, does not
impact the one jail from South Carolina Aiken County, included in this study as the local county district
court covers the fees.
Jails Cost Impact #7: Gathering, Reviewing, and Reporting Sexual Abuse Data (DC1 through DC3)
Gathering, reviewing and reporting data was not found to be a relatively significant cost impact for the
jail sites included in this study. Certain evidence that was examined when looking at this standard
included whether or not the facility was currently reporting data (e.g., BJS survey on sexual violence), the
volume of sexual abuse incidents, and the site's current reporting and review processes and procedures.
There were few costs expressed in order to comply with these standards and it was found that most costs
could be minimized using the PREA Coordinator whose cost is captured in standard PP1. Two out of the
16 sites felt they would need to either formalize their review process or update their policy to ensure
formal documentation and analysis is conducted. The main cost drivers expressed were staff time, level of
effort and formalizing the review process in an official, documented procedure.
Hennepin County, for example, does not have any review team in place for such incidents. The cost,
based on a staff level of effort, to assemble a multi-disciplined team comprised of senior staff, medical
and mental health care staff, and investigators for review is estimated at $1K. WA Piece County, on the
other hand does conduct a review but it is not formalized. To formally establish a team in a document
procedure is estimated to cost $500. Similarly, Sacramento County does have a review team but it is not
formalized. The cost associated with the level of effort for establishing and convening a team, assuming
two incidents per year, is approximately $1K per year.
Jails Cost Impact #8: Hiring and Promotion Decisions (PP6)
The primary cost driver of this standard is the requirement to conduct background checks for all
promotions. All sites visited in this study conducted some sort of criminal background check on new
hires but not for promotions. Since most jails were housed with or near the sheriff's office, the cost of a
background check was minimal, usually done in house without a marked cost impact even with an
increased frequency as a result of this standard. However, a few sites either contract out for this service or
indicated a budgetary cost impact above and beyond a level of effort. Assuming $50/criminal background
check for this study9, the following table depicts the sites expressing this cost impact and the assumed
average number of promotions per year.
Jails Cost Impact #9: Audits of Standards (AU1)
As this is not a nationally instituted policy, requirement or service, PREA audits are not conducted
anywhere in the county. Nevertheless, each site is very familiar with the auditing process whether it is
state mandated audits or ACA accreditation audits. Based on the wide degree of audits across the county,
we assumed a standard jail audit fee of $25K per triennial audit per facility, equating to approximately
8

South Carolina public law 16-3-1510, SECTION 16-3-1510 (d).

9

See Assumptions section on criminal background checks.

Appendix A - Underlying Causes of Cost Impacts/Jails

A-29

PREA Cost Impact Analysis
$8K year per facility10. The following table provides a breakdown of the costs associated with the PREA
audit.
Jails Cost Impact #10: Screening (SC1 and SC2)
It was found that most sites currently utilized a formal screening process however the vast majority of the
jails in this study felt that they would need to update their screening instruments to include PREA-related
questions mostly because they fell short of meeting all the PREA criteria or were not gender-specific. For
these jails, each site was at a different degree of compliance, some requiring modest modifications with
little or no costs and some requiring significant modifications depending on the state of their current
classification process and "gap" between that and the PREA standard. This leads to seemingly
incongruent costs from site to site however, the costs reported her represent a measure of the distance
each site is from the PREA standard. In addition, the modification effort is dependent on the current
processes in place whether it is a paper-based, less formal screening on one spectrum or a more robust,
electronic screening system on the other. A few sites appear to have a very large gap from current
processes to the PREA standard, requiring not only significant modifications but additional employees to
manage and execute screening altogether, with one site even requiring additional housing in anticipation
of inmates not subject to separate housing prior to PREA. On this topic, it is noted that one site, WI
Pierce County has a reciprocity agreement with adjacent county jails for the transfer of flagged inmates
requiring separate housing when it is not available. This is a particular issue at WI Pierce County due to
their relatively small size with very few options available at their facility for segregated housing. This
practice was not witnessed at any other site and could be a cost minimization technique for jails requiring
costly, additional facility space.

10

See Assumptions for description of audit calculation.

Appendix A - Underlying Causes of Cost Impacts/Jails

A-30

PREA Cost Impact Analysis
The following table shows the variable costs from site-to-site to meet the screening standards.
Site

Upfront

Yearly

Alachua County

$

2

$

133

WA Pierce County

$

1

$

111

Miami-Dade

$

3

$

111

$

1

Albany County
Pulaski County

$

80

Hennepin County

$

20

Anoka County

$

10

Denver County

$

1

Sacramento County

$

1

Aiken County
Essex County

$

Jefferson County
Marion County

Norfolk City
Peumansend Creek
WI Pierce County

-

Notes
Current screening process does not meet the standard. The upfront cost reflects outsourced efforts needed to
validate and modified existing tools plus upfront operational costs for a new employee. On-going costs
reflect the addition of one caseworker FT
Inmates are screened during intake but it does not include sexual abuse. Upfront cost reflects modification of
the screening process to meet PREA standards. On-going costs reflect the addition of one caseworker FTE
due to increased time involved with th
Current electronic screening process does not meet the standard. The upfront cost reflects outsourced efforts
needed to validate and modified existing tools plus upfront operational costs for a new employee. On-going
costs reflect an additional officer
Cost reflects annual printing cost for a new form during the admission process. The development or research
of the new form will be managed by the PREA Coordinator at no additional cost above the cost of this
position captured above.
Inmates are screened during intake but it does not include sexual abuse and the current instrument is not
gender specific. Cost reflects modification of existing software to meet PREA standards
Inmates are screened during intake but it does not include sexual abuse. Cost reflects modification of the
screening process to meet PREA standards
Inmates are screened during intake but it does not include sexual abuse. Cost reflects modification of the
screening process to meet PREA standards
Inmates are screened during intake but the current tool is not gender specific. Cost reflects modification of
the screening process to meet PREA standards
Inmates are screened during intake but it does not include sexual abuse. Modifications are expected to be
minimal.
Cost reflects effort for Classification Lieutenant to research and format assessment tool to include PREA
related information.
Essex County performs an extensive screening process for all inmates during intake.
Current screening is comprehensive and covers PREA material although it is not gender specific with separate
questions. This modification can be made at no additional/determinate cost.
Inmates are screened at intake at subsequent classification reviews to assess their risk of sexual victimization
and abusiveness.
There are numerous screening instruments in the Norfolk Sheriff's Office designed to identify any risks based
on inmate history, mental health history, observations by personnel, and admissions by the inmate.
Current screening is comprehensive and covers PREA material although it is not gender specific. This
modification can be made at no additional/determinate cost.
Current screening is not comprehensive on PREA criteria. This modification can be made at no
additional/determinate cost, mostly by leveraging state

Jail Cost Impact #11: Contracting with Other Entities for the Confinement of Inmates (PP2)
Marion County is the only jail to contract with a private entity for these services. As a matter of fact, they
have more inmates in contracted facilities than they do in their own facility. They contract with two
private facilities, Marion County Jail II (MCJII) and Liberty Hall, both of which are ACA accredited and
maintain this status as part of their contractual obligation. MCJII houses 1,125 and women's unit houses
250 and both would be subject to new requirements as a result of PREA, particularly in training,
reporting, and supervision. With a contractor ratio of 1.4, PP2 is the greatest ongoing cost impact to
Marion County with an annual cost of $755K.
Jails Cost Impact #12: Contract Modifications for Outside Services (RP2 through RP4, and RE3)
Most sites in this study have some sort of agreement in place with an external vendor or community
organization to that provides emotional support and can help victims of sexual abuse transition from
incarceration to the community. These partnerships however, are loosely arranged and, by and large, are
not codified with an MOU or formal written agreement. Formalizing this partnership does not equate to a
significant or reportable cost for most sites. On the other hand some sites do expect a cost such mostly
due to administrative or legal feels to draft and formalize the agreement. These costs are all between
$500 and $2K and impact WA Pierce, Essex, Hennepin, Alachua, and Aiken counties.
Appendix A - Underlying Causes of Cost Impacts/Jails

A-31

PREA Cost Impact Analysis
Other costs include publication and printing charges to ensure that inmates are aware of such services
(RE3). Essex County, for example, provides a hotline for inmates to report sexual abuse incidents but
this information is not published on posters or pamphlets, which results in additional upfront costs of $1K
for developing, printing and posting these materials. Likewise, WA Pierce County estimates $300 for the
same thing. Marion County has a similar situation but on a larger scale, estimating $9K to develop and
print out poster boards with service provider names and numbers.
Jails Cost Impact #13: Ongoing Medical and Mental Health Care for Sexual Abuse Victims and
Abusers (MM3)
Most sites in this study provide mental health care for both sexual abuse victims and abusers yet a few of
them do not provide this service to abusers, resulting in additional costs. The primary cost drivers were
the modification of contracts with mental health care providers as most jails do not have their own mental
heath care staff in house. Sites impacted by this standard include Norfolk, Sacramento, Alachua, and
Miami-Dade. The estimated cost to meet this requirement for Norfolk is $56K per year required to
modify their existing contract with their mental health practitioner. With only one substantiated case of
sexual abuse in the past year, Miami-Dade can by with a minimal impact, $150, to cover additional
counseling time for the abuser based on their current mental health care contract rates.
Alachua County, on the other and, expressed a concern about the number of known abusers that enter
their system annually. With 17,000 bookings and a known high quantity of sexual offenders entering
their system per year, they will require that at least four additional mental health care practitioners needed
to provide this service at an annual cost of $406K or roughly $102K per staff including salary, benefits
incidental costs. In addition, there are upfront operational costs of $4K since these are new hires.
Likewise, Sacramento County would need additional mental health care staff mostly because they have
experience an 80% cut in this area over the past few years due funding cuts from the state. For mental
health care, they consider themselves in "crisis mode" with absolutely no available resources for
additional duties. Although some inmates are able to provide services by an outside entity, the Man-Alive
Program, they would still need to hire six additional clinicians at a cost of $200K each per year yielding
an annual cost impact of $1M plus upfront operational costs of nearly $7K since these are new hires.
Jails Cost Impact #14: Supplement to SC2 Use of Screening Information (ID-6)
Standard ID-6, Supplement to SC2 User of Screening Information, appears to have a unique cost impact
on jails distinct from other sectors in this study, particularly is it relates to the requirement to house
immigrant detainees in separate housing. Not every jail houses immigrant detainees from ICE and CBP
but for the ones that do, the cost impact is either negligible or relatively significant because they either
have available, designated, separate housing or they do not. For those that do not have the space, the cost
of additional bed space and facility enlargements is relatively expensive. Three sites in particular
indicated a cost impact related to this standard: Albany County, Marion County, Denver County, and
Pulaski County Albany County does not have a contract with ICE but they do house ICE detainees and
currently house them with the general population (i.e., they are not held in separate housing). Enforcing
this standard would lead Albany County to refuse future detentions of immigrant detainees due the
budgetary requirements of housing them separately. Although space is not an issue, they would be
required to hire nine additional staff to supervise and manage this segregated inmate population at an
annual cost of $515K plus upfront costs of $9K since these are new hires. Likewise, Pulaski County also
Appendix A - Underlying Causes of Cost Impacts/Jails

A-32

PREA Cost Impact Analysis
does not have a contract with ice yet take in an average of 23 detainees per year with an average stay of
48 hours each. They treat their detainees just like the general inmate population and do not house them
separately. Assuming a housing cost of $56/day, this equates to approximately $3K on an annual,
ongoing basis to comply with this standard. Marion County, on the other hand does have a contract with
ICE but, like the others, they also do not house their immigrant detainees separately. If the jail were at
full capacity, this could require opening up a new cell block at a cost of approximately $19K/month for an
average capacity of 10 immigrants equating to $228K per year. This cost is for physical operations and
facilities only; on additional staff resources would be required. Denver County also has a contract with
ICE and does not house detainees separately, despite a recent ICE audit of their facility resulting in full
compliance with federal immigrant detention laws. Depending on how many immigrant detainees Denver
County houses, there might not any additional cost, particularly if that threshold does not exceed 48
detainees. However, if that count does exceed 48, Denver County would be required to open an
additional housing area to include nearly five additional staff with an estimated annual cost of $407K plus
upfront operational costs of approximately $5K since these are new hires. The probability of this is slim
therefore this cost is not included in the total cost impact for this standard.
Jails Cost Impact #15: Exhaustion of Administrative Remedies (RE2)
All of the jails included in this study were compliant with adhering to the exhaustion of administrative
remedies within a 90 day period.
However, there was some uncertainty about whether there would be a cost impact as a result of an inmate
deemed to have exhausted his or her administrative remedies 48 hours after notifying the agency of her or
her need for protection. Similar to prisons described above, it is worth mentioning that such a standard
would directly violate the Prison Litigation Reform Act (PLRA).
“No action shall be brought with respect to prison conditions under section 1983 of this title, or any other
Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such
administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a)
Due to the short time frame of incarceration in jails (anywhere from 10-30 days) however, most jails did
not think this would impact their population or considered their population as litigious. If there were a
cost impact, it would be limited to the level of effort attributable to documenting or modifying a policy
such as Essex Co's estimate of $3K or Sacramento's estimate of $2K for such purposes. On the other
hand there were four sites (Aiken, Anoka, Alachua, and Norfolk) that did indicate the possibility of
potential litigation and added legal costs. Similar to the litigation costs described in the prohibition of
cross-gender pat downs, these costs are considered speculative and unquantifiable in this study, however
it is worth noting that such costs could be significant.

Appendix A - Underlying Causes of Cost Impacts/Jails

A-33

PREA Cost Impact Analysis

Juvenile
The study reflects eight juvenile sites, one from the Northeast (MA Department of Youth Services), four
from the West (OR Youth Authority, ID Department of Youth Corrections, ACJCS, ID Juvenile, and CO
Division of Youth Corrections), one from the Southeast (FL Department of Juvenile Justice), and two
from the Midwest (IN Division of Youth Services and MO Division of Youth Services). Every site is
considered a jurisdiction having authority at the state level except for ACJCS, which is a county-run
facility. The ongoing and upfront tables highlighted with Harvey Balls represent an order of magnitude
signifying a cost impact in relation to overall budget for the juvenile sector. The degree to which each
Harvey ball is shaded indicates the magnitude of the cost impact. An empty ball represents standards that
do not result in any cost impact. On the other hand, a fully-shaded ball represents a percent impact on
annual operating budget that is greater than 0.50%. A quarter-shaded ball and half-shaded ball represent
an overall impact on annual operating budget between 0% and 0.25% and 0.25% and 0.50%, respectively.
The ongoing and upfront tables highlighted with Harvey Balls represent an order of magnitude signifying
a cost impact in relation to overall budget for the Prisons sector. The degree to which each Harvey ball is
shaded indicates the magnitude of the cost impact. An empty ball represents standards that do not result
in any cost impact. On the other hand, a fully-shaded ball represents a percent impact on annual operating
budget that is greater than 0.50%. A quarter-shaded ball and half-shaded ball represent an overall impact
on annual operating budget between 0% and 0.25% and 0.25% and 0.50%, respectively.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-34

PREA Cost Impact Analysis

OY

A

MO
DY
S

DY
S
MA

DY
S
IN

IDJ
C

FL
DJJ

CO
DY
C

CA
DJJ

JA
AR

AC
JCS

Prio
ri

ty

Table 20: Juvenile Ongoing Cost Impacts as % of Annual Operating Budget

0

0

1

0

0

0

0

0

0

0

0

0

0

4

0

0

4

0

0

0

0

1

4

r

1

1

1

0

0

1

0

0

0

0

0

r

4

0

0

0

5 Audits of standards

4

1

1

1

1

1

1

1

r

1

6 Training and Education

0

0

0

1

4

r

0

0

1

1

0

0

0

4

0

4

0

0

0

0

0

0

0

0

0

0

0

0

0

0

4

1

1

1

1

1

1

1

1

1

0

0

1

0

0

4

0

0

0

0

4

0

1

0

0

1

1

0

0

0

0

0

0

0

1

1

r

0

0

0

0

0

0

1

0

r

0

1

0

r

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

0

0

0

1

1

1

0

0

1

0

0

0

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

Limits to cross-gender
viewing and searches

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

Contracting with other entities
7 for the confinement of
inmates
Accomodating inmates with
8
special needs
Zero tolerance of sexual
9
abuse
Screening for risk of sexual
10
abuse
Contract modifications for
11
outside services
Evidence protocol and
12
forensic medical exams
13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

Appendix A - Underlying Causes of Cost Impacts/Juvenile

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

A-35

PREA Cost Impact Analysis

Limits to cross-gender
viewing and searches

A
OY

MO
DY
S

MA
DY
S

DY
S
IN

IDJ
C

DJJ
FL

YC
CO
D

CA
DJJ

JA
AR

AC
JCS

Prio
rity

Table 21: Juvenile Upfront Cost Impacts as % of Annual Operating Budget

0

0

1

0

0

0

0

0

0

0

0

0

0

1

0

0

1

0

0

0

0

1

r

4

4

4

4

4

0

4

0

0

0

0

0

0

0

0

0

0

5 Audits of standards

0

0

0

0

0

0

0

0

0

0

6 Training and Education

r

0

1

1

1

4

1

1

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

r

1

1

1

1

1

1

1

1

1

r

0

1

0

0

4

0

0

0

0

r

0

1

0

0

1

1

0

1

0

0

0

0

0

0

0

1

0

0

0

0

0

0

1

0

1

0

1

0

1

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

0

0

0

0

0

0

0

0

0

0

0

0

1

1

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

Contracting with other entities
7 for the confinement of
inmates
Accomodating inmates with
8
special needs
Zero tolerance of sexual
9
abuse
Screening for risk of sexual
10
abuse
Contract modifications for
11
outside services
Evidence protocol and
12
forensic medical exams
13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

Juvenile Cost Impact #1: Limits to Cross-Gender Viewing and Searches (PP4)
Cross-gender pat downs generally do not cause as much concern in the juvenile sector as it does for
prison and jails however, the major cost drivers are related to the same issue; the need to align staffing
and resident gender patterns more closely. To accomplish this, some sites may need to hire genderspecific personnel (usually males).
All Juvenile corrections jurisdictions in this study prohibit cross-gender pat downs, except the FL DJJ,
California DJJ and the IN DYS. The major cost drivers for the facilities that do not comply are based on
workforce realignment due to the imbalance between male-female staff ratios and male-female resident
ratios.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-36

PREA Cost Impact Analysis
The gender ratios that adequately allow facilities to prohibit cross-gender pat downs vary considerably.
This could be a result of shift assignments, the frequency that pat downs are conducted, and other
functional processes and/or policies that in place. For example, the Colorado DYC, which prohibits
cross-gender pat searches as a written policy and the IN DYS which states that cross-gender pat downs
cannot be avoided due to male to female staffing ratios, have roughly the same male to female staffing
ratio and male to female resident ratio; 57% of staff at CO DYC is male and 86% of residents are male,
while at IN DYS, 60% of staff are male and 85% of residents are male. In the case of IN Division of
Youth Services, only one facility (an all woman facility) has the appropriate male-female staffing ratio to
avoid conducting cross-gender pat downs; staff at this facility consists of 75% female.
Both IN Division of Youth Services and the FL Department of Juvenile Justice, report that efforts to
decrease the number of female staff while increasing the number of male staff would violate Federal laws,
particularly, Equal Employment Opportunity Commission (EEOC) laws. The Florida DJJ states that,
although issues of discriminatory hiring and shift assignments would be the main obstacles to overcome,
it was determined that the agency could become compliant with very little cost impact.
Juvenile Cost Impact #2: Inmate Supervision (PP3)
Most of the juvenile corrections agencies in this study reported very few substantiated sexual abuse
incidents. A few agencies did report increases over the past few years, but these are believed to be related
to an increase in awareness and a subsequent increase in reporting. Only the IN DYS and CO DYC
reported that the number of staff is currently inadequate to prevent sexual abuse. The cost drivers
associated with physical supervision are the wages, fringe benefits, and associated operating costs related
to hiring personnel.
The adequacy of physical supervision is often measured by the staff to resident ratio. The National
Council on Crime and Delinquency recommends a staff to resident ratio of 1:8 to effectively impact
abuse. The CO DYC estimates that an additional 25 staff will be needed to reach this ratio; these
additional positions are estimated to cost $1.3M in annual wages and benefits and $34K in operations
costs per year. To meet adequate supervision, the IN DYS believes that staffing ratios at its facilities need
to reach 1 staff per 10 residents. This would require 78 additional FTE’s at an estimated to cost $3.7M in
wages and benefits and $74K in operations costs.
Juvenile Cost Impact #3: Assessment and Use of Monitoring Technology (PP7)
Video monitoring is a common form of technical supervision in all corrections facilities. All juvenile
corrections agencies visited in Phase II of this study have at least some video monitoring in place
however, all (except MO DYS, which upgraded much of its video monitoring technology two years ago)
believe that some enhancements are needed. Some facilities lack video monitoring coverage in vital
common areas, others lack achieving capabilities and some others have outdated equipment that is in need
of upgrades or replacement.
The major cost drivers for technical supervision include the purchase and installation of equipment,
maintenance, and LOE related to the monitoring of camera systems. A few costs were identified by
jurisdictions that have recently installed video monitoring in their facilities or that have plans in place to
do so. The MA DYS recently obtained an estimate to install video cameras at its facilities, which ranged
from $63K to $115K per facility. In addition, the IN DYS noted that they recently purchased 108 new
cameras for their female facility at a cost of $300K for the equipment and installation; $3K per camera.
Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-37

PREA Cost Impact Analysis
Although the cost of equipment, on a per unit basis, is likely to be fairly consistent among facilities, the
cost of installation could vary considerably. Installation costs could be impacted by the age of buildings,
infrastructure issues and building designs. For example, older buildings may require more retrofitting
which could lead to additional costs. Other buildings may require infrastructure upgrades to support the
technology, leading to higher costs.
The FL DJJ, one of the largest juvenile systems in this study with 76 residential facilities and 25 detention
centers under its jurisdiction, had the largest estimated cost for technical supervision. The FL DJJ
estimated it would cost $380K per facility to update its camera systems to provide adequate coverage; the
total cost for all facilities combined is roughly $38M. This is a relatively high cost per unit, but may be a
result of high installation costs due to the issues noted above. And there is ample evidence justifying
technology investments at DJJ. An incident two years ago in a Collier County, Florida juvenile detention
center provides an example of the importance of adequate and updated camera technology. Portions of a
lawsuit against the Collier County Sheriff’s Office, which stemmed from an assault at the juvenile
detention center there, were dismissed for technical reasons, as a result of poor videotape. According to
naplesnews.com, a male juvenile was repeatedly attacked and sexual assaulted by two other male
residents between May 14 and 15, 2008. The attacks were recorded on videotape but the article notes that
the report of the incident ―… said a sheriff’s investigator couldn’t confirm all the boy’s allegations due to
the poor videotape quality, camera angle and because one boy covered the lens at one point.‖11 Since the
allegations could not be confirmed, as a result of the poor videotape, part of the lawsuit against the Collier
County Sheriff’s Office was dismissed.
The CO DYC identified the second largest cost associated with technical supervision, among the nine
juvenile systems in this study. The CO DYC estimates its cost for video monitoring using facility square
footage; the agency estimates that it would cost $27 per square foot to upgrade its facilities to provide
adequate coverage. The CO DYC has 10 facilities in need of upgrades, encompassing 657,526 square feet
of space; the estimated cost to upgrade these facilities is roughly $17.8M.
Other relatively large costs associated with technical supervision include $4M for the OR YA to purchase
and install new video monitoring equipment to provide complete coverage of its facilities and $2.5M for
the IN DYS to do the same. In addition, OR YA noted that at least one new FTE would be required to
staff the monitoring equipment.
Four of the nine juvenile corrections agencies in the study also do not conduct annual technology need
assessments and identify relatively small costs associated with these; costs ranged from $110K for the CO
DYC to $5K for IDJC.
Juvenile Cost Impact #4: Zero Tolerance of Sexual Abuse (PP1)
The major issue in this standard is the requirement for an agency to employ or designate a PREA
coordinator to oversee the agency's efforts to comply with the NPREC standards. For most of the sites
visited, this resulted in the need for at least one additional full-time staff member added to their
management and operational budget requirements. The following table lists the budget requirements for
an additional staff member assuming a senior level position reporting directly to the agency head. All
11

Naplesnews.com, ―Part of lawsuit over teen’s beating in Collier juvenile center dismissed‖, Aisling Swift, May
27, 2010.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-38

PREA Cost Impact Analysis
costs are annual, fully loaded, including salary and benefits (e.g., healthcare, retirement). Operational
upfront costs, such as office furniture and supplies, office equipment, communications services, training,
and other expenses above and beyond salary and fringe benefits, are also included.
Site
CA DJJ
MO DYS
OYA
CO DYC
FL DJJ
IN DYS
MA DYS
ACJCS
AR JA
IDJC

Upfront
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1
$
1

Yearly
$ 140
$ 101
$
92
$
86
$
76
$
72
$
71
$
59
$
38
$
34

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.
0.5 FTE salary, benefits and new hire operations costs.

None of the juvenile corrections jurisdictions in this study currently have a dedicated PREA Coordinator;
the IDJC has temporarily assigned PREA coordination duties to a Correctional Program Coordinator
within the Quality Improvement Unit. A full-time PREA Coordinator is required for jurisdictions
containing over 500 residents; jurisdictions with fewer than 500 residents only require a part-time
coordinator. Of the ten juvenile corrections jurisdictions in this study, seven will require a full-time
PREA Coordinator and three will require a part-time coordinator; ID DYC, ACJCS, and AR JA.
Although not required by PREA standards, to adequately perform the responsibilities of the position,
some of the larger jurisdictions may require a small staff to assist the PREA Coordinator or in some
instances multiple coordinators. For example, the FL DJJ may need two PREA Coordinators, as the
agency is divided into detention and residential divisions, both containing well over 500 residents.
The costs associated with the PREA Coordinator position consists of salary, benefits, and operational
costs. The positions should be management level and likely report directly to agency Directors or
departmental heads. The costs for a PREA Coordinator position, among the jurisdictions that will require
a full-time position, range from $139K to $69K for salary and benefits. The highest cost for a PREA
Coordinator is for CA DJJ, where wages are relatively high, and the lowest cost is for IDJC, where wages
are relatively lower. The operational cost associated with one full-time PREA Coordinator consists of a
$1,100 one-time cost for office equipment and training and a yearly cost of $1,450 for office supplies,
communications expenses, institutional expenses and ongoing training.
Juvenile Cost Impact #5: Training and Education (TR1 through TR5)
Training and education has a moderate to significant cost impact on many Juvenile corrections agencies
included in this study, particularly the training of employees. Primary costs drivers include modifications
to current curriculum and training to an expanded set of employees, contractors, and volunteers in order to
cover PREA material. It is assumed in this study that some of the smaller Juvenile corrections agencies
can leverage the PREA Coordinator to assist in curriculum development and even training delivery when
feasible. The following tables show the cost impacts by site according to the first three training standards;
employee training, volunteer and contractor training, and resident education. The remaining training
standards, training for investigators and training for medical and mental health staff, have a significantly
less cost impact and are described in narrative.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-39

PREA Cost Impact Analysis

Site

Employee Training (TR-1)
Upfront
Yearly

FL DJJ

$

36

$

3,364

CO DYC

$

1

$

61

IDJC

$

121

$

40

MO DYS

$

95

$

24

ACJCS

AR JA
CA DJJ
IN DYS

MA DYS

OYA

Site

Volunteer and Contractor
Upfront
Yearly

OYA

$

124

$

FL DJJ

$

7

$

MO DYS
ACJCS
AR JA
CA DJJ

$

1 $

CO DYC
IDJC
IN DYS
MA DYS

Notes
FL DJJ does not currently provide PREA training to all staff. Included are costs for two different levels of training: one for all
direct care that is very in depth, and then training for the rest of the facility staff. This cost includes development cost, and
wages for staff to attend the training. These costs are all due to PREA implementation: $36,000 is development and the rest is
staff time. 4,800 employees in total which will require increased training.
Training is provided to all employees on PREA related material. The New Hire Academy training does 1.5 hour PREA training
and then weaves the PREA issues throughout the entire 40-hour week within other modules. Yearly training is 2 hours for all
employees within DYC facilities. Refresher training is provided; 2 hours minimum per year. The mandates for initial and ongoing training of all staff, volunteers, and contractors would require at a minimum 1.0 FTE to ensure compliance. The cost for
training volunteers and contractors is included here, as noted in the chart below.
Only direct care employees receive training on sexual abuse and PREA. The training is conducted within classrooms by agency
employees. Refresher training will also need to be provided. In addition to the current training provided, the proposed training
requirements in the proposed standards would require additional training and training development for all IDJC staff. The cost
to develop the training would be $28.00 per hour for 40 hours. IDJC would need to train 400 staff at a cost of $100. 00 per
day for initial training. The training modules as outlined in the standards would require 3 days of training. It is estimated that
refresher training would require 400 staff to be trained for 8 hours, at $100.00 per day.
Training on PREA is not currently provided. It is estimated that the initial cost will be $95K to provide an additional four
hours of required training for all employees. Annual cost to provide one-hour refresher cost is estimated to be an additional
ACJCS does not currently provide PREA training to all staff. Only correctional staff is trained on sexual abuse prevention,
detection, and response policies and procedures for a length of one hour. Training is provided by staff and they are currently
working on offering computer based training. Although training for all staff is not currently provided, the PREA coordinator
would develop a PREA curriculum.
Training on PREA is provided to all employees. In addition, refresher courses are provided. Oral presentations are given and
pamphlets are provided.
The CDJJ provides an initial four (4) hour training of PREA at the peace officer academy, and one (1) hour of mandatory
annual. The CDJJ provides an initial four (4) hour training of PREA at the peace officer academy, and one (1) hour of
Every employee receives training that includes PREA. Training consists of 1 to 2 hours in classrooms and handbooks. Annual
refresher training is also provided. No cost is expected.
All direct care state employees and some contracted providers obtain PREA training through the DYS Basic Training 3 ½ hour
PREA course. Included in the DYS Basic Training curriculum are effective communication; de-escalation; and boundaries
modules. DYS also provides annual training including PREA to direct care staff and some contracted staff. Those who attend
the above courses are required to sign acknowledgement forms that they have received training on this information and
understand the training and policies. Currently, there are approximately 1000 state employees that receive our trainings with 4
trainers at the Training Academy. Per BAH, costs are considered sunk, as MA DYS is already in compliance.
All new OYA staff is required to attend one week of initial training. This includes two hours specific to PREA and is
conducted in a classroom setting. $500 in training costs was initially incurred to develop the training material. If the new staff
has contact with offenders, they attend an additional two weeks of training. Currently there is no refresher training but this is
being created. The refresher training can be delivered on an annual basis at no additional cost.

Notes
Volunteers receive PREA training as part of the approval process to work with OYA offenders, however, contractors do not.
Training for contractors is being designed. This training would be classroom and computed based. Costs provided are due to
30
increase in contractor payment and are yearly estimates. The term contractors would include those providing services in and
outside of OYA’s Juvenile Facilities.
Volunteers and contractors providing on-site maintenance and repair currently receive no training. These costs are for
2
volunteers to receive one hour of training and for a flyer to be prepared and distributed to contractors providing maintenance
<1 Additional training will be required for volunteers and contractors.
Contractors receive PREA training, however, volunteers do not. The PREA coordinator will train volunteers to PREA
Training, to include refresher, is provided to all volunteers and contractors.
CA DJJ policy requires training for all contractors and volunteers on PREA.
PREA training is provided to all employees and contractors at a length of 30 minutes through classroom settings and posters.
The additional FTE named in Standard TR1, above, would support in this area as well.
Training is provided to volunteers that have direct contact with residents. Contract providers are required to provide training
to their staff. If the new standards are approved, the cost for contract providers to implement the training would be passed on
to IDJC. These costs would be added into daily rates. This additional cost is included in standard PP2.
Training is provided to all volunteers and contractors that have direct contact with residents. Volunteer and contractor training
are consistent with employee training. No cost is expected.
All contracted employees that have contact with residents are provided PREA training.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-40

PREA Cost Impact Analysis

Site

Inmate Education (TR-3)
Upfront
Yearly

FL DJJ

$

22

$

IDJC

$

2

$

ACJCS

$

1

AR JA
CA DJJ
CO DYC

IN DYS
MA DYS
MO DYS

OYA

Notes
Education on PREA is not currently provided. The costs reflect a video for each facility as well as flyers and posters. Cost for
11 material and video deemed to be upfront cost. 2/3 of cost has been allotted to video and 1/3 to material. Assume video cost is
upfront and material cost is yearly.
Comprehensive education on sexual abuse is not provided to residents. Current cost for developing training curriculum for
POST academy is $28.00 per hour. It is estimated that it would take approximately 80 hours to develop a curriculum. It is
8
also estimated that it would cost $2K annually for materials. The provision of this training would take approximately 1 hour
for each juvenile coming into the system. Approximately 324 juveniles enter the system annually. The average salary and
Handbooks are provided to residents during the intake process. The handbooks contain educational information on sexual
abuse. Refresher training, however, is not provided. It will cost $1K to develop material, such as poster boards, to be used for
refresher training.
Resident education is provided and refresher training is provided by case managers, quarterly, and on DVD through monitors.
CDJJ currently does provide training to youth at the point of intake, quarterly and when the youth arrives at a new facility.
Education on PREA to youth in their care, however, the process is more defined in some facilities than others. The training is
provided through classroom and video. Refresher training is done typically on a weekly basis but the majority is conducted at
intake. There would be a cost associated with printing of the posters, handbooks, and updates as a means for refresher training
along with costs associated for training staff to be trainers to the youth. The additional FTE named in Standard TR1, above,
Comprehensive education on sexual abuse is provided to residents. This consists of a PREA video, a handbook, and other
material placed throughout the facilities. Refresher training is provided periodically, including a public address message played
on a weekly basis.
Residents receive a handbook with information on PREA standards and policies including how to report incidents through a
grievance box at all locations.
MO DYS provides an extensive and comprehensive education program to its residents, which includes training on sexual abuse
issues. The education is conducted on a continual basis, as part of the general philosophy of the agency’s programming.
All offenders are provided with PREA materials upon placement in OYA custody. The distribution of these materials is
tracked in the case management system and there is a monthly review of these dispersals. Offenders showing to have not
received these materials are noted and a concerted effort is taken to ensure these materials are delivered. These materials
consist of safety guides, contact cards and posters.

Specialized training for investigations and medical and mental health care had a significant less cost
impact. For some of the Juvenile corrections agencies in this study, investigations are conducted by local
or state authorities not directly employed by the jurisdiction. These authorities, usually state and local
police departments, generally receive training on sexual abuse but do not receive training specific to
conducting investigations in confinement settings. In other instances investigations are conducted by
internal investigators and/or other state agencies, such as child welfare services. Five of the ten sites will
require additional training for investigators and will accrue, in most instances, a relatively minor cost to
do so.
All medical and mental health staff, on the other hand are employed directly and/or contracted by the
juvenile corrections agencies in this study. The medical and mental health care staff generally receive
their training on sexual abuse through individual medical and professional licensure requirements; this is
done outside the juvenile facilities and external to their own training operations. In these cases it is
difficult to ensure the training they receive is compliant with the standard. In a few cases however,
additional training is also provided by staff employed by the juvenile corrections agency. Five of the ten
sites also expressed a need for some additional training for medical and mental health staff, with varying
costs, depending on the extent of the training required to meet the standard.
Examples of estimated training costs for Investigators include MA DYS’s upfront cost of $5K, IDJC’s
upfront cost of $2K and yearly cost of $5K, FL DJJ’s yearly cost of $10K, and IN DYS’s upfront cost of
$25K. The highest estimated cost to train investigators was for CA DJJ; roughly $82K to train 24 internal
staff on sexual abuse and conducting investigations in confinement settings.
As for examples on training for medical and mental health staff, it is estimated that OYA’s cost will be
$9K upfront and $5K yearly, IDJC’s cost will be $3K upfront and $6K yearly, FL DJJ’s cost will be
$30K yearly, and MO DYS’s will be $2K upfront. The highest estimated cost to train medical and mental
health staff was also for CA DJJ, and again is roughly $82K to train 24 internal staff on preserving
evidence of sexual abuse.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-41

PREA Cost Impact Analysis
Juvenile Cost Impact #6: Evidence Protocol and Forensic Medical Exams (RP1)
In most cases, victim advocacy services available to residents in juvenile corrections facilities are
provided by an outside entity. In many instances the entity may be a local hospital, in coordination with
the Sexual Assault Nurse Examiners (SANE), or a service provider within the community. It is estimated
that two of the ten juvenile systems in this study will incur costs associated with providing a victim
advocate to accompany a victim through the forensic medical exam process (RP1). The largest (and only
significant) of these costs is for IN DYS, where it is estimated the providing a victim advocate during the
forensic medical exam will cost $4K in upfront costs and $230K in yearly costs. IN DYS does not
provide a victim advocate and local hospitals do not always provide one when conducting forensic
medical exams. The cost is to create an internal part-time position to provide this service to residents.
Juvenile Cost Impact #7: Gathering, Reviewing, and Reporting Sexual Abuse Data (DC1 through
DC4)
The gathering, reviewing, and reporting of sexual abuse data is a common practice among juvenile
corrections jurisdictions. The majority of the juvenile corrections agencies in this study were found to be
in full compliance with these standards; the only exceptions being the CA DJJ and CO DYC. Any costs
associated with this standard can also be mitigated by employing a PREA Coordinator, as the efforts
associated with data collection and review should fall under the responsibility of that position. In some
cases an additional FTE may be required to adequately perform these duties, particularly in larger
jurisdictions, with many facilities, where a PREA Coordinator may need assistance to complete all of the
positions responsibilities. The major cost drivers associated with these standards are LOE costs related to
the staff time required to collect, analyze and report the data. Where an additional FTE would be required
to perform these duties, the cost of salary, benefits, and related operational costs would be accrued. The
FTE would likely be a mid-level data analyst reporting to the PREA Coordinator; in situations where the
PREA Coordinator itself did not perform these duties.
Juvenile Cost Impact #8: Hiring and Promotion Decisions (PP6)
Background checks on new hires are also a common practice among correctional jurisdictions, including
the juvenile facilities in this study. Background checks for employees being considered for promotion (as
also proposed by PREA) are however, not as common. Rather, many jurisdictions rely on periodic
checks, often annual, to learn of criminal activity among its employees. Similarly, none of the juvenile
corrections agencies in the study asked prior institutional employers specifically about allegations of
sexual abuse that a prospective hire may have been involved in. This is not a cost factor however, since
most jurisdictions contact prior employers and can ask the question without an additional cost. It should
be noted however, that most jurisdictions felt that information regarding past allegations of sexual abuse
will not be revealed by prior employers due to privacy issues.
The only cost driver for this standard is, thus, the cost to conduct additional criminal background checks
on employees being considered for promotions. Assuming $50/criminal background check for this
study12, the following table depicts the approximate costs (rounded) for each site where costs were
expressed and the assumed average number of promotions per year.

12

See Assumptions section.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-42

PREA Cost Impact Analysis
Juvenile Cost Impact #9: Audits of Standards (AU1)
As this is not a nationally instituted policy, requirement or service, PREA audits are not conducted
anywhere in the country. Nevertheless, each site is very familiar with the auditing process whether it is
state mandated audits, ACA accreditation audits, or PbS audits. Based on the wide degree of audits
across the county, we assumed a standard juvenile audit fee of $17K per triennial audit per facility,
equating to approximately $6K a year per facility13. The following table provides a breakdown of the
costs associated with the PREA audit.
Juvenile Cost Impact #10: Screening (AP1 and AP2)
The majority of juvenile corrections agencies in this study employ a screening instrument or process to
identify potential victims of sexual abuse and potential sexual predators. Of the ten juvenile corrections
agencies, seven employed an instrument or process to screen for the risk of sexual victimization and
abusiveness that complies with standard AP1. Of the three jurisdictions that were not in compliance, two
(IDJC and ACJCS) do not currently screen for the risk of being sexually victimized and being a sexual
predator. The remaining jurisdiction not in compliance, CA DJJ, does screen for the risk of being
sexually victimized but feels that additional questions need to be asked to be fully compliant with the
intent of the standard. The following table shows the variable costs from site-to-site to meet the screening
standards.
Site

Upfront

IDJC

$

2,753

CA DJJ

$

14

ACJCS

$

1

AR JA
CO DYC
FL DJJ
IN DYS

Notes
Residents are screened during intake regarding their needs. However, there is no specific tool to measure risk
for being sexually abused or for having the potential to be sexually abusive towards others. It is estimated
$ 1,530 that the cost to develop such a tool would be $10K. It is also estimated that it would cost $35K to norm and
Yearly

$

Currently there are two screening questions related to victimization of sexual abuse. There is the need to
60 develop additional screening questions to be incorporated in existing instruments to reach full compliance.
A screening process is not in place at intake that assesses the risk of residents being sexual abused and the risk
of being abusive. Cost impact of implementing this process would be $1K. Medical and mental health staff is
available to speak with residents.
There is currently a written screening instrument in place. There would be no cost to modify the tool to
include PREA.
All youth are screened during intake and assessed on their risk of being sexually abused or having the
potential to be sexually abusive. Medical and mental health staff is available to speak with residents.
Residents are currently screened during intake for predator and vulnerability. The screening instrument is
gender-specific. Medical and mental health staff is available to speak with residents.
Residents are screened during intake and again at each reassignment. The screening identifies all risks and is
gender specific. Medical and mental health practitioners are available to speak with residents.

MA DYS

MO DYS

OYA

13

A risk assessment and screening are performed on each resident at intake and throughout the resident’s
commitment at various stages that may be predetermined or deemed necessary due to new information
received during their residency. This information is critical in establishing the history and risk presented on
youth entering our care. These assessments take into account, among the other factors, the gender and risk of
being abused or abusing other residents. Medical and mental health staff are available to speak to residents.
Residents are screened during intake and again at each reassignment; the screening identifies all risks. The
assessments are not done by medical and mental health practitioners; however, residents are given an
opportunity to discuss any safety concerns or sensitive issues privately with another employee, the Service
Coordinator.
Residents are not screened to this standard; however, OYA has access to the state of Washington’s SAVY
screening tool which assesses for aggressive and vulnerable offenders. This can be used at no cost to the
agency. Medical and mental health practitioners are available to speak with residents.

See Assumptions section.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-43

PREA Cost Impact Analysis
There can also be costs associated with using the screening information to inform about housing, bed,
work, education and program assignments with the goal of keeping separate those at high risk of being
sexually abused from those at high risk of being sexual abusive; standard AP2. These costs could
potentially be much higher than the cost to modify existing screening instruments, as there could be
situations where additional capacity is needed to accomplish this. For example, it is estimated that the
IDJC could accrue an upfront cost of $2.7M and a yearly cost of $1.5M to add 15 beds to its current
facilities to adequately separate those residents that are at high risk of being sexually victimized from
potential sexual predators. The need for additional beds is driven by the fact that 37.2% of its residents
have a history of being sexual offenders, and thus would be categorized as a high risk. Additionally,
IDJC operates at close to capacity making it difficult to separate residents within its current housing
configurations.
Juvenile Cost Impact #11: Contracting with Other Entities for the Confinement of Inmates (PP2)
Contracting to private facilities for the confinement of residents is often viewed as a cost saving measure,
as the public correctional entities can avoid the costs to construct its own facilities and avoid the costs of
hiring direct staff. Five of the ten Juvenile corrections agencies in this study contract with other entities
for the confinement of residents. The MA DYS has contracts with 37 facilities throughout the state to
house its residents; MA DYS houses its residents in a total of 57 facilities. In the FL DJJ system, 84% of
76 resident facilities are contracted. The IDJC can contract with up to 19 facilities for the housing of its
residents and the CO DYC contracts 48 facilities.
It is also common for correctional agencies to mandate that all contracted facilities follow the same
policies and procedure as the jurisdiction places on its own facilities. In these situations, contract
modifications may not be required to ensure that contracted facilities meet PREA standards, as they
would be required to under contractual mandates. Contracted facilities would however, accrue a cost to
bring their facilities into compliance, just as the non-contracted facilities would. If not restricted under
contract, this cost is likely to be passed down to the jurisdictions providing the contract, through increased
fees to operate and provide services at the contracted facilities such as CO DYC and IDJC. CO DYC will
have an estimated yearly cost of $1.6M, the vast majority of which are costs associated with the need to
update the technological supervision of its contracted facilities; specifically the purchase and installation
of cameras. IDJC will have increased yearly costs of $1M. Unlike the CO DYC, these costs are not
concentrated in any one standard, but rather is spread among several standards that the contracted
facilities will be required to comply with. It should be noted that FL DJJ also anticipates a significant cost
impact since 84% of their offenders are housed in a contracted facility. With so many offenders under
contractor supervision, their increased costs are embedded throughout all their standards and not isolated
solely in PP2.
Juvenile Cost Impact #12: Contract Modifications for Outside Services (RP2 through RP4, and
RE3)
The costs are associated primarily with the provision of support services (RP2) by outside entities and
community service providers. It is estimated that the IN DYS will accrue an annual cost of $30K to
contract with an outside entity to provide support service. ACJCS has a contract with a service provider
(National Federation of Families) but it does not provide the specific services required by PREA,
requiring them to look elsewhere, such as the Idaho Youth Ranch, and establishing a contract costing
approximately $50K per year to cover their 15 youth requiring such services. CA DJJ, on the other hand
Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-44

PREA Cost Impact Analysis
expects to incur a one-time cost of $20K as a result of establishing a process for receiving reports from
public entities and coordination of the services to residents. This will be followed by an annual cost of
$19K for transition counseling services to victims of sexual abuse.
In regards to conducting criminal investigations and prosecuting violations (RP3 and RP4, respectively),
most juvenile correction jurisdictions in this study noted that State and local police investigate cases and
local prosecutors, such as District Attorney’s, prosecute violation. Since these entities operate under state
and local statues, MOU’s would generally not be required. IDJC, on the other hand feels that MOUs
would be required and if the state statute did not meet the standard, they would have to develop MOUs
with each of the state's 44 counties for both investigations and prosecutions resulting in a one-time cost of
$42K ($21K for investigations and another $21K for prosecutions).
It is estimated that five of the ten juvenile systems in this study will incur costs associated with providing
access to victim advocates (RE3). The major cost drivers for these standards are associated with
developing material or updating existing material to include contact information on outside victim
advocate services. The material could include posters, pamphlets, or other material that is either posted
throughout the facilities or provided directly to residents. The costs to develop the material are relatively
modest, estimated at $4K for MO DYS.
Juvenile Cost Impact #13: Accommodating Special Needs (PP5)
Every juvenile corrections jurisdiction studied reported having multiple ways for residents with special
needs to report incidents of sexual abuse. Methods of reporting included TTY machines for the deaf,
language lines and staff for LEP residents, and access to mental health care staff and outside entities for
the mentally disabled. No costs are, thus, associated with this standard.
Juvenile Cost Impact #14: Investigations (IN1 - IN3)
PREA standards propose that investigations be conducted for all allegations of sexual abuse, including
third party reports, that complainants and victims be notified in writing of investigative outcomes and
disciplinary sanctions, and that all reported incidents of sexual abuse are substantiated by a preponderance
of the evidence. It is common practice for correctional jurisdictions to investigate all third party reports
of sexual abuse, including all the juvenile corrections agencies in this study. There is the possibility
however, that increased awareness related to PREA will subsequently lead to an increase in reporting,
which may in some instances require the need for additional investigators. It was determined that three of
the ten juvenile corrections agencies in this study are under staffed for investigators and, thus, would
likely need to hire additional investigators to comply with Standard IN1; assuming the increased
awareness related to PREA leads to increased reporting. It is estimated that OYA will need to hire three
additional investigators at an upfront cost of $3K and a yearly costs of $227K. The MA DYS is estimated
to need two additional investigators; $2K in upfront costs and $179K in yearly costs. Finally, it is
estimated that IDJC will require one additional investigator to ensure all allegations of sexual abuse are
investigated, the cost would consist of $1K in upfront expenses and $64K in yearly costs.
CO DYC relies upon their local Social Service Agency and/or law enforcement agencies to conduct all
investigations of sexual abuse but does not believe they are being administered adequately. With
anticipated increased sexual abuse reports as a result of PREA, CO DYC believes that the addition of an
Inspector General will support a better practice and ensure case are investigated when substantiated by a
preponderance of the evidence (IN3). They believe this will employ a more robust inquiry process
Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-45

PREA Cost Impact Analysis
ensuring investigations are conducted efficiently and effectively. CO DYC is the only site among the 49
having a cost for this standard. This cost is $79K per year plus associated one-time upfront hiring costs.
Juvenile Cost Impact #15: Conducting Mental and Medical Health Evaluations and Providing Care
(MM3)
All juvenile corrections agencies in this study conduct mental and medical health evaluations for sex
offenders and provide some ongoing care. It is estimated that two of the ten juvenile corrections agencies
would accrue a cost to provide ongoing care to sex offenders, the largest of which is a $750K yearly cost
to IN DYS. IN DYS currently provides treatment only to adjudicated sex offenders or those determined
to have a need for such treatment at the time of admission to their facilities. The cost is associated with
expanding the existing treatment program to all known victims of sexual abuse.
Juvenile Cost Impact #16: Exhaustion of Administrative Remedies (RE2)
The majority of Juvenile facilities in this study provide multiple ways for residents to confidentially
report sexual abuse; these including reporting to any staff member, through grievance boxes, and to
outside entities through phone calls. Only one, very minimal cost, was estimated for Standard RE1, a
$100 upfront cost and $400 annually for IN DYS to establish a direct phone line as a means of reporting.
The Exhaustion of Administrative Remedies (RE2) is commonly part of the grievance process which all
jurisdictions have in place. This process generally requires action within well within the time frame
specified in the standard. Only one, very minimal, cost is associated with this standard; a $450 upfront
cost for IDJC to revise two written policies to expressly provide for the exhaustion of administrative
remedies and the additional protection of juveniles requesting the protection.

Appendix A - Underlying Causes of Cost Impacts/Juvenile

A-46

PREA Cost Impact Analysis

Community Corrections
The community corrections sector includes jurisdictions that are responsible for residential care as well as
programs responsible for the non-residential supervision of offenders. Non-residential supervision
includes parole, probation and pre-release as applicable. The standards for non-residential community
supervision are a subset of the community corrections standards. The study reflects six community
corrections jurisdictions including two from the South (SC PPP and AR DCC), one from the Northeast
(MA OCC), one from the West (WA CC), and two from the Midwest (IN DOR and MO PP). The
ongoing and upfront tables highlighted with Harvey Balls represent an order of magnitude signifying a
cost impact in relation to overall budget for the community corrections sector. The degree to which each
Harvey ball is shaded indicates the magnitude of the cost impact. An empty ball represents standards that
do not result in any cost impact. On the other hand, a fully-shaded ball represents a percent impact on
annual operating budget that is greater than 0.50%. A quarter-shaded ball and half-shaded ball represent
an overall impact on annual operating budget between 0% and 0.25% and 0.25% and 0.50%, respectively.
For example, the MO PP ongoing cost impact as a percentage of annual operating budget for limits to
cross-gender viewing and searches is equal to 13.18% and therefore represented by a fully-shaded Harvey
ball.

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-47

PREA Cost Impact Analysis

SC

WA
CC

PP
P

MO

PP

OC
C
MA

DO
R
IN

DC
C

4

0

0

4

0

0

0

0

0

0

0

4

n/a

n/a

n/a

n/a

n/a

n/a

0

0

0

0

0

0

5 Audits of standards

1

1

1

r

1

1

6 Training and Education

0

1

1

1

1

1

0

0

0

1

0

1

0

0

0

0

1

0

r

1

1

4

1

1

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

1

0

0

0

0

0

0

0

0

n/a

n/a

n/a

n/a

n/a

n/a

0

0

0

0

0

1

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

Pri

AR

orit
y

Table 22: Community Corrections Ongoing Cost Impacts as % of Annual Operating Budget

1

Limits to cross-gender
viewing and searches

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and
4
mental health care
3

7
8
9
10
11
12

Contracting with other
entities for the
confinement of inmates
Accomodating inmates
with special needs
Zero tolerance of sexual
abuse
Screening for risk of
sexual abuse
Contract modifications for
outside services
Evidence protocol and
forensic medical exams

13 Investigations
14

Supplement to SC-2: Use
of screening information

Hiring and promotion
decisions
Gathering, reviewing, and
16
reporting data
Exhaustion of
17
administrative remedies
Agency protection against
18
retaliation
15

Quartile 1

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

A-48

PREA Cost Impact Analysis

C
WA
C

SC
PP P

MO

PP

OC
C
MA

IN
DO
R

CC
AR
D

Pr io
rity

Table 23: Community Corrections Upfront Cost Impacts as % of Annual Operating Budget

1

0

0

r

0

0

0

0

0

0

0

1

n/a

n/a

n/a

n/a

n/a

n/a

0

0

0

0

0

0

5 Audits of standards

0

0

0

0

0

0

6 Training and Education

0

1

1

1

1

1

0

0

0

0

0

0

0

0

0

0

0

1

1

1

1

1

1

1

0

0

0

0

0

1

0

1

0

1

0

1

0

0

0

0

0

0

0

0

0

0

0

0

n/a

n/a

n/a

n/a

n/a

n/a

0

0

0

0

0

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

1

Limits to cross-gender
viewing and searches

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

Contracting with other
7 entities for the confinement
of inmates
Accomodating inmates with
8
special needs
Zero tolerance of sexual
9
abuse
Screening for risk of sexual
10
abuse
Contract modifications for
11
outside services
Evidence protocol and
12
forensic medical exams
13 Investigations
14
15
16
17
18

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

Quartile 1

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

Community Corrections Cost Impact #1: Zero Tolerance of Sexual Abuse (PP1)
The major issue in this standard is the requirement for an agency to employ or designate a PREA
coordinator to oversee the agency's efforts to comply with the NPREC standards. For each of the
jurisdictions visited, excluding WA CC, this resulted in the need for at least one additional full-time staff
member added to their management and operational budget requirements. The following table lists the
budget requirements for an additional staff member assuming a senior level position reporting directly to
the agency head. All costs are annual, fully loaded, including salary and benefits (e.g., healthcare,
retirement). Operational upfront costs are also includes office furniture and supplies, office equipment,
communications services, training, and other expenses above and beyond salary and fringe benefits.

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-49

PREA Cost Impact Analysis
Site
WA CC
AR DCC
SC PPP
MA OCC
MO PP
IN DOR

Upfront
$
1
$
1
$
1
$
1
$
1
$
1

Yearly
$ 113
$ 107
$ 78
$ 73
$ 71
$ 33

Notes
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.
1 FTE salary, benefits and new hire operations costs.

Community Corrections Cost Impact #2: Limits to Cross-Gender Viewing and Searches (PP4)
Where cross-gender pat downs are not prohibited, there are a number of cost drivers that could have a
significant impact on a jurisdiction's budget. Similar to the Prison and Jail sectors, the most common
reason for noncompliance, resulting in the greatest real cost impact, is a staff gender ratio that is out of
balance with the offender gender ratio. It is a particular challenge for many facilities where the rate of
incarceration is much higher for men while hiring practices are gender neutral. AR DCC, for example,
has a higher proportion of female officers relative to male offenders (42% female officers versus 72%
male offenders) resulting in many instances where female officers are the only ones available to conduct a
pat down. For systems with these characteristics, the most common means to comply with the standard
would be to redeploy staff among facilities (e.g., moving female officers from male facilities to female
facilities) and hire more male staff in the male facilities. This will get the staffing gender ratio closer to
the offender gender ratio and ensure that each and every post has the correct gender available for pat
downs.
For AR DCC, this strategy results in a redeployment of female staff (moving them from male to female
facilities) and hiring 50 additional male staff (ensuring each post in the male facilities has a male present)
for a net impact on their budget of $1.8M annually. Furthermore, because the local labor in pool in AR
simply does not provide enough qualified male applicants, AR DCC would need to increase their average
salary by 33% in order to ensure enough male applicants are available. In addition, there are operations
cost for each new hire based on several common expenses including office supplies, internet and phone
usage, training expenses, and public safety supplies equating to a one-time upfront cost of $48K. Besides
the challenges of hiring more males, since the community corrections facilities are distributed across the
state both within rural and urban areas, it is unlikely that enough female officers would relocate
voluntarily. And there are not enough positions available within the two all-female facilities to absorb
such a transfer. System-wide, the current ratio of officers to offenders is .36 officers to every offender. If
all female officers transferred to the two female facilities, those two facilities would have an increased
ratio of .53 officers to every offender, an untenable and difficult-to-justify situation from a budgetary
perspective, therefore likely resulting in staff reductions and union grievances. For example, the
redistribution of employees based on gender might potentially limit an officer's career path, particularly a
female, as there are fewer facilities and hence fewer growth opportunities.
AR DCC's relatively high proportion of female officers is the result of a concerted effort to increase their
female staff as a direct result of federal statute. All state correctional facilities are required to hire, assign,
transfer, and promote females on the same basis as males per Title VII of the Civil Rights Act of 1964 14.

14

United States of America v. State or Arkansas Department of Correction. US District Court for the Eastern
District of Arkansas. 1995

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-50

PREA Cost Impact Analysis
AR DCC, therefore, would face steep resistance from assigning gender-specific roles and rebalancing
their workforce or transferring all female officers to their two all-female facilities.
The prohibition of cross-gender pat downs would be difficult at MO PP as well. With a current
male/female staffing ratio of 55:45 and male/female offender ratio of 89:11, there are proportionately
more male offenders than male officers requiring frequent cross-gender pat searches, specifically female
officers on male offenders. And since all of the Community Supervision Centers (CSC) and Community
Release Centers (CRC) within MO PP serve both male and female offenders, they cannot redistribute
female officers to female facilities since they do not have any. Furthermore, MO PP would run against
Federal regulations making any gender related workforce adjustment potentially illegal. Therefore, the
path of least resistance is obtaining additional FTE authority to hire more male officers, specifically three
per shift at the CRC and one per shift at the CSC resulting in an annual cost impact of $1.7M to cover 36
FTE including salary, expenses, and benefits. Since this is a new hire, there are upfront operational cost of
$34K to cover common expenses such as office supplies, internet and phone usage, training expenses, and
public safety supplies.
Some facilities however, do not face the same challenges as AR DCC. The prohibition of cross-gender
pat downs did not apply at the SC PPP since they did not have any overnight facilities. The MA OCC
already prohibits cross-gender pat downs; a long-standing policy without any union or legal challenges to
date. It is very likely that they are able to accommodate this prohibition because the ratio of their male
officers and male offenders is relatively close, 70% and 83% respectively. This allows MA OCC to
adequately staff their posts with enough male officers where pat downs are likely to occur, very distinct
from AR DCC.
WA CC also has a policy in place that prohibits cross-gender pat downs. However, it was uncovered that
when cross-gender pat downs are conducted, only in the case of an emergency, an incident report is
required. Most officers at WA CC view these reports as a burden and choose to avoid the pat down all
together. The senior administrators at WA CC noted the increased security risk this places on their staff
and offenders. Although increasing the staff may alleviate such challenges, it neglects other operational
and procedural changes that WA CC has not explored yet (e.g., modifying the incident report process).
Likewise, the prohibition of cross-gender pat downs did not apply at the IN DOR since they did not have
any overnight facilities. However, this will impact the release centers throughout the state at a county
level. For the four counties sampled in this study (out of a total of 41), three already had a policy in place
prohibiting cross-gender pat downs. The fourth did not have a policy yet, but could implement one
without any cost impact.
Community Corrections Cost Impact #3: Training and Education (TR1 through TR5)
Training will be a high cost since most jurisdictions in this study do not currently have training
curriculum in place (for employees, volunteers/contractors, or offenders) that is compliant with or covers
PREA-related topics. At a minimum, this requires modest modifications to existing curriculum and
additional training time to deliver the required material. Although many jurisdictions offer some sort of
sexual abuse training or orientation, it is often not comprehensive enough to cover PREA and sometimes
excludes administrative staff (or un-sworn officers), volunteers, or contractors. The following tables
show the cost impacts by site according to the first thee training standards:

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-51

PREA Cost Impact Analysis

Site
MA OCC

Employee Training (TR-1)
Upfront
Yearly
$

112

$

IN DOR

$

11

$

SC PPP

$

43 $

WA CC

$

27

Notes
MA OCC ensures employees are trained on sexual abuse but the current curriculum is not comprehensive enough to cover
the topics in Appendix B. This will require modifications to their training curriculum. The on-going cost reflects refresher
119
training to be delivered on a regular basis to 99 Community Correction staff 879 probation officers, and 138 parole officers.
At the IN DOR, all parole officers receive the same intake and in-service training as the DOC that includes a PREA session
and an annual one hour refresher PREA class. There are no additional or anticipated costs. Officers at three of the four
11 county work release centers (Bartholomew, Tippecanoe, and Duvall Residential Center), on the other hand, do not receive
any training requiring one-time investments in curriculum development, training delivery, and travel
<1

AR DCC has already implemented changes to their employee training curriculum to cover the PREA topics
MO PP has a rigorous training curriculum developed and delivered by their own Department of Training that includes two
hours on PREA. Refresher training for employees is provided, however, the content is selected by the trainee (among a
menu of options) and may not necessarily include PREA; the PREA content is an option but is not mandated in the refresher
training. Officials at MO PP acknowledge that this policy needs to change but do not anticipate significant costs outside of
some additional printing and materials cost.

AR DCC

MO PP

Site

Training on sexual abuse is not provided to all employees requiring them to add curriculum to their classroom and computerbased training both for new hires and on-going refresher training for the entire staff.
The WA CC conducts initial PREA classroom training to all employees for two hours as a part of ―CORE‖ initiative.
Employees are also given an annual in-service training on PREA that lasts for 30 minutes. However, these current efforts,
initially funded by a PREA grant do not meet all the requirements outlined in Appendix B. Most notably, training
curriculum does not include how to properly conduct screenings and is not specific to the responsibilities of employees at
different levels. WA DCC provides initial comprehensive sexual abuse training, compliant with the PREA standards, to all
contractor and volunteers already so no additional costs are anticipated.

Volunteer and Contractor
Training (TR-2)
Upfront
Yearly

MA OCC

$

11

$

SC PPP

$

6

$

IN DOR

$

1 $

Notes
MA OCC contracts with approximately 260 outside employees to staff 26 facilities throughout the state. Currently, no
3 contracted staff receive any sexual abuse training, requiring upfront expenditures to develop curriculum and on going costs
for periodic refresher training.
SC PPP does not provide comprehensive training on sexual abuse to its volunteers which happen to be mostly students from
2
a local university
Only two of the four work release centers employ contractors or use volunteers. Those centers, Bartholomew and Duvall
<1 Residential Center, currently do not provide training. Upfront costs reflect development of training materials.

AR DCC

Volunteers and contractors already receive adequate on-line training that covers PREA material.
Most contractors and volunteers receive the same training as employees yet there are a few exceptions such as GED
teachers and other educational and job training service providers that do not receive the appropriate training. Officials at
MO PP acknowledge that additional training is required but, again, do not anticipate a significant cost impact

MO PP

The WA DCC conducts sexual abuse classroom training to offenders during intake. Efforts to provide refresher training,
such as posters at the work release centers are adequate for short term offenders

WA CC

Inmate Education (TR-3)
Site

Upfront

WA CC

MO PP

$

$

5

SC PPP

$

$

MA OCC

$

5

IN DOR

$

20

AR DCC

Notes
The WA CC conducts classroom PREA training for offenders during intake at work release centers and whenever an inmate
is transitioned from one facility to another. The WA CC makes available posters and hotlines at work release center for
20
offenders. Cost reflects refresher training for those offenders that have longer stays at one particular facility since nothing is
currently provided.

Yearly

$

MO PP provides comprehensive education on sexual abuse during the intake process but only for only
offenders in residential facilities and not the 74K offenders in probation and parole. To fill this gap, MO PP
will provide information contained in the materials developed for the employees already provided to all new
2
offenders in supervision. Upfront and on-going costs reflect printing and materials costs Additionally, for the
very few offenders in the program for more than one year, MO PP will develop and provide refresher training
at a minimal cost of $136 per year
2 SC will need to modify their offender handbook to include PREA content
Offender education at MA OCC is not existent. The 26 facilities operated by MA OCC are day centers where supervision
1 and services are provided for only a small portion of the day. Upfront costs reflect the development of education materials.
On going costs reflect periodic refresher education and materials/publications.

Parolees within the IN DOR system and at the county work release centers receive an orientation but do not
receive PREA specific intake or refresher training. Upfront cost distribution and materials after obtaining
existing orientation package and PREA brochure from IN DOC.
AR DCC provides classroom training, handbooks, and poster boards throughout their units for offender.

Specialized training for investigations (TR4) and medical and mental health care (TR5) had a significant
less cost impact. For some of the jurisdictions in this study, the investigators are employed by the system
itself and these investigators go through internal training. At SC PPP, for example, there is a staff of
Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-52

PREA Cost Impact Analysis
three special operations personnel that conduct investigations and receive their training from the State
Law Enforcement Division (SLED) training academy. This training does not cover training on sexual
abuse in a community corrections setting and will therefore require modifications with a one-time cost of
$2K. Investigators that work with WA CC receive their training from WA DOC. Current training covers
sexual abuse but does not include curriculum specific to the community corrections environment. This
will require modifying the existing curriculum, estimated at a one-time cost of $20K, with no additional
recurring costs. Specialized training for investigators at IN DOR leverage their internal affairs office that
supplies investigators that have been trained in community corrections settings. The work release centers,
on the other hand rely upon local law enforcement for investigations with no means or authority to
enforce specific training standards related to PREA. However it is assumed they have the appropriate
training in sexual abuse crimes. Since MO PP is part of the MO DOC, they share 47 investigators serving
the entire state. The investigators receive 40-80 hours of training, including training specific to
conducting investigations in a confinement setting but the training is not viewed as comprehensive
enough to meet this standard. The estimated cost of modifying and delivering this additional training is
$54K (to include contractor delivery and the investigators time) yet it covers both DOC and PP. MO PP's
share is calculated as the proportion of their sexual abuse incidents relative to DOC, which is 6%,
resulting in an upfront cost of $3K. AR DCC's one full-time investigator receives training that covers
sexual abuse topics.
On the other hand some jurisdictions such as MA OCC rely upon on local or state authorities to conduct
investigations. This is done outside the system and external to their own training operations. And for
most, it is difficult to ensure the training they receive is compliant with the standard. And if it were not,
particularly in rural areas, they have limited options of recourse because there simply are not many
resources available in the community. For MA OCC, officials assume that training is provided in the
field but it is uncertain and administratively cost prohibitive to follow up with training requirements and
investigative curriculum of every county in the state.
Specialized training for medical and mental health care (TR5) is another area that may result in additional
costs but it is unclear who will shoulder the burden; whether or not medical and mental health care
professionals receive their training as part of their routine professional licensure requirements. SC PPP
does not have any medical or mental health care practitioners on staff; these services are provided by
referrals through the state mental health agencies. And they do not have any means to ensure their
training meets the PREA standard and it is likely that the state mental health agencies are not aware of
this requirement and do not provide training. Although this may not be a cost burden to SC PPP, it will
nevertheless be a cost. Similarly, there are no medical and mental health care practitioners employed by
the MA OCC (TR5). In the event a day center requires medical support, MA OCC refers them to an
entity or institution in the community such as a hospital that provides such service or calls an ambulance
in the case of an emergency. Because they do not have a dedicated staff or even a consistent pool of
medical and mental health care practitioners to draw upon, MA OCC will need to work with entities such
as the state board of medicine to ensure adequate training is provided. If it is not, this will likely be a cost
burden on the state as MA OCC does not pay for their services.
As for Specialized Training: Medical and Mental Health Care, WA CC has ten mental health care
professionals on staff that get comprehensive PREA training, compliant with the standard. They do not
however, have any medical care staff on site, referring them to medical practitioners in the community. It
is assumed that these individuals receive adequate training through their professional licensure and
Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-53

PREA Cost Impact Analysis
certification requirements. IN DOR and the four work release centers have a similar arrangement for
their medical and mental health staff, relying upon local services such as hospitals and clinics with no
means or authority to enforce specific training standards related to PREA. However it is assumed they
have the appropriate training in sexual abuse.
MO PP does not employ medical and mental health staff at their facilities and community hospitals are
utilized when medical health care is needed. It is assumed that the community medical and mental health
care providers receive the training required by their licensure (TR5) and that their efforts to ensure its
adequacy is an indeterminate cost. AR DCC's medical and mental health care practitioners, provided by
CMS, require all staff to abide by all AR DCC's policies with CMS absorbing the added cost.
Community Corrections Cost Impact #4: Audits of Standards (AU1)
As this is not a nationally instituted policy, requirement or service, PREA audits are not conducted
anywhere in the county. Nevertheless, each site is very familiar with the auditing process whether it be
state mandated financial audits (SC PPP), ACA accreditation audits (SC PPP, AR DCC, WA CC, IN
DOR, MO PP), or central office audits (MA OCC). Based on the wide degree of audits across the county,
we assumed a standard audit fee of nearly $17K per year per facility equating to roughly $6K per year15.
The following table provides a breakdown of the costs associated with the PREA audit.
Community Corrections Cost Impact #5: Screening (SC1 and SC2)
The Screening Standards are only required for community correction facilities so the state jurisdictions
governing solely probation and parole (SC PPP and MA OCC) are exempt from this standard. Two
jurisdictions, AR DCC, and MO PP conduct comprehensive screening already and do not need any
modifications to meet the screening standards. WA CC, on the other hand screens every offender that
enters a work release center and again when an offender is transferred, however the screening is not
considered compliant with the standard and requires some modifications estimated at a one-time cost of
$11K and some process improvements, requiring additional level of effort of the screeners, estimated to
cost $54K per year. Likewise IN DOR does not have comprehensive screening in place. The probation
and parole centers use a tool developed and shared with IN DOC but among the four work release centers
included in this study, not a single one conducts any screening whatsoever. Such a tool could be
developed independently however, since the probation and parole centers within IN DOR are able to use
the screening instrument from IN DOC, it is reasonable to assume that the work centers could have access
to this as well. Therefore, there is no cost associated for the work centers and the execution of the
screening tool (SC2) would have minimal impacts on the centers. The one work center that is compliant,
Clark County, conducts a comprehensive gender-specific screening process of all offenders at intake.
Community Corrections Cost Impact #6: Inmate Supervision (PP3)
Physical supervision (Standard PP3) was not seen as an issue for most of the Community Corrections
jurisdictions. It was deemed not applicable at the SC PPP since they did not have any overnight facilities.
The AR DCC felt that, overall, their physical supervision was sufficient to minimize the incidents of
sexual abuse and current data corroborated this position as there have been relatively few reported
incident of sexual abuse in the past three years. In 2007, the AR DCC reported one incident in their
Community Corrections facility. In 2008, they reported one incident in Probation and Parole and in 2009
15

See Assumptions section for audit calculation.

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-54

PREA Cost Impact Analysis
they reported one incident in Community Corrections and two in Probation and Parole. The only
exception where they might have to add staff is in their Omega Unit where they have open dorms that
house technical violators, increasing the probability of sexual abuse. However, since there are not more
actual reports linked to this unit, they are not able to justify additional resources at this time.
The MA OCC has had no incidents or allegations of sexual abuse over the past three years. As a result,
administrative officials believe that current levels of staffing and physical supervision are sufficient. The
work release centers at IN DOR each have not experienced any incidents or allegations of sexual abuse
over the past three years therefore having no justification for increased supervision. And MO PP has only
seen one substantiated case of sexual abuse in the past three years and the agency feels that staffing levels
are adequate to prevent sexual abuse incidents.
The WA CC, on the other hand has seen an increase in reported incidents of sexual abuse, but not
necessarily an increase in substantiated cases. This is likely due to recent efforts to better educate and
train offenders on reporting policies, making it easier for offenders to make claims, most of which are
found to be unsubstantiated after investigations. Nevertheless, administrators at WA CC believe that
additional correctional officers are required to address the increased reports in the event this signals any
underlying causes of heightened risk factors associated with sexual abuse. One additional officer at each
of the 13 work release centers, at an annual cost of $66K, appears to be a reasonable assumption to
address the increased reporting, yielding an annual cost of $884K. In addition, there are some one-time
costs associated with hiring additional staff yielding an additional expense of $16K
Community Corrections Cost Impact #7: Contracting with Other Entities for the Confinement of
Inmates (PP2)
Three jurisdictions, IN DOR, WA CC, and MO PP, each have contracted facilities under their
jurisdiction. IN DOR reported two contracted facilities managed by their Duvall Residential Center. As
these are very small operations with close and integrated management by Duval administrators, they do
not anticipate any required contract modifications and/or cost increases. WA CC and MO PP both
contract out for the confinement of offenders and it is assumed that the contracted facilities will bear a
cost to comply with the PREA standards, similar to the state-owned facilities. WA CC contracts with
Pioneer Housing Services and Progress House Association for 13 out of the 15 work release centers, or
93% of their residential work release population of 688 offenders. These contracts would need to be
modified to include language related to PREA compliance, resulting in an annual cost of $34K. MO PP
contracts out with five facilities, covering 1.3% of their total offender population with an estimated cost
of compliance of $23K per year.
Community Corrections Cost Impact #8:
through RP4, and RE3)

Contract Modifications for Outside Services (RP2

All of the jurisdictions have relationships with outside public entities and community service providers
(RP2), although this standard does not apply to SC PP since they are only probation and parole.
However, none of the jurisdictions included in this study have formal MOUs or agreements in place. AR
CC, MA OCC, and MO PP do not believe that entering into agreements or MOUs will result in any cost
to their operations. Whereas one work release center at IN DOR anticipates a minimal cost impact of
$100 to set up an MOU with a local service provide. However, WA CC has run into a number of
challenges as they relate to VOCA funding and its prohibition on working with the inmate population.
Past attempts at contracting with Community Sexual Assault Programs (CSAPs) for free victim advocacy
Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-55

PREA Cost Impact Analysis
services have been unsuccessful. As a result, they will likely incur a cost for these services. Since WA
CC and WA DOC are an integrated system, they will be able to share this cost likely resulting in some
economies of scale savings. Nevertheless, as a whole, the integrated systems is looking at $840K per year
in contracts with victim advocacy groups throughout the state. As a percentage of their ADP, WA CC's
share of that equates to $79K per year.
All jurisdictions but one work very closely with their local law enforcement and prosecution agencies that
conduct investigations and prosecutions codified through state statute so there's no need to enter into
agreements or establish MOUs (RP3 and RP4). The one exception is WA CC where local authorities are
not always interested in immediately conducting investigations and prosecutions. As a matter of fact, one
of the largest counties in the state has provided written notification to WA DOC to that they will not
investigate crimes that are not against county residents, assuming inmates are not resident. There is no
statewide consistency in how counties handle investigations or how prosecutors move them through the
courts. Without the state enforcing this, WA CC will need to establish MOUs with all 39 counties. As
this impacts WA CC and WA DOC equally, efforts and associated cost of each will be distributed
proportionately. The estimated, annual cost for this is $250K to cover legal fees and level of effort to
establish MOUs with each of the 39 counties. WA CC's share of this cost, as a percentage of its ADP, is
$47K.
It is estimated that three of the six community correction jurisdictions in this study will incur costs
associated with providing access to victim advocates (RE3). The major cost drivers for these standards
are associated with developing material or updating existing material to include contact information on
outside victim advocate services. The material could include posters, pamphlets, or other material that is
either posted throughout the facilities or provided directly to residents. The costs to develop the material
are relatively modest, $1K for IN DOR, $3K for MO PP, and $4K for WA CC.
Community Corrections Cost Impact #9: Accommodating Special Needs (PP5)
The only jurisdictions reporting noncompliance with this standard are SC PP and WA CC. All other
jurisdictions provide a myriad of services such as interpreters, language telephone lines for nearly every
language, internet translation, university foreign language students, TTY machines for the deaf, and
mental health staff for the mentally challenged. Most of these services are already implemented or free of
charge yielding no additional cost. However, SC PP does not have any interpreters available and few
community resources available. They face the prospect of having to hire a contractor for these services at
$55/hour assuming 20 hours per year or $1K per year. WA CC, on the other hand, has a number of
translation services but most of their pamphlets and booklets are only in English and Spanish. With a
very diverse population, they need to publish these in Chinese, Cambodian, Korean, Russian, Laotian,
and Vietnamese with an estimated cost of $1.5K.
Community Corrections Cost Impact #10:
through DC3)

Gathering, Reviewing and Reporting Data (DC1

Most of the Community Corrections jurisdictions conduct sexual abuse incident reviews (DC1) following
similar procedures as any incident review. SC PP, for example, has a formal complaint form and it goes
to the special investigative unit for a review. This includes a full review of the site, the environment, and
corrective actions. AR DCC has a review team that includes an investigator, the deputy director, the
director, and the state police. Their review does consider whether incidents were motivated by racial or
other group dynamics at the facility and they do include recommendations for improvement. IN DOR has
Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-56

PREA Cost Impact Analysis
a Prison Rape Oversight Group (PROG) in place, which reviews all parole sexual abuse incidents. The
work release centers submit all reports to the IN DOR for their review. MO PP does not have a current
policy in place yet feel that all substantiated cases of sexual abuse would be evaluated by a multidisciplinary review team with a minimal workload increase but at no extra cost. Likewise MA OCC does
not have a team that reviews sexual abuse incidents but can institute one at no additional cost. The WA
CC, on the other hand passes all allegations through an investigation process and into an investigative
review board but they lack a site specific review board at each facility. A policy has been created to begin
this procedure, yet nothing has officially begun. The estimated annual cost of this enhanced procedure is
$1.5K based on their frequency of reported sexual abuse incidents.
On data collection (DC2) four of the jurisdictions already fill out the BJS Survey on Sexual Violence (SC
PP, AR DCC, WA CC, and MO PP). This is considered to meet the compliance requirements of the
standard. MA OCC does not prepare any annual reports on sexual abuse data but this could be assumed
as a responsibility of the PREA Coordinator whose cost is captured in PP1. IN DOR does prepare a
report but it is not the BJS report. Like MA OCC, this additional responsibility could be assumed by the
PREA Coordinator.
On data review for corrective action (DC3), most jurisdictions have a procedure in place or if they do not,
this is a responsibility that can be fulfilled by the PREA Coordinator. SC PP, for example, does not have
a formal review of sexual abuse data but they do conduct an annual review of all operational policies.
Adding a review of PREA policies to include sexual abuse data would be a role of the PREA Coordinator
and the cost captured in that salary. AR DCC conducts annual reviews on all policies to include an
analysis of data trends, statistics, and critical elements of all incidents. MA OCC does not have a policy
in place to conduct reviews but could be a responsibility of the PREA Coordinator. IN DOR conducts its
review through its PROG while the MO PP is developing a process to review and analyze all sexual abuse
cases. Due to the relative infrequency of incidents (one in the last three years), this will not be a large
effort and could be easily assumed by the PREA Coordinator. Finally, WA CC uses a newly deployed
data tracking system called Sierra that uses sexual abuse data to assess the effectiveness of current
procedure. However it does not include the consideration of racial dynamics. Modifying this system to
meet the standard is estimated to cost $50K upfront.

Appendix A - Underlying Causes of Cost Impacts/Community Corrections

A-57

PREA Cost Impact Analysis

Lockups
The study reflects four Lockup facilities including two from the West (WA Seattle Police Department and
CA Rocklin Police Department), one from the Northeast (MA Middleton Police Department), and one
from the Midwest (CO Denver County Pre-Arraignment facility). The ongoing and upfront tables
highlighted with Harvey Balls represent an order of magnitude signifying a cost impact in relation to
overall budget for the Prisons sector. The degree to which each Harvey ball is shaded indicates the
magnitude of the cost impact. An empty ball represents standards that do not result in any cost impact.
On the other hand, a fully-shaded ball represents a percent impact on annual operating budget that is
greater than 0.50%. A quarter-shaded ball and half-shaded ball represent an overall impact on annual
operating budget between 0% and 0.25% and 0.25% and 0.50%, respectively. For example, Middleton
PD’s ongoing cost impact as a percentage of annual operating budget for training and education is equal
to 0.29% and therefore represented by a half-shaded Harvey ball.

1

Limits to cross-gender
viewing and searches

2 Inmate Supervision
Assessment and use of
monitoring technology
Ongoing medical and mental
4
health care
3

0

0

0

0

0

6 Training and Education

0

0

0

0

0

0

0

r

0

r

4

4

1

0

4

0

0

0

0

0

0

0

0

0

0

0

0

0

0

n/a

n/a

n/a

n/a

1

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

LE

CK
LIN

SE
AT
T

RO

0

0

5 Audits of standards

0

0

0

0

6 Training and Education

r

r

1

1

0

0

0

0

0

0

0

0

1

1

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

3

0

LE
TO
N

0

2 Inmate Supervision

0

MID
D

0

0

0

0

DC
PA

0

0

1

18

0

0

1

17

0

0

0

1

16

1

0

1

r

15

1

0

4

1

Supplement to SC-2: Use of
screening information
Hiring and promotion
decisions
Gathering, reviewing, and
reporting data
Exhaustion of administrative
remedies
Agency protection against
retaliation

0

0

4

1

14

0

0

1

13 Investigations

Limits to cross-gender
viewing and searches

0

5 Audits of standards

Contracting with other entities
7 for the confinement of
inmates
Accomodating inmates with
8
special needs
Zero tolerance of sexual
9
abuse
Screening for risk of sexual
10
abuse
Contract modifications for
11
outside services
Evidence protocol and
12
forensic medical exams

Table 24: Lockups Upfront Cost Impacts as % of Annual Operating Budget

Prio
rity

E

LIN

SEA
TT
L

TO
N

RO
CK

DC
PA

MI
DD
LE

Prio
rity

Table 25: Lockups Ongoing Cost Impacts as % of Annual Operating Budget

Assessment and use of
monitoring technology
Ongoing medical and
4
mental health care

7
8
9
10
11
12

Contracting with other
entities for the confinement
of inmates
Accomodating inmates
with special needs
Zero tolerance of sexual
abuse
Screening for risk of sexual
abuse
Contract modifications for
outside services
Evidence protocol and
forensic medical exams

13 Investigations
Supplement to SC-2: Use
14
of screening information
Hiring and promotion
decisions
Gathering, reviewing, and
16
reporting data
Exhaustion of
17
administrative remedies
Agency protection against
18
retaliation
15

n/a

n/a

n/a

n/a

0

0

0

0

0

0

1

0

0

0

0

0

0

0

0

0

Quartile 1

0

= 0%

Quartile 3

1 = 0% - 0.25%
R = 0.25%-0.5%

Quartile 4

4

Quartile 2

= > 0.5%

Lockups Cost Impact #1: Limits to Cross-Gender Viewing and Searches (PP41)
Similar to other sectors, lockups express great difficulty with prohibiting cross-gender pat downs. This
standard results in a relatively high cost impact for three of the four facilities in this study but each one is
1

Lockups refer to this as PP5 but to maintain consistency throughout the document, Limits to Cross-Gender
Viewing and Searches is referred to as PP4

Appendix A - Underlying Causes of Cost Impacts/Lockups

A-58

PREA Cost Impact Analysis
incompliant. The only exception is due to an anomaly whereby the lockup and the local jail are merging
and can share resources to cover for any shortages as a result of new PREA policies regarding pat downs.
Police departments view this standard as contradictory to existing case law, which upholds the rights of
officers to conduct cross-gender pat downs in the field with most officers assuming that those rights and
procedures apply to the holding facility as well. Consequently, hiring additional female officers was the
preferred method to become compliant with this standard notably because they simply do not have
enough female officers on staff available for same gender pat downs. These additional female officers
would be required to staff the lockup facilities 24/7, allowing for one male and female officer to conduct
pat down searches.
The Rocklin PD currently has one, predominately male, on-duty police officer per shift in charge of the
temporary holding cells. Pat downs are conducted in the field immediately following an arrest, but may
also be conducted within the lockup facility if deemed necessary. Male officers conducting pat downs on
females use the back of their hands and unobtrusively conduct the pat down in accordance with the
department’s standard operating procedures, nevertheless, this is still noncompliant with the standard.
With the occasional female detainee and few available female officers, the Rocklin PD estimates a need
for 5.5 additional female officers to staff the lockup facility 24/7 at $125K annual salary plus benefits, or
a total annual cost of $698K. This would allow for a female officer to always be on duty with a male
officer at the lockup facility.
The Seattle PD does not have full time staff occupying their lockup facilities. They are typically closed
unless an officer has personally opened the facility to stage a detainee. Therefore the only officer with the
detainee (for the approximately 30 minutes while the officer fills out paperwork and makes necessary
phone calls) is the field officer that made the arrest. Therefore, if that officer is a male and the detainee is
a female, and a pat down needs to be conducted, it is typically that male officer that conducts the pat
down. A male officer may request a female officer to conduct pat down searches of female detainees
when and only if, one is available or nearby, however there are many cases where one is not. This practice
is supported by case law in Washington State, allowing officers in the field to conduct cross-gender pat
downs, and because custody of the detainee is not transferred while in the lockup, it is applied while in
the temporary holding cell. To become compliant with this standard, the Seattle PD would be required to
hire a substantial number of female officers. The department currently has approximately 1,305 sworn
officers, with only 188 (14%) of those being female. The Seattle PD believes the best course of action to
meet the requirements of this NPREC standard is to staff the five precinct facilities, on a 24/7 basis, with
a female officer. This would require a minimum of 25 full time employees at a cost of $3M per year plus
a one-time cost of $24K for new hire operational expenses.
The Middleton PD is fully compliant with this standard, and does not requiring any additional resources
to prohibit cross-gender searches. This is due to a unique community-based program called the
―Matrons,‖ a group of women in the community trained by local police on monitoring inmates and
conducting pat downs. The Middleton PD houses up to 20 female inmates in transition from the courts for
several hours every afternoon.
The DCPA facility allows female officers to conduct cross-gender pat downs on male inmates but does
prohibit male officers from cross-gender pat searches. In order to meet the PREA standard, DCPA will
need to realign their workforce, redeploying their female officers out of the male facility. Initially this
will result in a shortage of male officers suggesting a cost impact. However, since the Denver County Jail
and DCPA are merging under one roof, it is Booz Allen's assertion that there are male resources from
Appendix A - Underlying Causes of Cost Impacts/Lockups

A-59

PREA Cost Impact Analysis
Denver County Jail to cover for the open positions in the pre-arraignment facility. This is clearly a
unique case where meeting this standard does not result in a cost impact.
Lockups Cost Impact #2: Zero Tolerance of Sexual Abuse (PP1)
According the NPREC standards for lockups, the PREA Coordinator position can be a full or part time
position. Due to the size of each of the facilities in the study, it is assumed that all positions will be part
time. The following table lists the budget requirements for this role assuming a senior level position
reporting directly to the agency head. All costs are annual, fully loaded, including salary and benefits
(e.g., healthcare, retirement) and training. Operational upfront costs also include office furniture and
supplies, office equipment, communications services, training, and other expenses above and beyond
salary and fringe benefits.
Site

Upfront Yearly

Notes

Rocklin PD

$

1

$ 63 0.5 FTE salary, benefits and new hire operations costs.

DCPA

$

1

$ 57 0.5 FTE salary, benefits and new hire operations costs.

Middleton PD

$

1

Seattle PD

$ -

$ 53 0.5 FTE salary, benefits and new hire operations costs.
Handled by the Audit, Accreditation, and Policy
$ 5 department at minimal cost.

Lockups Cost Impact #3: Employee Training (TR1 - TR2)
Lockup facilities do not currently conduct training in accordance with the NPREC standards outlined in
Appendix B. Each site provided a different method for conducting this training as described below.
Site

Employee Training (TR-1)
Upfront
Yearly

DCPA

$

64

$

Middleton PD

$

4

$

Seattle PD

$

4

Rocklin PD

$

3

Notes
The Denver Co PA provides sexual abuse training, however it does not
meet the requirements of the NPREC standards. Upfront cost reflects
16
delivery of an initial four hour classroom session while on-going cost
reflects a one hour in-service training session.
At the Middleton PD, curriculum material would need to be developed to
comply with NPREC standards, and a yearly refresher course would also
4 need to be instituted at a cost of $4K. A total of 27 staff members would be
subject to this training along with the matrons, which would cost a total of
$4K per year.
Existing training curriculum at the Seattle PD does not meet the
requirements of the NPREC standards. Upfront cost reflects development of
a video loop on PREA, which would serve as initial and refresher training.
The Rocklin PD currently conducts initial training and annual in-service
training using a hired instructor, however these sessions do not meet the
requirements of the NPREC standards. Cost reflects annual one-hour
instructor provided training on PREA topics.

Appendix A - Underlying Causes of Cost Impacts/Lockups

A-60

PREA Cost Impact Analysis

Site

Volunteer and Contractor
Training (TR-2)
Upfront
Yearly

Rocklin PD

$

3

$

Middleton PD

$

<1 $

Notes
Rocklin PD must negotiate contract with Lexipol to develop and monitor
1
additional policy.
Middleton PD must develop material to provide contractors and volunteers.
<1

DCPA
Seattle PD

Lockups Cost Impact #4: Data Collection (DC2)
There are no facilities in this study that currently have a process in place for documenting and reporting
incidents of sexual abuse. In addition, there is not a Bureau of Justice Statistics (BJS) survey on sexual
violence tailored to police lockups. The DCPA however, completes this survey in coordination with the
Denver County Jail. Nevertheless, Booz Allen assumes that this responsibility can be fulfilled by the
PREA Coordinator position at no additional cost. The only cost impact related to data collection was
found at Rocklin PD where they would have to update their internal records management system to allow
data to be aggregated and reported with an estimated upfront cost of $6K.
Lockups Cost Impact #5: Audits of Standards (AU1)
As this is not a nationally instituted policy, requirement or service, PREA audits are not conducted
anywhere in the county. Nevertheless, each site is very familiar with the auditing process such as
Commission on Accreditation for Law Enforcement Agencies (CALEA), ACA, or ICE. Based on the
wide degree of audits across the county, we assumed a standard audit fee of $3K per year per site1.
Lockups Cost Impact #6: Accommodating Special Needs (PP6)
Only one site, Rocklin PD, cited a cost impact related to accommodating special needs. Despite having an
AT&T language line available, the influx and frequency of non-native English speakers, or LEP, in
central California, particularly Spanish speaking, is very prevalent and Rocklin PD does not have enough
bilingual staff available to meet language demands in a real-time interaction. Consequently, Rocklin PD
would like to incentivize the hiring of bilingual staff through a 5% increase in salary for bilingual staff,
which would equate to $38K additional salary cost per year.
Lockups Cost Impact #7: Hiring and Promotion Decisions (PP7)
The primary cost driver of this standard is the requirement to conduct background checks for all
promotions. All facilities visited in this study conducted some sort of criminal background check on new
hires but not for promotions. At the Rocklin PD, for example, extensive background checks are
completed on all new hires but not for promotions. The Rocklin PD hires a consultant to conduct
background checks at $50 per check for an average of two promotions per year, resulting in an annual
cost impact of $100. Initial and annual background checks are completed on all staff at DCPA but not for
each promotion. With approximately eight promotions per year, and at $50/check, this equates to an
annual cost impact of $400 for additional criminal history checks.

1

See assumptions section for calculations

Appendix A - Underlying Causes of Cost Impacts/Lockups

A-61

PREA Cost Impact Analysis

Appendix B: Site by Site Characteristics and Cost by State
Prisons
Arkansas Department of Corrections (AR DOC)
Sector

Prisons

Title

AR DOC
21

Total Facilities

68%

Percent PREA Compliant

3,230

Total Staff

67%

Percent Male Staff

33%

Percent Female Staff

12,953

Capacity

92%

Percent Male Offenders

8%

Percent Female Offenders

13,150

ADP

102%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$60.19

Unionized?

No

2008 Confirmed Incidents

12

2009 Confirmed Incidents

AR DOC, located in Pine Bluff, AR, oversees 21 correctional
facilities, which include 6 minimum security, 3 medium, 3
maximum, 1 super max facility, and 9 multi-level security
facilities. With a rated capacity of close to 13,000 and an ADP
of 13,150, AR DOC is over capacity.
AR DOC is 68% compliant with the NPREC standards. In
2004 the AR DOC received a PREA grant, which funded
training and inmate supervision compliance. It is estimated that
the AR DOC will have a total upfront cost of $286K and an
annual cost of $12.5M, to reach full compliance.
AR DOC does not permit female staff to conduct cross-gender
searches on male inmates. AR DOC proposed doubling staff
to have both genders present at each post (24/7). State statute
does not permit terminating female staff. While the Booz Allen
team felt it necessary to document their suggested plan of
action, we determined the cost to be unreasonable.

N/A
$ 291,589,687

Ninety seven percent of AR DOC’s estimated cost for PREA
compliance is attributable to increased inmate supervision. It
was estimated to cost $11.8M for 300 staff to conduct additional rounds in older facilities with double cells. This
cost also includes an increased salary to attract qualified male applicants. Booz Allen has estimated $285K upfront
operations costs for new hires.
Annual Operating Budget

Booz Allen estimated a PREA triennial audit to cost $227K, covering 21 facilities.
AR DOC contracts for the confinement of 280
inmates in county and city jails. Booz Allen
estimates $252K to be a percentage of the total
yearly cost estimate based on the number of
contracted inmates. Further, AR DOC houses a
small number of inmates at the AR Law
Enforcement Training Academy.

Cost Impacts
Limits to Cross-Gender Viewing and Searches (PP4)
Inmate Supervision (PP3)
Audits of Standards (AU1)Audits of Standards (AU1)
Contracting for the Confinement of Inmates (PP2)Contracting for
the Confinement of Inmates (PP2)
Zero Tolerance of Sexual Abuse (PP1)Zero Tolerance of Sexual
Abuse (PP1)
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
Hiring and Promotion Decisions (PP6)

According to the standard PP1, zero tolerance of
sexual abuse, AR DOC would require 1FTE to
serve as PREA Coordinator at an annual cost of
$121K. AR DOC also stated that one position for
the entire state would not be adequate. Currently, the AR DOC has thirteen full time, and nine part time employees,
supporting ACA accreditation.
AR DOC would need to develop and implement a contract with an outside service provider at $72K for
emotional support services (RP2). They currently have agreements with local hospitals for some support, yet not
enough to meet the NPREC requirements.
AR DOC does not conduct background checks for promotion decisions. AR DOC has 1,000 promotions per year.
Booz Allen estimates the yearly maintenance cost of these additional promotions to cost $50K.

Appendix B - Site by Site Characteristics

B-1

PREA Cost Impact Analysis

Arkansas Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.1%
Compliant?

4.3%

Upfront

68%

$

286,092

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-1

Yearly
Maintenance
$ 12,520,312
$
$

N
$

285

$

$

Explanation

121

Salary + benefits of 1 FTE at senior-level salary
Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 280
300 additional staff to increase additional rounds. Upfront and yearly operations
11,800
cost associated with new hires
Only meet this by having an officer of both genders at each post (restricting the
opposite gendered officer’s ability to secure certain areas would violate Title VII)
253

Per Booz Allen, the fee associated with criminal background check assumed to be
50 $50. Fee includes access to government sources and an internal LOE. AR DOC
has 1000 promotions

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

RE-3

Inmate access to outside confidential support services

N

Verified that a Rape Crisis number could be provided at the units

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

Do not notify 3rd party or victim of outcome due to confidentiality requirements

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

N

Not a specified period as according to standard, could be done without a cost.

IN-1

Duty to investigate

N

Don’t state outcomes of investigations regarding disciplinary action against others.
New policy can be implemented at no additional cost

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-1
MM-2

Y

N

$

6

$

72

Designate a member from their victim response team to provide services 24/7

Cost $72K to develop and implement an MOU for victim advocate services

Y

Y

Y

Y

Y

Y
Y
Y
Y

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4227 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-2

PREA Cost Impact Analysis
California Department of Corrections (CA DOC)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Prisons
CA DOC
33
76%
25,161
83%
17%
152,736
94%
6%
152,736
100%
No
$136.11
Yes
12
6
$ 5,000,000,000

CA DOC, located in Sacramento, CA, oversees 100 facilities
housing 170,361 inmates. CA DOC also has juvenile and
adult parole under it is jurisdiction. However, for the
purposes of this study only the 33 prison facilities are
included. The cost impact of the NPREC standards on the
Division of Juvenile Justice (CA DJJ) is included under a
separate site summary. CA DOC is overcrowded with the
highest inmate-to-officer ratio in the country. CA DOC is
under federal receivership and a federal court order to reduce
the inmate- to-officer ratio. There is political will to reduce
overcrowding but little support for doing so by releasing
prisoners. This is despite a recent order to release 40,000 nonviolent inmates.
CA DOC is currently 76% compliant with the NPREC
standards. It is estimated that the CA DOC will have a total
upfront cost of $8.8M and an annual cost of $30.4M, to reach
full compliance.

To eliminate cross-gender pat searches in female facilities,
an estimated 504 additional female staff would need to be hired at an annual cost of $26.3M and an upfront
operations cost of $479K. CA DOC currently has 40% male officers in female facilities. Nearly all CA DOC staff is
unionized, having fought for females to have equal opportunities in male facilities. CA DOC has gender-specific
posts or Bona Fide Occupational Qualifications (BFOQs). The bargaining unit, as part of their negotiated union
contract with the California Correctional Peace Officer Association (CCPOA), does address and allow genderspecific posts. As a result, Correctional Officers can bid their posts - up to 70% of the positions are eligible to be
bid.
Three institutions in CA DOC are equipped with monitoring technology from a PREA grant, while there is very
little video surveillance in the other 30 facilities. It is an old system with old buildings that are hard to retrofit with
video surveillance technology due to lead abatement and asbestos issues that make camera installation both difficult
and costly. It is estimated to cost $8.3M to upgrade 33 facilities with Assessment and Use of Monitoring
Technology, and $2.4M in annual costs for 33 additional Program Technicians to monitor the technology.
CA DOC contracts for the housing of 7,772 inmates. Booz Allen estimates an annual cost of $1.3M to comply with
NPREC standard PP2. This estimate is a percentage of
Cost Impacts
total yearly cost based on number of contracted
inmates.
Limits to Cross-Gender Viewing and Searches (PP4)
Booz Allen estimated a PREA triennial audit to
annually cost $356K, covering 33 facilities.

Assessment and Use of Monitoring Technology (PP7)
Contracting for the Confinement of Inmates (PP2)
Audits of Standards (AU1)
Zero Tolerance of Sexual Abuse (PP1)
Gathering, Reviewing and Reporting Data (DC1 - DC4)

According to the standard PP1, zero tolerance of
sexual abuse, CA DOC would require 1FTE to serve
as PREA Coordinator at an annual cost of $121K.
Although not included as a cost estimate, CA DOC believes a ―PREA unit‖ to better strategy for compliance, when
dealing with such a large system. This unit would consist of several staff members at a much higher cost.
Booz Allen estimates $3K yearly cost of a review team to gather, review and report data on sexual abuse. Cost to
conduct one-hour review with five officials was based on the number of confirmed sexual abuse incidents.

Appendix B - Site by Site Characteristics

B-3

PREA Cost Impact Analysis

California Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.1%

0.3%

Upfront

Yearly
Maintenance

76%

$

8,761,242

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7

Assessment and use of monitoring technology

N

RP-1

Y

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4

Agreements with the prosecuting authority

Y

TR-1

Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

Y

TR-5

Specialized training: Medical and mental health care

Y

SC-1

Screening for risk of victimization and abusiveness

Y

SC-2

Use of screening information

Y

RE-1

Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

Y

RE-4

Third-party reporting

Y

OR-1

Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

Y

PP-1

N

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Y

DI-2

Disciplinary sanctions for inmates

Y

MM-2
MM-3

Salary + benefits of 1 FTE at senior-level salary
Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 7,772

479

8,300

$

$

26,300 504 additional female FTE's
Background checks for promotions would result in an increse of LOE not a cost
increase
$8.25M upfront cost to upgrade video monitoring in 33 facilities. $1.5M annual cost
2,400 to hire 33 program technicians to monitor equipment. $825K annual cost to perform
system maintenance and conduct assessments.

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

State Law prevents communicating the outcomes of desciplinary actions on a staff
member. There are safety concerns with notifying a victim of sexual abuse with the
outcome of an investigation; however, the outcome is provided upon request.

Y
Y

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4

Data storage, publication, and destruction

Y

Audits of standards
Supplemental Standards

115
1,300

Y

DC-1

AU-1
AU*

$
$

Y

IN-1

MM-1

Explanation

30,428,099

Work force realignment will suffice at no additional cost
$

$

Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

$

N

Appendix B - Site by Site Characteristics

$

$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
3 officials was based on the number of confirmed sexual abuse incidents.

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4356 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-4

PREA Cost Impact Analysis
Colorado Department of Corrections (CO DOC)
Sector

Prisons

Title

CO DOC

Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP

24
41%
3,485
74%
26%
14,807
91%
9%
14,413

ADP/Capacity Percentage

97%

ACA Accredited?

Yes

Cost of care / day

$88.60

The CO DOC, located in Denver, CO, has a total of 24
facilities. The CO DOC is responsible for managing and
operating 19 state operated prisons and monitors five privately
owned facilities. The facilities are designed to supervise
offenders in five custody levels: minimum; minimum
restrictive; medium; close; and administrative segregation.
With an ADP of 14,413, CO DOC operates at 97% of their
capacity.
CO DOC is currently 41% compliant with the NPREC
standards. It is estimated that the CO DOC will have a total
upfront cost of $3.5M and an annual cost of $2.9M, to reach
full compliance.

An increase in the use of monitoring technology was the
most significant cost estimated. Based upon the number of
No
Unionized?
cameras in each facility, the appropriate number of monitors,
12
2008 Confirmed Incidents
DVR, wiring and installation were factored in for a total
N/A
2009 Confirmed Incidents
$ 752,969,584 upfront cost of $2.7M and an annual cost of $2.3M for support
Annual Operating Budget
staff. Currently, there is not a process in place for upper
management officials to review critical incidents, assess problem areas and take corrective action.
Prohibiting cross-gender pat searches presents the second largest cost impact. An upfront cost of $650K in moving
expenses was estimated to relocate 130 female staff in male facilities to female facilities and likewise move 130
males to fill these vacancies. This would help balance the staff/inmate gender ratio in female facilities. Moving
expenses are estimated at $5K per staff member.
Booz Allen estimated a PREA triennial audit to annually cost $259K, covering 24 facilities.
An upfront cost of $176K was estimated to modify
the current screening instrument to be genderspecific.
Booz Allen estimated the 713 additional
background checks for additional background
checks when making promotion decisions to cost
$80K. Cost includes access to government sources
and internal LOE.

Cost Impacts
Assessment and Use of Monitoring Technology (PP7)
Limits to Cross-Gender Viewing and Searches (PP4)
Audits of Standards (AU1)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Hiring and Promotion Decisions (PP6)
Exhaustion of Administrative Remedies (RE2)
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
Gathering, Reviewing and Reporting Data (DC1 - DC4)

In order to meet the NPREC requirements for the
exhaustion of administrative remedies, CO DOC
will incur an annual cost of $72K. This cost estimate is for a full time grievance officer to meet the demands of a
48hr timeline.
To establish a contract with an outside service provider, a community coordinator would need to be hired at
$60K. This position is necessary to help process referrals and work with the CCASA in coordinating emotional
support services.
Lastly, an annual cost of $58K was estimated in order to hire a staff member to gather, review and report sexual
abuse data. This position would develop forms, procedures, and implement a data review process. Additionally,
Booz Allen estimates $27K yearly cost of a review team to gather, review and report data on sexual abuse. Cost to
conduct one-hour review with five officials was based on the number of confirmed sexual abuse incidents.

Appendix B - Site by Site Characteristics

B-5

PREA Cost Impact Analysis
Colorado Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.5%
Compliant?
41%

PP-1

N

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

0.4%

Upfront
$

3,504,834

Yearly
Maintenance
$
2,878,765
$

9

Explanation

Salary increase to cover additional responsibilities of existing PREA Coordinator

Y

$

Additional security staff will be needed .Cost included in PP-7.
Moving expense to move 130 female staff from male facilities to female facilities.
Move 130 males to vacated slots left by females.

650

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

N

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

N

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

N

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

CO DOC does not notify third party's of criminal sanctions

N

Doesn't report incidents involving a victim less than 18 years old any differently

OR-2

Reporting to other confinement facilities

N

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

Does not monitor the conduct of inmates that have reported sexual abuse

N

Does not provide written notification on the outcome of investigations. No cost.

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review

N

MM-1
MM-2
MM-3
DC*

1

$

$

2,700

$

$

N

2,300 $2.6M in cameras and monitoring. $2.3M for 51 staff to monitor technology

60

Cost to provide inmates with confidential emotional support services hotline.
Requires 1FTE to coordinate this with Citizen Advocate Office.
Will work towards developing an MOU with each District Attorney’s office

Y

N

Cost to train additional investigators who are currently not trained to PREA

$

176

$

1

$

1

Cost for hiring a programmer to modify instrument to be gender specific.

Y
$

72 48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative. Annual cost to hire a grievance officer
Cost to inform inmates of new material with contact information on support services

Y
Sanctions do not include interventions designed to address and correct any
underlying reasons or motivations for abuse
Medical and mental health practitioners do not perform the screening, this is done
by classification and assessment programmers
Need for emergency medical treatment isn't determined by medical and mental
health practitioners.

N
N
N

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

Audits of standards
Supplemental Standards

$

1 Cost for sign language interpretative services
Per Booz Allen, fee associated with criminal background check assumed to be $50.
80 Fee includes access to government sources and an internal LOE. CO DOC has
713 promotions

Y

DC-1

AU-1
AU*

$

N

Appendix B - Site by Site Characteristics

Doesn't provide evaluations for offenders.

$

1

$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
27 officials was based on the number of confirmed sexual abuse incidents.

$

58 One FTE would be required to generate data, review, and compile reports.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4259 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-6

PREA Cost Impact Analysis
Indiana Department of Corrections (IN DOC)
Sector

Prisons

Title

IN DOC
21

Total Facilities

66%

Percent PREA Compliant

3,693

Total Staff

70%

Percent Male Staff

30%

Percent Female Staff

26,343

Capacity

91%

Percent Male Offenders

9%

Percent Female Offenders

20,698

ADP

79%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$53.96
No

Unionized?

9

2008 Confirmed Incidents

The IN DOC, located in Indianapolis, IN, operates 21 prison
facilities, ranging from Level 1 (minimum security) to Level 4
(maximum security). IN DOC has an ADP of 20,698 inmates,
or 79% of its maximum capacity.
IN DOC is currently 66% compliant with the NPREC
standards. It is estimated that IN DOC will have a total
upfront cost of $20M and an annual cost of $5.3M, to reach
full compliance.
Severance pay of $15M for IN DOC was due to the
prohibition of cross-gender pat searches. The IN DOC would
need to terminate 639 female officers, which could not be
absorbed into other custody positions. Equally, 639 male
officers need to be hired. However, Booz Allen considers the
salary swap to be a negligible cost. State law in Indiana
prohibits hiring discrimination on the basis of gender.

While the IN DOC considers current staffing levels adequate
to prevent sexual abuse, significant improvements in
Annual Operating Budget
Assessment and Use of Monitoring Technology. An upfront
cost of $5M was estimated for cameras, archiving equipment, and installation cost. An annual cost of $450K was
estimated for ongoing maintenance of the equipment, to include an increased LOE. Currently, existing video
monitoring lacks necessary supervision, leaving areas unmonitored or partially monitored.
2009 Confirmed Incidents

$

N/A
621,000,000

An annual cost of $3M was estimated for ongoing medical and mental health care. At IN DOC, only adjudicated
inmates labeled as sex offenders are required to attend the sex offender program. Those that may have committed
―lesser‖ offenses and not classified as a sex offender by the courts, and are not referred to the program for help. The
cost estimate is based on 75% more qualified candidates.
A victim advocate is not currently provided by the department for evidence protocol and forensic medical exams.
A part time internal victim advocate was estimated to be the most cost effective method to comply with this NPREC
standard. The creation of a 0.5 FTE at each facility amounted to $840K yearly and $11.K in upfront costs.
Additionally, $10K was estimated to develop
Cost Impacts
posters and pamphlets displaying victim advocate
services.
Limits to Cross-Gender Viewing and Searches (PP4)
IN DOC contracts for the housing of 2,400
inmates with GEO. Booz Allen estimates an
annual cost of $735K to comply with NPREC
standard PP2. This estimate is a percentage of total
yearly cost based on number of contracted
inmates.

Assessment and Use of Monitoring Technology (PP7)
Ongoing Medical and Mental Health Care (MM-3)
Evidence Protocol and Forensic Medical Exams (RP1)Evidence
Protocol and Forensic Medical Exams (RP1)
Audits of Standards (AU1)
Zero Tolerance of Sexual Abuse (PP1)
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)

Booz Allen estimated a PREA triennial audit to annually cost $227K, covering 21 facilities.
According to the NPREC standard PP1, zero tolerance of sexual abuse, IN DOC would require 1FTE to serve as
the PREA Coordinator at an annual cost of $72K.
IN DOC expressed concern over being able to develop an implement a contract with an outside service provider.
They feel there are not enough community service providers in Indiana to meet the NPREC requirements.
Nonetheless, an annual cost of $40K was estimated to provide 20 inmates with 20 contract hours.

Appendix B - Site by Site Characteristics

B-7

PREA Cost Impact Analysis

Indiana Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

20,055,143

$

5,365,290

N

$

1

$

72

PP-2

Contracting with other entities for the confinement of
inmates

N

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

Yearly
Maintenance

$

Zero tolerance of sexual abuse

MM-2

0.9%

Upfront

66%
PP-1

MM-1

3.2%

N

$

$

Explanation

Salary + benefits of 1 FTE at senior-level salary

Booz Allen estimates the cost to be a percentage of total yearly based on number of
735
contracted inmates = 2,400
Potential to displace 639 female officers that could not be absorbed into other
custody positions. Cost is attributable to estimated severance pay

15,000

Prior institutional employers are contacted. Questions regarding sexual abuse are
not asked. Could be accomplished at no additional cost and without legal
ramifications.
$

5,000

$

450

$

11

$

842

$

40

N

Upgrades and additional equipment are required. Annual maintenance is required.
Internal victim advocate at 0.5 FTE at each facility.
Approximately 20 contract hours for 20 inmates annually.

Y

Y

Y
48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative
$

10

Cost to update existing PREA material with contacts for victim advocate services
The outcome of an investigation is not permitted to be released.

Y

Y
The outcome of an investigation is not permitted to be released.

Y

N

Intake specialists are not medical/mental health practitioners.

Y
N

$

Cost of including all sex offenders (not just adjudicated) in the the sex offender
3,000 program

Y

N

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4227 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-8

PREA Cost Impact Analysis
Massachusetts Department of Correction (MA DOC)
Sector

Prisons

Title

MA DOC
18

Total Facilities

85%

Percent PREA Compliant

4,342

Total Staff

88%

Percent Male Staff

12%

Percent Female Staff

12,508

Capacity

92%

Percent Male Offenders

8%

Percent Female Offenders

12,508

ADP

100%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$124.28
Yes

Unionized?

33

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

15
514,626,570

MA DOC, located in Concord, MA, has a total of 18 facilities;
16 prisons, one prerelease center, and one facility for pregnant
woman. The average daily population of the facilities is
12,508, operating at 100% of their capacity.
MA DOC is 85% compliant with the NPREC standards. It is
estimated that MA DOC will have a total upfront cost of
$4.3M and an annual cost of $710K, to reach full compliance.
The largest cost estimate is attributed the enhancement and
use of monitoring technology. An upfront cost of $2.3M was
estimated for the purchase of 1,147 cameras and installation.
All facilities are equipped with technology however, many
facilities need upgrades.
An upfront cost of $2M in severance pay was estimated to
prohibit cross-gender pat searches. MA DOC polled each
facility to determine how many female staff had direct contact
with male inmates on each shift. It was determined that 69
female officers would need to be terminated.

An annual cost of $516K was estimated meet the
requirements of NPREC standard IN-1: Duty to investigate.
These costs are associated with hiring 11 investigators to
meet the increased requirements of grievance regulations
and third party reporting.
Booz Allen estimated a PREA triennial audit to annually
cost $194K, covering 18 facilities.

Appendix B - Site by Site Characteristics

Cost Impacts
Assessment and Use of Monitoring Technology (PP7)
Limits to Cross-Gender Viewing and Searches (PP4)
Investigations (IN1 and IN3)
Audits of Standards (AU1)

B-9

PREA Cost Impact Analysis

Massachusetts Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.8%
Compliant?
85%

PP-1
PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

0.1%

Upfront

Yearly
Maintenance
$
709,902

Explanation

$

4,277,988

$

2,000

69 additional male FTE's at $55,304 each

$

2,300

Purchase and installation of 1,147 cameras at $2,000 each

Y
Y

Y
N

MA DOC has in-house council that can draft MOU's at no additional cost

Y

Y

Y
48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

Y

Y
$

10

$

516 Cost for 11 FTE investigators

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4194 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Y
Y
Y
Y

N
Y

Appendix B - Site by Site Characteristics

B-10

PREA Cost Impact Analysis
Minnesota Department of Corrections (MN DOC)
Sector

Prisons

Title

MN DOC
10

Total Facilities

71%

Percent PREA Compliant

2,115

Total Staff

77%

Percent Male Staff

23%

Percent Female Staff

9,617

Capacity

94%

Percent Male Offenders

6%

Percent Female Offenders
ADP

9,619

ADP/Capacity Percentage

100%

ACA Accredited?

No

Cost of care / day

$89.24
Yes

Unionized?

2

2008 Confirmed Incidents
2009 Confirmed Incidents

Located in St. Paul, the MN DOC is a service and regulatory
agency, with a broad scope of activities and responsibilities.
The department currently operates ten correctional facilities
including eight for adults and two for juveniles. This study
focuses on the adult prison facilities. MN DOC has a fivelevel classification structure ranging from level 1 minimum
custody, to level 5 maximum custody. The one female facility
houses multiple security levels. Adult prison ADP is 9,619
inmates, operating at 100% capacity.
MN DOC is 71% compliant with the NPREC standards. It is
estimated that MN DOC will have a total upfront cost of $11K
and an annual cost of $433K, to reach full compliance.
The greatest issue expressed dealt with the prohibition of
cross-gender pat searches. Although cost estimates could not
be made, the MN DOC found this standard to conflict with
existing state legislation.

2
469,954,000

MN DOC stated that adequate use of monitoring technology
was in place however, to be fully compliant, an annual
assessment of the equipment would need to be conducted. An annual security audit of all facilities would result in an
annual cost of $135K.
Annual Operating Budget

$

Booz Allen estimated a PREA triennial audit to annually cost $108K, covering 10 facilities.
According to the NPREC standard PP1, zero tolerance
of sexual abuse, MN DOC would require 1FTE to serve
as the PREA Coordinator at an annual cost of $106K.
An annual cost of $75K was estimated to provide
refresher training/education for inmates. Currently,
refresher material is provided to inmates being
transferred between institutions. This cost estimate
educates all inmates once every three years.

Appendix B - Site by Site Characteristics

Cost Impacts
Limits to Cross-Gender Viewing and Searches (PP4)
Assessment and Use of Monitoring Technology (PP7)
Audits of Standards (AU1)
Zero Tolerance of Sexual Abuse (PP1)
Training and Education (TR1 - TR5)

B-11

PREA Cost Impact Analysis

Minnesota Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

PP-1

Standard Addressed

0.0%
Compliant?

0.1%

Upfront

71%

$

11,092

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

Yearly
Maintenance
$
432,535
$

106

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y
Speculative litigation costs associated with compliance have been removed

$

Per Booz Allen, fee associated with criminal background check assumed to be $50.
6 Fee includes access to government sources and an internal LOE. MN DOC has
122 promotions

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

Y

TR-5
SC*

Y

SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

RE-3

Inmate access to outside confidential support services

N

Working to identify alternative advocacy groups for all facilities at no additional cost

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Disciplinary sanctions for inmates
Medical and Mental Health Care

Y

MM-1

N

MM-3
DC*
DC-1

Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-2

$

135 Cost of providing ANNUAL security audits in all facilities

Y
Y

$
$

2 Annual cost to develop PREA material
75

Cost of refresher training for inmates

Y

Y

Y

Prohibited by state law from notifying victims of investigative outcomes for inmateon-inmate crimes. No additional costs anticipated

Y

Do not obtain informed consent from inmates before reporting info about prior
sexual victimization that didn't occur in institutional setting. No additional cost for
compliance

Y
Y
Y
$

There will be a one time LOE for automating database

10

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4108 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-12

PREA Cost Impact Analysis
Missouri Department of Corrections (MO DOC)
Sector

Prisons

Title

MO DOC

Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage

21
49%
7,913
70%
30%
31,319
91%
9%
30,578
98%

MO DOC, located in Jefferson City, MO, manages 21
facilities. MO DOC has developed an inmate classification
system to enhance safety and security for all staff, offenders,
and visitors at an institution. The classification system is based
on several factors including: length of sentence, type of crime,
and an offender’s individual needs for specialized programs
and services. Organizationally, the MO DOC is integrated
with the MO PP and many resources are and can be shared.
MO DOC is 49% compliant with the NPREC standards. It is
estimated that MO DOC will have a total upfront cost $3.2M
and an annual cost of $63.9M, to reach full compliance.

The lack of adequate inmate supervision was the largest cost
driver. Based on a recent analysis of custodial staffing relative
Yes to post requirements, MO DOC is operating at critically low
Unionized?
15
2008 Confirmed Incidents
levels. Over the past few years, the number of officers has
26
2009 Confirmed Incidents
decreased by roughly 750 while the number of inmates has
$ 466,690,803
Annual Operating Budget
increased. MO DOC requires 20% more officers than current
levels to supervise dormitories/housing and unit staff. An annual cost of $44.3M was estimated for 924 additional
staff. Since this is the addition of new staff members, there are additional $878K in upfront costs to cover hiring,
training, and office equipment. These positions are in addition to those added for standard PP4.
ACA Accredited?

No

Cost of care / day

$45.09

MODOC does not prohibit cross-gender pat searches. Although they have a staffing gender ratio close to their
inmate gender ratio, current procedures do not allow gender-specific posts with the exception of toileting and
showering (which displaces more female officers to areas where pat downs occur). MO DOC believes that
restricting females from pat downs would be a threat to security as pat downs are routine process and conducted at
uncertain places and uncertain times. MO DOC would not be able to reduce the number of female officers or restrict
duties due to labor management and binding union
Cost Impacts
agreements. The only means to address this standard
would be to hire more male officers. An annual cost
Inmate Supervision (PP3)
of $18.3M was estimated to hire 381 additional male
Limits to Cross-Gender Viewing and Searches (PP4)
Assessment and Use of Monitoring Technology (PP7)
staff. Since this is the addition of new staff members,
Screening for Risk of Sexual Abuse (SC1 and SC2)
there are additional $326K in upfront costs to cover
Triennial Auditing ( AU1)
hiring, training, and office equipment.
Training and Education ((TR1 through TR5)

MO DOC has increased their use of monitoring
Zero Tolerance of Sexual Abuse (PP1)
technology over the past few years with the funding
Contract Modifications for Outside Services (RP2 - RP4 and RE3)
Gathering, Reviewing and Reporting Data (DC1 - DC4)
from two PREA grants used to purchase additional
cameras. However, the MO DOC did not receive
enough funding to cover all identified areas. There were an additional 1,352 sites that were identified but did not
receive camera coverage. An upfront cost of $1.9M was estimated for cameras and DVRs to cover the additional
locations, for a total 1,352 cameras.
MO DOC has an internal classification process to determine housing decisions and it identifies those prone to
victimization and predators. However, their screening process is not gender-specific. A yearly cost of $804K is
estimated in order to meet the NPREC requirements. This cost includes the additional labor hours to modify the
existing classification process and administer the instrument. The new process was estimated to take one additional
hour per assessment. Currently, there are 20,000 intake assessments and 30,000 annual assessments.
Booz Allen estimated a PREA triennial audit to annually cost $227K, covering 22 facilities.

Appendix B - Site by Site Characteristics

B-13

PREA Cost Impact Analysis
At orientation, all MO DOC inmates are provided training and education and a handbook on sexual abuse.
Refresher training however, is not provided and would add an estimated $226K annually to their current operations.
Costs to modify their policy mandating PREA refresher training will result in additional training delivery costs and
staff time. It will require two additional hours of training for 7,913 staff plus the cost for the trainers. Training will
be conducted by DOC staff trainers. This refresher training cost includes the development of a video for closed
circuit TV and/or leveraging training content and curriculum from the NIC. All state investigators receive 40 to 80
hours of training, including training specific to conducting investigations in a confinement setting. They do not
however, receive comprehensive training on sexual abuse which can be added at an upfront cost of $51K.
According to the NPREC standard PP1, zero tolerance of sexual abuse, MO DOC would require 1 FTE to serve as
the PREA Coordinator at an annual cost of $79K. However, if MO DOC were to leverage their current unified
model, they would employ a hybrid approach with one central PREA Coordinator supported by two part time
assistants; one for prisons and one for probation and parole.
An upfront $20K for contract Modifications for Outside Services was estimate to post victim advocate
information throughout the facilities, also displayed on the closed circuit TV.
Lastly, Booz Allen estimates a $4K yearly cost of a review team to gather, review and report data on sexual
abuse. Cost to conduct one-hour review with five officials was based on the number of confirmed sexual abuse
incidents.

Appendix B - Site by Site Characteristics

B-14

PREA Cost Impact Analysis

Missouri Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.7%
Compliant?

13.7%

Upfront

Yearly
Maintenance
$ 63,866,691

Explanation

49%

$

3,226,771

N

$

1

$

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

$

878

$

PP-4

Limits to cross-gender viewing and searches

N

$

362

$

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

N

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

N

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y
N

Requires policy change with no additional cost

IN-2

Criminal and administrative agency investigations

N

Additional training is needed. Cost reflected in TR-4

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review

DC-1

Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

PP-1

MM-1
MM-2

79

Salary + benefits of 1 FTE at senior-level salary

Y
44,300 20% increase in staffing levels to officers than current levels = 914 new hires
18,300 381 new male staff required to fill existing female posts
Agency does not ask sexual abuse questions of prior employers but can do so at
no additional cost
$

1,900

Requires staff to monitor existing cameras and needs camera in other areas

N

Internal victim advocate can provide this service at no additional cost
Costs associated with entering into such an agreement will probably be part of the
duties assigned to the full-time PREA Coordinator.

N
Y
$

226 Cost to develop and implement refresher training for employees
No cost to update existing PREA training for volunteers and contactors
Refresher training is not provided, but associated costs are absorbable to the
department

$

51

Cost to send investigators to an outside training class

N
$

Currently updating screening process. (sunk cost not included)
804 LOE associated with additional assessment and intake (hrs/per caseworker)

Y

$

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative
Cost to develop Closed Circuit Television (CCT) PREA video loop and cost to
develop PREA posters

20

Y

Y

Y
Y
N

N

Revise policy at no additional cost

$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
4 officials was based on the number of confirmed sexual abuse incidents.
MO DOC does not have a formalized process but could make modifications at no
additional cost

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4227 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-15

PREA Cost Impact Analysis
New York State Department of Correctional Services (NY DOC)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Prisons
NY DOC
67
54%
32,986
75%
25%
66,079
95%
5%
60,217
91%
Yes
$152.38
Yes
22
14
$ 3,449,781,521

NY DOC, located in Albany, New York, is responsible for the
confinement and rehabilitation of approximately 60,217
inmates held at 67 state correctional facilities—with 14
minimum security (L2), 36 medium security (L-3), 16
maximum security (L-4) and 1 Drug Treatment Center. NY
DOC has a rated capacity of 66,079, making it the second
largest prison system in Phase II.
NY DOC is 54% compliant with the NPREC standards. It is
estimated that NY DOC will have a total upfront cost of
$628M and an annual cost of $44M, to reach full compliance.
The NPREC standard PP7, on Assessment and Use of
Monitoring Technology, proved to be 99% of the total upfront
cost. The estimated cost to comply would be $621M plus an
annual maintenance of $1.8M. NY DOC requires the
installation of full coverage video surveillance systems in 35
facilities and increased coverage in four female facilities.

The prohibition of cross-gender pat searches accounted for
77% of the total annual cost estimate. NY DOC would be required to increase the number of CO staffing at female
correctional facilities by 50% (an additional 620 COs at $53K new hire salary, including retirement and benefits) for
a yearly cost of $33.9M and an upfront cost of $589K. This standard will result in additional gender-specific posts
however, the ability to create such posts has been severely constrained by the courts. Even overstaffing by 50%, it is
unlikely that NY DOC could recruit and retain a sufficient number of female COs facilities. NY DOC states
compliance would also be in violation of Federal statute.
Training and education requirements weigh
Cost Impacts
heavily on the state when expanded across all
programs. NY DOC requires new curriculum to be
Assessment and Use of Monitoring Technology (PP7)
developed along with additional staff time. This
Limits to Cross-Gender Viewing and Searches (PP4)
resulted in a large upfront cost of $4.5M and a total
Training and Education ((TR1 through TR5)
Triennial Auditing ( AU1)
yearly training cost of $115K. These costs include
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
training for 21,000 employees and an additional
Agency Protection Against Retaliation (OR-5)
6,000 civilian staff, 200 contracted primary care
Evidence Protocol and Forensic Medical Exams (RP1)
providers, 87 new counselors, and 400 OMH
Gathering, Reviewing and Reporting Data (DC1 - DC4)
employees. An average of 25 hours was estimated
Zero Tolerance of Sexual Abuse (PP1)
to develop and modify current training to ensure all
staff, volunteers and contractors were covered on NPREC.
Booz Allen estimated a PREA triennial audit to annually cost $724K, covering 67 facilities.
NY DOC would need to develop and implement a contract with an outside service provider in 34 counties, and
for transitional services in 62 counties, at an upfront cost of $500K.
To comply with NPREC standard OR-5, agency protection against retaliation, would result in an upfront cost
$500K. This cost is associated with a computerized system to permit Central Office monitoring of inmate victims
and witnesses.
NY DOC does not provide inmates’ access to a victim advocate for evidence protocol and forensic medical
exams. NY DOC would need to create a ―fee for service‖ contract with every hospital in the area for each facility.
An annual cost of $250K was estimated based upon reimbursement at standard Medicaid rates.

Appendix B - Site by Site Characteristics

B-16

PREA Cost Impact Analysis
NYS DOC does not currently gather, review and report data, as per the requirements of the NPREC standards.
This would require the addition of research staff at a yearly cost of $81K.
According to the NPREC standard PP1, zero tolerance of sexual abuse, NY DOC would require 1FTE to serve as
the PREA Coordinator at an annual cost of $71K. However, due to their large size, NY DOC expressed they would
need more than one Zero tolerance of sexual abuse. They suggested one Deputy Commissioner, one Assistant
Commissioner, two field PREA auditors, and one clerical position, as a PREA unit, capable of meeting the NPREC
requirements for such a large system.

Appendix B - Site by Site Characteristics

B-17

PREA Cost Impact Analysis
New York State Department of Correctional Services

Cost Impact

Percent of Annual Operating Budget
ID

PP-1

Standard Addressed

18.2%

1.1%

Compliant?

Upfront

Yearly
Maintenance

54%

$ 627,095,704

$

37,411,110

$

1

$

71

$

589

$

$

621,500

$

PP-2

Zero
tolerance
sexual
abusefor the confinement of
Contracting
withofother
entities
inmates

N

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*

Assessment and use of monitoring technology
Response Planning

N

RP-1

N

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

N

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

Y

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

$
$

N
$

-

$

3,700

$

42

$

13

$

750

33,900 Increase number of correctional officers at female facilities by 50%

1,800 Full video coverage in 35 facilities, increased coverage in 4 female facilities
Would need to create a “fee for service” contract w/every hospital in the area of
every facility. Cost based upon reimbursement at standard Medicaid rates
Need to contract for emotional support services in 34 counties where DOC has
500
prisons. Need to contract for transitional services in all 62 counties
250

Approx. 5 hours of staff time to develop document plus 1 hour of executive review.

$

4 hour PREA training above 40 hour training program. OT costs for 21,000
employees and additional 6,000 civilian staff. 20 hours to update existing training
Require 4 hrs of training for 200 contract primary care providers and annual costs.
10
Would take approx. 10 hrs to modify existing training for volunteers.
Need 1 additional counselor at each facility, 5 additional counselors at 4 reception
centers. Total 87 new counselors (salary and benefits). 30 hrs to develop training.

$

Require 4 hour training of DOCS medical staff using video-teleconference
105 system,Training 400 OMH employees take 6-8 separate sessions and 30 hours to
develop

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

RE-3

Inmate access to outside confidential support services

N

Toll-free numbers to inmate phone system to permit free calls to victim advocate

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

Notification to non-victim complainants is contrary to state law

Y

Y

Y

OR-2

Reporting to other confinement facilities

N

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of sexual
abuse

Y

Access
emergency
and mental
health
services
Ongoingtomedical
and medical
mental health
care for
sexual
abuse
victims and abusers
Data Collection and Review

Y

MM-1
MM-2
MM-3
DC*

DOC policy requires that received allegations are reported to the Office of the
Inspector General. DOC centralizes all sexual abuse investigations. Allegations
received about abuse at another agency’s facility would typically be forwarded to
facility head.

$

Computerized system to allow central office to monitor inmate victims and
witnesses

500

N

Notification to non-victim complainants is contrary to state law

Y

N

Would be covered through training.

Y

DC-1

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

Appendix B - Site by Site Characteristics

$

1

$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
officials was based on the number of confirmed sexual abuse incidents. Cost of 1
81 FTE to prepare report for facility head = $80K

B-18

PREA Cost Impact Analysis
Oregon Department of Corrections (OR DOC)
Sector

Prisons

Title

OR DOC

Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage

14
80%
3,829
69%
31%
14,711
91%
9%
13,823
94%

ACA Accredited?

No

Cost of care / day

$84.46

OR DOC, located in Salem, OR has custody of offenders
sentenced to prison for more than 12 months. In addition to
adult prisons, OR DOC provides oversight and funding for the
community corrections activities of Oregon’s 36 counties. It
has seven major divisions. For the purposes of this study, cost
estimates are for adult prisons.
OR DOC is 80% compliant with the NPREC standards. It is
estimated that OR DOC will have a total upfront cost of
$258K and an annual cost of $774K, to reach full compliance.
Although no cost was provided, existing state statutes allow
female staff to conduct cross-gender pat searches on male
inmates.

In order to become compliant with the NPREC requirements
on screening, the OR DOC would need one additional
7
2008 Confirmed Incidents
counselor at the five largest facilities to handle the workload
5
2009 Confirmed Incidents
increase, resulting in an annual cost of $437K. The OR DOC
$ 550,167,137
Annual Operating Budget
would like to see this standard changed, so that counselor as
part of their counselor caseload management (CCM) could refer inmates for screening when they meet the criteria in
the standard. Cost estimates would be less if screening was allowed to be conducted in this method.
Unionized?

Yes

The majority of the upfront cost estimates are a result of monitoring technology. OR DOC has video monitoring in
place, however there is a camera upgrade plan for one institution that would require an upfront cost of $220K.
Currently, each institution is responsible for assessing the technology of their facility, but no centralized process
exists. An annual salary cost of 1FTE of $86K was estimated to formalize an assessment process of video
monitoring. This position would work with IT to develop a ―Lifecycle Replacement‖ policy for security electronics.
Booz Allen estimated a PREA triennial audit to annually cost $151K, covering 14 facilities.
An annual cost of $98K was estimated meet the requirements of
NPREC standard IN-1: Duty to investigate. OR DOC expressed
a security concern with notifying victims in writing of
investigative outcomes, with the potential of making the victim
vulnerable. Inmates can find out the status of their case by
contacting one of the SART members. A 0.5PTE would be
needed both on the East and West side of the state to
accommodate the increase workload of investigators.

Cost Impacts
Limits to Cross-Gender Viewing and Searches (PP4)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Assessment and Use of Monitoring Technology (PP7)
Audits of Standards (AU1)
Investigations (IN1 and IN3)
Training and Education (TR1 - TR5)
Gathering, Reviewing and Reporting Data (DC1 - DC4)

In order to provide PREA training for the 200 contracted
employees an upfront cost of $30K was estimated. This cost is based on a one hour training session provided at a
cost of $150/hour.
Booz Allen estimates a $1K yearly cost of a review team to gather, review and report data on sexual abuse. Cost
to conduct one-hour review with five officials was based on the number of confirmed sexual abuse incidents.

Appendix B - Site by Site Characteristics

B-19

PREA Cost Impact Analysis
Oregon Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.0%
Compliant?
80%

PP-1
PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

Explanation

Existing state law allow female correctional officers to conduct pat downs

$

221

$

30

$

86

Camera upgrades at 1 facility. Costis for purchase and installation of cameras
and annual technology assessments.

Y
Y

Y

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review

Y

MM-3
DC*

257,502

Y

Screening for risk of victimization and abusiveness

MM-2

$

Yearly
Maintenance
$
773,937

Y

SC-1

MM-1

0.0%

Upfront

$

5

200 contracted staff will require training to comply with this standard.
$

Current screening instrument is not gender specific. 5 FTE's (one each at the
437
five largest facilities) are required to meet the work load increase

Y
48hr exhaustion of administrative remedies is viewed as a major policy issue.
Cost estimates for compliance are speculative

Y

$

1

$

98

Do not notify victims or complainants in writing. 0.5FTE would be required in the
eastern and western regions of the state

Y

Y
Y
Y

DC-1

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*

Audits of standards
Supplemental Standards

N

Appendix B - Site by Site Characteristics

$

$

Booz Allen estimates a review team of upper management officials to consist of
4 senior-level staff and 1 junior analyst. Cost to conduct one-hour review with
these 5 officials was based on the number of confirmed sexual abuse
1 incidents.

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will
include 4-person audit team labor, meals and incidentals, hotel, air fare, and
151 mileage

B-20

PREA Cost Impact Analysis
Rhode Island Department of Corrections (RI DOC)
Sector

Prisons

Title

RI DOC
8

Total Facilities

68%

Percent PREA Compliant

1,332

Total Staff

79%

Percent Male Staff

21%

Percent Female Staff

4,251

Capacity

92%

Percent Male Offenders

8%

Percent Female Offenders

3,438

ADP

81%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$112.58
Yes

Unionized?

-

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

3
$ 177,390,562

RI DOC, located in Cranston, Rhode Island, operates a unified
correctional system, whereby all pretrial detainees and all
sentenced offenders (regardless of sentence length or crime)
are under it is jurisdiction. Rhode Island is one of six states
that have unified systems, incorporating the jail and state
prison into one Department. RI DOC has eight housing
facilities on the Pastore Government Center Complex in
Cranston – 5 for adult male offenders and 2 for female
offenders, with two minimum security, three medium security,
and three maximum. It employs 1,332 staff with an ADP of
3,438 inmates.
RI DOC is 68% compliant with the NPREC standards. It is
estimated that RI DOC will have a total upfront cost of $803K
and an annual cost of $265K, to reach full compliance.
Enhancements in the use of monitoring technology resulted
in the most significant cost impact. An upfront cost of $800K
included 244 cameras in minimum security facilities that do

not have video monitoring.
According to the NPREC standard PP1, zero tolerance of sexual abuse, RI DOC would require 1FTE to serve as
the PREA Coordinator at an annual cost of $145K.
Booz Allen estimated a PREA triennial audit to annually cost
$86K, covering 8 facilities.
Upgrading the existing employee training module was
estimated to annually cost $29K. This update targets non
uniform employees that do not receive the same training as
sworn officers.
RI DOC does not conduct background checks for candidates
being considered for promotion. RI DOC has 80 promotions
per year. Booz Allen estimates the yearly maintenance cost of
these additional promotions to cost $4K.

Appendix B - Site by Site Characteristics

Cost Impacts
Assessment and Use of Monitoring Technology
(PP7)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)
Training and Education (TR1 - TR5)
Hiring and Promotion Decisions (PP6)

B-21

PREA Cost Impact Analysis
Rhode Island Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.5%
Compliant?

0.1%

Upfront

68%

$

802,627

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

PP-1

Yearly
Maintenance
$
264,604
$

145

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

$
PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*

Third-party reporting
Official Reponse Following an Inmate Report

Y

$

800

Per Booz Allen, fee associated with criminal background check assumed to be $50.
4 Fee includes access to government sources and an internal LOE. RI DOC has 80
promotions
Cost for cameras, cost of installation, and on-going maintenance costs(staffing)

Y
Y

N

$

$

$

29 Cost estimate of upgrading training module for non-uniform employees
Copy of the video to DVD (cost of outside vendor) ,copies made for each facility,
and cost of programmer(1 hour time). Negligible cost impact

-

1

Update screening instrument. Programmer cost p/hr $49.93

Y
48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

Required to report to Department Children, Youth and Families in cases first
degree sexual assault (penetration) or attempted first degree sexual assault. No
cost impact

OR-1

Staff and facility head reporting duties

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

N

Utilizes Stress Team for staff. Inmates have direct access to Adult Counselors
assigned to respective facilities and/or RIDOC Social Workers

IN-1

Duty to investigate

N

RI state law and union prohibition does not permit the notification of disciplinary
actions taken upon an employee

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

N

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

AU-1
AU*

Audits of standards
Supplemental Standards

N

First responder training to be incorporated into employee training

Y
Policy does not specifically state termination for such activity

Y
Y
Y
Y

N

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 486 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-22

PREA Cost Impact Analysis
South Carolina Department of Corrections (SC DOC)
Sector

Prisons

Title

SC DOC
29

Total Facilities

49%

Percent PREA Compliant

5,212

Total Staff

54%

Percent Male Staff

46%

Percent Female Staff

24,081

Capacity

93%

Percent Male Offenders

7%

Percent Female Offenders

24,141

ADP

100%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

N/A

Unionized?

Yes
8

2008 Confirmed Incidents
2009 Confirmed Incidents

SC DOC, located in Columbia, SC oversees 28 correctional
facilities. Of these facilities, six are pre- release centers and
one is female. The SC DOC’s ADP is 24,081, which is nearly
100% of the system’s capacity. The SC DOC experienced
significant deficits in last year’s budget, which led to layoffs
and the closing of one prison.
SC DOC is 49% compliant with the NPREC standards.
However 99% of all costs are associated with the below major
issues. It is estimated that SC DOC will have a total upfront
cost of $4.3M and an annual cost of $3.3M, to reach full
compliance.
In South Carolina, existing state statutes and governing hiring
practices allow female staff to conduct cross-gender searches
on male inmates. A cost was not estimated for this standard
due to speculative litigation.

N/A
$ 311,971,609

SC DOC has a limited number of facilities equipped with
video monitoring, and many of the existing systems are
outdated. An upfront estimate of $4M was determined in order to enhance Assessment and Use of Monitoring
Technology in 17 facilities. This estimate includes the cost of cameras, equipment, and installation. Additionally, 3
FTEs per facility are required to monitor the equipment for an annual cost of $2.1M. SC DOC stated that this
upfront investment in Assessment and Use of Monitoring Technology eliminates the need for $50M estimated for
inmate supervision.
Annual Operating Budget

An annual cost of $665K was estimated to improve the existing screening process. This cost estimate includes one
additional case worker at 17 facilities to handle the increased work load. Additionally, an upfront cost of $35K was
estimated to upgrade the existing screening instrument.
Booz Allen estimated a PREA triennial audit to annually cost $324K, covering 29 prisons and the headquarters
facility.
The SC DOC has 575 medical and mental health care staff that
would need to be trained in accordance with the NPREC
requirements. An upfront cost of $150K was estimated to
develop the curriculum, print materials, and pay over time
hours. An annual cost of $14K was estimated for in house staff
to conduct inmate education training.
According to the NPREC standard PP1, zero tolerance of
sexual abuse, SC DOC would require 1FTE to serve as the
PREA Coordinator at an annual cost of $91K.

Cost Impacts

Limits to Cross-Gender Viewing and Searches (PP4)
Assessment and Use of Monitoring Technology
(PP7)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Audits of Standards (AU1)
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Hiring and Promotion Decisions (PP6)
Contracting for the Confinement of Inmates (PP2)

SC DOC does not conduct background checks for promotion
decisions. SC DOC has 291 promotions per year. Booz Allen estimates the yearly maintenance cost of these
additional promotions to cost $14K. In addition, 1.25FTEs were estimated to fulfill the increased LOE at $43K.
SC DOC contracts for the housing of 300 inmates. Booz Allen estimates an annual cost of $41K to comply with
NPREC standard PP2. This estimate is a percentage of total yearly cost based on number of contracted inmates.

Appendix B - Site by Site Characteristics

B-23

PREA Cost Impact Analysis
South Carolina Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

1.4%
Compliant?

1.1%

Upfront

Yearly
Maintenance
$
3,321,598

Explanation

49%

$

4,272,690

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

No cost estimate. Supervision costs are found in PP-7

PP-4

Limits to cross-gender viewing and searches

N

Per Booz Allen, litigation costs have been excluded.

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7

Assessment and use of monitoring technology

N

RP-1

N

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4

Agreements with the prosecuting authority

N

TR-1

Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

TR-5

PP-1

N

$

91

$

41

Salary + benefits of 1 FTE at senior-level salary
Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 300

Due to standardization of background check cost, Booz Allen assumes 1.0 FTE of
1.25FTE provided for contacting prior instutional employers.
Cost for new cameras, equipment and installation. Also cost for 1 additional FTE
2,100
per facility to monitor the video recording equipment.

$

1

$

$

4,000

$

$

8

$

4

N

$

5

Specialized training: Medical and mental health care

N

$

150

SC-1

Screening for risk of victimization and abusiveness

N

$

35

SC-2

Use of screening information

N

$

19

RE-1

Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

RE-3

Inmate access to outside confidential support services

N

Cost to establish a toll-free number with an advocacy group expressed in RP-1

RE-4

Third-party reporting

Y

OR-1

Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

N

Need to formalize process at no additional cost

IN-1

Duty to investigate

N

Need to notify victims in writing, no cost estimate

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Y

DI-2

Disciplinary sanctions for inmates

Y

MM-1
MM-2
MM-3

Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

N

$

14 Cost for one caseworker and one CO for 20 minutes/wk per 17 institutions
Cost to develop materials (30 individuals)
Cost to develop materials (575 individuals)
Cost to develop screening tool

$

665 Cost for one case worker at 17 facilities. Cost of upfront new hire costs

Do not obtain informed consent forms before the inmates report past events of
sexual abuse before incarceration.

Y
Y

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4

Data storage, publication, and destruction

Y

Audits of standards
Supplemental Standards
Supplement to SC-2

Modification of existing medical contract to provide the necessary advocate support
Cost to develop an MOU to establish services with an outside agency.

N

DC-1

AU-1
AU*
ID-6

58

N

$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
1 officials was based on the number of confirmed sexual abuse incidents.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4324 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-24

PREA Cost Impact Analysis
Washington Department of Corrections (WA DOC)
Sector

Prisons

Title

WA DOC
13

Total Facilities

51%

Percent PREA Compliant

5,212

Total Staff

78%

Percent Male Staff

22%

Percent Female Staff

16,756

Capacity

92%

Percent Male Offenders

8%

Percent Female Offenders

15,513

ADP

93%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$102
Yes

Unionized?

47

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

49
477,094,900

WA DOC, located in Tumwater, WA, oversees both the prison
system and community corrections. For the purpose of this
study, Booz Allen separates cost estimates of the WA DOC
from the WA CC. The cost estimates for the WA CC are
found in a separate site summary. Last year WA DOC had 14
prisons under its jurisdiction, including 11 male facilities and
three female facilities. However, due to budget cuts, WA DOC
has closed a female facility as of May 2010.
WA DOC is 51% compliant with the NPREC standards. It is
estimated that WA DOC will have a total upfront cost of
$3.2M and an annual cost of $12.3M, to reach full
compliance.
In Washington, existing state statutes and governing hiring
practices allow female staff to conduct cross-gender searches
on male inmates. A cost was not estimated for this standard
due to speculative litigation. Further, due to a recent
Teamsters suit against the Department, WA DOC anticipates
any staffing changes to result in further scrutiny.

Enhanced inmate supervision accounted for the largest cost impact. WA DOC is short-staffed due to budget cuts.
An annual cost of $10.5M, for 165.5 FTEs, was estimated to eliminate self-relieving posts. Additionally, an upfront
cost of $157K associated with new hires was estimated, which includes training, incidentals and office equipment.
An upfront cost of $2.6M was estimated to enhance monitoring technology. WA DOC has outdated video
monitoring equipment in every facility. In the event of sexual abuse incident, current technology cannot identify the
perpetrator. The cost estimate includes $900K for additional cameras and $1.7K for upgrading and standardizing
video storage and equipment.
WA DOC has recently learned that contracting
Cost Impacts
with an outside service provider for emotional
support services is now possible, so long as the
Limits to Cross-Gender Viewing and Searches (PP4)
provider does not receive VOCA funding. An
Inmate Supervision (PP3)
annual cost of $761K was estimated to establish
Assessment and Use of Monitoring Technology (PP7)
and maintain MOUs with outside victim advocate
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
Gathering, Reviewing and Reporting Data (DC1 - DC4)
service providers. Additionally, two upfront costs
Ongoing Medical and Mental Health Care (MM-3)
of $226K were estimated to develop and
Audits of Standards (AU1)
implement an MOU with 39 county law
Training and Education (TR1 - TR5)
enforcement agencies ensuring investigator
Screening for Risk of Sexual Abuse (SC1 and SC2)
support, and 39 county District Attorney offices
ensuring prosecutor support. This also yielded an
upfront cost of $4K to post victim advocate information throughout the facilities.
An upfront cost of $301K was estimated to assist with gathering, reviewing and reporting of sexual abuse data.
This cost estimate is to implement a new database that can meet the requirements of the NPREC standards. WA
DOC will also require 1FTE senior office assistant at $44K, for an annual cost of $46K to monitor this database.
At WA DOC, abusers of sexual abuse do not receive ongoing medical and mental health treatment. An annual
cost of $293K was estimated to implement a new treatment program. The per offender cost of the current program is
$9.7K per year, which was used to estimate the new program cost.
Booz Allen estimated a PREA triennial audit to annually cost $140K, covering 13 facilities.

Appendix B - Site by Site Characteristics

B-25

PREA Cost Impact Analysis
WA DOC provides annual and refresher training for all employees, contractors and volunteers. PREA training is
provided to inmates during intake. To become fully compliant with the NPREC training standards, WA DOC will
need to provide inmate refresher education. This training was estimated to annually cost $20K for increased staff
LOE and material development. WA DOC provides in depth training to investigators, yet not in confinement
settings. A two day training session for investigators was estimated to cost $20K, which included the development
of a new curriculum and LOE. Medical and mental health care staff receive sexual abuse training, but does not cover
the procedures for preserving physical evidence. An upfront cost of $27K was estimated for LOE and curriculum
development.
The WA DOC does not screen inmates during subsequent classification reviews. A policy change and a
modification to the current written screening instrument are required, to include gender differences. An upfront cost
of $9K was estimated to modify the screening instrument and train staff on the new tool. Additionally, updating WA
DOC’s information management system to store and analyze additional screening questions was estimated to cost
$46K, which included the cost to train personnel on the modifications.
WA DOC does not conduct background checks for promotion decisions. WA DOC has 235 promotions per year.
Booz Allen estimates the yearly maintenance cost of these additional promotions to cost $12K.

Appendix B - Site by Site Characteristics

B-26

PREA Cost Impact Analysis

Washington Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.7%
Compliant?
51%

PP-1

Y

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

2.6%

Upfront
$

3,206,094

$

157

Yearly
Maintenance
$ 12,255,442

Explanation

Y
$

$

10,500 Staffing cost to eliminate self relieving posts.

Per Booz Allen, fee associated with criminal background check assumed to be $50.
12 Fee includes access to government sources and an internal LOE. WA DOC has
235 promotions
Cost for additional cameras and for upgrading and standardizing video storage and
equipment.

PP-6

Hiring and promotion decisions

N

PP-7

Assessment and use of monitoring technology

N

RP-1

Y

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

RP-4

Agreements with the prosecuting authority

TR-1

Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

N

$

20

TR-5

Specialized training: Medical and mental health care

N

$

27

Curriculum development, materials, and student hours for two days of training.

$

9

Would require a policy change and modifications to current tool to make gender
specific.

$

46

Cost to develop an MOU to establish and maintain services with an outside victim
advocacy agency.

761

N

$

226 Develop MOUs with all 39 county law enforcement offices.

N

$

226 Develop MOUs with 39 county District Attorney's office

Screening for risk of victimization and abusiveness

N

SC-2

Use of screening information

N

RE-1

Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

N

RE-4

Third-party reporting

Y

OR-1

Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

N

IN-1

Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Y

DI-2

Disciplinary sanctions for inmates

N

MM-3

Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

N

DC-1

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4

Data storage, publication, and destruction

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-2

2,600

$

SC-1

MM-1

$

$

20 Cost for training materials.
Curriculum development, materials, and student hours for two days of training.

Cost to complete upgrades to information system and train staff..

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative
$

4

Required to publish posters and brochures in 8 languages

Y
Y
$

$

301

$

$

293

Implement mental health treatment for abusers and victims of sexual abuse

46 Cost for database improvements, and one FTE to monitor new database

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4140 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-27

PREA Cost Impact Analysis
Virginia Department of Corrections (VA DOC)
Sector

Prisons

Title

VA DOC
49

Total Facilities

55%

Percent PREA Compliant

6,328

Total Staff
Percent Male Staff

63%

Percent Female Staff

37%
32,224

Capacity

92%

Percent Male Offenders

8%

Percent Female Offenders

30,691

ADP

95%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$67.58

Unionized?

No

2008 Confirmed Incidents

16

2009 Confirmed Incidents
Annual Operating Budget

N/A
$ 995,149,159

VA DOC, located in Richmond, VA, manages 28 prisons,
eight field units, six work release centers, four diversion
centers, and three detention centers. The VA DOC, with an
ADP of 30,691 is one of the larger systems included in this
study.
VA DOC is 54% compliant with the NPREC standards. It is
estimated that VA DOC will have a total upfront cost of $31M
and an annual cost of $16.5M, to reach full compliance.
Enhancements monitoring technology resulted in the most
significant cost impact. All facilities have Rapid Eye cameras
installed however, coverage and clarity in dormitory or pod
style prisons is not adequate. An upfront cost of $30.1M was
estimated to double the number of existing cameras at each
facility. An annual cost of $7.9M was estimated for 1FTE at
each facility to monitor the additional cameras. Also, a cost of
$250K was estimated for the yearly maintenance of the new
equipment.

VA DOC constantly assesses inmate supervision and security procedures throughout its facilities. In fact, through
such assessments, VA DOC has found that staffing issues occur most when people are late to work or no-shows. An
additional 16FTEs at each facility were estimated to ensure adequate supervision, resulting in an annual cost of
$4.9M. Additionally, an upfront cost of $91K associated with new hires was estimated, which includes training,
incidentals and office equipment.
Cross-gender pat searches are currently only prohibited at female facilities. With over 90% male inmates,
limitations on cross-gender searches present operations and security issues. One solution for male facilities is to hire
50 male staff at an annual cost of $2.6M. VA DOC expressed difficulty in attracting qualified male applicants in
rural locations. VA DOC believes that prohibiting Limits to Cross-Gender Viewing and Searches conflicts with state
law and governing hiring practices. In addition, $48K in new hire costs was estimated as an upfront cost.
Booz Allen estimated a PREA triennial audit to annually cost $302K, covering 28 prison facilities.
An upfront cost of $500K was estimated to train volunteers, contractors and inmates. The cost estimate includes
increased LOE and curriculum development. An annual cost of $63K was estimated as 25% of initial training
impact, to refresher training. An additional $50K was estimated to ensure investigators are trained in confinement
settings and that medical and mental health contractors, including part-time associates, are trained in accordance to
the NPREC requirements.
While a screening tool has been implemented throughout the
VA DOC, modification will need to be made to include
gender-specific questions. Booz Allen estimates an upfront
cost of $174K to modify the existing instrument, along with
$50K to implement the new screening process.
According to the NPREC standard PP1, zero tolerance of
sexual abuse, VA DOC would require 1FTE to serve as the
PREA Coordinator at an annual cost of $112K.
In order to gather, review and report sexual abuse data, an
annual cost of $72K was estimated to hire 1FTE to fulfill the
increased LOE.

Appendix B - Site by Site Characteristics

Cost Impacts
Assessment and Use of Monitoring Technology (PP7)
Inmate Supervision (PP3)
Limits to Cross-Gender Viewing and Searches (PP4)
Audits of Standards (AU1)
Training and Education (TR1 - TR5)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Zero Tolerance of Sexual Abuse (PP1)
Gathering, Reviewing and Reporting Data (DC1 - DC4)
Hiring and Promotion Decisions (PP6)

B-28

PREA Cost Impact Analysis
VA DOC conducts background checks for promotion decisions. However, the increased LOE associated with
contacting prior institutional employers was determined to best met with an additional investigator at an annual cost
of $41K.

Appendix B - Site by Site Characteristics

B-29

PREA Cost Impact Analysis

Virginia Department of Corrections

Cost Impact

Percent of Annual Operating Budget
ID

PP-1
PP-2

Standard Addressed

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

Compliant?

3.1%

1.6%

Upfront

Yearly
Maintenance

$

30,997,776

$

16,245,959

N

$

1

$

112

$

91

$

4,900

$

48

$

2,600 With 60% of security force female, 50 additional FTE's (BFOQs) males are required

N

PP-3

Inmate supervision

N

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

$

1

$

$

30,100

$

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

N

$

250

TR-3

Inmate education

N

$

250

$

2

PP-7
RP*
RP-1

Explanation

54%

Salary + benefits of 1 FTE at senior-level salary
Cost impact has been provided under TR-2 and TR-3
To provide sufficient LOE, add a 24/7 post to each of 3 dormitory housing units in 6
dormitory facilities for each facility

41 Cost of $40K- salary and benefits for investigator position
Cost to double number of cameras plus one additional 24/7 post to each facility,
and additional maintenance costs

8,100

Y
N

A formal agreement is not in place but can be achieved at insignificant cost

Y
$

63 Train staff at its contracted jail facilities
Train inmates at contracted jail facilities
Investigators are not specifically trained on PREA. Cost to attend Department of
Criminal Justice Services (DCJS) training.

TR-4

Specialized training: Investigations

N

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

$

48

Training hours of staff including PT medical and mental health support.

N

$

176

Assessment modification and update of offender management system

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

$

50

RE-2

Exhaustion of administrative remedies

N

48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative

RE-3

Inmate access to outside confidential support services

N

RCASA will allow VA DOC to use their hotline free of charge

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

Third-party individuals are not informed in writing

N

There is no special report given to victims under the age of 18 years

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y
N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

Integration of a risk screening tool into existing information system.

Y

Disciplinary actions and results of investigations cannot be released

Y

Y
Y
Y
Y

N

$

1

$

One additional staff member (including salary and benefits) would be necessary to
72 analyze data, evaluate and update current training

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4302 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-30

PREA Cost Impact Analysis

Jails
Aiken County Detention Center (Aiken County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Aiken County

$

1
59%
75
75%
25%
317
85%
15%
394
124%
No
$45.00
No
5,000,000

Aiken County, located in Aiken, S.C., is a large jail, with an
ADP to Capacity ratio of 124%. The facility is relatively new,
opening in 2002, and employing 75 staff. Aiken County
operates a direct supervision model and has had no confirmed
incidents of sexual abuse the past three years.
Aiken County is 59% compliant with the NPREC standards.
It is estimated that Aiken County will have a total upfront cost
of $507K and an annual cost of $29K, to reach full
compliance.
Standard PP7, Assessment and Use of Monitoring
Technology, amounted to 99% of the total upfront cost. An
upfront cost of $500K was estimated to upgrade the close
circuit TV system, purchase and install 16 cameras and DVRs.
According to the standard PP1, zero tolerance of sexual
abuse, Aiken County would require 0.5PTE to serve as the
PREA Coordinator at an annual cost of $21K.

Booz Allen estimated a PREA triennial audit to annually cost
$8K.
The development of a training curriculum and employee labor
hours to attend a four hour session was estimated to cost $4K.
An upfront cost of $1K was estimated to cover additional LOE
of volunteers and contractors to attend this training. Lastly, an
upfront cost of $1K was estimated to develop a PREA new
orientation video for inmates, to also be shown as refresher
training on the close circuit TV.

Appendix B - Site by Site Characteristics

Cost Impacts
Assessment and Use of Monitoring Technology
(PP7)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)
Training and Education (TR1 - TR5)

B-31

PREA Cost Impact Analysis

Aiken County Detention Center

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

10.1%

0.6%

Upfront

Yearly
Maintenance

59%

$

507,383

$

29,188

N

$

1

$

21

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N
$

500

$

1

$

4

PP-1

N

RP-2
RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

N
N

Employee training

N

TR-2

Volunteer and contractor training

N

$

1

TR-3

Inmate education

N

$

1

TR-4

Specialized training: Investigations

N

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

N

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-2

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

Changes to current procedure can be completed at no additional cost
Current CCTV equipment is antiquated. Additional cameras and DVR equipment
are necessary to enhance capabilities of supervision.
$

TR-1

MM-1

.5 FTE at senior-level salary

Y

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

PP-7
RP*
RP-1

Explanation

-

Internal victim advocate cost of $100 per incident. No existing incidents
Cost to develop MOU with the Cumbee Center.

Cost of salaries for all employees to attend a 4 hour session, and cost of training
supplies. Per Booz Allen, cost associated with development of training material is
responsibility of PREA Coordinator.
$

-

Cost of additional labor hours for volunteers and contractors
Production of new orientation video to include PREA-specific curriculum
Training does not currently include confinement settings. Cost would be minimal.
Would be ensured through medical services contract

$

-

Labor cost for Classification Lieutenant to research and format assessment tool.
Information can be uploaded into JMS at no additional cost

Y
48hr exhaustion of administrative remedies is viewed as a major policy issue. Cost
estimates for compliance are speculative
$

1

Materials cost including printing to provide outside access to services.
Third-parties are currently not notified of the results of an investigation, but can be at
no additional cost

Y
No policy is in place for this, but can be created at a negligible cost

Y

Y

Y
Y
Y
Y

N

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-32

PREA Cost Impact Analysis
Alachua County Jail (Alachua County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Alachua County
1
49%
240
71%
29%
1,148
87%
13%
904
79%
No
$84.00
No
26,703,372

Alachua County, located in Florida, was built in 1994 and is
considered a large jail, with 314,000 square feet, and a
capacity of 1,148. Alachua County incarcerates both male and
female inmates for up to one year.
Alachua County is 49% compliant with the NPREC standards.
It is estimated that Alachua County will have a total upfront
cost of $205K and an annual cost of $797K, to reach full
compliance.

At Alachua County, abusers of sexual abuse do not receive
ongoing medical and mental health treatment. An annual
cost of $406K was estimated for the addition of 4 health care
practitioners. This cost is associated with the high percentage
of victims of sexual abuse (17,000 bookings per year), along
with an unknown number of abusers of sexual abuse. Alachua
County expressed concern that NPREC standard MM-3, was
$
cost prohibitive and incongruent with how many jails struggle
for contracted medical support, let alone develop a sexual abuse program. They argue that this standard was written
with prisons in mind.
The NPREC requirements for training and education would have a substantial cost impact on Alachua County
Vendor developed training was estimated to cost $100K, which also included the additional labor hours of staff. An
annual cost of $25K was estimated to provide refresher training as a part of the annual training cycle. Alachua
County has approximately 75 contract employees and hundreds of volunteers, with new employees and volunteers
being hired or cleared to volunteer regularly. Additionally, an upfront cost of $70K to train its Criminal
Investigations Division (CID) in confinement settings and to train six contracted medical and mental health
practitioners.
According to the standard PP1, zero tolerance of sexual abuse, Alachua County would require 1FTE to serve as
PREA Coordinator at an annual cost of $136K.
A substantial increase in LOE will be required to
meet NPREC requirements on screening. Based on
the current volume of inmates classified and
reclassified, one additional case worker will be
needed at an annual cost of $76K. Alachua County
believes an increase in LOE will result from the
new screening criteria. The increased LOE to make
informed housing decisions was estimated at an
annual cost of $56K.

Cost Impacts
Ongoing Medical and Mental Health Care (MM-3)
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Screening for Risk of Sexual Abuse ( SC1 and SC2)
Evidence Protocol and Forensic Medical Exams (RP1)
Exhaustion of Administrative Remedies (RE2)
Audits of Standards (AU1)
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)

An annual cost of $61K was estimated for 1FTE to
serve as the internal victim advocate for evidence protocol and forensic medical exams. Costs also include
anticipated travel expenses. In addition, $25K was estimated to develop victim advocate posters and pamphlets, and
cover additional LOE with distributing these materials.
Increased LOE associated with the 48 hour exhaustion of administrative remedies requirement was determined to
cost $25K. This cost estimate is a result of Alachua County housing federal prisoners, who will likely exercise
exhaustion of administrative remedies more frequently.
Booz Allen estimated a PREA triennial audit to annually cost $8K.

Appendix B - Site by Site Characteristics

B-33

PREA Cost Impact Analysis
Lastly, an upfront cost of $1K was estimated to contract with an outside provider of emotional support services.
While Booz Allen acknowledges certain restrictions, specifically with VOCA funding, advocacy groups are allowed
to use funding from alternate sources to work with inmates.

Appendix B - Site by Site Characteristics

B-34

PREA Cost Impact Analysis
Alachua County Jail

Cost Impact
Percent of Annual Operating Budget

ID

Standard Addressed

Compliant?

0.8%

3.0%

Upfront

Yearly
Maintenance

49%

$

204,786

$

796,923

N

$

1

$

136

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

PP-1

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

$
PP-6

Hiring and promotion decisions

N

PP-7
RP*

Assessment and use of monitoring technology
Response Planning

Y

RP-1

N

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

TR-5
SC*
SC-1

1

$

1

$

100

N

$

50

Cost to train the Criminal Investigations Division

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

$

20

Cost to provide training to 6 contracted practitioners

N

$

1

$

76 One FTE to conduct increased screening LOE

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

N

$

1

$

56 Increased LOE associated with making informed decisions based on new criteria.

RE-2

Exhaustion of administrative remedies

N

$

25

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*

Third-party reporting
Official Reponse Following an Inmate Report

Y

OR-1

Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

N

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

N

Agency does not monitor, for at least 90 days, conduct and/or treatment of staff or
inmates. No cost impact

IN-1

Duty to investigate

N

Victims are notified by State Attorney of outcomes, but not third parties. No cost
impact

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-1
MM-2

61

One FTE to serve as victim advocate. Additional transportation and security fees
incurred

$

N

$

Per Booz Allen, fee associated with criminal background check assumed to be $50.
2 Fee includes access to government sources and an internal LOE. Alachua Co. has
40 promotions

Cost associated with developing and implementing an MOU

Y
$

25 Cost to train contractors and volunteers
PREA Coordinator can conduct this training

Y

$

25

Increased LOE for the 48hr requirement because Federal prisoners are housed at
facility.
Cost to print material and LOE associated with distribution to inmates.

Medical staff are not required to advise inmates of their duty to report. No cost
impact
Local law enforcement reports all incidents, not facility head. No cost impact
Staff responders are not required to instruct the victim to preserve physical
evidence. No cost impact

Y
Sanctions do not include interventions. No cost impact

Y
Y
N

$

4

$

N

4 additional practitioners to provide ongoing treatment. (17,000 inmates annually
406 booked)
A review team is not currently in place. No cost to implement.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-35

PREA Cost Impact Analysis
Albany County Jail (Albany County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Albany County
1
61%
353
94%
6%
963
85%
15%
700
73%
No
$166.40
Yes
$43,348,512

Albany County, located in Albany, New York, is one of the
largest County Correctional Facilities in the state. The facility
has a capacity of 963 beds, providing custody for local, state
and federal prisoners. During the past year, over 7,000
prisoners were admitted to the facility.
Albany County is 61% compliant with the NPREC standards.
It is estimated that Albany County will have a total upfront
cost of $19.4K and an annual cost of $1M, to reach full
compliance.

A large portion of the total upfront costs are a result of the
NPREC standard ID-6: Supplement to SC2: Use of
Screening Information. Albany County contracts with ICE
for the housing of inmates. They do not house them
separately, which is noncompliant with the standard. An
annual cost of $515K and an upfront cost of $9K were
estimated to hire nine additional staff to monitor ICE inmates
separately from the general jail population. Albany County stated that if this standard with enacted, they would opt
out of the ICE contract, because the revenue generated is not enough to cover costs.
The prohibition of cross-gender pat searches was the second largest cost driver, with an annual cost of $309K and
an upfront cost of $5K. Albany County does not prohibit Limits to Cross-Gender Viewing and Searches, requiring
five additional female staff at $60K.
The NPREC requirement for training and education would result in an annual cost of $122K. This cost includes
modifications to the current curriculum and over time for officers
Cost Impacts
and civilians. Training was estimated to cost $50K for every four
hours of training for sworn officers, $65K for civilians and $5K for
Immigrant Detainees (ID-6)
volunteers. An annual cost of $1K was estimated for conducting
Limits to Cross-Gender Viewing and Searches
(PP4)
refresher training.
According to the standard PP1, zero tolerance of sexual abuse,
Albany County would require 1FTE to serve as PREA Coordinator
at an annual cost of $101K.

Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

Booz Allen estimated a PREA triennial audit to cost an annual $8K.

Appendix B - Site by Site Characteristics

B-36

PREA Cost Impact Analysis
Albany County Jail

Cost Impact
Percent of Annual Operating Budget

ID

PP-1

Standard Addressed

0.0%
Compliant?

2.4%

Upfront

Yearly
Maintenance
$
1,056,987

Explanation

61%

$

19,392

N

$

1

$

101

$

5

$

309 5 additional female FTE's at $60K salary plus benefits.

$

-

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

Salary + benefits of 1 FTE at senior-level salary

Y

Per Booz Allen, fee associated with criminal background check assumed to be $50.
Fee includes access to government sources and an internal LOE. Albany Co. has 5
promotions

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y
N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

TR-2

Volunteer and contractor training

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

$

6

N

$

1 Annual printing cost for the new form during the admission process.

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

N

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

Victim advocate services available at negligible cost
Can be proivded by local hospital or the Center of Law and Justice (provides
transitional services)

N

$
$

5

$

115 4 hrs of training for civilian staff and 4 hours for sworn officers
1

Cost to train volunteers for 4 hours
PREA Coordinator position can modify handbooks and conduct training
Cost to train Medical and Mental Health staff

Y

Y
Any incident would have resulted in a call (not writing) to the head of other facility,
providing him/her with all pertinent info on allegation. No cost impact
Currently does not provide this training, but this will be included in a training
program at no additional cost

Releasing investigative outcomes to third parties is prohibited by state law. Could
result in union issues

Y
Do not provide intervention programs at the correctional facility. No cost impact

Y
Y
Y
Y

N
N

Appendix B - Site by Site Characteristics

$
$

9

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage
515 Additional staff necessary if ICE inmates were required to be housed separately.

B-37

PREA Cost Impact Analysis

Anoka County Jail (Anoka County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Anoka County

$

1
49%
76
75%
25%
248
78%
22%
199
80%
No
$105.47
Yes
8,527,460

Anoka County, located in Andover, MN, is the primary intake
and booking facility for all law enforcement agencies. The
facility has a capacity of 248, an ADP of 199 and employs 76
staff members. Although the jail detains women, they are
only kept in the facility for 12 hours or less before being
transferred. As such, 99% of available bed space is dedicated
to male inmates.
Anoka County is compliant with 49% of the NPREC
standards. It is estimated that Anoka County will have a total
upfront cost of $52K and an annual cost of $312K, to reach
full compliance.
The prohibition of cross-gender pat searches accounted for
85% of the total annual cost. An annual cost of $259K was
estimated to hire five male FTEs. Due to the configuration
and design of the jail, only staff member can cover a post at a
time. These additional positions will enable a 24 hour post
dedicated exclusively for conducting pat downs on male

inmates.
The NPREC standards on training and education would require an upfront cost of $29K. Employee training was
estimated to cost $4K, which included staff labor hours and curriculum development. Inmate education was
estimated to cost $13K for materials, while the Zero tolerance of sexual abuse position was assumed by Booz Allen
to be the instructor of this session. An upfront cost of $13K was identified to develop investigator training that is
specific to confinement settings. Developing and implementing training for medical and mental health care staff was
estimated to cost $3K upfront and $1K for refresher. Costs include OT of staff, materials, and new programs to
ensure that medical staff and investigators are covered on NPREC.
According to the standard PP1, zero tolerance of sexual abuse, Anoka County would require a 0.5PTE to serve as
PREA Coordinator at an annual cost of $25K.
Anoka County’s inmates are screened during intake, but not regarding sexual abuse. An upfront cost of $10K was
estimated to modify and implement a new screening process.
An annual cost of $8K was estimated to accommodate special needs in accordance with the NPREC requirements.
Cost estimates include purchasing equipment for the deaf and disabled, an increased use of interpreters and
translation technology, and increased staff LOE for security of special needs inmates.
Booz Allen estimated a PREA triennial audit to cost an
annual $8K.
An $8K annual cost was associated with the 48 hour
exhaustion of administrative remedies requirement. In
response to a higher volume of inmates needing to get to
court, the cost estimate is for the travel and overtime of
two deputies.
An upfront cost of $5K was a result of NPREC standard
DI-2: Disciplinary sanctions for inmates. The cost
estimate was to develop an intervention program
designed to address and correct underlying reasons or

Appendix B - Site by Site Characteristics

Cost Impacts
Limits to Cross-Gender Viewing and Searches (PP4)
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Screening for Risk of Sexual Abuse ( SC1 and SC2)
Accommodating Special Needs ( PP5)
Triennial Auditing ( AU1)
Exhaustion of Administrative Remedies (RE2)
Disciplinary Sanctions for Inmates (DI-2)
Contract Modifications for Outside Services (RP2-RP4 and RE-3)

B-38

PREA Cost Impact Analysis
motivation behind the sexual abuse incident.
An upfront cost of $4K was estimated to develop and distribute posters and pamphlets for victim advocate outside
services. Anoka County is presently looking into non-profit groups, (such as a national crisis line), and determine if
a partnership is a possibility. Also, Anoka County is developing a relationship with the Alexandra House, however
there is a potential conflict of interest if they use their services. If the Alexandra House is representing a sexual
abuse victim and the perpetrator of that abuse is in custody at Anoka County, the abuser might be able to harass
his/her victims because they will have direct access to their services. That said, Anoka County will first set up
internal victim advocate services.

Appendix B - Site by Site Characteristics

B-39

PREA Cost Impact Analysis
Anoka County Jail

Cost Impact
Percent of Annual Operating Budget

ID

Standard Addressed

Compliant?

0.6%

3.7%

Upfront

Yearly
Maintenance

49%

$

51,719

$

312,403

N

$

1

$

25

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

$

5

$

259

PP-5

Accommodating inmate with special needs

N

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

$

TR-3

Inmate education

N

$

13

TR-4

Specialized training: Investigations

N

$

13

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

$

3

PP-1

Explanation

.5 FTE at senior-level salary

Y
Create one 24-hour male deputy post specifically for inmate pat searches and 5
additional male deputies
Purchase of additional equipment for deaf and disabled inmates. Increased use of
8
on-site interpreters, use of translation technology,and staff time to provide security.

$

There are few promotions. No additional costs are anticipated.

Y
Will use current contracted mental health provider to fulfill this requirement

$

$

-

$

4
-

Develop and hold annual classroom training on PREA. Per Booz Allen assumes
2/3 of range to be staff salary and 1/3 to be material cost.
Expanded training- 500 Brochures annually - minimal cost
Cost of materials. PREA coordinator can handle training responsibilities.
Investigators do receive training, more training required to fully comply

$

1

Upfront cost for SART training. Annual Refresher Training
Does all intake screenings electronically for record retention purposes. Cost to
modify existing jail software.

10

SC-1

Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

N

Captain or designee would contact the facility in question, not facility head

OR-3

Staff first responder duties

N

Policy updates. No additional cost

OR-4

Coordinated response

N

Policy updates. No additional cost

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

Needs to be added to policy. No additional cost

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-1
MM-2

Y
$
$

8 Personnel costs associated with accompanying inmates to court.
Set up advocacy program with Alexandra House. Includes developing and
distribution of posters, pamphlets and other notices w/i jail facility.

4

Y

Y

Y
$

5

Labor hours to develop a program for disciplinary action
Current health care, mental health and classification screening tools are not in
compliance, but can be at no additional cost

N
Y
Y
N

Policy updates. No additional cost

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-40

PREA Cost Impact Analysis
Denver County Jail (Denver County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Denver County
1
84%
302
78%
22%
1,634
81%
19%
2,118
130%
Yes
$66.40
Yes
4
3
44,098,530

Denver County, located in Denver, CO is under the
jurisdiction of the Denver Sheriff’s Department, which also
operates the Denver County Pre-arraignment Detention Center
(DCPA)1. The DCPA is found within the lockup sector of the
site summaries. Denver County is classified as a large jail,
with a total capacity of 1,634. The jail is overcrowded,
operating at 122% capacity.
Denver County is 88% compliant with the NPREC standards.
It is estimated that Denver County will have a total upfront
cost of $134K and an annual cost of $166K, to reach full
compliance. Several cost estimates were not provided by
Denver County; however Booz Allen estimated several
responses based on discussions at the site visit meeting and
comparable data provided by the DCPA.

The training costs estimates for Denver County resulted in an
upfront cost of $132K and an annual cost of $33K. Denver
County can not remove any of the existing 40 hours of
mandatory training. All pre-service personnel would be provided with an additional four hours of PREA training. A
one-hour refresher session would be also be conducted for all personnel during annual in-service training.
$

According to the standard PP1, zero tolerance of sexual abuse, Denver County would require 1FTE to serve as
PREA Coordinator at an annual cost of $124K.
Booz Allen estimated a PREA triennial audit to cost an annual
$8K.
Lastly, a $1K upfront cost was estimated to modify the current
screening process. Inmates are currently screened during
classification, however the screening instrument is not genderspecific. The screening tool will require some additional
modifications.

1

Cost Impacts
Training and Education ( TR1 through TR5)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)
Screening for Risk of Sexual Abuse ( SC1 and SC2)

The two facilities are merging under one roof but will still be operated independently.

Appendix B - Site by Site Characteristics

B-41

PREA Cost Impact Analysis
Denver County Jail

Cost Impact
Percent of Annual Operating Budget

ID

Standard Addressed

0.3%
Compliant?

0.4%

Upfront

84%

$

134,172

$

1

PP-1

Zero tolerance of sexual abuse

N

PP-2

Contracting with other entities for the confinement of inmates

Y

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

Yearly
Maintenance
$
165,945

Explanation

$

124

Salary + benefits of 1 FTE at senior-level salary

$

-

Per Booz Allen, fee associated with criminal background check assumed to be $50. Fee
includes access to government sources and an internal LOE. Denver County has 3
promotions

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*

Y

SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Site did not provide response

OR-3

Staff first responder duties

Site did not provide response

OR-4

Coordinated response

Site did not provide response

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Site did not provide response
Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of sexual
abuse

Site did not provide response

Site did not provide response

MM-3
DC*
DC-1

Access to emergency medical and mental health services
Ongoing medical and mental health care for sexual abuse
victims and abusers
Data Collection and Review
Sexual abuse incident reviews

Y

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards

N

Supplemental Standards
Supplement to SC-2

Y

MM-1
MM-2

Y
Y

N

$

132

$

1

$

33 Cost to train 302 staff at $548.14 each to NPREC standards; includes refresher training

Cost to modify existing screening instrument to comply; primarily involves staff time

Y

Site did not provide response

Site did not provide response

Site did not provide response

Y

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain internal LOE
to support the audit process. Assumed an auditor’s fee will include 4-person audit team
8 labor, meals and incidentals, hotel, air fare, and mileage

B-42

PREA Cost Impact Analysis
Essex County Jail (Essex County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Essex County
1
70%
291
83%
17%
990
100%
0%
1,300
131%
Yes

$

35,055,517

Essex County, located in Middleton, MA is classified as a
large jail. The jail is part of the Essex County House of
Corrections, which also has a small minimum security facility
for Women in Transition (WIT). The House of Corrections
also has a pre-release center that houses 350 offenders. This
study does not include the two adjacent community
corrections facilities, focusing entirely on the all male jail.
Essex County houses sentenced county inmates, pre-trial
county inmates, a few federal inmates, and sentenced state
inmates. The average sentence for a county inmate is nine
months. Essex County books over 8,000 inmates per year.
Essex County is 70% compliant with the NPREC standards. It
is estimated that Essex County will have a total upfront cost of
$11K and an annual cost of $101K, to reach full compliance.
According to the standard PP1, zero tolerance of sexual
abuse, Essex County would require 1FTE to serve as PREA

Coordinator at an annual cost of $93K.
An upfront cost of $9K was estimated for training and education. This cost includes $2.5K for the development of
PREA material for inmates, $3.5K to train investigators in
confinement settings, and $1.5K to update training for medical and
Cost Impacts
mental health care staff.
Booz Allen estimated a PREA triennial audit to cost an annual
$8K.
Lastly, Essex County estimated $3K to develop a new policy that
includes the 48hr exhaustion of administrative remedies
requirement.

Appendix B - Site by Site Characteristics

Zero Tolerance of Sexual Abuse (PP1)
Training and Education (TR1 - TR5)
Audits of Standards (AU1)
Exhaustion of Administrative Remedies (RE2)

B-43

PREA Cost Impact Analysis
Essex County Jail

Cost Impact
Percent of Annual Operating Budget

ID

PP-1

Standard Addressed

0.000373465

0.002885822

Upfront

Yearly
Maintenance

Compliant?
70%

$

13,092

$

101,164

N

$

1

$

93

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

TR-4

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y
Does not currently prohibit cross gender pat downs, the facility feels it can develop
a cost effective solution through staffing realignments.
Background checks for staff being considered for promotion are not currently
conducted. Can be completed at no additional cost

Y
$

1

N

$

3

Cost of refresher training

Specialized training: Investigations

N

$

4

Cost represents staff time to provide training for investigators

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

$

2

Additional training material for medical and mental health care staff

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

$

3

$

1

Cost to modify current policy to meet 48hr exhaustion of administrative remedies
Cost for materials such as posters or pamphlets displaying contact information for
outside support services

Y

Y

Y

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

N

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

Cost to develop an MOU with an outside entity

Y

Y

Y
Y
Y

N

Does not have a formal process for a review team. No cost associated
Does not complete the BJS survey. Per Booz Allen, PREA coordinator can handle
responsibilities of data collection/review.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-44

PREA Cost Impact Analysis
Hennepin County Jail (Hennepin County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Hennepin County
1
56%
246
78%
23%
839
91%
8%
694
83%
Yes
$116.88
Yes
3
1
35,702,816

Hennepin County located in Minneapolis, MN operates the
largest pre-trial detention facility state. The jail has
consistently earned the distinction of being accredited by
ACA for maintaining the high standards of inmate custody
and care.
Hennepin County is 56% compliant with the NPREC
standards. It is estimated that Hennepin County will have a
total upfront cost of $148K and an annual cost of $118K, to
reach full compliance.

Training and education is estimated to cost $126K in
upfront costs and $7K annually. Employee training is
estimated at $48K initial and $7K refresher for the Zero
tolerance of sexual abuse to develop and implement a training
curriculum. Inmate education was estimated to cost $50K,
which develops and implements a PREA video loop to be
$
regularly displayed in common areas. An upfront cost of $8K
was estimated to train investigators in confinement settings. The 35 nurses on staff can be specifically trained on
preserving evidence of sexual abuse for $20K.
According to the standard PP1, zero tolerance of sexual abuse, Hennepin County would require 1FTE to serve as
PREA Coordinator at an annual cost of $101K. Hennepin County expressed concern over the intent of this standard,
believing it to be an unnecessary and impractical use of resources. They believe a senior level employee could
oversee PREA in addition to other duties.
An upfront cost of $20K was estimated in order to
execute and revise a new screening instrument in
the electronic jail management system.
Booz Allen estimated a PREA triennial audit to
cost an annual $8K.

Cost Impacts
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Audits of Standards (AU1)
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
Gathering, Reviewing and Reporting Data (DC1 - DC4)

An upfront cost of $2K was estimated to contract
with an outside provider of emotional support
services. Hennepin County has an existing
relationship with HCMC, however it is unlikely that
they would provide the services outlined in the NPREC standards.

Booz Allen estimates a $1K yearly cost of a review team to gather, review and report data on sexual abuse. Cost
to conduct one-hour review with five officials was based on the number of confirmed sexual abuse incidents.

Appendix B - Site by Site Characteristics

B-45

PREA Cost Impact Analysis
Hennepin County Jail

Cost Impact
Percent of Annual Operating Budget

ID

PP-1

Standard Addressed

0.4%
Compliant?

0.3%

Upfront

56%

$

147,692

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

TR-4

Specialized training: Investigations

TR-5
SC*

Yearly
Maintenance
$
118,375
$

101

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y
Accommodations through reassignments of shifts ; no costs associated.

$

Per Booz Allen, fee associated with criminal background check assumed to be $50.
1 Fee includes access to government sources and an internal LOE. Hennepin Co.
has 25 promotions
Hennepin CO. does not currently conduct yearly assessments of technology needs,
can be done at no additional cost

Y
$

2

$

48

N

$

50

N

$

8

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

$

20

SC-1

Screening for risk of victimization and abusiveness

N

$

20

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

Policy update, no additional cost

N

Does not notify victims in writing. Can comply without cost impact

IN-2

Criminal and administrative agency investigations

N

Cost assumed to be included under TR-4.

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review

N

MM-1
MM-2
MM-3
DC*

N

7 Cost for PREA Coordinator to conduct initial and refresher training to employees
Cost to develop PREA video loop and deliver training
Cost to train investigators
Cost to train 35 nurses

Cost to revise the screening instrument in the electronic jail management system

Y
Policy update, no additional cost

Y
Policy update, no additional cost

Y
Y
Y

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

Audits of standards
Supplemental Standards
Supplement to SC-2

$

Y

DC-1

AU-1
AU*
ID-6

Costs associated with drafting an MOU.

N

$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
1 officials was based on the number of confirmed sexual abuse incidents
Policy update, no additional cost

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-46

PREA Cost Impact Analysis
Jefferson County Jail (Jefferson County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Jefferson County
1
53%
30
70%
30%
335
80%
20%
245
73%
No
$35.00
No
1
1
13,000,000

Jefferson County, located in Hillsboro, MO, sits along the
Mississippi River just south of St. Louis. Jefferson County
serves a rural population in the State of Missouri with over
225,000 people covering 660 square miles. Jefferson County
is a 260-bed facility with the original section (110 beds) built
in 1991 and a new section completed in 2009 with an
additional 150 beds.
Jefferson County is 53% compliant the NPREC standards. It is
estimated that Jefferson County will have a total upfront cost
of $175K and an annual cost of $598K, to reach full
compliance.

Jefferson County has been forced to reduce staffing by 25% in
the past few years due to budget constraints at the local and
state level. As a result, they see a heightened requirement for
inmate supervision. Although there have been only two
$
sexual abuse incidents in the past two years, they see this
reduction in force as a security risk to both the inmates and the officers, heightening the potential for destabilizing
activities to include sexual assault. An estimated annual cost of $393K will hire 11 additional staff. Booz Allen
estimates an upfront cost of $10K for operations costs associated with new hires.
The new portion of the jail is fully equipped with modern surveillance technology, however the old jail currently has
no monitoring technology. Jefferson County has already
conducted a needs assessment and determined that the old jail
Cost Impacts
requires 36 cameras at a cost of $164K to include installation
Inmate Supervision (PP3)
and purchase. Additionally, four staff members are required to
Assessment and Use of Monitoring Technology (PP7)
monitor the technology at an annual cost of $143K.
According to the standard PP1, zero tolerance of sexual
abuse, Jefferson County would require 1FTE to serve as
PREA Coordinator at an annual cost of $53K.

Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

Booz Allen estimated a PREA triennial audit to cost an annual $8K.

Appendix B - Site by Site Characteristics

B-47

PREA Cost Impact Analysis

Jefferson County Jail

Cost Impact
Percent of Annual Operating Budget

ID

Standard Addressed

0.013487846
Compliant?

Upfront

0.045975183
Yearly
Maintenance
$
597,677

Explanation

53%

$

175,342

N

$

1

$

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

$

10

$

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

TR-2

Volunteer and contractor training

N

PREA Coordinator can conduct training

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

N

PREA Coordinator can conduct training
Investigators are not trained specifically in conducting investigations in
confinement settings. Cost not provided

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

HPL can provide at no additional cost
Screening instrument is gender specific but Jefferson Co will need to develop a
new policy that separates the questions more directly. Cost not provided

PP-1

$

164

$

393 11 additional FTE's to adequately supervise inmates. Upfront new hire costs

Prior institutional employers are contacted. Questions regarding sexual abuse are
not asked. Could be accomplished at no additional cost
Old jail does not have any video monitoring technology. Costs cover 36 cameras
143
(upfront) and 4 FTEs to monitor footage.

Y
N

Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

OR-3

Staff first responder duties

OR-4

Coordinated response

OR-5
IN*

Agency protection against retaliation
Investigations

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-2

Salary + benefits of 1 FTE at senior-level salary

Y

SC-1

MM-1

53

Can develop MOUs, if needed, at no additional cost

$

-

Current training does not include refresher training. Minimal cost impact

Y

Need to publish names of service providers in inmate handbook. Cost not provided

Specific criminal sanctions cannot be revealed to the victim or complainants under
State law. Cost not provided

N

Confer with medical and mental health care services. No cost impact

Y

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-48

PREA Cost Impact Analysis
Marion County Jail (Marion County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Marion County
1
59%
461
72%
28%
1,135
70%
30%
958
84%
No
$35.00
Yes
29,000,000

Marion County, is located in Indianapolis, IN, and is the
largest jail in the state of Indiana, with 1,135 beds.
Marion County is 59% compliant with the NPREC standards.
It is estimated that Marion County will have a total upfront
cost of $130K and an annual cost of $1.3M, to reach full
compliance.
Marion County contracts with two private facilities for the
confinement of inmates, the MCJ II and Liberty Hall. Both
facilities are ACA accredited, maintaining this status as part of
their contractual obligation. MCJ2 houses 1,125 and women’s
unit houses 250. Booz Allen estimates an annual cost of
$775K to comply with NPREC standard PP2. This estimate is
a percentage of total yearly cost based on number of
contracted inmates.

Enhancements in Assessment and Use of Monitoring
Technology are estimated to cost $116K for 50 additional
cameras, recorders, monitors and installation. An annual cost of $179K will hire three FTEs to monitor the
technology.
$

Marion County contracts with ICE for the housing of immigrant detainees (ID6), yet does not house them
separately from the general population. Marion County requires an additional cell block specifically for housing
immigrant detainees. A cost of $19K per month has been estimated to house an average of 10 detainees, equating to
$228K annually.
According to the standard PP1, zero tolerance of sexual abuse, Marion County would require 1FTE to serve as
PREA Coordinator at an annual cost of $92K.
An upfront cost of $9K was estimated to develop posters
that inform inmates of available victim advocate services.
Booz Allen estimated a PREA triennial audit to cost an
annual $8K.
Marion County does not conduct background checks for
promotion decisions. Marion County has 100 promotions
per year. Booz Allen estimates the yearly maintenance cost
of these additional promotions to cost $5K.

Cost Impacts
Contracting for the Confinement of Inmates (PP2)
Assessment and Use of Monitoring Technology (PP7)
Supplement to SC-2: Use of Screening Information (ID-6)
Zero Tolerance of Sexual Abuse (PP1)
Victim Advocacy (RP1 and RE-3)
Audits of Standards (AU1)
Hiring and Promotion Decisions (PP6)
Training and Education (TR1 - TR5)

An upfront cost of $2K was estimated to establish training
curriculum for volunteers. In addition, an upfront cost of $2K was estimated to train investigators in confinement
settings.

Appendix B - Site by Site Characteristics

B-49

PREA Cost Impact Analysis
Marion County Jail

Cost Impact
Percent of Annual Operating Budget

ID

PP-1

Standard Addressed

Compliant?

0.4%

4.4%

Upfront

Yearly
Maintenance

59%

$

129,517

$

N

$

1

$

92

$

755

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

N

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

N

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

N

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

Salary + benefits of 1 FTE at senior-level salary
Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 1,375
Cross-gender pat downs are currently not prohibited in the case of females patting
down males. Can comply at no additional cost

$
PP-6

Explanation

1,268,588

$

116

$

Per Booz Allen, fee associated with criminal background check assumed to be $50.
5 Fee includes access to government sources and an internal LOE. Marion Co. has
100 promotions
50 additional cameras and associated recording equipment and 3 FTEs to monitor
179
surveillance

Y
No MOU's have been established with outside entities or offices. Can be done at no
additional cost

N

Y
$

2

$

1 Volunteer training on PREA curriculum.

$

2

Training cost includes tuition, transportation, and food.

$

9

Development of poster boards with the agency name and phone number.

Refresher training will require a video loop and signs, can be done at minimal cost

Y

Y

Y

Victims and other complaintants are not notified in writing of investigative
outcomes. Can be completed at no additional cost
Specialized training for investigators is not currently being conducted. No cost
impact

Y

Practitioners do not obtain informed consent from inmates before reporting
information. No cost impact

N
Y
Y

A formal process to review incidents is currently not in place. No cost impact
Sexual abuse data is not currently reviewed and analyzed. No cost impact

AU-1
AU*

Audits of standards
Supplemental Standards

N

$

ID-6

Supplement to SC-2

N

$

Appendix B - Site by Site Characteristics

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage
Cost to open a new cell block for ICE detainees based off of increased cost of care
228 per day.

B-50

PREA Cost Impact Analysis
Miami-Dade County Corrections and Rehabilitation Department (Miami-Dade)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Miami-Dade
5
63%
1,932
48%
52%
5,845
93%
7%
6,299
108%
Yes
$134.27
Yes
1
326,000,000

Miami-Dade is comprised of five correctional facilities, and
two programs. The largest of which is the Metro West
Detention Center, which houses over 3,000 inmates. Over the
past three years, 50 cases of sexual abuse have been
investigated with only one confirmed.
Miami-Dade is 63% compliant with the NPREC standards. It
is estimated that Miami-Dade will have a total upfront cost of
$25.1M and an annual cost of $7.3M, to reach full
compliance.
Based on the last technical assessment, an upfront cost of
$25M was estimated to enhance monitoring technology.
This cost breaks down to 16,667 cameras at $1.5K per camera
plus installation.

An annual cost of $6.7M was estimated to increase inmate
supervision, based on filling current staffing vacancies. These
required positions amount to an additional 89 COs, 21
corporals, and two lieutenants. Booz Allen estimates $112K in upfront operations costs associated with the new
hires.
$

An annual cost of $261K was estimated to train 2,200 employees for two hours, which includes the cost of
implementing refresher training. An upfront cost of $28K was estimated to update inmate handbooks and install
monitors to display PREA information.
Miami-Dade would be required to modify its existing screening instrument at an upfront cost of $3K. In addition,
an additional FTE would be required to facilitate the new screening process at an annual cost of $31K. At MiamiDade, 20 high risk sexual offenders are identified each month. Normally, these high risk offenders would be housed
with another inmate. However, in order to separate them for approximately 30 days, an annual cost of $80K was
estimated, which accounts for the increased cost of care per day in separated pods.
According to the standard PP1, zero tolerance of sexual
abuse, Miami-Dade would require 1FTE to serve as PREA
Coordinator at an annual cost of $92K.
Booz Allen estimated a PREA triennial audit to cost an
annual $41K, covering all five facilities.
Miami-Dade does not conduct background checks promotion
decisions. Miami-Dade has 40 promotions per year. Booz
Allen estimates the yearly maintenance cost of these additional
promotions to cost $2K.

Appendix B - Site by Site Characteristics

Cost Impacts
Assessment and Use of Monitoring Technology (PP7)
Inmate Supervision (PP3)
Training and Education (TR1 - TR5)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)
Hiring and Promotion Decisions (PP6)

B-51

PREA Cost Impact Analysis
Miami-Dade Corrections and Rehabilitation

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

7.7%
Compliant?

2.2%

Upfront

Yearly
Maintenance
$
7,281,125

63%

$

25,144,372

N

$

1

$

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

$

112

$

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

PP-1

141

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

N

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

Y

SC-1

Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

N

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-2

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

Salary + benefits of 1 FTE at senior-level salary

Y
6,700 118 additional FTE's to adequately provide supervision of inmates.

Per Booz Allen, fee associated with criminal background check assumed to be $50.
2 Fee includes access to government sources and an internal LOE. Miami-Dade has
40- promotions

$

MM-1

Explanation

$

25,000

16,667 new cameras at $1.5K each

Y
Y
Y
$

261 Labor hours to train 2,203 staff, includes refresher training.
Per Booz Allen, PREA coordinator can handle training, cost covered under PP-1

$

28

Cost to update inmate handbooks
Costs for this training were not provided

$

3

Modification and updates to screening instrument to reflect standard. One FTE to
facilitate efforts.

$

31

$

80 Cost to house 20 inmates separately

Y

Y
Policy update, no cost impact

Y

Y

N

Policy update, no cost impact

Y
N

$

-

Ongoing care based on 1 incident annually. Minimal cost impact

Y

N

Report does not currently include year-over-year analysis. No cost impact

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 441 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-52

PREA Cost Impact Analysis
Norfolk City Jail (Norfolk City)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Norfolk City

$

1
61%
373
76%
24%
833
90%
10%
1,524
183%
No
$51.25
No
2
34,095,629

Norfolk City, located in Norfolk, VA, is classified as a large
jail facility with a rated capacity of 833 beds. At the time of
our meeting, the ADP was more than 500 inmates over
capacity. The 2009 ACA directory on jails describes the
Norfolk City Jail as having ―temporary holding/lockup‖
supervision. While on site, Booz Allen learned this area was a
few dedicated cells within the facility dedicated to booking.
Norfolk City is 61% compliant with the NPREC standards. It
is estimated that Norfolk City will have a total upfront cost of
$20K and an annual cost of $124K, to reach full compliance.
According to the standard PP1, zero tolerance of sexual
abuse, Norfolk City would require 1FTE to serve as PREA
Coordinator at an annual cost of $56K.
An annual cost of $56K was estimated to hire an additional
medical care FTE to assist in conducting ongoing medical
and mental health care for abusers and victims of sexual

abuse.
An annual cost of $18K and an upfront cost of $3K were required to meet the NPREC training requirements.
Norfolk City has 12 civilian staff to be trained, at $20 an hour for 4 hours, resulting in a $1K upfront cost. The
upfront cost estimate for hiring three vendors to provide PREA training to contractors and volunteers was estimated
at $5K. Inmate education could be provided by the Zero tolerance
Cost Impacts
of sexual abuse, yet would require $2K for materials. Specialized
training for investigators and medical health care staff were both
Zero Tolerance of Sexual Abuse (PP1)
estimated to cost $5K.
Ongoing Medical and Mental Health Care (MM-3)
Booz Allen estimated a PREA triennial audit to cost an annual
$8K.

Appendix B - Site by Site Characteristics

Training and Education (TR1 - TR5)
Audits of Standards (AU1)

B-53

PREA Cost Impact Analysis
Norfolk City Jail

Cost Impact
Percent of Annual Operating Budget

ID

Standard Addressed

0.1%
Compliant?

0.4%

Upfront

61%

$

20,311

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-1

Yearly
Maintenance
$
124,047
$

56

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

TR-3

Inmate education

TR-4

Male/female staffing levels would need to be adjusted by 10%, reducing the
number of female deputies in excess of 40 FTEs. Hoping to come into compliance
through attrition over time. No cost impact

$

Cost to modify contracts to ensure that a contractor is contacting previous
employers

1

Y
Norfolk City can enter into an agreement at no additional cost

12 civilian staff are currently not trained, initial training of 4 hours and recurring
training of 1 hour once every 2 years.

$

1

$

N

$

5

$

1

Modification of existing training to 3 contracts

N

$

2

$

2

Cost to develop training video and materials

Specialized training: Investigations

N

$

5

Training of investigators in confinement settings

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

$

5

Modification of existing training to medical contracts

SC-2
RE*

Use of screening information
Reporting

Y

RE-1

Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*

Third-party reporting
Official Reponse Following an Inmate Report

Y

OR-1

Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

N

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

Y

MM-3
DC*
DC-1
DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*

Audits of standards
Supplemental Standards

N

MM-2

No requirement in policy that directs the Sheriff to report incidents involving victims
less than 18 years of age to any designated state or local agency. No cost impact
Any such incident results in a telephone call (not writing) to the head of the other
facility. No cost impact

Y

N

MM-1

Advocate made available through medical contract negotiations, outside access
provided.

Y

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DI-2
MM*

-

The hearing officer can only request voluntary participation by the inmate in any
suggested treatment or program. Without court order, cannot require attendance.
No cost impact
No informed consent obtained from inmates who admits to prior non-institutional
sexual victimization. No cost impact

N
Y
N

$

1

$

56

One additional FTE to provide medical/mental health care as necessary

Y

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-54

PREA Cost Impact Analysis
Peumansend Creek Regional Jail (Peumansend Creek)
Sector

Jails

Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Peumansend Creek
1
73%
112
46%
54%
336
83%
17%
288
86%
Yes
$83.14
No
$
9,382,283

Peumansend Creek, located in Bowling Green, VA, is
classified as a large jail facility with a rated capacity of 336
beds. Faced with overcrowding, the counties of Arlington,
Loudoun, Caroline, and Prince William, along with the cities
of Alexandria and Richmond, agreed to build an institution
whose prime purpose is to offer programs and services,
assisting with transitioning inmates into society. Each
participating jurisdiction listed above, transports non-violent
able-bodied offenders to the Peumansend Creek facility.
Peumansend Creek is 73% compliant with the NPREC
standards. It is estimated that Peumansend Creek will have a
total upfront cost of $642K and an annual cost of $58K, to
reach full compliance.

Enhancements monitoring technology accounted for a
significant amount of the total upfront cost. An estimated
$400K purchased and installed ten new cameras. Existing
equipment at Peumansend Creek is outdated and incompatible with new systems.
Prohibiting cross-gender pat searches would result in the termination of 13 female employees. Otherwise, female
staff would be limited to the female housing unit, female work crew, and a female intake/transportation post.
Further, Peumansend Creek would be challenged to identify 13 qualified male applicants. The cost impact of this
standard is $233K in severance pay for the terminated employees and $38K in annual operations cost associated
with new hires
Conducting refresher training for employees was estimated to cost an annual $11K. The cost includes a four hour
classroom session, written materials, and a lecture presentation. Investigators can be trained at a five day AJA
training course that is specific to confinement settings.
Cost Impacts
LOE cost associated with training medical and mental
health care staff was estimated to cost $1K upfront.
Assessment and Use of Monitoring Technology (PP7)
Booz Allen estimated a PREA triennial audit to cost
an annual $8K.
The Rappahannock Council Against Sexual Assault
(RCASA) will charge a small fee to provide victim
advocate outside services at $1K annually.

Appendix B - Site by Site Characteristics

Limits to Cross-Gender Viewing and Searches (PP4)
Training and Education (TR1 - TR5)
Audits of Standards (AU1)
Contract Modifications for Outside Services (RP2 - RP4 and RE3)

B-55

PREA Cost Impact Analysis
Peumansend Creek Regional Jail

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

6.8%
Compliant?
73%

PP-1

0.6%

Upfront
$

641,581

$

233

Yearly
Maintenance
$
58,219

Explanation

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*

Assessment and use of monitoring technology
Response Planning

N

RP-1

N

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

TR-2

Volunteer and contractor training

Y

TR-3

Inmate education

Y

TR-4

Specialized training: Investigations

N

$

7

AJA 5-day course of training

TR-5
SC*

N

$

1

Labor hours for medical staff to attend training

SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-1
MM-2

Y
Y
$

38 Cost for severance for 13 female staff being terminated
Does not currently conduct background checks on staff being considered for
promotion. At 2 promotions a year, this can be done at no cost.

$

400

Upgraded surveillance system with 10 additional cameras.
$

N

1

The Rappahannock Council Against Sexual Assault (RCASA) will charge a small
fee to provide this service.
No additional cost to enter into an MOU with the RCASA

$
$

-

11 Cost for 4 hours of refresher training for all staff.
Cost of printing of the Volunteer Handbooks and printing of the Contractor
Handbooks.

Y

Y

Y

Y

Y
No intervention program in place. No cost impact

N

No program in place to refer inmates for treatment. No cost impact

Y
Y
Y

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-56

PREA Cost Impact Analysis
Pulaski County Regional Detention Center (Pulaski County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
Pulaski County
1
54%
256
48%
52%
980
88%
12%
979
100%
No
$34.38
No
1
21,643,319

Pulaski County, located in Little Rock, AR, opened in 1994
and is the largest county detention facility in Arkansas,
housing more than 979 inmates. The jail is the only long-term
detention facility in Pulaski County supporting 12 law
enforcement agencies and 33 state and local courts. The jail is
direct supervision with only one confirmed incident in the past
three years.
Pulaski County is 54% compliant with the NPREC standards.
It is estimated that Pulaski County will have a total upfront
cost of $1.9M and an annual cost of $123K, to reach full
compliance.

Pulaski County does not prohibit cross-gender pat searches
and would have to undergo dramatic workforce adjustments if
this standard were enforced. Reducing the frequency of pat
downs is was determined to be a security risk. Alternatively,
$
Pulaski County can relocate staff to alternate posts, moving
female officers away from posts requiring pat downs. Pulaski County states that more grievance reports from a
male-on-male pat down than a female-on-male pat down. As a result, having more men pat down men might lead to
more problems of sexual abuse, not fewer. In order to comply with the standard, Pulaski County would be forced to
terminate 82.5 female officers resulting in $1.8M in severance pay.
According to the standard PP1, zero tolerance of sexual abuse, Pulaski County would require 1FTE to serve as
PREA Coordinator at an annual cost of $92K.
To modify the current screening tool and existing software
to include gender-specific questions and a question on
domestic battery, Pulaski County would incur an upfront
cost of $80K.
An upfront cost of $30K was estimated to provide training
for employees, volunteers, contractors and inmates. An
annual cost of $20K was requireed to conduct refresher
training.

Cost Impacts
Limits to Cross-Gender Viewing and Searches (PP4)
Zero Tolerance of Sexual Abuse (PP1)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Training and Education (TR1 - TR5)
Audits of Standards (AU1)
Supplement to SC-2: Use of Screening Information (ID6)

Booz Allen estimated a PREA triennial audit to cost an
annual $8K.
Pulaski County contracts with ICE to house immigrant detainees (ID6). On average, Pulaski County has 23 ICE
inmates in custody. An annual cost of $3K was estimated to house these inmates separately from the general
population.

Appendix B - Site by Site Characteristics

B-57

PREA Cost Impact Analysis
Pulaski County Jail

Cost Impact
Percent of Annual Operating Budget

ID

PP-1

Standard Addressed

8.7%
Compliant?

0.6%

Upfront

54%

$

1,873,719

N

$

1

$

1,800

Yearly
Maintenance
$
123,479

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y
N

$

15

$

TR-2

Volunteer and contractor training

N

$

9

$

TR-3

Inmate education

N

$

7

$

TR-4

Specialized training: Investigations

N

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

N

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1
MM-2

$

92

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y
Severance pay for 82.5 female FTE's

$

-

There are few promotions. No additional costs are anticipated

Y

N

Access to a rape crisis facility in area that could provide a victim advocate at no cost

$

-

$

-

$

80

11 Cost to conduct initial and refresher training
2 Cost to train volunteers
7

Does orientation on rules and regulations but doesn't cover sexual abuse, nor do
they provide any refresher education.
Sexual abuse is part of their criminal training, however it doesn't necessarily cover
investigations in a confinement setting.
Assumes that the medical and mental health care staff receive training through
their standards boards and licensing requirements.
Modifications to current screening tool

Y

Y

Notifies victims in writing but do not include any details on disciplinary actions. No
cost impact

N

Y

N

Information on prior abuse is not shared with the administration. No cost impact

Y
Y
Y

AU-1
AU*

Audits of standards
Supplemental Standards

N

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

ID-6

Supplement to SC-2

N

$

Had 12 ICE detainees in 2008, 43 in 2009, and 15 in 2010. Or an average of 23 per
3 year at a unit cost of $56 an inmate for up to 48 business hours.

Appendix B - Site by Site Characteristics

B-58

PREA Cost Impact Analysis
Sacramento County Jail (Sacramento County)
Sector

Jails

Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Sacramento County
2
56%
606

$

4,057
88%
12%
4,042
100%
No
$77.17
Yes
2
2
64,007,412

Sacramento County, located in Sacramento, CA, is comprised
of two jails in the county, the Main Jail and the Rio Coses
Correctional Center (RCCC). The RCCC is the primary
custody facility for inmates sentenced to the County Jail from
the Sacramento County Courts. An increasing percentage of
inmates are pre-sentence, housed at RCCC to maintain the
population at the Main Jail. In addition, the RCCC houses
inmates en route to other jurisdictions, federal prisoners under
a contract with the U.S. Bureau of Prisons, and reciprocal
prisoners from other counties. RCCC is the primary reception
point for parole violators who are being held pending
revocation hearings and the central transportation point for all
defendants sentenced to State Prison.
Sacramento County is 56% compliant with the NPREC
standards. It is estimated that Sacramento County will have a
total upfront cost of $1M and an annual cost of $6M, to reach
full compliance.

Sacramento County has undergone significant staff reductions over the past few years due to budget constraints. As
a result, they see a heightened requirement for inmate supervision. The jail is considered overcrowded with inmates
double bunking in cells not designed for such purposes and the staff to inmate ratio has climbed to 63:1 The
Sacramento County has recently undergone a 80% reduction of the medical staff, which means that available
officers are required to escort inmates to the hospital for emergency treatment, yet remove them from supervisory
duty. Compounding this issue, future budget cuts are in the works and Sacramento County anticipates loosing
additional staff as the State of California faces a monumental budget crisis with major budget cuts being passed
down to the county level. Although sexual abuse incidents over the past year have not been alarmingly high, the
reduction in staff has led to deficit in inmate supervision. An estimated $4.4M would increase each shift by six
officers. An upfront cost of $17K is for one-time costs associated with the new hires.
Current medical and psychiatric staffing levels in the Sacramento County jail facilities are not sufficient to provide
ongoing medical and mental health care to all known users of sexual abuse. Meeting such a requirement would
require hiring dedicated personnel on a 24/7 basis. It is estimated that six clinical FTE’s would be required in order
to meet NPREC standards. At an average cost per
clinician of $200K, an annual cost of $1M and
Cost Impacts
upfront cost of $7K will be incurred.
Although monitoring technology is sufficient at the
RCCC, the coverage at the main jail is inadequate
with many areas that do not have cameras, including
14 floors of confinement space. A current draft RFP,
waiting for funding, estimates a cost of $684K in
upfront costs.

Inmate Supervision (PP3)
Ongoing Medical and Mental Health Care (MM-3)
Assessment and Use of Monitoring Technology (PP7)
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Investigations (IN1 and IN3)
Audits of Standards (AU1)
Contract Modifications for Outside Services (RP2 - RP4 and RE3)

An upfront cost of $328 K and an annual cost of $1K
were estimated in order for Sacramento County to meet the training requirements. The costs include training for
inmates and volunteers, along with the 100 medical practitioners.
According to the standard PP1, zero tolerance of sexual abuse, Sacramento County would require 1FTE to serve as
PREA Coordinator at an annual cost of $199K.
Recently Sacramento County has had several incidents in the facility where inmates witnessed crimes, identifying
another inmate. The duty to investigate all crimes can be completed with the addition of 1FTE assigned to the
Appendix B - Site by Site Characteristics

B-59

PREA Cost Impact Analysis
facility at an annual cost of $182K. This would allow for every incident to be investigated as well as notification of
investigative outcomes.
Booz Allen estimated a PREA triennial audit to cost an annual $16K, covering the two facilities.
An upfront cost of $5K was estimated to develop and distribute victim advocate materials for outside services.

Appendix B - Site by Site Characteristics

B-60

PREA Cost Impact Analysis
Sacramento County Jail

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

1.6%
Compliant?

9.3%

Upfront

Yearly
Maintenance
$
5,971,312

56%

$

1,047,073

N

$

1

$

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

N

$

17

$

$

2

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

PP-1

199

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

$

4,400 Increase of 6 deputies per shift at the Main Jail
Cost for time to complete the word processing, time associated with review and
approval of a policy as well as implementation on the Sheriff’s Department intra-net
Website.
Per Booz Allen, fee associated with criminal background check assumed to be $50.
3 Fee includes access to government sources and an internal LOE. Sacramento Co.
has 63 promotions
Current coverage at the main jail is inadequate, with many areas that do not have
cameras, including 14 floors of confinement space. 200 cameras

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

N

$

3

TR-3

Inmate education

N

$

25

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

$

300

N

$

1

Modification to screening instrument to make it gender specific

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

Y

RE-2

Exhaustion of administrative remedies

N

$

2

$

5

Policy update for 48hr requirement
Staff time to prepare an MOU; create and distribute informational materials; and to
pay for services of an advocate, as needed.

$

1

Women Escaping A Violent Environment (WEAVE) assists. Do not have an MOU
and do not document attempts to establish an MOU with WEAVE. Costs are
unknown.

Y
$

1

Current training for volunteers does not cover sexual abuse.
Inmates only receive orientation but not a comprehensive education.
Cost of training for 100 medical practitioners

Y

Inmate access to outside confidential support services

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-2

684

Y

RE-3

MM-1

$

Y

$

182

Investigation of all crimes can be completed with an additional body assigned to
the facility.

Y

N

All suspected abuse is referred to licensed mental health personnel within facility.

Y
N
N

$

7

$
$

1,000

Addition of 6 clinical FTE's

1 Cost of materials and 3 attendees on review team
Requires a simple process modification at no additional cost

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 416 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-61

PREA Cost Impact Analysis
Washington Pierce County Jail (WA Pierce County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
WA Pierce County

$

Note: the 2 confirmed incidents in 2009 are pending review

2
56%
316
77%
23%
1,730
86%
14%
1,261
73%
No
$82.00
Yes
2
48,589,260

WA Pierce County, located in Tumwater, WA, is
medium/maximum security and consists of two facilities, the
New Jail and the Main Jail, confining over 1261 inmates.
WA Pierce County is 56% compliant with the standards. It is
estimated that WA Pierce County will have a total upfront cost
of $101K and an annual cost of $301K, to reach full
compliance.
According to the standard PP1, zero tolerance of sexual
abuse, WA Pierce County would require 1FTE to serve as
PREA Coordinator at an annual cost of $163K.
An upfront cost of $97K was estimated and an annual cost of
$16K in order to meet the NPREC training requirements.
Costs include training for 316 uniformed staff, 1,200
contracted employees, a video loop for inmate education,
investigator training, and medical and mental health care
training.

The second largest cost driver was a result of improvements to the
screening process, resulting in an annual cost of $111K. Booz
Allen estimates the need for one additional FTE to facilitate the
new screening process.
Booz Allen estimated a PREA triennial audit to cost an annual
$16K, covering the two facilities.

Appendix B - Site by Site Characteristics

Cost Impacts
Zero Tolerance of Sexual Abuse (PP1)
Training and Education (TR1 - TR5)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Audits of Standards (AU1)

B-62

PREA Cost Impact Analysis
WA Pierce County Jail

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.2%

0.6%

Upfront

Yearly
Maintenance

56%

$

101,034

$

309,385

N

$

1

$

163

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating inmate with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*
RP-1

N

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

PP-1

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

$

2 Labor hours to conduct annual needs assessment of video monitoring

Y
$

1

N

$

63

$

N

$

1

$

$

12

$

11

$

10

$

1

N

TR-3

Inmate education

N

TR-4

Specialized training: Investigations

N

Cost to develop and implement an MOU for victim advocate services

16 4 hour initial training session and for a 1 hour in-service refresher
-

Initial training of volunteers and contractors
Cost to develop PREA pamphlets and develop PREA video loop to be shown on
Closed Circuit TV
Cost to conduct investigator training in a confinement setting
Cost to provide medical and mental health care staff with dedicated sexual abuse
training

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

N

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

N

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y
N

Would need policy change, no cost impact

OR-2

Reporting to other confinement facilities

N

Would need policy change, no cost impact

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

N

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-1
MM-2

N

$

111 1 additional FTE to assist with the screening process
Minimal cost to improve the use the additional screening information

Y
$

-

Minimal cost to develop and print posters displaying a victim advocate hotline

Y

Y
Would need policy change

N

Cost is captured in SC-1

Y
Y
N

$
$

-

Minimal cost to assemble review team based on low number of incidents
Minimal cost to improve review process

-

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 416 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-63

PREA Cost Impact Analysis
Wisconsin Pierce County Jail (WI Pierce County)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Jails
WI Pierce County
1
66%
15
47%
53%
29
80%
20%
52
179%
No
$62.00
Yes
2,100,100

WI Pierce County is a full- service jail facility located in
Ellsworth, Wisconsin. They are a small jail responsible for the
confinement of 52 inmates, with a rated capacity of only 29,
and a staff count of 15. WI Pierce County is also the location
for the dispatchers unit. Staff split their time between inmate
supervision and dispatching 911 calls. WI Pierce County
voluntarily caps off their population and operates under a
direct supervision model.
WI Pierce County is 66% compliant with the NPREC
standards. It is estimated that WI Pierce County will have a
total upfront cost of $11K and an annual cost of $433K, to
reach full compliance.

The proposed prohibition of cross-gender pat searches would
result in an annual cost of $384K and an upfront cost of $5K.
WI Pierce County has about a 50/50 split between
$
male/female staff accompanied by an 80% male inmate
population. To eliminate cross-gender pat downs, WI Pierce County would need five additional FTEs to occupy one
post 24/7.
WI Pierce County will need to enhance their sexual abuse training and education since it currently does not cover
administrative staff or volunteers. A total annual cost of $21K
was estimated to meet this requirement and an upfront cost of
Cost Impacts
$6K. Costs include the development of a video loop, along with
Limits to Cross-Gender Viewing and Searches (PP4)
in-house classroom based training.
According to the standard PP1, zero tolerance of sexual abuse,
WI Pierce County would require 0.5PTE to serve as PREA
Coordinator at an annual cost of $20K.

Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

Booz Allen estimated a PREA triennial audit to cost an annual $8K.

Appendix B - Site by Site Characteristics

B-64

PREA Cost Impact Analysis

WI Pierce County Jail

Cost Impact
Percent of Annual Operating Budget

ID

PP-1

Standard Addressed

0.5%
Compliant?

20.6%

Upfront

Yearly
Maintenance
$
432,713

66%

$

10,796

N

$

1

$

$

5

$

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
inmates

PP-3

Inmate supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating inmate with special needs

Y

20

Explanation

.5 FTE at senior-level salary

Y
384 One additional post with 5 FTE’s (including benefits)
Prior institutional employers are contacted. Questions regarding sexual abuse are
not asked. Could be accomplished at no additional cost and without legal
ramifications

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

N

TR-2

Volunteer and contractor training

N

$

5

TR-3

Inmate education

N

$

1

TR-4

Specialized training: Investigations

N

Cost covered under TR-1 through in-house training

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

Cost covered under TR-1 through in-house training

SC-1

Screening for risk of victimization and abusiveness

N

Inmates are screened during intake, but this does not cover PREA standards. No
cost impact

SC-2
RE*
RE-1

Use of screening information
Reporting
Inmate reporting

N

Need to implement new questions into housing model. No cost impact

RE-2

Exhaustion of administrative remedies

Y

RE-3

Inmate access to outside confidential support services

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-3
DC*
DC-1

Disciplinary sanctions for inmates
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1
AU*
ID-6

Audits of standards
Supplemental Standards
Supplement to SC-2

N

MM-1
MM-2

Y
Cost to draft MOU’s would be dependent on the Office of Corporation Counsel.

Y
$
$

20 Program run in-house; $20K in personnel costs to train all county employees
1 Cost to develop a video based training program.
Cost to develop handbooks

Y
Cost included in TR-3

Y

Y

Y

Y
Y
Y
Y
Wi Pierce Co. does not fill out BJS survery, can be done by PREA Coordinator. Cost
covered under PP-1

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 48 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Appendix B - Site by Site Characteristics

B-65

PREA Cost Impact Analysis

Juvenile
Ada County Juvenile (ACJCS)
Sector

Juvenile

Title

ACJCS
1

Total Facilities

68%

Percent PREA Compliant

30

Total Staff
Percent Male Staff

67%

Percent Female Staff

33%
71

Capacity
Percent Male Offenders

N/A

Percent Female Offenders

N/A
34

ADP

48%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

N/A
No

Unionized?

-

2008 Confirmed Incidents

ACJCS, located in Boise, Idaho, has several branch offices,
and a 71-bed detention facility (2 pods, 3 wings, 1 dorm and
observation rooms). As mandated by the 1995 Juvenile
Corrections Act, ACJCS practices the Balanced Approach to
juvenile services. The Balanced Approach requires that court
staff give equal consideration to methods for holding a
juvenile accountable, assessing and implementing ways to
ensure protection of the community, and assisting a young
person to develop pro-social skills.
ACJCS is 68% compliant with the NPREC standards. It is
estimated that ACJCS will have a total upfront cost of $4K
and an annual cost of $115K, to reach full compliance.
According to the standard PP1, zero tolerance of sexual
abuse, ACJCS would require 0.5PTE to serve as PREA
Coordinator at an annual cost of $59K.

The majority of remaining annual cost is associated with
contract modifications and the development of MOU’s.
Annual Operating Budget
ACJCS currently has an MOU in place with the National
Federation of Families to provide some victim advocate services, but it may not meet the requirements of the
NPREC standards. An agreement with an advocacy group may need to be established to provide some of the
services. ACJCS is exploring this option with Idaho Youth Ranch, a local non-profit agency, to provide a
reintegration specialist at a cost of $25 per day per
youth. ACJCS currently has about 15 youth that
Cost Impacts
would meet this criterion, for a total annual cost of
Zero Tolerance of Sexual Abuse (PP1)
$50K.
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
2009 Confirmed Incidents

$

1
282,000

Booz Allen estimated a PREA triennial audit to
cost $6K annually.

Appendix B - Site by Site Characteristics

Audits of Standards (AU1)

B-66

PREA Cost Impact Analysis
Ada County Juvenile

Cost Impact
Percent of Annual Operating Budget

ID

Standard Addressed

Compliant?

1.5%

40.8%

Upfront

Yearly
Maintenance

68%

$

4,092

$

115,127

N

$

1

$

59

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating resident with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Y

RP-2

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Resident education

N

TR-4

Specialized training: Investigations

Y

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

Y

AP-1

Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Resident reporting

N

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an resident Report
Staff and facility head reporting duties

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

N

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1
DI-2
MM*
MM-1

Y

MM-3
DC*
DC-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff
Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

PP-1

AP-2
RE*
RE-1
RE-2

MM-2

Explanation

.5 FTE at senior-level salary

Y

Do not currently contact prior institutional employers but can do so at no additoinal
cost.

Y
$

50

Will use Idaho Youth Ranch, a local non-profit agency, to provide a reintegration
specialist for about 15 youth that would meet this criteria.

PREA coordinator would develop a PREA curriculum for all staff. Cost covered
under PP-1
Contractors receive PREA training, however, volunteers do not. PREA coordinator
will train volunteers to PREA standards.
$

1

Refresher training not provided. Cost <$1K to develop material

$

1

Screening process is not in place at intake that assesses the risk of residents
being sexual abused and the risk of being abusive. Cost impact of implementing.

N

Involve a change in practice, at no additional cost

Y

N

$

Residents are not provided access to outside victim advocate services. Cost <$1K
to develop material and implement policy.

1

Y
Y
The agency would become compliant through PREA training

Victims and other complainants are currently not notified in writing of investigation
outcomes. Investigations are facilitated by the prosecutor’s office at no cost.

Y
Y
Y
Y
Y
Y

Appendix B - Site by Site Characteristics

The BJS survey is not compeleted, could become part of PREA Coordinator duties.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 46 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-67

PREA Cost Impact Analysis
Arkansas Juvenile Assessment (AR JA)
Sector

Juvenile

Title

AR JA
8

Total Facilities

85%

Percent PREA Compliant

392

Total Staff
Percent Male Staff

59%

Percent Female Staff

41%
347

Capacity
Percent Male Offenders

86%

Percent Female Offenders

15%
296

ADP

85%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$156.00
No

Unionized?

-

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

58,800,000

Located in Little Rock, AR, AR JA is under the Division of
Youth Services, as part of the Arkansas Department of Human
Services. AR JA has privatized all eight of their facilities
(residential treatment and correctional) with multiple year
private contracts. All of the facilities are non-union and all are
ACA accredited. With a rated capacity of 347 and an ADP of
296, AR JA operates at 85% capacity.
AR JA is 85% compliant with the NPREC standards. It is
estimated that the AR JA will have a total upfront cost of $7K
and an annual cost of $85K, to reach full compliance.
Fifty three percent of AR JA’s annual cost is attributable to the
PREA triennial audit. Booz Allen estimated a triennial audit
to cost $45K annually, covering 8 facilities.
The majority of the remaining total yearly cost is associated
zero tolerance of sexual abuse and the need for a part-time
PREA Coordinator position at an annual cost of $38K.

The
remaining upfront cost is associated with the use of
monitoring technology. A yearly cost of $6K was estimated
to install cameras to cover blind spots and areas not currently
within range. A $1K annual cost is also associated with
camera maintenance.

Appendix B - Site by Site Characteristics

Cost Impacts
Audits of Standards (AU1)
Zero Tolerance of Sexual Abuse (PP1)
Assessment and Use of Monitoring Technology (PP7)

B-68

PREA Cost Impact Analysis
Arkansas Juvenile Assessment

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.0%
Compliant?

0.1%

Upfront

85%

$

6,546

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating residents with special needs

Y

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside public entities and community
service providers

Y

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Resident education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

PP-1

AP-2
RE*
RE-1

$

6

$

Do not currently contact prior institutional employers but can do so at no additoinal
cost.
Cost to install and cover blind spots and areas not currently configured in the
1
available technology’s range and yearly maintenance.

Y
N

Cost to modify tool to include PREA standard is null.
Assigned staff would be responsible for any increase in classification review at no
additonal cost.

N
Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*
MM-1

Y

MM-3
DC*
DC-1

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

Audits of standards

.5 FTE at senior-level salary

Y

RE-3

AU-1

38

Y

Y

MM-2

$

Explanation

Y

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-2

Yearly
Maintenance
$
84,659

Y

Y

Y

Y

Y
Y
Y
Y

N

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 445 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-69

PREA Cost Impact Analysis
California Division of Juvenile Justice (CA DJJ)
Sector

Juvenile

Title

CA DJJ
6

Total Facilities

68%

Percent PREA Compliant

2,551

Total Staff

62%

Percent Male Staff

38%

Percent Female Staff

4,585

Capacity

93%

Percent Male Offenders

7%

Percent Female Offenders

1,408

ADP

31%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$544.43
Yes

Unionized?

The CA DJJ, located in Sacramento, CA, operates six juvenile
detention facilities and falls under the jurisdiction of the CA
DOC. For the purposes of this study, the cost impacts of the
NPREC standards are measured separately from the adult
prison system. The CA DJJ receives its youthful offender
population from both juvenile and superior court referrals. The
CA DJJ provides training and treatment for these youths and
carries out its responsibilities through three divisions: the
Division of Juvenile Facilities, the Division of Juvenile
Programs, and the Division of Juvenile Parole Services. With
a rated capacity of 4,585 and an ADP of 1,408, CA DJJ
operates at 31% capacity.
CA DJJ is 68% compliant with the NPREC standards. It is
estimated that CA DJJ will have a total upfront cost of $1.2M
and an annual cost of $3.1M, to reach full compliance.

7

2008 Confirmed Incidents

Seventy one percent of CA DJJ’s annual cost and seventy five
percent of its upfront cost are attributable to monitoring
$
Annual Operating Budget
technology. The CA DJJ facilities have outdated cameras,
which no longer can identify a perpetrator. It is estimated that 120 new cameras in each facility and 12 additional
FTEs for monitoring would be required have adequate video monitoring in place. The cost to purchase, install, and
maintain the cameras, and to employ the additional FTE’s is estimated to cost $2.2M annually and $904K upfront.
2009 Confirmed Incidents

N/A
326,075,000

Currently, the CA DJJ permits female staff to conduct cross-gender pat searches. It is estimated to cost $680K
annually and $85K upfront to prohibit cross-gender pat downs. These costs include the addition of four new posts
along with the time associated to rewrite policies by the HR staff.
According to standard PP1, zero tolerance of sexual abuse, CA DJJ would require one FTE to serve as PREA
Coordinator at an annual cost of $140K.
CA DJJ will also be required to provide specialized training to investigators and medical and mental health care
providers. Upfront costs of $82K each are estimated to
Cost Impacts
train investigators in confinement settings and to train
medical and mental health care staff on preservation of
Assessment and Use of Monitoring Technology (PP7)
Cross Gender Pat Downs (PP4)
forensic evidence. These costs included tuition,
Zero Tolerance of Sexual Abuse (PP1)
materials development, labor hours and travel.
To be in compliance with the NPREC screening
standards, CA DJJ would be required to develop a new
screening instrument, implement a screening process at
all classification reviews, and to make housing, bed and
program assignments. This would cost $60K annually
and $14K upfront.

Training and Education (TR1 - TR5)
Screening (SC1, SC2)
Audits of Standards (AU1)
Victim Advocate (RE-3)
Gathering, Reviewing, and Reporting Data (DC1 through DC4)
Contract Modifications for Outside Services (RP2 - RP4 and RE3)

Booz Allen estimated a PREA triennial audit to cost $34K annually, covering 6 facilities.
CA DJJ will also need to implement contract modifications or develop and MOU with an outside service provider
for emotional support services. This cost estimated to cost $20K upfront and $19K annually.
CA DJJ also does not currently have a formal process for gathering, reviewing and reporting sexual abuse data.
An upfront cost of $15K was estimated to purchase a server necessary to store data for an additional three years
along with an annual cost of $5K to formalize a review team process and document corrective actions.

Appendix B - Site by Site Characteristics

B-70

PREA Cost Impact Analysis
California Department of Juvenile Justice

Cost Impact

Percent of Annual Operating Budget
ID

PP-1

Standard Addressed

0.4%
Compliant?

1.0%

Upfront

Yearly
Maintenance
$
3,100,931

Explanation

68%

$

1,206,800

N

$

1

$

140

Salary + benefits of 1 FTE at senior-level salary

$

85

$

680

Cost for policy writing, 4 additional posts, staffing negotiations, and court expert's to
review policy

$

904

$

$

20

$

$

82

$

82

$

14

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating residents with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Resident education

Y

TR-4

Specialized training: Investigations

N

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

N

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

N

There is no 90-day policy in place for staff. Could be accomplished at no additional
cost.

IN-1

Duty to investigate

N

Victims and families are not notified to the extent of the standard according to Article
14_31140.4.10

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*
MM-1

Y

MM-3
DC*

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review

DC-1

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

N

AP-2
RE*
RE-1
RE-2

MM-2

AU-1

Audits of standards

Y

2,200 12 FTEs to monitor video monitoring, 600 cameras (120 at each facility)

Y
19

Cost to develop an MOU with an outside agency, develop a process for receiving
reports from a public entity,and for transition services

Y

Y

Cost for investigator training specific to confinement settings, (includes tuition,
travel, labor hours).
Implement sexual abuse training specific for medical staff (includes tuition,
materials development, travel, labor hours).
Cost to develop a new written screening instrument.
$

Y

60

Labor hour cost involved to implement new process at intake and reclassifications

Y

N

$

Cost to train staff on victim advocate responsibilities, PREA materials, hotline
installation

4

Explanation found in IN-1

Y

Y

Y
Y
Y

N

Appendix B - Site by Site Characteristics

$

$

5 Cost to develop an incident review report and labor hours for incident review team.

Cost to purchase server, and maintenance fees.

15

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 434 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-71

PREA Cost Impact Analysis
Colorado Division of Youth Corrections (CO DYC)
Sector

Juvenile

Title

CO DYC
11

Total Facilities

63%

Percent PREA Compliant

1,004

Total Staff

57%

Percent Male Staff

43%

Percent Female Staff

1,708

Capacity

86%

Percent Male Offenders

14%

Percent Female Offenders

1,628

ADP

95%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$231.86
Yes

Unionized?

14

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

N/A
40,421,663

CO DYC is located in Denver, CO and manages state operated
and privately contracted residential facilities. CO DYC is also
responsible for community alternative programs that treat
youth between 10-21 years who have demonstrated deliquent
behavior.
CO DYC is 63% compliant with the NPREC standards. It is
estimated that CO DYC will have a total upfront cost of
$17.8M and an annual cost of $3.4M, to reach full
compliance.
CO DYC has 10 State operated facilities in need of
enhancements in monitoring technology. CO DYC believes
that monitoring technology is only one small piece in the
prevention of sexual abuse and not necessarily a tool that
eliminates sexual abuse incidents. Nonetheless, an upfront cost
of $17.8M was estimated to upgrade these 10 facilities.
Additionally, an annual cost of $192K was estimated to
conduct annual assessments of monitoring equipment.

CO DYC contracts for the housing of 747.5 residents. Booz
Allen estimates an annual cost of $1.6M to comply with NPREC standard PP2. This estimate is a percentage of total
yearly cost based on number of contracted inmates.
An increase in inmate supervision was determined necessary to increase the number of staff to resident ratio,
aiming for 1:8. An additional 24.8 FTEs would bring the shift relief factor from 4.2 to 5.2. These positions amount
to $1.3M in annual salaries and an upfront cost for new hires of $24K.
According to the standard PP1, zero tolerance of sexual abuse, CO DYC would require 1FTE to serve as PREA
Coordinator at an annual cost of $86K.
Investigations at CO DYC are typically conducted
through local law enforcement, the Social Security’s
office, or the District Attorney’s Office. CO DYC has
not been content with these services. An in-house
Inspector General was decided as one option to meet the
requirements of this standard. The annual cost of this
position was estimated to be $79K.
An additional FTE at $72K was estimated to gather,
review and report sexual abuse data for CO DYC’s
contracted facilities.

Cost Impacts
Assessment and Use of Monitoring Technology (PP7)
Contracting for the confinement of residents (PP2)
Inmate Supervision (PP3)
Zero Tolerance of Sexual Abuse (PP1)
Investigations (IN1 and IN3)
Gathering, Reviewing, and Reporting Data (DC1 through DC4)
Training and Education (TR1 - TR5)
Audits of Standards (AU1)

An additional FTE $61K was estimated to develop the curriculum and instruct employee training.
Booz Allen estimated a PREA triennial audit to cost $62K annually, covering 11 facilities.

Appendix B - Site by Site Characteristics

B-72

PREA Cost Impact Analysis
Colorado Department of Youth Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

44.0%
Compliant?

8.4%

Upfront

63%

$

17,780,988

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

N

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating residents with special needs

Y

PP-1

Yearly
Maintenance
$
3,382,508
$
$

N
$

24

$

$

Explanation

86

Salary + benefits of 1 FTE at senior-level salary
Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 747.5
24.8 FTE's to bring to a 5.2 shift relief factor, numbers would result in the balance of
1,300
a staffing analysis generated by Voorhis Associates, Inc.
1,600

Per Booz Allen, the fee associated with criminal background check assumed to be
3 $50. Fee includes access to government sources and an internal LOE. CO DYC
has 53 promotions
Cost to oversee yearly maintenance, upgrade, and feasibility of the monitoring
192
equipment.

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside public entities and community
service providers

Y

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

Cost covered in TR-1

TR-3

Resident education

N

Cost covered in TR-2

TR-4

Specialized training: Investigations

Y

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

N

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-4
OR*
OR-1

AP-2
RE*
RE-1
RE-2

$

17,800

$

$

1

$

Y

61

One FTE necessary for training of employees, on-going site training at the facilities,
and the quality assurance process (audit) at each facility.

Do not conduct their own investigations so training agenda is absent. No costs
are associated.

Y
Y
Y

N

National hotline or community based service would be added to current handbook
at a nominal cost.

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

Calls the local County Department of Social Services for investigation.

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

N

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

N

DI-2
MM*
MM-1

Y

MM-3
DC*
DC-1

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

MM-2

Y

Policy update, no cost impact

Y

$

1

$

79

An Inspector General FTE would need to be hired to ensure that proper
investigations would take place as standard outlines.

$

1

$

72

Cost to gather data from contracted facilities for annual reporting.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 462 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Y
Y
Y
Y

Appendix B - Site by Site Characteristics

B-73

PREA Cost Impact Analysis
Florida Department of Juvenile Justice (FL DJJ)
Sector

Juvenile

Title

FL DJJ

Total Facilities
Percent PREA Compliant
Total Staff

101
40%
5,301

Percent Male Staff

N/A

Percent Female Staff

N/A

Capacity
Percent Male Offenders
Percent Female Offenders

6,442
N/A
N/A

FL DJJ, located in Tallahassee, FL, runs five distinct
operations including probation, detention, prevention,
executive direction, and residential. This study focuses on
detention and residential. Detention and residential operations
account for more than 60% of FL DJJ’s annual operating
budget. There are currently 76 residential facilities, 84% of
which contract out their direct care, and 25 detention facilities.
FL DJJ is 40% compliant with NPREC standards. It is
estimated that FL DJJ will have a total upfront cost of $38.1M
and an annual cost of $3.7M to reach full compliance.

The vast majority of FL DJJ’s upfront costs for PREA
87% compliance are attributable to monitoring technology.
ADP/Capacity Percentage
No Currently, 50% of all residential facilities have some form of
ACA Accredited?
$113.47 Assessment and Use of Monitoring Technology, while all
Cost of care / day
Yes detention facilities have some video monitoring, much of it is
Unionized?
12
2008 Confirmed Incidents
deemed inadequate. In order to properly provide adequate
8
2009 Confirmed Incidents
Assessment and Use of Monitoring Technology across its 101
$ 385,018,181
Annual Operating Budget
facilities, it is estimated that FL DJJ will require $38M in
upfront costs. In addition, $86K per year will be required to perform annual technical assessments of each facility.
ADP

5,635

The NPREC standards on training and education will require FL DJJ to provide in-depth training to direct care
employees and high-level training to remaining staff. In total, development and staff time for 4,800 employees
equates to $36K in upfront curriculum development costs and $3.4M in staff labor hours. An additional one hour of
training will be provided to volunteers, at an annual cost of $2K, while materials will be provided to the remaining
contractors at an upfront cost of $7K. Resident education is currently limited to posters and pamphlets because the
average length of stay is only 11 days. FL DJJ anticipates developing a PREA video loop for each facility at an
upfront cost of $22K. Recurring training, through the distribution of flyers and posters, is estimated to cost $11K
annually. Inspectors from the Office of the Attorney General will be required to receive specialized training on
conducting investigations in confinement settings. This
Cost Impacts
training is estimated to cost $10K annually. Training
medical and mental health care staff on preserving forensic
Assessment and Use of Monitoring Technology (PP7)
Training and Education (TR1 - TR5)
evidence of sexual abuse was estimated to cost $30K
Audits of Standards (AU1)
annually.
Booz Allen estimated a PREA triennial audit to cost of
$574K annually, covering 101 facilities.

Zero Tolerance of Sexual Abuse (PP1)

According to standard PP1, zero tolerance of sexual abuse, FL DJJ would require 1FTE to serve as PREA
Coordinator at an annual cost of $76K.

Appendix B - Site by Site Characteristics

B-74

PREA Cost Impact Analysis
Florida Department of Juvenile Justice

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

9.9%
Compliant?

1.1%

Upfront

40%

$

38,066,292

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating residents with special needs

Y

PP-1

Yearly
Maintenance
$
4,165,161
$

76

N

Explanation

Salary + benefits of 1 FTE at senior-level salary
Contracts have not been amended to include PREA language. No cost impact
Not current practice but can be implemented with no additional cost.

$

Per Booz Allen, the fee associated with criminal background check assumed to be
8 $50. Fee includes access to government sources and an internal LOE. FL DJJ has
166 promotions
Cost to update equipment across 100 detention/residential facilitie and technology
86
assessment cost on an annual basis at 100 facilities.

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside public entities and community
service providers

N

No formal agreement has been implemented.

RP-3

Agreements with outside law enforcement agencies

N

Law enforcement has the legal authority to conduct investigations.

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

$

38,000

N

$
$

$

36

$

$

7

$

$

22

$

4

Exam cost of an estimated 8 incidents annually.

In-depth direct care training and high-level training for rest of staff. In total,
development cost and staff time for 4,800 employees to attend training.
One hour training for volunteers and material cost to produce flyers to be
2
distributed to contractors.
Costs reflect a video for each facility (upfront) as well as flyers and posters to be
11
distributed annually.

3,400

TR-3

Resident education

N

TR-4

Specialized training: Investigations

N

$

10

Specialized training for Office of the Inspector General

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

N

$

30

Training to medical and mental health practitioners on evidence preservation.

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

No notification in writing is provided to the third-party.

N

OR-2

Reporting to other confinement facilities

N

A "need to know" policy has not been implemented.
Programs report allegations to a central communications center, not in writing to
the facility director.

OR-3

Staff first responder duties

N

Staff are not trained on evidence preservation.

OR-4

Coordinated response

N

Staff are not appropriately trained to adhere to the standard as written.

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

There is no 90-day policy in place.

N

Victims and families are not notified to the extent of the standard.

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*
MM-1

N

MM-3
DC*
DC-1

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

AP-2
RE*
RE-1
RE-2

MM-2

Y
Y
Y

Y

Y
Programs do not apply discipline or sanctions.

Y
Payments for medical services for incarcerated youth are not able to be paid from
victims crimes fund.

N
Y
N

Appendix B - Site by Site Characteristics

A team could be assembled at no cost to review incidents.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4574 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-75

PREA Cost Impact Analysis
Idaho Department of Juvenile Corrections (IDJC)
Sector

Juvenile

Title

IDJC

Total Facilities
Percent PREA Compliant
Total Staff

3
38%
105

Percent Male Staff

55%

Percent Female Staff

45%

Capacity

268

Percent Male Offenders

89%

Percent Female Offenders

11%

ADP
ADP/Capacity Percentage

268
100%

ACA Accredited?

Yes

Cost of care / day

$201.47

Located in Boise, Idaho, IDJC has regionalized state services
for committed juveniles, aiming to keep residents close to
parents and loved ones who can even take part in the
treatment. All three facilities provide a full complement of
services for 268 youth who range from 10 to 20 years of age
(including the new co-occurring unit). IDJC averages about
300 juveniles in custody, approximately 70% of the residents
are in state facilities, the remaining 30% are with contracted
providers.
IDJC is 38% compliant with the NPREC standards. It is
estimated that IDJC will have a total upfront cost of $3.1M
and an annual cost of $2.8M, to reach full compliance.

IDJC does not have a screening instrument to determine
abuser/victim characteristics. An upfront cost of $45K was
No
Unionized?
estimated to develop a new screening instrument.
10
2008 Confirmed Incidents
Administering this tool was estimated to annually cost $24K.
11
2009 Confirmed Incidents
$ 21,364,200 Current numbers state that 37.2% of IDJC offenders have a
Annual Operating Budget
history of sexual offending. IDJC currently estimates that an
average of 128 juvenile offenders fit in this category. IDJC
expressed concern over the attempt to use screening information, yet without the housing space to follow through.
Currently, there are only 113 treatment beds, 15 less than needed. A 15 bed expansion was determined to be the best
course of action for protecting these offenders. IDJC estimates $180.5K as the cost per bed on which to base an
expansion. A 15 bed expansion would cost $2.7M in upfront building costs. Further, housing residents separately is
expected to annually cost $1.5M.
IDJC contracts for the housing of 134 offenders with 19 other facilities. Booz Allen estimates an annual cost of
$1M to comply with NPREC standard PP2. This estimate is a percentage of total yearly cost based on number of
contracted inmates.
Enhanced monitoring technology and that their archiving capabilities are limited. To ensure that IDJC’s
Assessment and Use of Monitoring Technology systems would be adequate, they would need to replace DVR
servers that do not incorporate a RAID storage array, additional cameras would need to be installed where no
cameras currently exist, and all old BNC (analog) cameras would need to be replaced with IP cameras. It should be
noted that the cost impact estimate does not include the cost for IDJC residential contract providers to update and
install new systems. These costs would be added into daily rates and passed on to IDJC. They feel that it is
impossible to determine the additional costs to them in the
Cost Impacts
short time frame allowed for this study. However, 33% of all
services provided by IDJC are contract provided. An
Screening for Risk of Sexual Abuse (SC1 and SC2)
estimate of 33% of the total cost would be appropriate. An
Contracting for the Confinement of Inmates (PP2)
Assessment and Use of Monitoring Technology (PP7)
upfront cost of $174K and an annual cost of $5K were
Training and Education (TR1 - TR5)
estimated to meet the standard.
Investigations (IN1 and IN3)

To enhance training and education, an estimated upfront
Ongoing Medical and Mental Health Care (MM-3)
cost of $129K and an annual cost of $60K would be incurred
Zero Tolerance of Sexual Abuse (PP1)
to meet this requirement. These costs include the
Audits of Standards (AU1)
development and production of materials needed. The
majority of these estimates are for training employees, while the remainder is for residents, investigators and
medical/mental health care staff. IDJC estimates that 33% of all services provided are provided by contractors.

Appendix B - Site by Site Characteristics

B-76

PREA Cost Impact Analysis
An annual cost of $64K is estimated to hire an internal investigator to ensure that incidents are investigated by
trained, qualified staff.
Currently residents are not placed in sex offender specific programs and/or are not receiving ongoing medical and
mental health treatment. It is estimated that the 15 juveniles with a history of sexually abusive behavior, would
need a minimum of one hour per week of treatment, at a cost of $75 per hour, resulting in an annual cost of $59K.
According to the standard PP1, zero tolerance of sexual abuse, IDJC would require 0.5PTE to serve as PREA
Coordinator at an annual cost of $34K.
Booz Allen estimated a PREA triennial audit to cost $17K annually, covering 3 facilities.

Appendix B - Site by Site Characteristics

B-77

PREA Cost Impact Analysis
Idaho Deptartment of Juvenile Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

14.5%
Compliant?

13.1%

Upfront

38%

$

3,106,180

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating residents with special needs

Y

PP-1

N

Yearly
Maintenance
$
2,795,652
$

34

$

1,000

$

Explanation

.5 FTE at senior-level salary
Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 134

Per Booz Allen, the fee associated with criminal background check assumed to be
1 $50. Fee includes access to government sources and an internal LOE. IDJC has
50 promotions
Cost to replace DVR servers that don't incorporate RAID storage array.Additional
5
cameras installed where no cameras exist. Old BNC cameras replaced as well

PP-6

Hiring and promotion decisions

N

PP-7
RP*

Assessment and use of monitoring technology
Response Planning

N

RP-1

Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

N

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

N

TR-1

Employee training

N

TR-2

Volunteer and contractor training

Y

TR-3

Resident education

N

TR-4

Specialized training: Investigations

N

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

AP-1

N

AP-2
RE*
RE-1

Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Resident reporting

RE-2

Exhaustion of administrative remedies

N

RE-3
RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an resident Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

N

Policy update, no cost impact

OR-3

Staff first responder duties

N

Policy update, no cost impact

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

IN-2

Criminal and administrative agency investigations

N

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

N

DI-2
MM*

Y

MM-2

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and Mental Health Screenings - history of
sexual abuse
Access to emergency medical and mental health
services

MM-3
DC*
DC-1

Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1

$

174

$

$

1

Cost for victim advocate. If each incident investigated by IDJC in 2009 required a
victim advocate for 1.5 hours, would need 37.5 hours services.

Cost to develop an initial MOU for entities and subsequent MOUs with other entities
for similar services.
Attempt to enter into MOUs with the law enforcement agencies, in each of Idaho’s
8
44 counties, responsible for conducting such investigations.

$

4

$

21

$

21

$

121

$

40

$

2

$

8

$

2

$

$

3

$

5 One internal investigator to ensure incidents are investigated by trained staff
Cost for materials, 4 hours of training for mental health practitioners, and 6 hours
6
for medical practitioners.

$

45

$

$

2,700

$

$

-

$
N
Resident access to outside support services and legal representation

-

N

$

Cost to develop an initial MOU and subsequent MOUs of similar nature.
Cost to develop training for 40 hours. Need to train 400 staff for initial
training,require 3 days of training. Refresher training would require 400 staff

Cost of materials.

Cost to develop a tool and to norm and validate the tool and LOE at 30 minutes
during intake.
Screening information isn't collected on residents that are potentially at high risk of
1,500
being sexually abused.Cost to implement would require 15 additional beds.
24

Y

$

Revise existing 2 policies.
Cost of services and materials - 8 hours of services per month.
2

1 internal investigator

Y

N

Policy update, no cost impact
$

1

$

64 Do not notify victims in writing.Cost to add at 1 internal investigator.
Full time investigator who would over see the process. Cost covered in TR-5.
Per Booz Allen,cost provided in IN-1 for additional investigator will also be
responsible for compliance with IN-3.

Y

Y
Y

N

$

Residents are not placed in sex offender specific program and not receiving
ongoing treatment, 15 residents would need a minimum of 1 hour a week of
59 treatment.

Y

Appendix B - Site by Site Characteristics

B-78

PREA Cost Impact Analysis
Indiana Division of Youth Services (IN DYS)
Sector

Juvenile

Title

IN DYS
7

Total Facilities

63%

Percent PREA Compliant

483

Total Staff

60%

Percent Male Staff

40%

Percent Female Staff

1,151

Capacity
Percent Male Offenders

85%

Percent Female Offenders

15%
805

ADP

70%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$173.02
No

Unionized?

IN DYS operates seven juvenile correctional facilities and is a
division within IN DOC. IN DYS has adopted the Balanced
and Restorative Justice Model from the Office of Juvenile
Justice and Delinquency Prevention as the foundation and core
beliefs in providing juvenile justice services. In 2007 there
were two confirmed incidents of sexual abuse compared to
five in 2008. The increase is believed to be due to an increase
in reporting due to greater awareness. While not confirmed, an
estimated 40 to 50 allegations of sexual abuse were reported
among the seven facilities last year.
IN DYS is currently 63% compliant with the NPREC
standards. It is estimated that IN DYS will have a total upfront
cost of $2.6M and an annual cost of $5M, to reach full
compliance.

In order to provide adequate inmate supervision of residents,
the agency feels that a significant amount of additional staff
$
would be needed to eliminate sexual abuse incidents. In many
Annual Operating Budget
instances the staff to resident ratio is as low as 1:24. This ratio
does not adequately provide inmate supervision of inmates. In order to increase the staff to resident ratio to 1:10, a
yearly cost impact of $3.7M for an additional 75 COs and three Internal Affairs Officers. Booz Allen estimated an
upfront cost of $74K for these new hires.
5

2008 Confirmed Incidents
2009 Confirmed Incidents

N/A
61,291,377

IN DYS feels many of their facilities will require an upgrade in monitoring technology in order to adequately
provide supervision of the residents. The female facility is currently in process of receiving 108 new cameras at cost
of $300K, or $2.8K per camera. IN DYS believes that while cameras may not prevent incidents from occurring, they
are very important in the investigation process. An upfront cost of $2.5M to purchase and install cameras with
archiving capability. Upfront costs at Pendleton Juvenile alone are estimated at $1.1M. An annual cost of $140K
annually has been provided to for ongoing maintenance.
Medical and/or mental health treatment is currently only provided to an adjudicated sex offender or those
determined to have a need for such therapy at admission. IN DYS anticipates a significant cost to provide ongoing
medical and mental health care. An annual cost of $750K, or ¾ of their full sex offender treatment program has
been estimated to meet the requirements of the standard.
Currently a victim advocate is not available to the residents at the local hospitals during a medical exam. An annual
cost of $230K and an upfront cost of $4K was estimated for a part time internal victim advocate, plus overtime, at
each facility to accompany the victim though the
forensic medical exam.
Cost Impacts
According to the standard PP1, zero tolerance of
sexual abuse, IN DYS would require 1FTE to serve as
PREA Coordinator at an annual cost of $72K.
Booz Allen estimated a PREA triennial audit to cost
$40K annually, covering 7 facilities.

Inmate Supervision (PP3)
Assessment and Use of Monitoring Technology (PP7)
Ongoing Medical and Mental Health Care (MM-3)
Evidence Protocol and Forensic Medical Exams (RP1)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)
Contract Modifications for Outside Services (RP2 - RP4 and RE3)
Training and Education (TR1 - TR5)

In order to ensure that appropriate transitional services
are provided an annual cost of $30K was estimated to
develop a contract for transition services. The cost is
estimated to be $200 per day for 30 days. There were 5 kids in the previous year that required such services.

Appendix B - Site by Site Characteristics

B-79

PREA Cost Impact Analysis
Lastly a one-time training cost of $25K will result from ensuring Correctional Peace Officer curriculum and
confinement specific training materials are provided to investigators.

Appendix B - Site by Site Characteristics

B-80

PREA Cost Impact Analysis
Indiana Division of Youth Services

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

4.3%
Compliant?

8.1%

Upfront

Yearly
Maintenance
$
4,965,066

63%

$

2,607,116

N

$

1

$

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

N

$

74

$

PP-4

Limits to cross-gender viewing and searches

N

PP-5

Accommodating residents with special needs

Y

PP-1

72

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y
3,700 78 additional FTE's, includes salaries plus benefits
Per Booz Allen,litigation costs will not be included in cost figures.
Prior institutional employers are contacted. Questions regarding sexual abuse are
not asked. Could be accomplished at no additional cost and without legal
ramifications

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

$

2,500

$

140 Additional monitoring technology at 6 facilities and annual maintenance cost.

N

$

4

$

230

RP-2

Agreements with outside public entities and community
service providers

N

$

30

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Resident education

Y

TR-4

Specialized training: Investigations

N

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

Y

AP-2
RE*
RE-1

Y

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care

Y

$

-

$

-

Direct line from a facility to an outside entity

Y
N

$

3

Update PREA information material with new contacts.
Legal Division states In DYS is only allowed to relay that the matter has been
looked into

Y

Legal Division states In DYS is only allowed to relay that the matter has been
looked into

Y

General intake personnel are not qualified to question residents about prior sexual
victimization and abusiveness

N

MM-3
DC*
DC-1

Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

MM-2

Cost for external investigators, Correctional Peace Officers curriculum and
confinement-specific training material.

25

Y
N

RE-3

MM-1

$

Y

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-2

0.5 FTE at each facility to provide in-house advocate services
Cost to provide appropriate transitional services of residents through an outside
entity or office.

Y
N

$

750

Cost to provide on-going care and treatment of inmates.

Y

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 440 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-81

PREA Cost Impact Analysis
Massachusetts Department of Youth Services (MA DYS)
Sector

Juvenile

Title

MA DYS

Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity

57
88%
777
78%
22%
1,030

Percent Male Offenders

86%

Percent Female Offenders

14%

ADP

814

MA DYS, located in Boston, MA, operates 86 programs with
57 facilities, ranging from staff secure group homes to highly
secure locked units. There are 29 programs to service youth
who live in the community (residing with a parent, guardian,
foster parent or in an independent living program). Of their 57
facilities, 37 are contracted.
MA DYS is currently 88% compliant with the NPREC
standards. It is estimated that MA DYS will have a total
upfront cost of $933K and an annual cost of $574K, to reach
full compliance.

The largest cost estimated, which attributes to 99% of the total
Yes upfront cost, is a result of enhanced monitoring technology.
ACA Accredited?
$250.00 Currently, state facilities have video monitoring in place,
Cost of care / day
Yes however some private contract facilities do not. Of the 57
Unionized?
4
2008 Confirmed Incidents
secure residential program locations, only about 20 locations
5
2009 Confirmed Incidents
have video monitoring. In 2006, consults came to MA DYS to
$ 158,000,000 estimate the cost of installing or upgrading video surveillance.
Annual Operating Budget
The cost for the analysis alone was $10K, which covered approximately 20 locations. Based on this analysis, one
building that housed three to four programs had an estimated cost of approximately $63K to upgrade video
monitoring. A larger campus that housed more than four programs had a cost of over $115K. Based on these
assessments, an estimate was determined of $25K per program. Therefore, to equip the remaining 37 programs, an
upfront cost of 925K was estimated.
ADP/Capacity Percentage

79%

Booz Allen estimated a PREA triennial audit to cost $324K
annually, covering 57 facilities.
In order to ensure that investigations are conducted
appropriately, an annual cost of $178K and an upfront cost of
$2K were estimated. These costs are associated with hiring two
investigators in anticipation of increased reports to investigate.
According to the standard PP1, zero tolerance of sexual
abuse, MA DYS would require 1FTE to serve as PREA
Coordinator at an annual cost of $71K.

Cost Impacts
Assessment and Use of Monitoring Technology (PP7)
Audits of Standards (AU1)
Investigations (IN1 and IN3)
Zero Tolerance of Sexual Abuse (PP1)
Training and Education (TR1 - TR5)

Lastly, $5K was estimated to train investigators in confinement settings.

Appendix B - Site by Site Characteristics

B-82

PREA Cost Impact Analysis
Massachusetts Department of Youth Services

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.6%

0.4%

Upfront

Yearly
Maintenance

88%

$

932,992

$

573,570

N

$

1

$

71

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating residents with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

$

925

RP-2

Agreements with outside public entities and community
service providers

Y

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

Y

TR-2

Volunteer and contractor training

Y

TR-3

Resident education

Y

TR-4

Specialized training: Investigations

N

$

5

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

Y

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y
N

$

2

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*
MM-1

Y

MM-3
DC*
DC-1

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

PP-1

AP-2
RE*
RE-1
RE-2

MM-2

AU-1

Audits of standards

Explanation

Salary + benefits of 1 FTE at senior-level salary

Y

Cost to upgrade cameras at 37 facilities, $25K per facility

Y

Y

Cost to train 2 investigators, at $2.5K each

Y
Y
Y

Y

Y

$

178 LOE to send notification letters

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4324 person audit team labor, meals and incidentals, hotel, air fare, and mileage

Y

Y
Y
Y
Y

N

Appendix B - Site by Site Characteristics

B-83

PREA Cost Impact Analysis
Missouri Division of Youth Services (MO DYS)
Sector

Juvenile

Title

MO DYS
32

Total Facilities

78%

Percent PREA Compliant

921

Total Staff
Percent Male Staff

48%

Percent Female Staff

52%
801

Capacity
Percent Male Offenders

87%

Percent Female Offenders

13%
767

ADP

96%

ADP/Capacity Percentage
ACA Accredited?

N

Cost of care / day

$126.12
Y

Unionized?

2

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

N/A
60,000,000

MO DYS, located in Jefferson City, MO, operates residential
care facilities, community-based residential programs (group
homes under 24-hour supervision), moderately structured
facilities, and secure care. All facilities are direct supervision
where residents are under physical surveillance 24 hours/day.
MO DYS is currently 68% compliant with the NPREC
standards. It is estimated that MO DYS will have a total
upfront cost of $103K and an annual cost of $310K, to reach
full compliance.
Booz Allen estimated a PREA triennial audit to cost $182K
annually, covering 32 facilities.
According to the standard PP1, zero tolerance of sexual
abuse, MO DYS would require 1FTE to serve as PREA
Coordinator at an annual cost of $101K. MO DYS however,
does not feel that a stand-alone PREA Coordinator is required
for their operating model and philosophy whereby many of the
PREA Coordinator duties and roles are performed by all

management and supervision staff.
To ensure that all employees are trained according to the NPREC
requirements an upfront cost of $95K and an annual cost of $24K
would be incurred. These costs include providing an additional four
hours of training and one hour for refresher material. Smaller upfront
costs of $1K and $2K were estimated to ensure training for contractors
and volunteers and medical/mental health care practitioners.

Appendix B - Site by Site Characteristics

Cost Impacts
Audits of Standards (AU1)
Zero Tolerance of Sexual Abuse (PP1)
Training and Education (TR1 - TR5)

B-84

PREA Cost Impact Analysis

Missouri Division of Youth Services

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.2%

0.5%

Upfront

Yearly
Maintenance

78%

$

102,792

$

310,312

N

$

1

$

101

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating residents with special needs

Y

PP-1

PP-6

Hiring and promotion decisions

N

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

Y

RP-2

Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

Y

TR-2

Volunteer and contractor training

N

TR-3

Resident education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*
AP-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting
Residents reporting

N

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

N

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*
MM-1

Y

MM-3
DC*
DC-1

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care
Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

RE-2

MM-2

Salary + benefits of 1 FTE at senior-level salary

Y

Per Booz Allen, the fee associated with criminal background check assumed to be
3 $50. Fee includes access to government sources and an internal LOE. MO DYS
has 60 promotions

$

AP-2
RE*
RE-1

Explanation

Y
MOU not in place for these services, can be done at minimal costs

24

Additional 4 hours of required training for all employees and annual cost to provide
1 hour refresher cost

$

95

$

$

1

$

$

2

Initial 4 hours of additional training for medical and mental health professionals.

$

4

Cost to obtain available materials from MO Dept of Social Services and place them
throughout the facilities.

-

Additional 2 hours of required training to all volunteers and contractors.

Y
Y
Y

Y
Policy update, no cost impact

Y

Y

N

Policy update, no cost impact

Y
Y
Y

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4182 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-85

PREA Cost Impact Analysis
Oregon Youth Authority (OYA)
Sector

Juvenile

Title

OYA
11

Total Facilities

63%

Percent PREA Compliant

1,101

Total Staff
Percent Male Staff

62%

Percent Female Staff

38%
900

Capacity
Percent Male Offenders

89%

Percent Female Offenders

11%
890

ADP

99%

ADP/Capacity Percentage
ACA Accredited?

Yes

Cost of care / day

$219.00
Yes

Unionized?

26

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

6
79,833,022

OYA, located in Salem, OR, incarcerates youth who cannot
safely live in the community, and provides supervision and
treatment opportunities to offenders in all 36 counties. OYA
exercises legal and physical custody over youth offenders who
commit offenses between the ages of 12 and 18 and have been
committed by the courts. Offenders may remain in OYA's
legal and physical custody up to age 25.
OYA is currently 63% compliant with the NPREC standards.
It is estimated that OYA will have a total upfront cost of
$4.1M and an annual cost of $473K, to reach full compliance.
An upfront cost of $4M and an annual cost of $58K were
estimated for the enhancement of the monitoring technology.
Video equipment was recently purchased using federal grant
money. However, additional cameras are required to monitor
many uncovered areas. An additional FTE at $58K will also
be required to monitor the cameras.

In order to ensure that investigations are conducted
effectively, an annual cost of $227K and an upfront cost of $3K were estimated. These costs are associated with
hiring three investigators in anticipation of more sexual abuse reports as a result of PREA.
An upfront cost of $129K and an annual cost of $35K were estimate
for enhanced training. Costs are for ensuring that contractors and
medical/mental health care practitioners receive training via
classroom and web based programs.
According to the standard PP1, zero tolerance of sexual abuse, OYA
would require 1FTE to serve as PREA Coordinator at an annual cost
of $92K.
Booz Allen estimated a PREA triennial audit to cost $62K annually,
covering 11 facilities.

Appendix B - Site by Site Characteristics

Cost Impacts
Assessment and Use of Monitoring
Technology (PP7)
Investigations (IN1 and IN3)
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

B-86

PREA Cost Impact Analysis
Oregon Youth Authority

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

5.2%

0.6%

Upfront

Yearly
Maintenance

Explanation

63%

$

4,138,287

$

473,209

N

$

1

$

92

Salary + benefits of 1 FTE at senior-level salary

PP-2

Zero tolerance of sexual abuse
Contracting with facilities for the confinement of
residents

PP-3

Resident supervision

Y

PP-4

Limits to cross-gender viewing and searches

Y

PP-5

Accommodating residents with special needs

Y

PP-6

Hiring and promotion decisions

Y

PP-7
RP*
RP-1

Assessment and use of monitoring technology
Response Planning
Evidence protocol and forensic medical exams

N

$

4,000

$

58

Cost of purchasing and installing cameras and 1 FTE to support the additional
monitoring.

RP-2

Agreements with outside public entities and community
service providers

Y

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Resident education

Y

TR-4

Specialized training: Investigations

N

TR-5
SC*

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and

N

PP-1

Y

Y

$

124

$

$

9

$

Currently developing a refresher training program and can be provided at no
additional cost.
Cost for the development of classroom based training and for developing a
30
computer based module for contractors
A training program is currently under development. No cost impact
5

Cost to provide medical care staff with training

N

AP-2
RE*

Obtaining information about residents
Placement of residents in housing, bed, program,
education, and work assignments
Reporting

Residents are not screened to this standard. OYA has access to the State of WA
SAVY screening tool and believes this can be used at no additional cost.

N

The WA SAVY screening tool can be used to comply at no additional cost.

RE-1

Residents reporting

N

Will use phone systems that will permit the reporting of sexual abuse without staff
assistance, can be provided at no additional cost.

RE-2

Y

RE-3

Exhaustion of administrative remedies
Resident access to outside support services and legal
representation

RE-4
OR*
OR-1

AP-1

N

Access to outside victim advocate services is not readily available. Have identified
providers and no additional cost

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

Currently under-staffed for investigators, cost covered under IN-1.

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Interventions for residents who engage in sexual abuse
Medical and Mental Health Care

Y

MM-1

Y

N

3

$

227 3 FTE investigators

Y

It is mandatory for all staff to report sexual abuse, independent of whether or not
there is consent.

N

MM-3
DC*
DC-1

Medical and mental health intake screenings
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

MM-2

Does not track the conduct and treatment of offenders.
$

Y
Y
Y

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 462 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-87

PREA Cost Impact Analysis

Community Corrections
AR Department of Community Corrections (AR DCC)
Sector

Community
Corrections

Title

AR DCC

Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage

6
66%
577
58%
42%
1,615
72%
28%
1,566
97%

ACA Accredited?

Yes

Cost of care / day

$53.01

AR DCC, located in Little Rock, AR, operates two major
components -- probation and parole community supervision
services and residential services, both of which are supported
by the central administration and are included in this report.
For probation and parole, there are 52 probation and parole
offices serving 75 Arkansas counties and 5 Day Reporting
Centers. For residential services, AR DCC operates six
community-based residential centers, three of which house
technical violator programs.
AR DCC is currently 66% compliant with the NPREC
standards. It is estimated that AR DCC will have a total
upfront cost of $49K and an annual cost of $2M, to reach full
compliance.

The greatest cost impact to AR DCC as a result of the NPREC
standards is the prohibition of cross-gender pat searches.
1
2008 Confirmed Incidents
Without violating state statute, the only means to comply with
3
2009 Confirmed Incidents
$ 31,249,659 this standard would be to redeploy staff among the six
Annual Operating Budget
facilities (e.g., moving female officers from male facilities to
female facilities) and hire more male staff in the male facilities to get the staffing gender ratio closer to the offender
gender ratio. This strategy results in a redeployment of 12 female staff and a net impact on their budget of $1.8M for
50 additional male staff. In order to ensure enough male applicants are available, AR DCC assumes an average 33%
increase in salaries because the local labor pool simply does not provide enough qualified male applicants. In
addition, there are a couple one-time costs associated with hiring additional staff, that result in an upfront cost of
$48K.
Unionized?

No

According to the standard PP1, zero tolerance of sexual abuse,
Marion County would require 1FTE to serve as PREA
Coordinator at an annual cost of $107K.
Booz Allen estimated a PREA triennial audit to cost $40K
annually, covering 6 facilities.

Appendix B - Site by Site Characteristics

Cost Impacts

Limits to Cross-Gender Viewing and Searches (PP4)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

B-88

PREA Cost Impact Analysis
Arkansas Department of Community Corrections

Cost Impact

Percent of Annual Operating Budget
ID

PP-1

Standard Addressed

PP-2

Zero tolerance of sexual abuse
Contracting to house or supervise
defendants/offenders under community corrections
authority

PP-3

Defendant/offender supervision

PP-4

Limits to cross-gender viewing and searches
Accommodating defendants/offenders with special
needs

PP-5

0.2%
Compliant?

6.4%

Upfront

Yearly
Maintenance
$
1,996,503

66%

$

48,592

N

$

1

$

107

$

48

$

1,800

Salary + benefits of 1 FTE at senior-level salary

Y
Y
N

Per Booz Allen, 12 staff replacement at Central Arkansas Center will be offset by 11
staff at Southeast Center . Additional 50 FTE's needed

Y
Prior institutional employers are contacted. Questions regarding sexual abuse are
not asked. Could be accomplished at no additional cost and without legal
ramifications

N
PP-6
RP*
RP-1

Explanation

RP-2

Hiring and promotion decisions
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

Y

RP-4
TR*
TR-1

Agreements with the prosecuting authority
Training and Education
Employee training

N

Requires minimal training modifications with no cost impact

TR-2

Volunteer and contractor training

N

Requires minimal training modifications with no cost impact

TR-3

Defendant/offender education

Y

TR-4

Specialized training: Investigations

Y

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Defendant/offender reporting

Y

RE-2

Y

RE-3

Exhaustion of administrative remedies
Defendant/offender access to outside confidential
support services

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

N

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*

Agency protection against retaliation
Investigations

N

Policy could be changed to require this monitoring

IN-1

Duty to investigate

N

State police provide written notice of outcomes but it does not include disciplinary or
criminal sanctions. No cost impact associated

IN-2

Criminal and administrative agency investigations

Y

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-2
DC*
DC-1

Disciplinary sanctions for defendants/offenders
Medical and Mental Health Care
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

MM-1

AU-1

Audits of standards

Y
Costs associated with entering into such an agreement will probably be part of the
duties assigned to the full-time PREA Coordinator.

Y

N

Screening instrument requires modest changes with no cost impact

Y
Contacts made with the local Rape Crisis Center found they were willing to provide
these services at no cost to AR DCC
Do not notify 3rd party or victim of outcome in writing. Policy could be amended at no
additional cost

N

Y

Y

Y
Y
Y

N

Appendix B - Site by Site Characteristics

Cost is captured in PREA Coordinators salary under PP-1

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 440 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-89

PREA Cost Impact Analysis
Indiana Division of Re-entry (IN DOR)
Sector

Community
Corrections

Title

IN DOR
NA

Total Facilities

48%

Percent PREA Compliant

644

Total Staff

44%

Percent Male Staff

56%

Percent Female Staff

31,549

Capacity

80%

Percent Male Offenders

20%

Percent Female Offenders

31,522

ADP

100%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$3.15

Unionized?

No

2008 Confirmed Incidents

-

2009 Confirmed Incidents
Annual Operating Budget

$

1
40,868,000

IN DOR, located in Indianapolis, IN, is a division of IN DOC
and serves as a pass through of financial support to the county
run work release centers, and also manages the division of
parole services. In Indiana, 77 out of 92 counties participate in
community corrections. Programs offered by county
community corrections include work release centers, day
reporting centers, home detention, and other diversion
programs. Of the 77 participating counties, 41 operate work
release centers. Probation services in Indiana are not a
responsibility of IN DOR, they are a function of the judicial
branch of the state government. For this study, cost estimates
were provided from the division of parole services and four
work release centers. The work release centers represented
Marion County, Bartholomew County, Tippecanoe County,
and Clark County.
IN DOR is currently 48% compliant with the NPREC
standards. It is estimated that IN DOR will have a total upfront
cost of $33K and an annual cost of $50K, to reach full

compliance.
An upfront cost of $11K and annual cost of $11K were estimated to ensure employee training for the four work
release centers, which includes the instructor’s travel, LOE, and materials. An upfront cost of $1K was estimated to
provide volunteer training at the work release centers and an upfront cost of $20K was estimated to modify the
offender handbook. Parole agents within IN DOR get the same intake and in-service training as IN DOC, which is a
two hour initial PREA session and a one hour refresher class, no additional cost.
According to the standard PP1, zero tolerance of sexual abuse, IN
DOR would require 1FTE to serve as PREA Coordinator at an annual
cost of $33K. This position would ensure the PREA compliance of the
county run work release centers and parole services.
Booz Allen estimated a PREA triennial audit to cost $6K annually.

Appendix B - Site by Site Characteristics

Cost Impacts
Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

B-90

PREA Cost Impact Analysis
Indiana Division of Re-entry

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.1%
Compliant?

0.1%

Upfront

Yearly
Maintenance
$
50,252

Explanation

48%

$

33,192

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting to house or supervise
defendants/offenders under community corrections
authority

PP-3

Defendant/offender supervision

Y

PP-4
PP-5

Limits to cross-gender viewing and searches
Accommodating defendants/offenders with special
needs

Y

PP-6

Hiring and promotion decisions

Y

RP-1
RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

N

RP-4

Agreements with the prosecuting authority

Y

TR-1

Employee training

N

$

11

$

TR-2

Volunteer and contractor training

N

$

1

$

TR-3

Defendant/offender education

N

$

20

TR-4

Specialized training: Investigations

Y

TR-5

Specialized training: Medical and mental health care

Y

SC-1

Screening for risk of victimization and abusiveness

SC-2

Use of screening information

RE-1

Defendant/offender reporting

RE-2
RE-3

Exhaustion of administrative remedies
Defendant/offender access to outside confidential
support services

RE-4

Third-party reporting

OR-1

Staff and facility head reporting duties

Cost and compliance not provided from Work Release Centers

OR-2

Reporting to other confinement facilities

Cost and compliance not provided from Work Release Centers

OR-3

Staff first responder duties

Cost and compliance not provided from Work Release Centers

OR-4

Coordinated response

Cost and compliance not provided from Work Release Centers

OR-5

Agency protection against retaliation

IN-1

Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Cost and compliance not provided from Work Release Centers

DI-2

Disciplinary sanctions for defendants/offenders

Cost and compliance not provided from Work Release Centers

PP-1

Booz Allen assumes Work Release centers can implement this process under the
guidance of the IN DOC at no additional cost
Do no have any agreements in place, could be referred to Life Springs or another
mental health agency of their choosing at no additional cost

N
N
$

-

Minimal cost to develop an MOU with State Police

11 Cost includes materials and yearly fee for instructor time and travel
-

Cost to provide training at work release centers
Cost to develop and modify offender handbook

Booz Allen assumes Work Release centers can use the instrument from the IN
DOC at no additional cost
Booz Allen assumes Work Release centers can implement this process under the
guidance of the IN DOC at no additional cost

N
N
Y
Y
N

$

1

Cost to provide posters and pamphlets on victim advocate services

Y

Cost and compliance not provided from Work Release Centers

DC-1

Sexual abuse incident reviews

N

DC-2

Data Collection

N

DC-3

Data review for corrective action

N

DC-4

Data storage, publication, and destruction

N

Audits of standards

Salary + benefits of 1 FTE at senior-level salary

Y

MM-2

AU-1

33

N

Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

MM-1

$

Y
Y

N

Appendix B - Site by Site Characteristics

Due to low level of incidents could develop a team at no additional cost
Very few incidents, however,if needed to report to Board of Directors could do so at
no additional cost
Have not had sufficient data to analyze due to low number of incidents
Do not have any data, however it would be printed out and kept in a locked cabinet
behind a locked door.

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 46 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-91

PREA Cost Impact Analysis
Massachusetts Office of Community Corrections (MA OCC)
Sector
Title
Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity
Percent Male Offenders
Percent Female Offenders
ADP
ADP/Capacity Percentage
ACA Accredited?
Cost of care / day
Unionized?
2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

Community
Corrections
MA OCC
21
74%
275
70%
30%
1,500
83%
17%
1,220
81%

$

0
0
159,971,922

MA OCC, located in Braintree, MA, is responsible for the
oversight of 26 contracted Community Correction Centers. In
the early 1990's the Commonwealth of Massachusetts began
an initiative to provide more effective and efficient criminal
justice sentencing and specifically address prison
overcrowding. As a result, the Office of Community
Corrections was established in 1996 by virtue of
Massachusetts General Law chapter 211F. MA OCC is a
division of the Office of the Commissioner of Probation,
responsible for the oversight and funding of the CCCs. MA
OCC, does not confine inmates, is not institutional in nature,
and does not have legal custody of offenders. For the purposes
of this study, Booz Allen is only capturing the cost impact on
MA OCC’s 21 CCCs.
MA OCC is currently 74% compliant with the NPREC
standards. It is estimated that MA OCC will have a total
upfront cost of $129K and an annual cost of $119K, to reach
full compliance.

Booz Allen estimated an upfront cost of $128K and an annual cost of $123K were determined to meet the NPREC
standards on training.
Booz Allen estimated a PREA triennial audit to cost $119K annually,
covering 26 facilities.
According to the standard PP1, zero tolerance of sexual abuse, MA
OCC would require 1FTE to serve as PREA Coordinator at an annual
cost of $73K.

Appendix B - Site by Site Characteristics

Cost Impacts
Training and Education (TR1 - TR5)
Audits of Standards (AU1)
Zero Tolerance of Sexual Abuse (PP1)

B-92

PREA Cost Impact Analysis

Massachusettes Office of Community Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.1%

0.2%

Upfront

Yearly
Maintenance

Explanation

74%

$

129,441

$

315,165

N

$

1

$

73

PP-2

Zero tolerance of sexual abuse
Contracting to house or supervise
defendants/offenders under community corrections
authority

PP-3

Defendant/offender supervision

Y

PP-4

Y

PP-5

Limits to cross-gender viewing and searches
Accommodating defendants/offenders with special
needs

PP-6

Hiring and promotion decisions

N

RP-1

Y

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4

Agreements with the prosecuting authority

Y

TR-1

Employee training

N

$

112

$

TR-2

Volunteer and contractor training

N

$

11

$

3 Cost to update materials and implement training for volunteers

TR-3

Defendant/offender education

N

$

5

$

1 Cost of training materials and staff time

TR-4

Specialized training: Investigations

Y

TR-5

Specialized training: Medical and mental health care

Y

SC-1

Screening for risk of victimization and abusiveness

Y

SC-2

Use of screening information

Y

RE-1

Defendant/offender reporting

Y

RE-2

Y

RE-3

Exhaustion of administrative remedies
Defendant/offender access to outside confidential
support services

RE-4

Third-party reporting

Y

OR-1

Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

Y

IN-1

Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Y

DI-2

Disciplinary sanctions for defendants/offenders

Y

PP-1

Salary + benefits of 1 FTE at senior-level salary

Y

Y
MA OCC has very few promotions,can be completed at no additional cost

Y

119 Cost of updating materials and additional staff time to implement training.

Y

MM-2

Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

DC-1

Sexual abuse incident reviews

N

Incidents are infrequent and therefore there is no cost.

DC-2

Data Collection

N

Incidents are infrequent and therefore there is no cost.

DC-3

Data review for corrective action

N

Incidents are infrequent and therefore there is no cost.

DC-4

Data storage, publication, and destruction

N

Incidents are infrequent and therefore there is no cost.

MM-1

AU-1

Audits of standards

Y
Y

N

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 4119 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-93

PREA Cost Impact Analysis
Missouri Division of Parole and Probation (MO PP)
Sector

Community
Corrections

Title

MO PP

Total Facilities
Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity

8
61%
288
55%
24%
1,110

Percent Male Offenders

89%

Percent Female Offenders

12%

ADP
ADP/Capacity Percentage
ACA Accredited?

914
82%
No

MO PP, located in Jefferson City, MO, oversees all aspects of
Community Release/Supervision Centers and community
based programs such as electronic monitoring; contract
residential facilities; outpatient substance abuse treatment;
mental health treatment; employment services; cognitive skills
development classes, sex offender treatment and registration,
and day reporting centers. Organizationally, MO PP is
integrated with MO DOC and many resources are and can be
shared.
MO PP is currently 61% compliant with the NPREC
standards. It is estimated that MO PP will have a total upfront
cost of $46K and an annual cost of $1.8M, to reach full
compliance.

MO PP currently does not prohibit cross-gender pat
searches. In order to comply, additional male staff would need
2008 Confirmed Incidents
to be hired to balance the staff to offender gender ratio. MO
2009 Confirmed Incidents
PP is hesitant to conduct work force realignment or replace
$ 12,565,316
Annual Operating Budget
female staff due to EEOC issues stemming from genderspecific posts and/or discriminatory practices. However, all of the Community Supervision Centers (CSC) and
Community Release Centers (CRC) serve both male and female offenders. MO PP would require additional FTE
authority (three per shift at the CRC and one per shift at the CSC). An annual cost of $1.7M and an upfront cost of
$34K are estimated for an additional 36 FTE's.
Cost of care / day
Unionized?

$40.07
Yes

According to the standard PP1, zero tolerance of sexual abuse, MO PP would require 1FTE to serve as PREA
Coordinator at an annual cost of $71K. Leveraging their current unified model however, they suggest a hybrid
approach with one central Zero tolerance of sexual abuse supported by two part time assistants; one for prisons and
one for probation and parole.
Booz Allen estimated a PREA triennial audit to cost $45K annually, covering 8 facilities.
MO PP contracts for the confinement of 244 offenders with five facilities. Booz Allen estimates an annual cost of
$23K to comply with NPREC standard PP2. This estimate is a percentage of total yearly cost based on number of
contracted inmates.
Comprehensive training and education on sexual abuse is provided to offenders during the intake process at
residential facilities only, excluding probation and
Cost Impacts
parole. Extending this training to all offenders in
probation and parole is estimated to cost $2K per
Limits to Cross-Gender Viewing and Searches (PP4)
year and an upfront cost of $5K. Integrated with MO
Zero Tolerance of Sexual Abuse (PP1)
DOC, all state investigators receive 40 to 80 hours of
Audits of Standards (AU1)
Contracting for the Confinement of Inmates (PP2)
training, including training specific to conducting
Training and Education (TR1 - TR5)
investigations in a confinement setting. They do not
Contract Modifications for Outside Services (RP2 - RP4 and RE3)
however, receive comprehensive training on sexual
abuse which can be added at an annual cost of $3K.
An upfront cost of $3K was estimated to identify and post information for victim advocate outside services.

Appendix B - Site by Site Characteristics

B-94

PREA Cost Impact Analysis
Missouri Division of Parole and Probation

Cost Impact

Percent of Annual Operating Budget
ID

PP-1

Standard Addressed

PP-2

Zero tolerance of sexual abuse
Contracting to house or supervise
defendants/offenders under community corrections
authority

PP-3

Defendant/offender supervision

PP-4

Limits to cross-gender viewing and searches
Accommodating defendants/offenders with special
needs

PP-5

PP-6
RP*
RP-1

0.4%
Compliant?

14.3%

Upfront

61%

$

46,670

N

$

1

N

$

34

Explanation

$

71

$

23 Booz Allen estimates the cost to be a percentage of total yearly based on number of
contracted inmates = 244

N
Y
$

Salary + benefits of 1 FTE at senior-level salary

1,700 Cost to hire an additional 36 Male FTE's to supplement current staff

Y
Prior institutional employers are contacted. Questions regarding sexual abuse are
not asked. Could be accomplished at no additional cost and without legal
ramifications

N

RP-2

Hiring and promotion decisions
Response Planning
Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

N

RP-4
TR*

Agreements with the prosecuting authority
Training and Education

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Defendant/offender education

N

$

5

TR-4

Specialized training: Investigations

N

$

3

TR-5
SC*
SC-1

Specialized training: Medical and mental health care
Screening for Risk of Sexual Victimization and
Screening for risk of victimization and abusiveness

Y

SC-2
RE*
RE-1

Use of screening information
Reporting
Defendant/offender reporting

Y

RE-2

Y

RE-3

Exhaustion of administrative remedies
Defendant/offender access to outside confidential
support services

$

3

RE-4
OR*
OR-1

Third-party reporting
Official Reponse Following an Inmate Report
Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5
IN*
IN-1

Agency protection against retaliation
Investigations
Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

N

IN-3
DI*
DI-1

Evidence standard for administrative investigations
Discipline
Disciplinary sanctions for staff

Y

DI-2
MM*

Y

MM-2
DC*
DC-1

Disciplinary sanctions for defendants/offenders
Medical and Mental Health Care
Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers
Data Collection and Review
Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4
AU*

Data storage, publication, and destruction
Audits

Y

AU-1

Audits of standards

N

MM-1

Yearly
Maintenance
$
1,796,099

$

N

-

Cost for an agency employee not assigned to the facility
Costs associated with entering into such an agreement will probably be part of the
duties assigned to the full-time PREA Coordinator.
Criminal investigations are conducted internally by MO DOC investigators. No cost
is expected.

N

PREA content is an option but not mandated in refresher training. Would be no
additional cost to agency
No cost associated, contractors are spread throughout the state and many receive
no direct compensation from the agency
$

2

Training does not cover offenders in Probation & Parole
Sexual abuse training is not comprehensive enough for investigators

Y

Y

N

Cost to provide a victim advocate to offenders.

Y

Y
Additional training is needed. Cost reflected in TR-4

Y

Y
Y

Appendix B - Site by Site Characteristics

Policy modification to include multi-disciplined team, at no additional cost

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 445 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-95

PREA Cost Impact Analysis
South Carolina Department of Probation, Parole and Pardon Services (SC PPP)
Sector

Community
Corrections

Title

SC PPP
NA

Total Facilities

63%

Percent PREA Compliant

644

Total Staff

44%

Percent Male Staff

56%

Percent Female Staff

31,549

Capacity

80%

Percent Male Offenders

20%

Percent Female Offenders

31,522

ADP

100%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$3.15
No

Unionized?

-

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

1
40,868,000

SC PPP, located in Columbia, SC, is composed of three
divisions. The Field Operations Division supervises offenders
through 46 county offices and four satellite offices. The
Administrative Services Division is responsible for oversight
of training compliance, professional development, fiscal and
materials management, budget services, and information
technology systems and services. The Legal Services Division
addresses all legal matters, interprets policies, and advises
management on issues that have legal implications to the
Department. SC PPP oversees 31,552 offenders with 644
probation and parole officers.
SC PPP is currently 66% compliant with the NPREC
standards. It is estimated that SC PPP will have a total upfront
cost of $53K and an annual cost of $88K, to reach full
compliance.
According to the standard PP1, zero tolerance of sexual
abuse, SC PPP would require 1FTE to serve as PREA
Coordinator at an annual cost of $78K.

An upfront cost of $43K was estimated to implement training for 768 employees. This estimate includes the cost of
external trainers, travel, and material development. Similarly, it would
cost $6K to conduct training for volunteers and $2K for specialized
Cost Impacts
investigator training in upfront costs. Updates to the offender handbook
Zero Tolerance of Sexual Abuse (PP1)
which would serve as informative and refresher training for offenders,
Training and Education (TR1 - TR5)
were estimated to cost $2K annually.
Audits of Standards (AU1)

Booz Allen estimated a PREA triennial audit to cost $6K annually.

Appendix B - Site by Site Characteristics

B-96

PREA Cost Impact Analysis
South Carolina Probation, Parole and Pardon Services

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.1%
Compliant?

0.2%

Upfront

Yearly
Maintenance
$
88,170

Explanation

63%

$

52,655

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting to house or supervise
defendants/offenders under community corrections
authority

PP-3

Defendant/offender supervision

Y

PP-4

Y

PP-5

Limits to cross-gender viewing and searches
Accommodating defendants/offenders with special
needs

N

PP-6

Hiring and promotion decisions

Y

RP-1

Y

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

RP-3

Agreements with outside law enforcement agencies

Y

RP-4

Agreements with the prosecuting authority

Y

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Defendant/offender education

N

TR-4

Specialized training: Investigations

N

TR-5

Specialized training: Medical and mental health care

Y

SC-1

Screening for risk of victimization and abusiveness

Y

SC-2

Use of screening information

Y

RE-1

Defendant/offender reporting

Y

RE-2

Y

RE-3

Exhaustion of administrative remedies
Defendant/offender access to outside confidential
support services

RE-4

Third-party reporting

N

Cost to modifying existing offender handbook. Cost is covered under TR-3

OR-1

Staff and facility head reporting duties

N

Section 44-23-1150 of the SC Code already mandates zero tolerance towards all
forms of sexual abuse. No cost impact to update policy

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

N

IN-1

Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

N

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Y

DI-2

Disciplinary sanctions for defendants/offenders

Y

PP-1

$

78

Salary + benefits of 1 FTE at senior-level salary
SC PPP will develop contract language to comply with PREA standards at no
additional cost

N

$

1

Cost to contract out for interpretive services when needed.

Y

$

43

$

$

6

$

$

2

$

-

Cost to develop and implement training for 768 employees, including a one time
upfront cost of hiring an independent consultant to conduct the training
Cost to develop and implement training for volunteers, including a one time upfront
2
cost of hiring an independent consultant to conduct the training
2 Cost to modify existing offender handbook
Cost to develop and implement training for investigators, including a one time
upfront cost of hiring an independent consultant to conduct the training

Y

Plans to modify existing policies to the extent necessary to comply with PREA
standards, at no additional cost

Cost for developing this training is covered under TR-4

MM-2

Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

DC-1

Sexual abuse incident reviews

Y

DC-2

Data Collection

N

Cost is captured in PREA Coordinators salary under PP-1

DC-3

Data review for corrective action

N

Cost is captured in PREA Coordinators salary under PP-1

DC-4

Data storage, publication, and destruction

Y

AU-1

Audits of standards

N

MM-1

Y
Y

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 46 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-97

PREA Cost Impact Analysis
Washington Department of Corrections- Community Corrections (WA CC)
Sector

Community
Corrections

Title

WA CC

Total Facilities

162 field offices

Percent PREA Compliant
Total Staff
Percent Male Staff
Percent Female Staff
Capacity

47%
967
54%
46%
19,293

Percent Male Offenders

84%

Percent Female Offenders

16%

ADP

NA

ADP/Capacity Percentage

NA

ACA Accredited?

Yes

Cost of care / day

$15.00

WA CC, located in Tumwater, Washington, is an agency
within the Department of Corrections. The WA CC oversees
162 field offices who manage the 19,293 offenders. WA CC
transitions offenders into society through community based
supervision, not using parole. For the purposes of this study,
Booz Allen has captured the costs for the WA CC separately
from the WA DOC.
WA CC is currently 50% compliant with the NPREC
standards. It is estimated that WA CC will have a total upfront
cost of $183K and an annual cost of $1.3M, to reach full
compliance.
An annual cost of $884K was estimated for one additional FTE
at 13 work release centers to increase inmate supervision.

WA CC has recently learned that contracting with an outside
service provider is now possible, so long as the provider does
6
2008 Confirmed Incidents
not receive VOCA funding. An annual cost $79K was
3
2009 Confirmed Incidents
$ 114,651,997 estimated to establish and maintain MOUs with outside victim
Annual Operating Budget
advocate service providers. An annual cost of $24K was
estimated to develop and maintain MOUs with the 39 county local law enforcement agencies to ensure
investigations were conducted. In addition, an annual cost of $24K was estimated to develop an MOU with these
counties to ensure all substantiated cases of sexual abuses were prosecuted.
Unionized?

Yes

According to the standard PP1, zero tolerance of sexual abuse, WA CC. would require 1FTE to serve as PREA
Coordinator at an annual cost of $113K.
Booz Allen estimated a PREA triennial audit to cost $85K annually, covering 15 work release centers.
In order to ensure compliance with the NPREC training standards, an upfront cost of $27K was estimated for
updating materials and additional LOE to implement training for employees. An annual cost of $20K was estimated
to update training materials for contractors and volunteers. Also, a two day training session for investigators in
confinement settings was estimated to cost $20K, which included the development of a new curriculum and staff
time.
WA CC screens offenders during intake and for all transfers but not during every classification review. Upfront
costs of $11K and $54K were estimated to
Cost Impacts
develop an instrument and train custody staff on
how to screen and interpret along with an
Inmate Supervision (PP3)
upgrade to the information system.
Contract Modifications and/or Policy Updates (RP2 - RP4 and RE3)
WA CC gathers, reviews and reports on sexual
abuse however, they do not consider racial
dynamics. An upfront cost of $50K was
estimated to update the Sierra database to include
this variable and an annual cost of $1K to create
a review team of upper management officials.

Appendix B - Site by Site Characteristics

Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)
Training and Education (TR1 - TR5)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Gathering, Reviewing and Reporting Data (DC1 - DC4)

B-98

PREA Cost Impact Analysis

Washington Community Corrections

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.2%
Compliant?

1.1%

Upfront

47%

$

183,465

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting to house or supervise
defendants/offenders under community corrections
authority

PP-3

Defendant/offender supervision

N

PP-4

Y

PP-5

Limits to cross-gender viewing and searches
Accommodating defendants/offenders with special
needs

N

PP-6

Hiring and promotion decisions

N

RP-1

Y

RP-2

Evidence protocol and forensic medical exams
Agreements with outside public entities and community
service providers

N

RP-3

Agreements with outside law enforcement agencies

RP-4

Agreements with the prosecuting authority

TR-1

Employee training

N

TR-2

Volunteer and contractor training

N

TR-3

Defendant/offender education

N

TR-4

Specialized training: Investigations

N

TR-5

Specialized training: Medical and mental health care

Y

SC-1

Screening for risk of victimization and abusiveness

SC-2

Use of screening information

RE-1

Defendant/offender reporting

Y

RE-2

N

RE-3

Exhaustion of administrative remedies
Defendant/offender access to outside confidential
support services

RE-4

Third-party reporting

Y

OR-1

Staff and facility head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

N

IN-1

Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Disciplinary sanctions for staff

Y

DI-2

Disciplinary sanctions for defendants/offenders

N

PP-1

Yearly
Maintenance
$
1,266,896
$
$

N
$

16

$

2

$

$

MM-1
MM-2

Access to emergency medical and mental health
services
Ongoing medical and mental health care for sexual
abuse victims and abusers

34 Contracts for 13 out of the 15 work release centers. Booz Allen estimates the cost
to be a percentage of total yearly based on number of contracted offenders = 688
884 1 FTE for each of the 13 work release centers

Cost to translate posters and brochures into multiple languages
Per Booz Allen, the fee associated with criminal background check assumed to be
3 $50. Fee includes access to government sources and an internal LOE. WA CC has
62 promotions

Cost to develop an MOU to establish and maintain services with an outside victim
advocacy agency.

79

N

$

24 MOUs with the 39 county local law enforcement agencies.

N

$

24 MOUs with the 39 county District Attorney's office

$

27

Cost of updating materials and additional staff time to implement training.
Required to update materials, at no additional cost
$

20 Cost of training materials and staff time.

$

20

Curriculum development, materials, and labor hours for two days of training.

N

$

11

Cost to develop instrument and train custody staff on how to screen and interpret

N

$

54

Cost to complete upgrades to information system and train staff

N

Grievance process lasts for 90 days, could not meet the 48 hour requirement
$

4

Cost to publish posters and brochures

Agency does not monitor inmates after a sexual abuse incident.

Policy update, no cost impact

Y
Y

Sexual abuse incident reviews

Y

DC-2

Data Collection

Y

DC-3

Data review for corrective action

N

DC-4

Data storage, publication, and destruction

Y

Audits of standards

Salary + benefits of 1 FTE at senior-level salary

$

DC-1

AU-1

113

Explanation

N

Appendix B - Site by Site Characteristics

$
$

Booz Allen estimates a review team of upper management officials to consist of 4
senior-level staff and 1 junior analyst. Cost to conduct one-hour review with these 5
1 officials was based on the number of confirmed sexual abuse incidents.
Cost for updating database to include racial dynamics

50

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
internal LOE to support the audit process. Assumed an auditor’s fee will include 485 person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-99

PREA Cost Impact Analysis

Lockups
Denver County Pre-Arraignment Facility (DCPA)
Sector

Lockups

Title

DCPA
1

Total Facilities

73%

Percent PREA Compliant

145

Total Staff
Percent Male Staff

71%

Percent Female Staff

29%
158

Capacity
Percent Male Offenders

86%

Percent Female Offenders

15%
231

ADP

146%

ADP/Capacity Percentage
ACA Accredited?

No

Cost of care / day

$66.40
Yes

Unionized?

2

2008 Confirmed Incidents
2009 Confirmed Incidents

$19,484,534.00

DCPA, located in Denver County, operates under the Denver
Sheriff’s Department, which also has the Denver County Jail
in its jurisdiction. The DCPA is a short term holding facility
that does not share the administration or operations of the
Denver County Jail. However, the two facilities are merging
and DCPA will be physically housed in conjunction with
Denver County Jail.
DCPA is currently 68% compliant with the NPREC standards.
It is estimated that DCPA will have a total upfront cost of
$71K and an annual cost of $445K, to reach full compliance.
An upfront cost of $64K and an annual cost of $16K were
estimated for DCPA to add PREA training on top of the
facilities mandatory 40 hours of training. All pre-service
personnel would be provided with 4 hours of PREA training,
and a one hour annual refresher course. Volunteers would
receive written information pertaining to PREA.

According
to
the
standard PP1, zero tolerance of sexual abuse, Marion County
would require 0.5PTE to serve as PREA Coordinator at an
annual cost of $57K.
Annual Operating Budget

Booz Allen estimated a PREA triennial audit to cost $3K
annually.

Appendix B - Site by Site Characteristics

Cost Impacts
Limits to Cross-Gender Viewing and Searches
(PP4)Training and Education (TR1 - TR5)
Zero Tolerance of Sexual Abuse (PP1)
Audits of Standards (AU1)

B-100

PREA Cost Impact Analysis

Denver County Pre-arraignment Detention Facility

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

0.3%
Compliant?

0.4%

Upfront

73%

$

64,677

N

$

1

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
detainees

PP-3

Detainee supervision

Y

PP-4

Heightened protection for vulnerable detainees

Y

PP-5

Limits to cross-gender viewing and searches

N

PP-6

Accommodating detainees with special needs

Y

PP-7

Hiring and promotion decisions

N

PP-1

Yearly
Maintenance
$
76,698
$

57

Explanation

.5 FTE at senior-level salary

Y

Booz Allen believes this standard can be met by redeploying female staff at Jail to the
Lockup, at no additional cost

$

-

Per Booz Allen, the fee associated with criminal background check assumed to be $50. Fee
includes access to government sources and an internal LOE. DCPA has 8 promotions

PP-8

Assessment and use of monitoring technology

Y

RP-1

Evidence protocol and forensic medical exams

Y

RP-2

Agreements with outside law enforcement agencies

Y

RP-3

Agreements with the prosecuting authority

Y

TR-1

N

TR-2

Employee and volunteer training
Detainee, attorney, contractor, and inmate worker notification
of the agency’s zero-tolerance policy

TR-3

Specialized training: Investigations

Y

RE-1

Detainee reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Third-party reporting

Y

OR-1

Staff and agency head reporting duties

N

OR-2

Reporting to other confinement facilities

N

Facility head is not required to report an incident involving a victim under 18 years of age to
the designated State or local services agency
Information will be forwarded to other facility, however, do not ensure investigation is
completed by other facility or agency.

OR-3

Staff first responder duties

N

Policy update, no cost impact

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Y

DI-2

Disciplinary sanctions for staff
Referrals for prosecution for detainee-on-detainee sexual
abuse.

MM-1

Access to emergency medical and mental health services

Y

DC-1

Sexual abuse incident reviews

Y

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4

Data storage, publication, and destruction

Y

AU-1

Audits of standards

$

64

$

Cost for updating training to cover PREA material and consist of staff time for both initial
16 training and refresher training

Y

Do not notify complainant in writing of the investigation outcomes, this however, would be
done by the Denver County Police Dept. at no additional cost

Y

N

Appendix B - Site by Site Characteristics

$

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain internal LOE
3 to support the audit process. Assumed an auditor’s fee will include 4-person audit team
labor, meals and incidentals, hotel, air fare, and mileage

B-101

PREA Cost Impact Analysis
Middleton Police Department Lockup (Middleton PD)
Sector

Lockups

Title

Middleton PD
1

Total Facilities

63%

Percent PREA Compliant

27

Total Staff
Percent Male Staff

89%

Percent Female Staff

11%
12

Capacity

100%

Percent Male Offenders

0%

Percent Female Offenders

2

ADP

17%

ADP/Capacity Percentage

No

ACA Accredited?
Cost of care / day
Unionized?

-

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

1,400,000

Middleton PD, located in Essex County, MA, is a relatively
small police department with only 13 full time staff officers.
The department has three temporary holding cells, one of
which is primarily dedicated to housing female inmates in
transition from the local courts. The high percentage of female
detainees has led the department to develop the matron
program, which trains women from the community to conduct
pat down searches and provide oversight. This program allows
male officers to continue their responsibilities in the field,
while also avoiding conducting cross-gender pat down
searches. With an ADP of only two, Middleton PD operates at
17% of their capacity.
The Middleton PD is currently 63% compliant with the
NPREC standards. It is estimated that Middleton PD will have
a total upfront cost of $5K and an annual cost of $81K, to
reach full compliance.
According to the standard PP1, zero tolerance of sexual
abuse, Middleton PD would require 0.5PTE to serve as PREA

Coordinator at an annual cost of $53K.
Middleton PD believes that the NPREC Screening Standards would add an extra hour for each booking, which
would keep the arresting officer from his field duties. An annual
cost of $20K was estimated to increase based on the number of
Cost Impacts
arrests/ bookings and the number of hours of coverage.
In order to meet the training requirements, an estimated upfront
of $4K and an annual cost of $4K were determined. This cost
estimate is to train 27 staff and the contracted matrons.

Zero Tolerance of Sexual Abuse (PP1)
Screening for Risk of Sexual Abuse (SC1 and SC2)
Training and Education (TR1 - TR5)
Audits of Standards (AU1)

Booz Allen estimated a PREA triennial audit to cost $3K
annually.

Appendix B - Site by Site Characteristics

B-102

PREA Cost Impact Analysis

Middleton Police Department

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.4%

5.8%

Upfront

Yearly
Maintenance

Explanation

63%

$

5,342

$

80,668

N

$

1

$

53

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
detainees

PP-3

Detainee supervision

Y

PP-4

Heightened protection for vulnerable detainees

N

$

20

PP-5

Limits to cross-gender viewing and searches

Y

PP-6

Accommodating detainees with special needs

N

PP-7

Hiring and promotion decisions

Y

PP-8

Assessment and use of monitoring technology

Y

RP-1

Evidence protocol and forensic medical exams

N

RP-2

Agreements with outside law enforcement agencies

Y

RP-3

Agreements with the prosecuting authority

Y

TR-1

N

TR-2

Employee and volunteer training
Detainee, attorney, contractor, and inmate worker
notification of the agency’s zero-tolerance policy

TR-3

Specialized training: Investigations

N

RE-1

Detainee reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Third-party reporting

Y

OR-1

Staff and agency head reporting duties

Cost or compliance for this standard was not provided

OR-2

Reporting to other confinement facilities

Cost or compliance for this standard was not provided

OR-3

Staff first responder duties

Cost or compliance for this standard was not provided

OR-4

Coordinated response

Cost or compliance for this standard was not provided

OR-5

Agency protection against retaliation

Cost or compliance for this standard was not provided

IN-1

Duty to investigate

IN-2

Criminal and administrative agency investigations

IN-3

Evidence standard for administrative investigations

DI-1
DI-2

Disciplinary sanctions for staff
Referrals for prosecution for detainee-on-detainee
sexual abuse.

MM-1

Access to emergency medical and mental health
services

DC-1

Sexual abuse incident reviews

N

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4

Data storage, publication, and destruction

Y

PP-1

Y

N

Audits of standards

Additional time for booking would result in $20K needed to backfill for officers not in
the field.
Would contract with the local hospital,no cost associated

Local hospital would provide these services through the SANE program at no
additional cost.

$
$

4
-

$
$

4
-

Cost associated with training of 27 staff members and matrons, when hired to help
with supervision.
Not currently being performed, can be done at minimal costs to print materials
No additional cost to print materials

Y
Cost or compliance for this standard was not provided
Y
Cost or compliance for this standard was not provided
Cost or compliance for this standard was not provided

Cost or compliance for this standard was not provided
No incidents reported, cost associated with the data review team is null.

$
AU-1

.5 FTE at senior-level salary

N

Appendix B - Site by Site Characteristics

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
3 internal LOE to support the audit process. Assumed an auditor’s fee will include 4person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-103

PREA Cost Impact Analysis
Rocklin Police Department (Rocklin PD)
Sector

Lockups

Title

Rocklin PD

Total Facilities
Percent PREA Compliant
Total Staff

1
73%
49

Percent Male Staff

88%

Percent Female Staff

12%

Capacity

10

Percent Male Offenders

50%

Percent Female Offenders

50%

ADP
ADP/Capacity Percentage

4
42%

ACA Accredited?

N/A

Cost of care / day

$0.00

Unionized?

Rocklin PD, located in Rocklin, CA , has a population 55,000
in north central California about 20 miles east of Sacramento
in Placer County. Among a number of units and specialties
(including
uniformed
patrol,
traffic
enforcement,
investigations, canines, school resource officers, crime
prevention, dispatch, records, evidence, and animal control),
Rocklin PD also operates a lockup facility for temporary
detainees before being transferred to the county jail or
released. Of the 49 full time officers, the lock up is managed
by shift supervisors with one dedicated jail sergeant.
Rocklin PD is currently 73% compliant with the NPREC
standards. It is estimated that Rocklin PD will have a total
upfront cost of $19K and an annual cost of $802K, to reach
full compliance.

No

Rocklin PD would require six additional female FTEs and a
workforce realignment to eliminate cross-gender pat
2009 Confirmed Incidents
$ 12,034,245 searches in order to ensure a female officer is on staff 24/7,
Annual Operating Budget
available for pat downs when needed. The current policy at
Rocklin PD states that if staff is available Limits to Cross-Gender Viewing and Searches are prohibited however,
prohibiting Limits to Cross-Gender Viewing and Searches is not an official policy. A workforce realignment and
gender-specific hiring may result in EEOC issues and labor negotiations particularly senior level staff that is not as
willing to change their work schedules. An upfront cost of $6K and an annual cost of $760K were estimated as a
result of the six new FTE female positions.
2008 Confirmed Incidents

-

According to the standard PP1, zero tolerance of sexual abuse, Marion County would require 0.5PTE to serve as
PREA Coordinator at an annual cost of $63K.
Although located in a multi-lingual region of the country, particularly Spanish speaking, Rocklin PD does not have
adequate interpretation facilities. In order to better accommodate inmates with special needs, they propose to
incentivize their current staff to become bilingual with a 5% salary increase. Assuming this would be applied to six
staff members, an annual cost of $38K is estimated
As part of its gathering, reporting and reviewing of sexual abuse data efforts, Rocklin PD does not prepare any
annual reports. In order to track this data (if it existed), Rocklin PD would have to update their internal records
management system at an estimated, one-time, cost of $6K. This would provide the functionality to aggregate and
report on sexual abuse incidents.
Rocklin PD currently conducts initial training and annual in-service training using a hired instructor but it does not
cover PREA standards. In order to accommodate additional
Cost Impacts
training material, the training provider will likely charge extra
to include the PREA standards. The estimated cost of this is
Limits to Cross-Gender Viewing and Searches (PP4)
Zero Tolerance of Sexual Abuse (PP1)
$3K upfront is to cover training for new employees and
Accommodating Special Needs (PP5)
annual refresher training for all current employees to include
Gathering, Reviewing and Reporting Data (DC1 - DC4)
training for investigators. There will also be an additional
Training and Education (TR1 - TR5)
one-time cost of $3K to update current policies on Rocklin's
Audits of Standards (AU1)
zero tolerance policy and notification.
Booz Allen estimated a PREA triennial audit to cost $3K annually.

Appendix B - Site by Site Characteristics

B-104

PREA Cost Impact Analysis

Rocklin Police Department

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.2%

6.7%

Upfront

Yearly
Maintenance

73%

$

18,982

$

801,670

N

$

1

$

63

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
detainees

PP-3

Detainee supervision

Y

PP-4

Heightened protection for vulnerable detainees

Y

PP-5

Limits to cross-gender viewing and searches

N

$

6

$

698

PP-6

Accommodating detainees with special needs

N

PP-7

Hiring and promotion decisions

N

PP-8

Assessment and use of monitoring technology

Y

RP-1

Evidence protocol and forensic medical exams

Y

RP-2

Agreements with outside law enforcement agencies

Y

RP-3

Agreements with the prosecuting authority

Y

TR-1

N

TR-2

Employee and volunteer training
Detainee, attorney, contractor, and inmate worker
notification of the agency’s zero-tolerance policy

TR-3

Specialized training: Investigations

N

RE-1

Detainee reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Third-party reporting

Y

OR-1

Staff and agency head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

Y

IN-1

Duty to investigate

Y

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Y

DI-2

Disciplinary sanctions for staff
Referrals for prosecution for detainee-on-detainee
sexual abuse.

MM-1

Access to emergency medical and mental health
services

Y

DC-1

Sexual abuse incident reviews

Y

DC-2

Data Collection

N

DC-3

Data review for corrective action

Y

DC-4

Data storage, publication, and destruction

Y

PP-1

$

N

$

3

$

3

$

6 female FTEs to monitor lockup facility 24/7 (.5 of the FTE cost is for PREA
Coordinator).
Cost for a 5% salary increase for 6 staff members to incentivize them to become
38
bilingual.
Per Booz Allen, the fee associated with criminal background check assumed to be
$50. Fee includes access to government sources and an internal LOE. Rocklin PD
has 2 promotions

Cost to provide training for 58 sworn positions and for an additional 1 hour of
training.
Need to renegotiate contract with Lexipol to develop and monitor this additional
1
policy
Additional training would be covered under TR-1.

Y

$

Cost to update internal records management system to provide the functionality to
aggregate and report on sexual abuse incidents.

6

$
Audits of standards

.5 FTE at senior-level salary

Y

$

AU-1

Explanation

N

Appendix B - Site by Site Characteristics

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
3 internal LOE to support the audit process. Assumed an auditor’s fee will include 4person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-105

PREA Cost Impact Analysis
Seattle Police Department Lockup (Seattle PD)
Sector

Lockups

Title

Seattle PD
5

Total Facilities

82%

Percent PREA Compliant

1,305

Total Staff
Percent Male Staff

86%

Percent Female Staff

14%
N/A

Capacity
Percent Male Offenders

N/A

Percent Female Offenders

N/A

ADP

N/A

ADP/Capacity Percentage

N/A

ACA Accredited?

No

Cost of care / day

N/A

Unionized?

N/A
-

2008 Confirmed Incidents
2009 Confirmed Incidents
Annual Operating Budget

$

246,000,000

Seattle PD, located in downtown Seattle, WA, oversees the
administration of five precincts. Booz Allen met with the
Audit, Accreditation and Policy Section of the department.
Four of the Seattle PD precincts have lockup facilities that are
unique in comparison to other Lockup facilities. These
facilities are open 24 hours a day, yet are not manned by a full
time officer. Once a police officer has made an arrest on the
street, the detainee is taken to the Lockup facility and placed
in a temporary holding cell for approximately 30 minutes. The
arresting officer then completes necessary paperwork and
phone calls before coordinating transportation of the detainee
to the local Jail. The East and South precincts have three
holding cells, while the North has four. The West precinct has
6 holding cells and two glass observation cells used for
individuals on suicide watch. The holding cells are a
responsibility of the precincts however the Audit,
Accreditation and Policy Section of the Department would
oversee the precincts compliance with NPREC standards.

*Total Staff is the entire Seattle PD

Seattle PD is currently 82% compliant with the NPREC
standards. It is estimated that Seattle PD will have a total
upfront cost of $28K and an annual cost of $3M, to reach full compliance.
The largest cost and concern was a result of prohibiting cross-gender pat searches. This practice is viewed to go
against existing state statues that allow police officers to conduct pat downs in the field. At Seattle PD, police
officers do not transfer responsibility of the detainee to another officer at the Lockup facility, which would indicate
that existing state statues are upheld. To become fully compliant with this standard Seattle PD would be required to
hire a substantial number of female officers. Seattle PD currently has about 1,310 sworn officers, with only 188
(14%) of those being female. The cost is prohibitive, but even if male and female officers were in equal numbers,
which would take many years to accomplish, it would not eliminate cross-gender search situations. One option for
Seattle PD to become fully compliant with the standard is to staff the five precinct facilities on a 24/7 basis with a
female officer, which would require a minimum of 25 full time employees at a cost of approximately $3M per year
and $24K upfront.
Further, fulling standard PP1, zero tolerance of sexual abuse, the PREA Coordinator responsibilities would be a
function of Audit, Accreditation and Policy section. Labor hours
Cost Impacts
involved in this responsibility are seen to be minimal at $5K per
Limits to Cross-Gender Viewing and Searches (PP4)
year, not requiring a full or part time position.
Seattle PD would also need to develop a training video for
employees, which was estimated to cost $34K.

Zero Tolerance of Sexual Abuse (PP1)
Training and Education (TR1 - TR5)
Audits of Standards (AU1)

Booz Allen estimated a PREA triennial audit to cost $3K
annually.

Appendix B - Site by Site Characteristics

B-106

PREA Cost Impact Analysis

Seattle Police Department Lockup

Cost Impact

Percent of Annual Operating Budget
ID

Standard Addressed

Compliant?

0.0%

1.2%

Upfront

Yearly
Maintenance

82%

$

27,523

$

3,050,982

N

$

-

$

5

PP-2

Zero tolerance of sexual abuse
Contracting with other entities for the confinement of
detainees

PP-3

Detainee supervision

Y

PP-4

Heightened protection for vulnerable detainees

Y

PP-5

Limits to cross-gender viewing and searches

N

$

3,000

PP-6

Accommodating detainees with special needs

Y

PP-7

Hiring and promotion decisions

N

PP-8

Assessment and use of monitoring technology

Y

RP-1

Evidence protocol and forensic medical exams

Y

RP-2

Agreements with outside law enforcement agencies

Y

RP-3

Agreements with the prosecuting authority

Y

TR-1

N

TR-2

Employee and volunteer training
Detainee, attorney, contractor, and inmate worker
notification of the agency’s zero-tolerance policy

TR-3

Specialized training: Investigations

Y

RE-1

Detainee reporting

Y

RE-2

Exhaustion of administrative remedies

Y

RE-3

Third-party reporting

Y

OR-1

Staff and agency head reporting duties

Y

OR-2

Reporting to other confinement facilities

Y

OR-3

Staff first responder duties

Y

OR-4

Coordinated response

Y

OR-5

Agency protection against retaliation

Y

IN-1

Duty to investigate

N

IN-2

Criminal and administrative agency investigations

Y

IN-3

Evidence standard for administrative investigations

Y

DI-1

Y

DI-2

Disciplinary sanctions for staff
Referrals for prosecution for detainee-on-detainee
sexual abuse.

MM-1

Access to emergency medical and mental health
services

Y

DC-1

Sexual abuse incident reviews

Y

DC-2

Data Collection

Y

DC-3

Data review for corrective action

Y

DC-4

Data storage, publication, and destruction

Y

PP-1

Audits of standards

.5 FTE at senior-level salary

Y

$

24

25 female FTEs to staff the 5 lockup facilities (24/7).
Background checks for promotion are not conducted and would be in violation of
labor agreements.

$

4

Cost to develop a 30 minute video on sexual abuse.

Y

Investigative units are responsible for communicating status of report. There is no
cost to update this process for PREA compliance.

Y

$
AU-1

Explanation

N

Appendix B - Site by Site Characteristics

Booz Allen assumes a PREA audit will consist of an auditor’s fee and a certain
3 internal LOE to support the audit process. Assumed an auditor’s fee will include 4person audit team labor, meals and incidentals, hotel, air fare, and mileage

B-107

PREA Cost Impact Analysis

Appendix C - Approach to Questionnaire Development and Data Gathering
The objective of the questionnaire development was to winnow down the entire list of standards into a
manageable list of questions that could be addressed in a limited amount of time, approximately two
hours per site visit. The lead-in questions (to be provided in advance of the interview along with a
summarized list of all the standards) were phrased to be as objective as possible with yes/no responses,
followed up with more detailed questions requiring a qualitative response depending on the previous
answer. The intent was to initiate internal discussions at the site prior to the actual face-to-face site visit
where the Booz Allen team further discussed the qualitative responses, interpretations and final responses.

No

Similar and
redundant
questions
combined
and
categorized

Questionnaire

Yes

Standards
translated
into questions
based on
checklist
items

Questions

Is the standard
quantifiable in
monetary
value?

Quantifiable Standards

Standards

The following diagram provides an illustration of the steps taken to pare down the exhaustive list of
standards and myriad of potential costs into a manageable list of questions that are respectful of the
interviewee's time. Starting with the full set of standards, the team 1) determined on a case-by-case basis
if the standard would result in a cost, 2) analyzed what data would be necessary to estimate the cost, 3)
drafted lead-in questions to determine whether the site is compliant with the standard, 4) assessed whether
there were similar standards that could be addressed with one question and organized the questions into
similar cost categories, and finally 5) developed follow-up questions to gather quantitative data and a
qualitative justification to estimate costs. These follow-up questions were based on the required data we
need to estimate a cost and their response to the lead-in questions.

 General Data
(employee,
contractor, and outsourcing rates)
 Policies &
Procedures
 Training
 Physical Security
 Investigations
 Counseling &
Treatment

Standard is not
included in
questionnaire

The questionnaires were sent to the participating sites approximately 2 weeks in advance, providing
ample time to become familiar with the questions. Accompanying the questions was also a demographic
form to be filled out and returned to Booz Allen prior to the meeting. This form, when completed,
described the site size and complexity in terms of number of staff and offenders, gender ratios, operating
budget, number of contracted facilities, and if the workforce is unionized or not. It provided the interview
team with additional background material that could be discovered on the Internet. The sites were
encouraged to fill out the questionnaire prior to our visit but there were only a handful that had the time to
accomplish this.
Appendix C

C-1

PREA Cost Impact Analysis
The interviews were limited to two-hours. This was sometimes followed by a tour of the facility if the
interview took place at a jail, as opposed to the general administrative offices of a state prison system.
The discussions were lively and participants were very engaged. They were also very knowledgeable of
PREA, requiring little to no background of the history of PREA and the purpose of our visit. With the
ultimate objective to obtain cost data, it was infrequent to have final answers at the conclusion of the site
visit. Sites were, more often than not, required to gather additional data and documentation based on our
discussion, providing us with final answers two to three weeks after our visit. To facilitate this process,
Booz Allen provided the sites with typed meeting minutes and an additional data gathering template with
clear instructions where additional data were needed. This form, seen in Appendix E – Data Reports, is
divided into two parts, the first part focusing on the interview questions pre-populated with data gathered
at the site visit and the second part focusing on standards that, by and large (as determined by our Phase I
study) do not have a cost impact. This second part of the data report captured two critical pieces of
information, 1) the site's compliance on standards that were not discussed during the meeting and 2) it
provided an opportunity for a site to alert Booz Allen if there actually was a cost associated with any of
these standards. On only one occasion, a site provided an additional cost for part two, confirming our
finding from Phase I that this particular set of standards did not have a cost impact.
The retrieval of the filled out data forms was inevitably followed by a prolonged communication and a
series of data validation and questions and answers to ensure data were an accurate portrayal, based on
reasonable assumptions, of a site's operations. All answers were vetted within team, accounting
methodologies were scrutinized, and responses were validated and compared with other sites to determine
commonalities or anomalies.

Appendix C

C-2

PREA Cost Impact Analysis

Appendix D – Questionnaires
Adult Prisons and Jails
Prison Rape Elimination Act (PREA) Cost Impact Analysis
Office of Justice Programs / Department of Justice
Site Visit Discussion Questionnaire
Version: Adult Prisons & Jails
During this study led by Booz Allen Hamilton, several standards published by the National Prison Rape Elimination
Commission (NPREC) have led to increased attention and discussion whereas others have less of an impact. The
objective of this data gathering effort is to quantify, in monetary terms, the impact of the standards that may result in
the greatest impact on your operations, policies, and procedures. Responses gathered will inform the Attorney
General of the Department of Justice as he makes a final decision on the implementation of guidelines and
regulations due to be published in the summer of 2010. Please note that the data we gather will not be held to an
expectation of confidentiality and that by contract, information will be provided to the Office of Justice Programs by
name of organization.
The list below highlights twelve major topics followed by four minor topics as they relate to cost impacts or
difficulties with implementing the NPREC standards.

Major Topic #1: Cross-gender Pat Down Searches
Questions:
 Except in the case of an emergency, does your
Limits to cross-gender viewing and searches (PP-4):
jurisdiction/facility prohibit cross-gender pat downs?
Except in the case of emergency, the facility prohibits
o If not, what are the major reasons? Such as:
cross-gender strip and visual body cavity searches.
 A labor market that drives hiring opportunities?
Except in the case of emergency or other
extraordinary or unforeseen circumstances, the facility
 State or Federal mandates for equal opportunity
restricts nonmedical staff from viewing inmates of the
employment?
opposite gender who are nude or performing bodily
 Union concerns?
functions and similarly restricts cross-gender pat
o How would male/female staffing levels need to be
down searches. Medical practitioners conduct
examinations of transgender individuals to determine
altered to prohibit cross-gender pat downs searches?
their genital status only in private settings and only
o Would you consider adjusting your pat down policy to
when an individual’s genital status is unknown.
comply with this standard? Specifically how?
o Are there other policies that you could employ to comply with this standard? How would you do this and
what are the risks?
Notes:____________________________________________________________________________ _________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Prisons and Jails

D-1

PREA Cost Impact Analysis
Major Topic #2: Inmate/Resident Supervision - Physical Supervision
Questions:
 Over the past few years have you seen a variation or
Inmate supervision (PP-3): Security staff provides the
significant increase in the number of sexual abuse
inmate supervision necessary to protect inmates from
allegations made, either inmate-on-inmate or staff-onsexual abuse. The upper management officials
inmate?
responsible for reviewing critical incidents must examine
areas in the facility where sexual abuse has occurred to
o Are you able to provide historical data regarding
assess whether physical barriers may have enabled the
sexual abuse statistics prevalent in your
abuse, the adequacy of staffing levels in those areas
jurisdiction/facility (e.g., BJSs Survey on Sexual
during different shifts, and the need for monitoring
Violence, Form SSV-IA)?
technology to supplement security staff supervision (DC1). When problems or needs are identified, the
 Does your historical data suggest a decrease,
jurisdiction/facility takes corrective action (DC-3).
increase, or flat rate of sexual abuse incidents?
 If a problem is/was evident, what is the best
method for reducing sexual abuse incidents in your facility?
 Please explain how you would go about implementing these changes.
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #3: Inmate/Resident Supervision - Technical Supervision
Questions:
 Does your jurisdiction/facility currently have video monitoring in
Assessment and Use of Monitoring
place?
Technology (PP-7): The agency uses video
o If so, do you believe your jurisdiction/facility is adequately
monitoring systems and other cost-effective
suited to reduce sexual abuse incidents?
and appropriate technology to supplement its
sexual abuse prevention, detection, and
o Please explain its coverage, review and archiving.
response efforts. The agency assesses, at least
o If it is not considered sufficient, what cost would you estimate
annually, the feasibility of and need for new
for this technology?
or additional monitoring technology and de Do you employ other methods of technology supervision (e.g.,
velops a plan for securing such technology.
Radio Frequency Identification bracelets)?
 Do you annually assess the feasibility of your currently technology, including developing a plan for securing
new technology?
o If not, do you anticipate a cost associated with conducting this assessment?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #4: PREA Coordinator
Questions:
 Does your jurisdiction/facility have a PREA Coordinator to develop,
implement, and oversee efforts to comply with the PREA standards?
o Note: A PREA coordinator is a full-time position in the
governing body of the State prison systems and agencies that
operate large jails (more than 500 inmates) but may be a part-

Appendix D- Questionnaire/Prisons and Jails

Zero tolerance of sexual abuse (PP-1): The
agency has a written policy mandating zero
tolerance toward all forms of sexual abuse
and enforces that policy by ensuring all of its
facilities comply with the PREA standards.
The agency employs or designates a PREA
coordinator to develop, implement, and
oversee agency efforts to comply with the
PREA standards.

D-2

PREA Cost Impact Analysis

o

time position in jurisdictions that operate medium (101-500 inmates) and small jails (100 inmates or
fewer).
Have you considered the cost of the PREA coordinator including base salary plus benefits?

Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #5: Training and Education
Questions:
Employee training (TR-1): The agency trains all employees to be able to
 Do you provide training to all employees
fulfill their responsibilities under agency sexual abuse prevention, detection,
on sexual abuse prevention, detection,
and response policies and procedures; the PREA standards; and relevant
and response policies and procedures;
Federal, State, and local law. The agency trains all employees to communicate
the PREA standards; and relevant
effectively and professionally with all inmates. Additionally, the agency trains
all employees on an inmate’s right to be free from sexual abuse, the right of
Federal, State, and local law?
inmates and employees to be free from retaliation for reporting sexual abuse,
o What are the means of training?
the dynamics of sexual abuse in confinement, and the common reactions of
Class-room/
Computer
based?
sexual abuse victims. Current employees are educated as soon as possible
What is the length?
following the agency’s adoption of the PREA standards, and the agency
provides periodic refresher information to all employees to ensure that they
o Who
provides
the
training?
know the agency’s most current sexual abuse policies and procedures. The
Employees or contractors?
agency maintains written documentation showing employee signatures
 Do you provide periodic refresher
verifying that employees understand the training they have received.
information to all employees?
o How frequently do you provide refresher training?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you provide training to all volunteers and
Volunteer and contractor training (TR-2): The agency ensures
contractors who have contact with inmates on
that all volunteers and contractors who have contact with inmates
sexual abuse prevention, detection, and response
have been trained on their responsibilities under the agency’s
policies and procedures; the PREA standards; and
sexual abuse prevention, detection, and response policies and
relevant Federal, State, and local law?
procedures; the PREA standards; and relevant Federal, State, and
local law. The level and type of training provided to volunteers
o What are the means of training? Class-room/
and contractors is based on the services they provide and level of
Computer based? What is the length?
contact they have with inmates, but all volunteers and contractors
o Who provides the training? Employees or
who have contact with inmates must be notified of the agency’s
contractors?
zero-tolerance policy regarding sexual abuse. Volunteers must
also be trained in how to report sexual abuse. The agency
 Notes:____________________________________
maintains written documentation showing volunteer and
_________________________________________
contractor signatures verifying that they understand the training
_________________________________________
they have received.
_________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________

Appendix D- Questionnaire/Prisons and Jails

D-3

PREA Cost Impact Analysis
Questions:
 Following the intake process, do you provide
Inmate education (TR-3): During the intake process, staff informs
comprehensive education to inmates on sexual
inmates of the agency’s zero-tolerance policy regarding sexual abuse
abuse?
and how to report incidents or suspicions of sexual abuse. Within a
reasonably brief period of time following the intake process, the agency
o What are the means of training? Classprovides comprehensive education to inmates regarding their right to
room/ Computer based?
be free from sexual abuse and to be free from retaliation for reporting
o Who provides the training? Employees or
abuse, the dynamics of sexual abuse in confinement, the common
contractors?
reactions of sexual abuse victims, and agency sexual abuse response
policies and procedures. Current inmates are educated as soon as
o Is the training accessible to inmates with
possible following the agency’s adoption of the PREA standards, and
disabilities?
the agency provides periodic refresher information to all inmates to
 Do you provide periodic refresher information
ensure that they know the agency’s most current sexual abuse policies
to all inmates?
and procedures. The agency provides inmate education in formats
accessible to all inmates, including those who are LEP, deaf, visually
o What are the means? (e.g., poster boards,
impaired, or otherwise disabled as well as inmates who have limited
handbooks, closed circuit TV)
reading skills. The agency maintains written documentation of inmate
o How frequently do you provide refresher
participation in these education sessions.
training?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
Specialized training: Investigations (TR-4): In addition to the general
 Do you ensure sexual abuse training has been
training provided to all employees (TR-1), the agency ensures that
provided
to
investigators
specifically
agency investigators conducting sexual abuse investigations have
conducting investigations in confinement
received comprehensive and up-to-date training in conducting such
settings?
investigations in confinement settings. Specialized training must
include techniques for interviewing sexual abuse victims, proper use of
o Where do they get their training?
Miranda- and Garrity-type warnings, sexual abuse evidence collection
o How do you ensure the training meets the
in confinement settings, and the criteria and evidence required to
PREA standard?
substantiate a case for administrative action or prosecution referral. The
Notes:____________________________________
agency maintains written documentation that investigators have
completed the required specialized training in conducting sexual abuse
__________________________________________
investigations.
__________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you ensure your full and part-time
Specialized training: Medical and mental health care (TR-5): The agency
medical and mental health care
ensures that all full- and part-time medical and mental health care practitioners
working in its facilities have been trained in how to detect and assess signs of
practitioners have been trained on how
sexual abuse and that all medical practitioners are trained in how to preserve
to detect and assess signs of sexual
physical evidence of sexual abuse. All medical and mental health care
abuse and that all medical practitioners
practitioners must be trained in how to respond effectively and professionally
are trained on how to preserve physical
to victims of sexual abuse and how and to whom to report allegations or
suspicions of sexual abuse. The agency maintains documentation that medical
evidence of sexual abuse?
and mental health practitioners have received this specialized training.
o Where do they get their training?
o How do you ensure the training meets the PREA standard?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
=
Appendix D- Questionnaire/Prisons and Jails

D-4

PREA Cost Impact Analysis
Major Topic #6: Victim Advocacy
Questions:
 Do you provide a victim advocate to
Evidence protocol and forensic medical exams (RP-1): The agency follows a
uniform evidence protocol that maximizes the potential for obtaining usable
accompany the victim through the
physical evidence for administrative proceedings and criminal prosecutions.
forensic medical exam process?
The protocol must be adapted from or otherwise based on the 2004 U.S.
o Who would provide this service? A
Department of Justice’s Office on Violence Against Women publication ―A
current employee or outside entity?
National Protocol for Sexual Assault Medical Forensic Examinations,
Adults/Adolescents,‖ subsequent updated editions, or similarly comprehensive
Notes:_______________________________
and authoritative protocols developed after 2004. As part of the agency’s
____________________________________
evidence collection protocol, all victims of inmate-on-inmate sexually abusive
____________________________________
penetration or staff-on-inmate sexually abusive penetration are provided access
____________________________________
to forensic medical exams performed by qualified forensic medical examiners.
Forensic medical exams are provided free of charge to the victim. The facility
____________________________________
makes available a victim advocate to accompany the victim through the
____________________________________
forensic medical exam process.
____________________________________
___________________________________________________________________________________
Questions:
 Are inmates provided access to outside victim advocate services?
o Are there posters or pamphlets with
Inmate access to outside confidential support services (RE-3): In addition
this
information
around
the
to providing on-site mental health care services, the facility provides
facility/jurisdiction?
inmates with access to outside victim advocates for emotional support
o Who provides this outside victim
services related to sexual abuse. The facility provides such access by
giving inmates the current mailing addresses and telephone numbers,
advocacy support?
including toll-free hotline numbers, of local, State, and/or national victim
o Do these services ensure entities
advocacy or rape crisis organizations and enabling reasonable
receive and immediately forward
communication between inmates and these organizations. The facility
inmate reports of sexual abuse to
ensures that communications with such advocates are private, confidential,
facility heads, provide inmates with
and privileged, to the extent allowable by Federal, State, and local law. The
confidential emotional
support
facility informs inmates, prior to giving them access, of the extent to which
such communications will be private, confidential, and/or privileged.
services, and help victims of sexual
abuse during their transition from
incarceration to the community?
o Is there a fee borne by you for these services or is it provided by the state, county or other non-profit
service (state-level sexual assault coalition or its local affiliates)?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Prisons and Jails

D-5

PREA Cost Impact Analysis
Major Topic #7: Gathering, Reviewing, and Reporting Sexual Abuse Data
Questions:
 Do you have a review team to evaluate
Sexual abuse incident reviews (DC-1): The facility treats all instances of
each incident of sexual abuse?
sexual abuse as critical incidents to be examined by a team of upper
o Do you prepare a report for each
management officials, with input from line supervisors, investigators, and
sexual abuse incident?
medical/mental health practitioners. The review team evaluates each
o Does the report consider whether
incident of sexual abuse to identify any policy, training, or other issues
incidents were motivated by racial or
related to the incident that indicate a need to change policy or practice to
other group dynamics at the facility?
better prevent, detect, and/or respond to incidents of sexual abuse. The
o Does
this
report
include
review team also considers whether incidents were motivated by racial or
other group dynamics at the facility. When incidents are determined to be
recommendations for improvement?
motivated by racial or other group dynamics, upper management officials
Notes:_________________________________
immediately notify the agency head and begin taking steps to rectify those
______________________________________
underlying problems. The sexual abuse incident review takes place at the
______________________________________
conclusion of every sexual abuse investigation, unless the allegation was
______________________________________
determined to be unfounded. The review team prepares a report of its
______________________________________
findings and recommendations for improvement and submits it to the
______________________________________
facility head.
______________________________________
_____________________________________________________________________________________________
Questions:
 Do you prepare an annual report on aggregated
Data collection (DC-2): The agency collects accurate,
sexual abuse data using a standardized instrument
uniform data for every reported incident of sexual abuse using
and set of definitions (e.g., BJS survey on sexual
a standardized instrument and set of definitions. The agency
violence)?
aggregates the incident-based sexual abuse data at least
annually. The incident-based data collected includes, at a
o Does it include contracted facilities?
minimum, the data necessary to answer all questions from the
Notes:________________________________________
most recent version of the BJS Survey on Sexual Violence.
______________________________________________
Data are obtained from multiple sources, including reports,
______________________________________________
investigation files, and sexual abuse incident reviews. The
agency also obtains incident-based and aggregated data from
______________________________________________
every facility with which it contracts for the confinement of its
______________________________________________
inmates.
______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Prisons and Jails

D-6

PREA Cost Impact Analysis
Questions:
 Do you review, analyze, and use all sexual
Data review for corrective action (DC-3): The agency reviews,
analyzes, and uses all sexual abuse data, including incident-based and
abuse data to assess and improve the
aggregated data, to assess and improve the effectiveness of its sexual
effectiveness of your sexual abuse prevention,
abuse prevention, detection, and response policies, practices, and
detection, and response policies, practices, and
training. Using these data, the agency identifies problem areas,
training?
including any racial dynamics underpinning patterns of sexual abuse,
takes corrective action on an ongoing basis, and, at least annually,
o Does this review identify problem areas
prepares a report of its findings and corrective actions for each facility
(including any racial dynamics, underlying
as well as the agency as a whole. The annual report also includes a
patterns of sexual abuse, issues with
comparison of the current year’s data and corrective actions with those
particular physical locations or times of
from prior years and provides an assessment of the agency’s progress
in addressing sexual abuse. The agency’s report is approved by the
day), and take corrective action on an
agency head, submitted to the appropriate legislative body, and made
ongoing basis?
readily available to the public through its Web site or, if it does not
 Do you compare data from your annual report
have one, through other means. The agency may redact specific
to data from the previous year?
material from the reports when publication would present a clear and
specific threat to the safety and security of a facility, but it must
o Do you provide an assessment of your
indicate the nature of the material redacted.
progress?
 Is your annual data available to the public or on line?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
Data storage, publication, and destruction (DC-4): The
 Is your sexual abuse data properly stored, securely
agency ensures that the collected sexual abuse data are
retained, and protected?
properly stored, securely retained, and protected. The
o What medium (electronic or paper) and where is it
agency makes all aggregated sexual abuse data, from
stored?
facilities under its direct control and those with which it
contracts, readily available to the public at least annually
o Unless otherwise authorized by local or state law, do
through its Web site or, if it does not have one, through
you retain it for at least 10 years?
other means. Before making aggregated sexual abuse data
Notes:____________________________________________
publicly available, the agency removes all personal
_________________________________________________
identifiers from the data. The agency maintains sexual
abuse data for at least 10 years after the date of its initial
_________________________________________________
collection unless Federal, State, or local law allows for
_________________________________________________
the disposal of official information in less than 10 years.
_________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #8: Background Checks
for Hiring and Promotions
Questions:
 Do you and your contractors contact all
prior institutional employers for
information on substantiated allegations
of sexual abuse?
 Do you and your contractors run
criminal background checks for all
applicants
and
employees
being

Appendix D- Questionnaire/Prisons and Jails

Hiring and promotion decisions (PP-6): The agency does not hire or promote
anyone who has engaged in sexual abuse in an institutional setting or who has
engaged in sexual activity in the community facilitated by force, the threat of
force, or coercion. Consistent with Federal, State, and local law, the agency
makes its best effort to contact all prior institutional employers for
information on substantiated allegations of sexual abuse; must run
criminal background checks for all applicants and employees being
considered for promotion; and must examine and carefully weigh any history
of criminal activity at work or in the community, including convictions for
domestic violence, stalking, and sex offenses. The agency also asks all
applicants and employees directly about previous misconduct during
interviews and reviews.

D-7

PREA Cost Impact Analysis
considered for promotion?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #9: Triennial Auditing of the NPREC standards
Questions:
 What types of audits and/or accreditations do you
Audits of standards (AU-1): The public agency ensures that
all of its facilities, including contract facilities, are audited to
undergo on a periodic basis?
measure compliance with the PREA standards. Audits must be
o Would any of these be similar to what you
conducted at least every three years by independent and
would expect for a PREA audit?
qualified auditors. The public or contracted agency allows the
Notes:_________________________________________
auditor to enter and tour facilities, review documents, and
interview staff and inmates, as deemed appropriate by the
______________________________________________
auditor, to conduct comprehensive audits. The public agency
______________________________________________
ensures that the report of the auditor’s findings and the public
______________________________________________
or contracted agency’s plan for corrective action (DC-3) are
______________________________________________
published on the appropriate agency’s Web site if it has one or
______________________________________________
are otherwise made readily available to the public.
______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #10: Screening for Risk of Sexual Victimization and Abusiveness
Questions:
 Are all inmates screened during intake
(and at all subsequent classification
reviews) to assess their risk of being
sexually abused by other inmates or
having the potential to be sexually
abusive towards other inmates?
 Do you have a written screening
instrument tailored to the gender of the
population being screened?
Notes:______________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
_

Appendix D- Questionnaire/Prisons and Jails

Screening for risk of victimization and abusiveness (SC-1): All inmates are
screened during intake, during the initial classification process, and at all subsequent
classification reviews to assess their risk of being sexually abused by other inmates
or sexually abusive toward other inmates. Employees must conduct this screening
using a written screening instrument tailored to the gender of the population being
screened. Although additional factors may be considered, particularly to account for
emerging research and the agency’s own data analysis, screening instruments must
contain the criteria described below. All screening instruments must be made
available to the public upon request.
• At a minimum, employees use the following criteria to screen male inmates for
risk of victimization: mental or physical disability, young age, slight build, first
incarceration in prison or jail, nonviolent history, prior convictions for sex offenses
against an adult or child, sexual orientation of gay or bisexual, gender
nonconformance (e.g., transgender or intersex identity), prior sexual victimization,
and the inmate’s own perception of vulnerability.
• At a minimum, employees use the following criteria to screen male inmates for
risk of being sexually abusive: prior acts of sexual abuse and prior convictions for
violent offenses.

• At a minimum, employees use the following criteria to screen female inmates for
risk of sexual victimization: prior sexual victimization and the inmate’s own
perception of vulnerability.
• At a minimum, employees use the following criteria to screen female inmates for
risk of being sexually abusive: prior acts of sexual abuse.

D-8

PREA Cost Impact Analysis
Questions:
 Do you use the screening information to inform
Use of screening information (SC-2): Employees use
housing, bed, work, education, and program
information from the risk screening (SC-1) to inform
assignments with the goal of keeping separate those
housing, bed, work, education, and program assignments with
the goal of keeping separate those inmates at high risk of
inmates at high risk of being sexually victimized
being sexually victimized from those at high risk of being
from those at high risk of being sexually abusive?
sexually abusive. The facility makes individualized
o If yes, please explain.
determinations about how to ensure the safety of each inmate.
Notes:_________________________________________
Lesbian, gay, bisexual, transgender, or other gendernonconforming inmates are not placed in particular facilities,
______________________________________________
units, or wings solely on the basis of their sexual orientation,
______________________________________________
genital status, or gender identity. Inmates at high risk for
______________________________________________
sexual victimization may be placed in segregated housing
______________________________________________
only as a last resort and then only until an alternative means
of separation from likely abusers can be arranged. To the
______________________________________________
extent possible, risk of sexual victimization should not limit
______________________________________________
access to programs, education, and work opportunities.
______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #11: Contract Modifications and/or Policy and Procedure Updates
Questions:
Contracting with other entities for the confinement of inmates
 Do you contract with other agencies or facilities for
(PP-2): If public correctional agencies contract for the
the confinement of inmates?
confinement of their inmates, they do so only with private
o If so, how many facilities?
agencies or other entities, including other government
o What will it take to ensure these
agencies, committed to eliminating sexual abuse in their
facilities, as evidenced by their adoption of and compliance
agencies/facilities are in compliance?
with the PREA standards. Any new contracts or contract
o Will this require any contract modifications?
renewals include the entity’s obligation to adopt and comply
o Do you think any contract modifications, as a
with the PREA standards and specify that the public agency
result of PREA, would result in greater costs to
will monitor the entity’s compliance with these standards as
part of its monitoring of the entity’s performance.
you?
Notes:_________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you maintain or attempt to enter into
Agreements with outside public entities and community service
providers (RP-2): The agency maintains or attempts to enter into
memoranda of understanding (MOUs) or other
memoranda of understanding (MOUs) or other agreements with an
agreements with an outside public entity or
outside public entity or office that is able to receive and immediately
office that is able to 1) receive and immediately
forward inmate reports of sexual abuse to facility heads (RE-1). The
forward inmate reports of sexual abuse to
agency also maintains or attempts to enter into MOUs or other
agreements with community service providers that are able to: (1)
facility heads, 2) provide inmates with
provide inmates with confidential emotional support services related
confidential emotional support services related
to sexual abuse and (2) help victims of sexual abuse during their
to sexual abuse, and 3) help victims of sexual
transition from incarceration to the community (RE-3, MM-3). The
abuse during their transition from incarceration
agency maintains copies of agreements or documentation showing
attempts to enter into agreements.
to the community?
o Who currently provides these services (if
anyone)?
o Do you have any MOUs with them?
 If not, how much would it cost to develop these MOUs?
 If not possible to establish a MOU, do you document the attempt to enter an agreement?
Appendix D- Questionnaire/Prisons and Jails

D-9

PREA Cost Impact Analysis
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you conduct your own criminal
Agreements with outside law enforcement agencies (RP-3): If an agency
investigations or is it an outside legal authority?
does not have the legal authority to conduct criminal investigations or has
elected to permit an outside agency to conduct criminal or administrative
o If outside, who is it?
investigations of staff or inmates, the agency maintains or attempts to
o Do you have an MOU with them?
enter into a written MOU or other agreement specific to investigations of
 If not, how much would it cost to
sexual abuse with the law enforcement agency responsible for conducting
develop these MOUs?
investigations. If the agency confines inmates under the age of 18 or other
inmates who fall under State and local vulnerable persons statutes, the
 If not possible to establish a MOU, do
agency maintains or attempts to enter into an MOU with the designated
you document the attempt to enter an
State or local services agency with the jurisdiction and authority to conagreement?
duct investigations related to the sexual abuse of vulnerable persons
 If applicable, does it cover vulnerable
within confinement facilities. When the agency already has an existing
agreement or long-standing policy covering responsibilities for all
persons (e.g., under 18 years of age)?
criminal investigations, including sexual abuse investigations, it does not
Notes:____________________________________
need to enter into a new agreement. The agency maintains a copy of the
__________________________________________
agreement or documentation showing attempts to enter into an agreement.
__________________________________________
__________________________________________
_____________________________________________________________________________________________
Questions:
 Who are the authorities that prosecute violations?
Agreements with the prosecuting authority (RP-4):
o Do you have a MOU with them?
The agency maintains or attempts to enter into a
 If not, how much would it cost to develop these
written MOU or other agreement with the auMOUs?
thority responsible for prosecuting violations of
criminal law. The agency maintains a copy of the
 If not possible to establish a MOU, do you document
agreement or documentation showing attempts to
the attempt to enter an agreement?
enter into an agreement.
Notes:_________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
____________________________________________________________________________________________

Major Topic #12: Accommodating Special Needs
Questions:
 Do you ensure that inmates who are LEP, deaf, or disabled
Accommodating inmates with special needs (PP-5):
are able to report sexual abuse to staff directly through
The agency ensures that inmates who are limited
interpretive technology or through non-inmate interpreters?
English proficient (LEP), deaf, or disabled are able to
report sexual abuse to staff directly, through interpretive
o What services and tools do you employ?
technology, or through non-inmate interpreters.
 What interpretive technology do you use?
Accommodations are made to convey all written
 Do you provide services for the mentally
information about sexual abuse policies, including how
to report sexual abuse, verbally to inmates who have
disabled?
limited reading skills or who are visually impaired.
Notes:_____________________________________________
___________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Prisons and Jails

D-10

PREA Cost Impact Analysis
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #1: Medical Exams
Questions:
Evidence protocol and forensic medical exams (RP-1): The agency
 Are Forensic medical exams provided free of
follows a uniform evidence protocol that maximizes the potential for
charge to the victim?
obtaining usable physical evidence for administrative proceedings and
o Who provides the exams?
criminal prosecutions. The protocol must be adapted from or otherwise
o Who bears the cost?
based on the 2004 U.S. Department of Justice’s Office on Violence
Against Women publication ―A National Protocol for Sexual Assault
Notes:___________________________________
Medical Forensic Examinations, Adults/Adolescents,‖ subsequent
_________________________________________
updated editions, or similarly comprehensive and authoritative protocols
_________________________________________
developed after 2004. As part of the agency’s evidence collection
_________________________________________
protocol, all victims of inmate-on-inmate sexually abusive penetration or
staff-on-inmate sexually abusive penetration are provided access to
_________________________________________
forensic medical exams performed by qualified forensic medical
_________________________________________
examiners. Forensic medical exams are provided free of charge to the
_________________________________________
victim. The facility makes available a victim advocate to accompany the
_________________________________________
victim through the forensic medical exam process.
_________________________________________
_____________________________________________________________________________________________

Minor Topic #2: Conducting Investigations
Questions:
Third-party reporting (RE-4): The facility receives and
 Do you investigate all third-party reports of sexual abuse?
investigates all third-party reports of sexual abuse (IN-1).
At the conclusion of the investigation, the facility notifies
Notes:____________________________________________
in writing the third-party individual who reported the
__________________________________________________
abuse and the inmate named in the third-party report of
__________________________________________________
the outcome of the investigation. The facility distributes
__________________________________________________
publicly information on how to report sexual abuse on
behalf of an inmate.
__________________________________________________
__________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you notify victims and/or other complainants in
Duty to investigate (IN-1): The facility investigates all
writing of investigation outcomes and any disciplinary or
allegations of sexual abuse, including third-party and
anonymous reports, and notifies victims and/or other
criminal sanctions, regardless of the source of the
complainants in writing of investigation outcomes and
allegation?
any disciplinary or criminal sanctions, regardless of the
 Are all investigations carried through to completion,
source of the allegation. All investigations are carried
regardless of whether the alleged abuser or victim
through to completion, regardless of whether the alleged
abuser or victim remains at the facility.
remains at the facility?
Notes:____________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________
Questions:


Are allegations of sexual abuse substantiated if supported
by a preponderance of the evidence?

Evidence standard for administrative investigations (IN3): Allegations of sexual abuse are substantiated if
supported by a preponderance of the evidence.

Notes:____________________________________________
Appendix D- Questionnaire/Prisons and Jails

D-11

PREA Cost Impact Analysis
Minor Topic #3: Conducting Mental and Medical Health Evaluations and Providing Care
Questions:
 Does the facility/jurisdiction provide ongoing medical
and/or mental health evaluations and treatment to all
known abusers of sexual abuse?
Notes:___________________________________________
_________________________________________________
_________________________________________________
_________________________________________________
_________________________________________________

Ongoing medical and mental health care for sexual abuse victims
and abusers (MM-3): The facility provides ongoing medical
and/or mental health evaluation and treatment to all known
victims of sexual abuse. The evaluation and treatment of sexual
abuse victims must include appropriate follow-up services,
treatment plans, and, when necessary, referrals for continued care
following their release from a community corrections facility. The
level of medical and mental health care provided to
defendant/offender victims must match the community level of
care generally accepted by the medical and mental health
professional communities. The facility conducts a mental health
evaluation of all known abusers and provides treatment, as
deemed necessary by qualified mental health practitioners.

Minor Topic #4: Confidential Reporting
Questions:
 How do victims confidentially report sexual abuse
(in multiple ways)?
 Are there means to report sexual abuse to an outside
public entity?
o Who is it?
o Does this entity charge a fee for such services?
Notes:________________________________________
_____________________________________________
_____________________________________________
_____________________________________________
Questions:
 Please explain your policies/procedures for the
exhaustion of administrative remedies available to an
inmate.
o Does it cover a 90 day period (unless you have
made a final determination earlier)?
o Does it cover a 48 hours requirement after an
inmate has notified any agency staff member of his
or her need for protection?
Notes:__________________________________________
________________________________________________
________________________________________________
________________________________________________
________________________________________________

Appendix D- Questionnaire/Prisons and Jails

Inmate reporting (RE-1): The facility provides multiple internal ways
for inmates to report easily, privately, and securely sexual abuse,
retaliation by other inmates or staff for reporting sexual abuse, and staff
neglect or violation of responsibilities that may have contributed to an
incident of sexual abuse. The facility also provides at least one way for
inmates to report the abuse to an outside public entity or office not
affiliated with the agency that has agreed to receive reports and forward
them to the facility head (RP-2), except when an inmate requests
confidentiality. Staff accepts reports made verbally, in writing,
anonymously, and from third parties and immediately puts into writing
any verbal reports.

Exhaustion of administrative remedies (RE-2): Under agency
policy, an inmate has exhausted his or her administrative remedies
with regard to a claim of sexual abuse either (1) when the agency
makes a final decision on the merits of the report of abuse
(regardless of whether the report was made by the inmate, made
by a third party, or forwarded from an outside official or office) or
(2) when 90 days have passed since the report was made,
whichever occurs sooner. A report of sexual abuse triggers the
90-day exhaustion period regardless of the length of time that has
passed between the abuse and the report. An inmate seeking
immediate protection from imminent sexual abuse will be deemed
to have exhausted his or her administrative remedies 48 hours
after notifying any agency staff member of his or her need for
protection.

D-12

PREA Cost Impact Analysis

Juvenile Facilities

Prison Rape Elimination Act (PREA) Cost Impact Analysis
Office of Justice Programs / Department of Justice
Site Visit Discussion Questionnaire
Version: Juvenile Facilities
During this study led by Booz Allen Hamilton, several standards published by the National Prison Rape Elimination
Commission (NPREC) have led to increased attention and discussion whereas others have less of an impact. The
objective of this data gathering effort is to quantify, in monetary terms, the impact of the standards that may result in
the greatest impact on your operations, policies, and procedures. Responses gathered will inform the Attorney
General of the Department of Justice as he makes a final decision on the implementation of guidelines and
regulations due to be published in the summer of 2010. Please note that the data we gather will not be held to an
expectation of confidentiality and that by contract, information will be provided to the Office of Justice Programs by
name of organization.
The list below highlights twelve major topics followed by three minor topics as they relate to cost impacts or
difficulties with implementing the NPREC standards.

Major Topic #1: Cross-gender Pat Down Searches
Questions:
 Except in the case of an emergency, does your
Limits to cross-gender viewing and searches (PP-4):
jurisdiction/facility prohibit cross-gender pat downs?
Except in the case of emergency, the facility prohibits
cross-gender strip and visual body cavity searches.
o If not, what are the major reasons? Such as:
Except in the case of emergency or other
 A labor market that drives hiring opportunities?
extraordinary or unforeseen circumstances, the facility
 State or Federal mandates for equal opportunity
restricts nonmedical staff from viewing residents of
employment?
the opposite gender who are nude or performing
bodily functions and similarly restricts cross-gender
 Union concerns?
pat down searches. Medical practitioners conduct
o How would male/female staffing levels need to be
examinations of transgender individuals to determine
altered to prohibit cross-gender pat downs searches?
their genital status only in private settings and only
o Would you consider adjusting your pat down policy to
when an individual’s genital status is unknown.
comply with this standard? Specifically how?
o Are there other policies that you could employ to comply with this standard? How would you do this and
what are the risks?
Notes:____________________________________________________________________________ _________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-13

PREA Cost Impact Analysis
Major Topic #2: Inmate/Resident Supervision - Physical Supervision
Questions:
 Over the past few years have you seen a variation or
Resident supervision (PP-3): Direct care staff provides
significant increase in the number of sexual abuse
the resident supervision necessary to protect residents
allegations made, either resident-on-resident or staff-onfrom sexual abuse. The facility administrators and
resident?
supervisors responsible for reviewing critical incidents
must examine areas in the facility where sexual abuse
o Are you able to provide historical data regarding
has occurred to assess whether physical barriers may
sexual abuse statistics prevalent in your
have enabled the abuse, the adequacy of staffing levels
jurisdiction/facility (e.g., BJAs Survey on Sexual
in those areas during different shifts, and the need for
Violence, Form SSV-IA)?
monitoring technology to supplement direct care staff
supervision (DC-1). When problems or needs are
 Does your historical data suggest a decrease,
identified, the jurisdiction/facility takes corrective action
increase, or flat rate of sexual abuse incidents?
(DC-3).
 If a problem is/was evident, what is the best
method for reducing sexual abuse incidents in
your facility?
 Please explain how you would go about implementing these changes.
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #3: Inmate/Resident Supervision - Technical Supervision
Questions:
 Does your jurisdiction/facility currently have video monitoring in
place?
Assessment and Use of Monitoring
Technology (PP-7): The agency uses video
o If so, do you believe your jurisdiction/facility is adequately
monitoring systems and other cost-effective
suited to reduce sexual abuse incidents?
and appropriate technology to supplement its
o Please explain its coverage, review and archiving.
sexual abuse prevention, detection, and
o If it is not considered sufficient, what cost would you estimate
response efforts. The agency assesses, at least
annually, the feasibility of and need for new
for this technology?
or additional monitoring technology and de Do you employ other methods of technology supervision (e.g.,
velops a plan for securing such technology.
Radio Frequency Identification bracelets)?
 Do you annually assess the feasibility of your currently technology, including developing a plan for securing
new technology?
o If not, do you anticipate a cost associated with conducting this assessment?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-14

PREA Cost Impact Analysis
Major Topic #4: PREA Coordinator
Zero tolerance of sexual abuse (PP-1): The
Questions:
agency has a written policy mandating zero
 Does your jurisdiction/facility have a PREA Coordinator to develop,
tolerance toward all forms of sexual abuse
implement, and oversee efforts to comply with the PREA standards?
and enforces that policy by ensuring all of its
facilities comply with the PREA standards.
o Note: A PREA coordinator is a full-time position in the
The agency employs or designates a PREA
governing body of the State prison systems and agencies that
coordinator to develop, implement, and
operate large jails (more than 500 residents) but may be a partoversee agency efforts to comply with the
time position in jurisdictions that operate medium (101-500
PREA standards.
residents) and small jails (100 residents or fewer).
o Have you considered the cost of the PREA coordinator including base salary plus benefits?

Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_

Major Topic #5: Training and Education
Questions:
Employee training (TR-1): The agency trains all employees to be able to
 Do you provide training to all employees
fulfill
their responsibilities under agency sexual abuse prevention, detection,
on sexual abuse prevention, detection, and
and response policies and procedures; the PREA standards; and relevant
response policies and procedures; the
Federal, State, and local law. The agency trains all employees to communicate
PREA standards; and relevant Federal,
effectively and professionally with all residents. Additionally, the agency
trains all employees on a resident’s right to be free from sexual abuse, the right
State, and local law?
of residents and employees to be free from retaliation for reporting sexual
o What are the means of training?
abuse, the dynamics of sexual abuse in confinement, and the common
Class-room/ Computer based? What
reactions of sexual abuse victims. Current employees are educated as soon as
is the length?
possible following the agency’s adoption of the PREA standards, and the
agency provides periodic refresher information to all employees to ensure that
o Who
provides
the
training?
they know the agency’s most current sexual abuse policies and procedures.
Employees or contractors?
The agency maintains written documentation showing employee signatures
 Do you provide periodic refresher
verifying that employees understand the training they have received.
information to all employees?
o How frequently do you provide refresher training?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-15

PREA Cost Impact Analysis
Questions:
 Do you provide training to all volunteers and
Volunteer and contractor training (TR-2): The agency ensures
contractors who have contact with residents on sexual
that all volunteers and contractors who have contact with
abuse prevention, detection, and response policies and
residents have been trained on their responsibilities under the
agency’s sexual abuse prevention, detection, and response
procedures; the PREA standards; and relevant Federal,
policies and procedures; the PREA standards; and relevant
State, and local law?
Federal, State, and local law. The level and type of training
o What are the means of training? Class-room/
provided to volunteers and contractors is based on the services
Computer based? What is the length?
they provide and level of contact they have with residents, but all
volunteers and contractors who have contact with residents must
o Who provides the training?
Employees or
be notified of the agency’s zero-tolerance policy regarding
contractors?
sexual abuse. Volunteers must also be trained in how to report
 Notes:______________________________________
sexual abuse. The agency maintains written documentation
____________________________________________
showing volunteer and contractor signatures verifying that they
understand the training they have received.
____________________________________________
____________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________
Questions:
 Following the intake process, do you provide
Resident education (TR-3): During the intake process, staff informs
comprehensive education to residents on sexual
residents of the agency’s zero-tolerance policy regarding sexual abuse
abuse?
and how to report incidents or suspicions of sexual abuse in an age
appropriate fashion. Within a reasonably brief period of time following
o What are the means of training? Classthe intake process, the agency provides comprehensive, age appropriate
room/ Computer based?
education to residents regarding their right to be free from sexual abuse
o Who provides the training? Employees or
and to be free from retaliation for reporting abuse, the dynamics of
contractors?
sexual abuse in confinement, the common reactions of sexual abuse
victims, and agency sexual abuse response policies and procedures.
o Is the training accessible to residents with
Current residents are educated as soon as possible following the
disabilities?
agency’s adoption of the PREA standards, and the agency provides
 Do you provide periodic refresher information to
periodic refresher information to all residents to ensure that they know
all residents?
the agency’s most current sexual abuse policies and procedures. The
agency provides resident education in formats accessible to all
o What are the means? (e.g., poster boards,
residents, including those who are LEP, deaf, visually impaired, or
handbooks, closed circuit TV)
otherwise disabled as well as residents who have limited reading skills.
o How frequently do you provide refresher
The agency maintains written documentation of resident participation
training?
in these education sessions.
Notes:_____________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
Specialized training: Investigations (TR-4): In addition to the general
 Do you ensure sexual abuse training has been
training provided to all employees (TR-1), the agency ensures that
provided
to
investigators
specifically
agency investigators conducting sexual abuse investigations have
conducting investigations in confinement
received comprehensive and up-to-date training in conducting such
investigations in confinement settings. Specialized training must
settings?
include techniques for interviewing sexual abuse victims, proper use of
o Where do they get their training?
Miranda- and Garrity-type warnings, sexual abuse evidence collection
o How do you ensure the training meets the
in confinement settings, and the criteria and evidence required to
PREA standard?
substantiate a case for administrative action or prosecution referral. The
agency maintains written documentation that investigators have
Notes:____________________________________
completed the required specialized training in conducting sexual abuse
__________________________________________
investigations.
__________________________________________
Appendix D- Questionnaire/Juvenile Facilities

D-16

PREA Cost Impact Analysis
_____________________________________________________________________________________________
Questions:
 Do you ensure your full and part-time
medical and mental health care
Specialized training: Medical and mental health care (TR-5): The agency
ensures that all full- and part-time medical and mental health care practitioners
practitioners have been trained on how
working in its facilities have been trained in how to detect and assess signs of
to detect and assess signs of sexual
sexual abuse and that all medical practitioners are trained in how to preserve
abuse and that all medical practitioners
physical evidence of sexual abuse. All medical and mental health care
are trained on how to preserve physical
practitioners must be trained in how to respond effectively and professionally
to young victims of sexual abuse and how and to whom to report allegations or
evidence of sexual abuse?
suspicions of sexual abuse. The agency maintains documentation that medical
o Where do they get their training?
and mental health practitioners have received this specialized training.
o How do you ensure the training
meets the PREA standard?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #6: Victim Advocacy
Questions:
 Do you provide a victim advocate to
accompany the victim through the
forensic medical exam process?
o Who would provide this service? A
current employee or outside entity?
Notes:________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
Questions:
 Are residents provided access to outside
victim advocate services?
o Are there posters or pamphlets with this
information
around
the
facility/jurisdiction?
o Who provides this outside victim
advocacy support?
o Do these services ensure entities receive
and immediately forward inmate reports
of sexual abuse to facility heads, provide
inmates with confidential emotional
support services, and help victims of
sexual abuse during their transition from
incarceration to the community?
Appendix D- Questionnaire/Juvenile Facilities

Evidence protocol and forensic medical exams (RP-1): The agency follows a
uniform evidence protocol that maximizes the potential for obtaining usable
physical evidence for administrative proceedings and criminal prosecutions.
The protocol must be adapted from or otherwise based on the 2004 U.S.
Department of Justice’s Office on Violence Against Women publication ―A
National Protocol for Sexual Assault Medical Forensic Examinations,
Adults/Adolescents,‖ subsequent updated editions, or similarly comprehensive
and authoritative protocols developed after 2004. As part of the agency’s
evidence collection protocol, all victims of resident-on-resident sexually
abusive penetration or staff-on-resident sexually abusive penetration are
provided access to forensic medical exams performed by qualified forensic
medical examiners who are trained in the unique psychological and emotional
conditions of younger victims of sexual abuse. Forensic medical exams are
provided free of charge to the victim. The facility makes available a victim
advocate to accompany the victim through the forensic medical exam
process.

Resident access to outside confidential support services (RE-3): In
addition to providing on-site mental health care services, the facility
provides residents with access to outside victim advocates for emotional
support services related to sexual abuse. The facility provides such
access by giving residents the current mailing addresses and telephone
numbers, including toll-free hotline numbers, of local, State, and/or
national victim advocacy or rape crisis organizations and enabling
reasonable communication between residents and these organizations. The
facility ensures that communications with such advocates are private,
confidential, and privileged, to the extent allowable by Federal, State, and
local law. The facility informs residents, prior to giving them access, of the
extent to which such communications will be private, confidential, and/or
privileged. The facility also provides residents with unimpeded access to
their attorney or other legal representation and their families.

D-17

PREA Cost Impact Analysis
o

Is there a fee borne by you for these services or is it provided by the state, county or other non-profit
service (state-level sexual assault coalition or its local affiliates)?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
______________________

Major Topic #7: Gathering, Reviewing, and Reporting Sexual Abuse Data
Questions:
 Do you have a review team to evaluate
each incident of sexual abuse?
Sexual abuse incident reviews (DC-1): The facility treats all instances of
o Do you prepare a report for each
sexual abuse as critical incidents to be examined by a team of upper
sexual abuse incident?
management officials, with input from line supervisors, investigators, and
medical/mental health practitioners. The review team evaluates each
o Does the report consider whether
incident of sexual abuse to identify any policy, training, or other issues
incidents were motivated by racial or
related to the incident that indicate a need to change policy or practice to
other group dynamics at the facility?
better prevent, detect, and/or respond to incidents of sexual abuse. The
o Does
this
report
include
review team also considers whether incidents were motivated by racial or
recommendations for improvement?
other group dynamics at the facility. When incidents are determined to be
Notes:_________________________________
motivated by racial or other group dynamics, upper management officials
immediately notify the agency head and begin taking steps to rectify those
______________________________________
underlying problems. The sexual abuse incident review takes place at the
______________________________________
conclusion of every sexual abuse investigation, unless the allegation was
______________________________________
determined to be unfounded. The review team prepares a report of its
______________________________________
findings and recommendations for improvement and submits it to the
______________________________________
facility head.
______________________________________
Questions:
 Do you prepare an annual report on aggregated
Data collection (DC-2): The agency collects accurate,
sexual abuse data using a standardized instrument
uniform data for every reported incident of sexual abuse using
and set of definitions (e.g., BJS survey on sexual
a standardized instrument and set of definitions. The agency
aggregates the incident-based sexual abuse data at least
violence)?
annually. The incident-based data collected includes, at a
o Does it include contracted facilities?
minimum, the data necessary to answer all questions from the
Notes:_________________________________________
most recent version of the BJS Survey on Sexual Violence.
______________________________________________
See Appendix C for a list of recommended data elements.
Data are obtained from multiple sources, including reports,
______________________________________________
investigation files, and sexual abuse incident reviews. The
______________________________________________
agency also obtains incident-based and aggregated data from
______________________________________________
every facility with which it contracts for the confinement of
______________________________________________
its residents.
______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-18

PREA Cost Impact Analysis
Questions:
 Do you review, analyze, and use all sexual
Data review for corrective action (DC-3): The agency reviews,
abuse data to assess and improve the
analyzes, and uses all sexual abuse data, including incident-based and
effectiveness of your sexual abuse prevention,
aggregated data, to assess and improve the effectiveness of its sexual
abuse prevention, detection, and response policies, practices, and
detection, and response policies, practices, and
training. Using these data, the agency identifies problem areas, intraining?
cluding any racial dynamics or other group dynamics underpinning
o Does this review identify problem areas
patterns of sexual abuse, takes corrective action on an ongoing basis,
(including any racial dynamics, underlying
and, at least annually, prepares a report of its findings and corrective
actions for each facility as well as the agency as a whole. The annual
patterns of sexual abuse, issues with
report also includes a comparison of the current year’s data and
particular physical locations or times of
corrective actions with those from prior years and provides an
day), and take corrective action on an
assessment of the agency’s progress in addressing sexual abuse. The
ongoing basis?
agency’s report is approved by the agency head, submitted to the
appropriate legislative body, and made readily available to the public
 Do you compare data from your annual report to
through its Web site or, if it does not have one, through other means.
data from the previous year?
The agency may redact specific material from the reports when
o Do you provide an assessment of your
publication would present a clear and specific threat to the safety and
progress?
security of a facility, but it must indicate the nature of the material
redacted.
 Is your annual data available to the public or on
line?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Is your sexual abuse data properly stored, securely
Data storage, publication, and destruction (DC-4): The
retained, and protected?
agency ensures that the collected sexual abuse data are
properly stored, securely retained, and protected. The
o What medium (electronic or paper) and where is it
agency makes all aggregated sexual abuse data, from
stored?
facilities under its direct control and those with which it
o Unless otherwise authorized by local or state law, do
contracts, readily available to the public at least annually
you retain it for at least 10 years?
through its Web site or, if it does not have one, through
other means. Before making aggregated sexual abuse data
Notes:_____________________________________________
publicly available, the agency removes all personal
__________________________________________________
identifiers from the data. The agency maintains sexual
__________________________________________________
abuse data for at least 10 years after the date of its initial
__________________________________________________
collection unless Federal, State, or local law allows for
the disposal of official information in less than 10 years.
__________________________________________________
__________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #8: Background Checks for Hiring and Promotions
Questions:
 Do you and your contractors contact all
prior
institutional
employers
for
information on substantiated allegations
of sexual abuse?
 Do you and your contractors run criminal
background checks for all applicants and
employees
being
considered
for
promotion?

Appendix D- Questionnaire/Juvenile Facilities

Hiring and promotion decisions (PP-6): The agency does not hire or promote
anyone who has engaged in sexual abuse in an institutional setting or who has
engaged in sexual activity in the community facilitated by force, the threat of
force, or coercion. Consistent with Federal, State, and local law, the agency
makes its best effort to contact all prior institutional employers for
information on substantiated allegations of sexual abuse; must run
criminal background checks for all applicants and employees being
considered for promotion; and must examine and carefully weigh any history
of criminal activity at work or in the community, including convictions for
domestic violence, stalking, child abuse and sex offenses. The agency also asks
all applicants and employees directly about previous misconduct during interviews and reviews.

D-19

PREA Cost Impact Analysis
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_________________________________

Major Topic #9: Triennial Auditing of the NPREC standards
Questions:
 What types of audits and/or accreditations do you
Audits of standards (AU-1): The public agency ensures that
undergo on a periodic basis?
all of its facilities, including contract facilities, are audited to
o Would any of these be similar to what you would
measure compliance with the PREA standards. Audits must be
conducted at least every three years by independent and
expect for a PREA audit?
qualified auditors. The public or contracted agency allows the
Notes:__________________________________________
auditor to enter and tour facilities, review documents, and
_______________________________________________
interview staff and residents, as deemed appropriate by the
_______________________________________________
auditor, to conduct comprehensive audits. The public agency
ensures that the report of the auditor’s findings and the public
_______________________________________________
or contracted agency’s plan for corrective action (DC-3) are
_______________________________________________
published on the appropriate agency’s Web site if it has one or
_______________________________________________
are otherwise made readily available to the public.
_______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #10: Screening for Risk of Sexual Victimization and Abusiveness
Questions:
 Are all residents screened during
Obtaining information about residents (AP-1): During intake and periodically
throughout a resident’s confinement, employees obtain and use information about
intake (and at all subsequent
each resident’s personal history and behavior to keep all residents safe and free from
classification reviews) to assess
sexual abuse. At a minimum, employees attempt to ascertain information about prior
their risk of being sexually abused
sexual victimization or abusiveness; sexual orientation and gender identity; current
by other residents or having the
charges and offense history; age; level of emotional and cognitive development;
physical size/stature; mental illness or mental disabilities; intellectual/developmental
potential to be sexually abusive
disabilities; physical disabilities; and any other specific information about individual
towards other residents?
residents that may indicate heightened needs for supervision, additional safety
 Do you have medical and mental
precautions, or separation from certain other residents. This information may be
health practitioners available to
ascertained through conversations with residents at intake and medical and mental
health screenings; during classification assessments; and by reviewing court records,
talk with residents? If not, are
case files, facility behavioral records, and other relevant documentation from the
residents provided the opportunity
residents’ files. Medical and mental health practitioners are the only staff permitted
to discuss any safety concerns or
to talk with residents to gather information about their sexual orientation or gender
sensitive issues privately with
identity, prior sexual victimization, history of engaging in sexual abuse, mental
health status, and mental or physical disabilities. If the facility does not have
another employee?
medical or mental health practitioners available, residents are given an opportunity
Notes:__________________________
to discuss any safety concerns or sensitive issues privately with another employee.
________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:

Appendix D- Questionnaire/Juvenile Facilities

D-20

PREA Cost Impact Analysis


Do you use the screening information to inform
Placement of residents in housing, bed, program, education,
housing, bed, work, education, and program
and work assignments (AP-2): Employees use all
assignments with the goal of keeping separate those
information obtained about the resident at intake and
residents at high risk of being sexually victimized
subsequently to make placement decisions for each resident
from those at high risk of being sexually abusive?
on an individualized basis with the goal of keeping all residents safe and free from sexual abuse. When determining
o If yes, please explain.
housing, bed, program, education and work assignments for
Notes:__________________________________________
residents, employees must take into account a resident’s age;
_______________________________________________
the nature of his or her offense; any mental or physical
_______________________________________________
disability or mental illness; any history of sexual victimization or engaging in sexual abuse; his or her level of
_______________________________________________
emotional and cognitive development; his or her
_______________________________________________
identification as lesbian, gay, bisexual, or transgender; and
_______________________________________________
any other information obtained about the resident (AP-1).
_______________________________________________
Residents may be isolated from others only as a last resort
when less restrictive measures are inadequate to keep them
_______________________________________________
and other residents safe, and then only until an alternative
_______________________________________________
means of keeping all residents safe can be arranged.
_______________________________________________
_____________________________________________________________________________________________

Major Topic #11: Contract Modifications and/or Policy and Procedure Updates
Questions:
 Do you contract with other agencies or facilities for
the confinement of residents?
Contracting with other entities for the confinement of
residents (PP-2): If public juvenile justice agencies contract
o If so, how many facilities?
for the confinement of their residents, they do so only with
o What will it take to ensure these
private agencies or other entities, including other government
agencies/facilities are in compliance?
agencies, committed to eliminating sexual abuse in their
o Will this require any contract modifications?
facilities, as evidenced by their adoption of and compliance
o Do you think any contract modifications, as a
with the PREA standards. Any new contracts or contract
result of PREA, would result in greater costs to
renewals include the entity’s obligation to adopt and comply
you?
with the PREA standards and specify that the agency will
Notes:__________________________________________
monitor the entity’s compliance with these standards as part
_______________________________________________
of its general monitoring of the entity’s performance.
_______________________________________________
Questions:
 Do you maintain or attempt to enter into
Agreements with outside public entities and community service
memoranda of understanding (MOUs) or other
providers (RP-2): The agency maintains or attempts to enter into
agreements with an outside public entity or
memoranda of understanding (MOUs) or other agreements with an
outside public entity or office that is able to receive and immediately
office that is able to 1) receive and immediately
forward resident reports of sexual abuse to facility heads (RE-1). The
forward resident reports of sexual abuse to
agency also maintains or attempts to enter into MOUs or other
facility heads, 2) provide residents with
agreements with community service providers that are able to: (1)
confidential emotional support services related to
provide residents with emotional support services related to sexual
abuse and (2) help victims of sexual abuse during their transition
sexual abuse, and 3) help victims of sexual abuse
from incarceration to the community (RE-3, MM-3). The agency
during their transition from incarceration to the
maintains copies of agreements or documentation showing attempts
community?
to enter into agreements.
o Who currently provides these services (if
anyone)?
o Do you have any MOUs with them?
 If not, how much would it cost to develop these MOUs?
 If not possible to establish a MOU, do you document the attempt to enter an agreement?

Appendix D- Questionnaire/Juvenile Facilities

D-21

PREA Cost Impact Analysis
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
Agreements with outside law enforcement agencies (RP-3): If an agency
 Do you conduct your own criminal
does not have the legal authority to conduct criminal investigations or has
investigations or is it an outside legal
elected to permit an outside agency to conduct criminal or administrative
authority?
investigations of staff or residents, the agency maintains or attempts to
enter into a written MOU or other agreement specific to investigations of
o If outside, who is it?
sexual abuse with the law enforcement agency responsible for conducting
o Do you have an MOU with them?
investigations. The agency also maintains or attempts to enter into an
 If not, how much would it cost to
MOU with the designated State or local services agency with the
develop these MOUs?
jurisdiction and authority to conduct investigations related to the sexual
abuse of children within confinement facilities. When the agency already
 If not possible to establish a MOU,
has an existing agreement or long-standing policy covering
do you document the attempt to enter
responsibilities for all criminal investigations, including sexual abuse
an agreement?
investigations and child abuse investigations conducted by a designated
 If applicable, does it cover vulnerable
State or local services agency, it does not need to enter into new
agreements. The agency maintains copies of its agreements or
persons (e.g., under 18 years of age)?
documentation showing attempts to enter into agreements.
Notes:___________________________________
_________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Who are the authorities that prosecute violations?
Agreements with the prosecuting authority (RP-4):
o Do you have a MOU with them?
The agency maintains or attempts to enter into a
written MOU or other agreement with the au If not, how much would it cost to develop these
thority responsible for prosecuting violations of
MOUs?
criminal law. The agency maintains a copy of the
 If not possible to establish a MOU, do you document
agreement or documentation showing attempts to
the attempt to enter an agreement?
enter into an agreement.
Notes:_________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-22

PREA Cost Impact Analysis

Major Topic #12: Accommodating Special Needs
Questions:
 Do you ensure that residents who are LEP, deaf, or
Accommodating residents with special needs (PP-5):
disabled are able to report sexual abuse to staff directly
The agency ensures that residents who are limited
through interpretive technology or through non-resident
English proficient (LEP), deaf, or disabled are able to
interpreters?
report sexual abuse to staff directly, through interpretive
technology, or through non-resident interpreters.
o What services and tools do you employ?
Accommodations are made to convey all written
 What interpretive technology do you use?
information about sexual abuse policies, including how
 Do you provide services for the mentally
to report sexual abuse, verbally to residents who have
disabled?
limited reading skills or who are visually impaired.
Notes:_____________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #1: Medical Exams
Questions:
 Are Forensic medical exams provided free
Evidence protocol and forensic medical exams (RP-1): The agency
follows a uniform evidence protocol that maximizes the potential for
of charge to the victim?
obtaining usable physical evidence for administrative proceedings and
o Who provides the exams?
criminal prosecutions. The protocol must be adapted from or otherwise
o Who bears the cost?
based on the 2004 U.S. Department of Justice’s Office on Violence
Notes:_________________________________
Against Women publication ―A National Protocol for Sexual Assault
Medical Forensic Examinations, Adults/Adolescents,‖ subsequent
______________________________________
updated editions, or similarly comprehensive and authoritative protocols
______________________________________
developed after 2004. As part of the agency’s evidence collection
______________________________________
protocol, all victims of resident-on-resident sexually abusive penetration
______________________________________
or staff-on-resident sexually abusive penetration are provided access to
forensic medical exams performed by qualified forensic medical
______________________________________
examiners who are trained in the unique psychological and emotional
______________________________________
conditions of younger victims of sexual abuse. Forensic medical exams
______________________________________
are provided free of charge to the victim. The facility makes available
______________________________________
a victim advocate to accompany the victim through the forensic medical
exam process.
______________________________________
______________________________________
___________________________________________________________________________________________

Minor Topic #2: Conducting Investigations
Questions:
 Do you investigate all third-party reports of sexual
abuse?
Notes:____________________________________________
_________________________________________________
_________________________________________________
_________________________________________________
_________________________________________________
_________________________________________________
_________________________________________________
Appendix D- Questionnaire/Juvenile Facilities

Third-party reporting (RE-4): The facility receives and
investigates all third-party reports of sexual abuse and
refers all third-party reports of abuse to the designated
State or local services agency with the authority to
conduct investigations into allegations of sexual abuse
involving child victims (IN-1 and RP-4). At the conclusion of the investigation, the facility notifies in writing
the third-party individual who reported the abuse and the
resident named in the third-party report of the outcome of
the investigation. The facility distributes information on
how to report sexual abuse on behalf of a resident to
residents’ parents or legal guardians, attorneys, and the
public.

D-23

PREA Cost Impact Analysis
Questions:
 Do you notify victims and/or other complainants in
Duty to investigate (IN-1): The facility investigates all
writing of investigation outcomes and any disciplinary or
allegations of sexual abuse, including third-party and
criminal sanctions, regardless of the source of the
anonymous reports, and notifies victims and/or other
complainants in writing of investigation outcomes and
allegation?
any disciplinary or criminal sanctions, regardless of the
 Are all investigations carried through to completion,
source of the allegation. If additional parties were
regardless of whether the alleged abuser or victim
notified of the allegation (OR-1), the facility notifies
remains at the facility?
those parties in writing of investigation outcomes. All
investigations are carried through to completion,
Notes:____________________________________________
regardless of whether the alleged abuser or victim
__________________________________________________
remains at the facility and regardless of whether the
__________________________________________________
source of the allegation recants his or her allegation.
__________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:


Are allegations of sexual abuse substantiated if supported
by a preponderance of the evidence?

Evidence standard for administrative investigations (IN3): Allegations of sexual abuse are substantiated if
supported by a preponderance of the evidence.

Notes:____________________________________________
__________________________________________________
_____________________________________________________________________________________________

Minor Topic #3: Conducting Mental and
Medical Health Evaluations and Providing Care
Questions:
 Does the facility/jurisdiction provide ongoing
medical and/or mental health evaluations and
treatment to all known abusers of sexual abuse?
Notes:_________________________________________
______________________________________________
______________________________________________
______________________________________________
______________________________________________

Ongoing medical and mental health care for sexual abuse victims
and abusers (MM-3): The facility provides ongoing medical
and/or mental health evaluation and treatment to all known
victims of sexual abuse. The evaluation and treatment of sexual
abuse victims must include appropriate follow-up services,
treatment plans, and, when necessary, referrals for continued care
following their release from custody. The level of medical and
mental health care provided to resident victims must match the
community level of care generally accepted by the medical and
mental health professional communities. The facility conducts a
mental health evaluation of all known abusers and provides
treatment, as deemed necessary by qualified mental health
practitioners.

Minor Topic #4: Confidential Reporting
Questions:
Resident reporting (RE-1): The facility provides multiple internal ways
for residents to report easily, privately, and securely sexual abuse,
 How do victims confidentially report sexual
retaliation by other residents or staff for reporting sexual abuse, and
abuse (in multiple ways)?
staff neglect or violation of responsibilities that may have contributed
 Are there means to report sexual abuse to an
to an incident of sexual abuse. The facility also provides at least one
outside public entity?
way for residents to report the abuse to an outside public entity or office
not affiliated with the agency that has agreed to receive reports and
o Who is it?
forward them to the facility head (RP-3). Staff accepts reports made
o Does this entity charge a fee for such
verbally, in writing, anonymously, and from third parties and
services?
immediately puts into writing any verbal reports.
Notes:____________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-24

PREA Cost Impact Analysis

Questions:
 Please explain your policies/procedures for the
Exhaustion of administrative remedies (RE-2): Under agency
exhaustion of administrative remedies available to a
policy, a resident has exhausted his or her administrative remedies
with regard to a claim of sexual abuse either (1) when the agency
resident.
makes a final decision on the merits of the report of abuse
o Does it cover a 90 day period (unless you have
(regardless of whether the report was made by the resident, made
made a final determination earlier)?
by a third party, or forwarded from an outside official or office) or
o Does it cover a 48 hours requirement after a
(2) when 90 days have passed since the report was made,
whichever occurs sooner. A report of sexual abuse triggers the 90resident has notified any agency staff member
day exhaustion period regardless of the length of time that has
of his or her need for protection?
passed between the abuse and the report. A resident seeking
Notes:_______________________________________
immediate protection from imminent sexual abuse will be deemed
_____________________________________________
to have exhausted his or her administrative remedies 48 hours
after notifying any agency staff member of his or her need for
_____________________________________________
protection.
_____________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Juvenile Facilities

D-25

PREA Cost Impact Analysis

Community Corrections
Prison Rape Elimination Act (PREA) Cost Impact Analysis
Office of Justice Programs / Department of Justice
Site Visit Discussion Questionnaire
Version: Community Corrections
During this study led by Booz Allen Hamilton, several standards published by the National Prison Rape Elimination
Commission (NPREC) have led to increased attention and discussion whereas others have less of an impact. The
objective of this data gathering effort is to quantify, in monetary terms, the impact of the standards that may result in
the greatest impact on your operations, policies, and procedures. Responses gathered will inform the Attorney
General of the Department of Justice as he makes a final decision on the implementation of guidelines and
regulations due to be published in the summer of 2010. Please note that the data we gather will not be held to an
expectation of confidentiality and that by contract, information will be provided to the Office of Justice Programs by
name of organization.
The list below highlights eleven major topics followed by four minor topics as they relate to cost impacts or
difficulties with implementing the NPREC standards.

Major Topic #1: Cross-gender Pat Down Searches
Questions:
Limits to cross-gender viewing and searches (PP-4):
 Except in the case of an emergency, does your
Except in the case of emergency, the facility prohibits
jurisdiction/facility prohibit cross-gender pat downs?
cross-gender strip and visual body cavity searches.
Except in the case of emergency or other
o If not, what are the major reasons? Such as:
extraordinary or unforeseen circumstances, the facility
 A labor market that drives hiring opportunities?
restricts nonmedical staff from viewing
 State or Federal mandates for equal opportunity
defendants/offenders of the opposite gender who are
employment?
nude or performing bodily functions and similarly
restricts cross-gender pat down searches. Medical
 Union concerns?
practitioners conduct examinations of transgender
o How would male/female staffing levels need to be altered
individuals to determine their genital status only in
to prohibit cross-gender pat downs searches?
private settings and only when an individual’s genital
o Would you consider adjusting your pat down policy to
status is unknown.
comply with this standard? Specifically how?
o Are there other policies that you could employ to comply with this standard? How would you do this and
what are the risks?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-26

PREA Cost Impact Analysis
Major Topic #2: Defendant/offender Supervision - Physical Supervision
Questions:
 Over the past few years have you seen a variation or
Defendant/offender supervision (PP-3): Facility staff
provides the defendant/offender supervision necessary to
significant increase in the number of sexual abuse
protect defendants/offenders from sexual abuse. The
allegations
made,
either
defendant/offender-onfacility administrators and supervisors responsible for
defendant/offender or staff-on-defendant/offender?
reviewing critical incidents must examine areas in the
o Are you able to provide historical data regarding sexual
facility where sexual abuse has occurred or may be
likely to occur to assess whether physical barriers may
abuse statistics prevalent in your jurisdiction/facility
allow the abuse to go undetected, the adequacy of
(e.g., BJSs Survey on Sexual Violence, Form SSV-IA)?
staffing levels in those areas during different shifts, and
 Does your historical data suggest a decrease,
the need for monitoring technology to supplement
increase, or flat rate of sexual abuse incidents?
facility staff supervision. When problems or needs are
identified, facility administrators and supervisors take
 If a problem is/was evident, what is the best
corrective action (DC-3).
method for reducing sexual abuse incidents in your
facility?
 Please explain how you would go about implementing these changes.
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

____________________________________________________________________________________
Major Topic #3: PREA Coordinator
Questions:


Does your jurisdiction/facility have a PREA Coordinator to develop,
Zero tolerance of sexual abuse (PP-1): The
implement, and oversee efforts to comply with the PREA standards?
agency has a written policy mandating zero
o Note: The PREA coordinator is a full-time position in all
tolerance toward all forms of sexual abuse
and enforces that policy by ensuring all of its
agencies that operate their own community corrections facilities
facilities and community supervision
housing more than 500 defendants/offenders in one location.
functions comply with the PREA standards.
The PREA coordinator may be a part-time position in agencies
The agency employs or designates a PREA
that operate their own community corrections facilities with
coordinator to oversee agency efforts to
comply with the PREA standards.
less than 500 defendants/offenders in one location or those
agencies that solely contract with community corrections
providers for the placement of defendants/offenders. The PREA coordinator may also be a part-time
position in probation, pretrial, and parole agencies.
o Have you considered the cost of the PREA coordinator including base salary plus benefits?

Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-27

PREA Cost Impact Analysis
Major Topic #4: Training and Education
Questions:


Do you provide training to all employees
Employee training (TR-1): The agency or facility trains all employees to be
on sexual abuse prevention, detection,
able to fulfill their responsibilities under agency or facility sexual abuse
prevention, detection, and response policies and procedures; the PREA stanand response policies and procedures;
dards; and under relevant Federal, State, and local law. The agency or facility
the PREA standards; and relevant
trains all employees to communicate effectively and professionally with all
Federal, State, and local law?
defendants/offenders. Additionally, the agency or facility trains all employees
o What are the means of training?
on a defendant/offender’s right to be free from sexual abuse, the right of
defendants/offenders and employees to be free from retaliation for reporting
Class-room/
Computer
based?
sexual abuse, the dynamics of sexual abuse, and the common reactions of
What is the length?
sexual abuse victims. Current employees are educated as soon as possible
o Who
provides
the
training?
following the agency’s or facility’s adoption of the PREA standards, and the
Employees or contractors?
agency or facility provides periodic refresher information to all employees to
ensure that they know the agency’s or facility’s most current sexual abuse
 Do you provide periodic refresher
policies and procedures. The agency or facility maintains written
information to all employees?
documentation showing employee signatures verifying that employees
o How frequently do you provide
understand the training they have received.
refresher training?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_______

Questions:




Do you provide training to all volunteers and
Volunteer and contractor training (TR-2): The agency or facility
contractors
who
have
contact
with
ensures that all volunteers and contractors who have contact
defendant/offenders on sexual abuse prevention,
through the agency or facility with defendants/offenders have
been trained on their responsibilities under the agency’s sexual
detection, and response policies and procedures; the
abuse prevention, detection, and response policies and
PREA standards; and relevant Federal, State, and
procedures; the PREA standards; and relevant Federal, State, and
local law?
local law. The level and type of training provided to volunteers
o What are the means of training? Class-room/
and contractors is based on the services they provide and level of
contact they have with defendants/offenders, but all volunteers
Computer based? What is the length?
and contractors who have contact with defendants/offenders
o Who provides the training? Employees or
must be notified of the agency’s or facility’s zero-tolerance
contractors?
policy regarding sexual abuse. Volunteers must also be trained in
Notes:_____________________________________
how to report sexual abuse. The agency or facility maintains
written documentation showing volunteer and contractor
__________________________________________
signatures verifying that they understand the training they have
__________________________________________
received.
__________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-28

PREA Cost Impact Analysis
Questions:
 Following the intake process,
Defendant/offender education (TR-3): During the intake process into a facility or
do you provide comprehensive
upon initial stages of supervision, staff informs defendants/offenders of the agency’s
education to defendant/offenders on
or facility’s zero-tolerance policy regarding sexual abuse and how to report
incidents or suspicions of sexual abuse. Within a reasonably brief period of time, the
sexual abuse?
agency or facility provides comprehensive education to defendants/offenders
o What are the means of training?
regarding their right to be free from sexual abuse and to be free from retaliation for
Class-room/ Computer based?
reporting abuse, the dynamics of sexual abuse, the common reactions of sexual
o Who provides the training?
abuse victims, and agency or facility sexual abuse response policies and procedures.
Current defendants/offenders are educated as soon as possible following the
Employees or contractors?
agency’s or facility’s adoption of the PREA standards, and the agency or facility
o Is the training accessible to
provides periodic refresher information to all defendants/offenders to ensure that
defendant/offenders
with
they know the agency’s or facility’s most current sexual abuse policies and
disabilities?
procedures. Periodic refresher training may or may not be necessary in community
corrections facilities given the shorter time period defendants/offenders may reside
 Do you provide periodic refresher
in these facilities. The agency or facility provides defendant/offender education in
information
to
all
formats accessible to all defendants/offenders, including those who are LEP, deaf,
defendants/offenders?
visually impaired, or otherwise disabled as well as defendants/offenders who have
o What are the means? (e.g., poster
limited reading skills. All information provided to defendants/offenders is
communicated in a manner that is appropriate for the defendant/offender’s age and
boards, handbooks, closed circuit
level of cognitive and emotional development. The agency or facility maintains
TV)
written documentation of defendant/offender participation in these education
o How frequently do you provide
sessions.
refresher training?
Note: Periodic refresher training may or may not be necessary in community corrections facilities given the
shorter time period defendants/offenders may reside in these facilities.
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you ensure that investigators hired
Specialized training: Investigations (TR-4): In addition to the general
training provided to all employees (TR-1), the agency or facility ensures that
by your facility/agency receive sexual abuse
investigators employed by the agency or facility and conducting sexual
training
specifically
in
conducting
abuse investigations have received comprehensive and up-to-date training in
investigations in community corrections
conducting such investigations in community corrections settings.
settings?
Specialized training must include population-appropriate techniques for
interviewing sexual abuse victims, proper use of Miranda- and Garrity-type
o Where do they get their training?
warnings, sexual abuse evidence collection in community corrections
o How do you ensure the training meets
settings, and the criteria and evidence required to substantiate a case for
the PREA standard?
administrative action or prosecution referral. The agency or facility
Notes:__________________________________
maintains written documentation that investigators have completed the
required specialized training in conducting sexual abuse investigations.
_______________________________________
_______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-29

PREA Cost Impact Analysis

Questions:


Do you ensure your full and part-time
Specialized training: Medical and mental health care (TR-5): The
medical and mental health care practitioners
agency or facility ensures that all medical and mental health care
practitioners employed or contracted with by the community corrections
(either employed or contracted) have been
or pretrial, probation, or parole agency have been trained in how to
trained on how to detect and assess signs of
detect and assess signs of sexual abuse and how to preserve physical evisexual abuse and that all medical
dence of sexual abuse. All medical and mental health care practitioners
practitioners are trained on how to preserve
must be trained in how to respond effectively and professionally to
victims of sexual abuse and how and to whom to report allegations or
physical evidence of sexual abuse?
suspicions of sexual abuse. The agency or facility maintains
o Where do they get their training?
documentation that medical and mental health practitioners have
o How do you ensure the training meets
received this specialized training.
the PREA standard?
Notes:__________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #5: Victim Advocacy
Questions:
 Do you provide a victim advocate
Evidence protocol and forensic medical exams (RP-1): The agency or facility
follows a uniform evidence protocol that maximizes the potential for obtaining usable
to accompany the victim through
physical evidence for administrative proceedings and criminal prosecutions. The
the forensic medical exam
protocol must be adapted from or otherwise based on the 2004 U.S. Department of
process?
Justice’s Office on Violence Against Women publication ―A National Protocol for
o Who would provide this
Sexual Assault Medical Forensic Examinations, Adults/Adolescents,‖ subsequent
updated editions, or similarly comprehensive and authoritative protocols developed
service? A current employee
after 2004. As part of the agency’s or facility’s evidence collection protocol, the
or outside entity?
agency or facility refers all victims of defendant/offender-on-defendant/offender
Notes:_________________________
sexually abusive penetration or staff-on-defendant/offender sexually abusive
_______________________________
penetration to forensic medical exams performed by qualified forensic medical
examiners. Forensic medical exams are provided free of charge to the victim. The
_______________________________
agency or facility makes available or provides referrals to a victim advocate to
_______________________________
accompany the victim through the forensic medical exam process.
_______________________________
_______________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-30

PREA Cost Impact Analysis
Questions:
 Are defendant/offenders provided access
Defendant/offender access to outside confidential support services (RE-3):
to outside victim advocate services?
The facility provides defendants/offenders with access to outside victim
o Are there posters or pamphlets with
advocates for emotional support services related to sexual abuse. The
this
information
around
the
facility provides such access by giving defendants/offenders the current
mailing addresses and telephone numbers, including toll-free hotline
facility/jurisdiction?
numbers, of local, State, and/or national victim advocacy or rape crisis
o Who provides this outside victim
organizations and enabling reasonable communication between
advocacy support?
defendants/offenders and these organizations. The facility ensures that
o Do these services ensure entities
communications with such advocates are private, confidential, and
privileged, to the extent allowable by Federal, State, and local law. The
receive and immediately forward
facility informs defendants/offenders, prior to giving them access, of the
inmate reports of sexual abuse to
extent to which such communications will be private, confidential, and/or
facility heads, provide inmates with
privileged.
confidential
emotional
support
services, and help victims of sexual abuse during their transition from incarceration to the community?
o Is there a fee borne by you for these services or is it provided by the state, county or other non-profit
service (state-level sexual assault coalition or its local affiliates)?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #6: Gathering, Reviewing, and Reporting Sexual Abuse Data
Questions:


Do you have a review team to evaluate
Sexual abuse incident reviews (DC-1): The agency or facility treats all
each incident of sexual abuse?
instances of sexual abuse as critical incidents to be examined by a team of
o Do you prepare a report for each
upper management officials, with input from line supervisors, investigators,
and medical/mental health practitioners. The review team evaluates each
sexual abuse incident?
incident of sexual abuse to identify any policy, training, or other issues
o Does the report consider whether
related to the incident that indicate a need to change policy or practice to
incidents were motivated by racial or
better prevent, detect, and/or respond to incidents of sexual abuse. The
other group dynamics at the facility?
review team also considers whether incidents were motivated by racial or
other group dynamics. When incidents are determined to be motivated by
o Does
this
report
include
racial or other group dynamics, upper management officials immediately
recommendations for improvement?
notify the agency or facility head and begin taking steps to rectify those
Notes:_________________________________
underlying problems. The sexual abuse incident review takes place at the
______________________________________
conclusion of every sexual abuse investigation, unless the allegation was
determined to be unfounded. The review team prepares a report of its
______________________________________
findings and recommendations for improvement and submits it to the
______________________________________
agency or facility head.
______________________________________
______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-31

PREA Cost Impact Analysis
Questions:
 Do you prepare an annual report on
Data collection (DC-2): The agency or facility collects accurate,
aggregated sexual abuse data using a
uniform data for every reported incident of sexual abuse using a
standardized instrument and set of definitions
standardized instrument and set of definitions. The agency
aggregates the incident-based sexual abuse data at least annually.
(e.g., BJS survey on sexual violence)?
The incident-based data collected includes, at a minimum, the
o Does it include contracted facilities?
data necessary to answer all questions from the most recent
Notes:_____________________________________
version of the BJS Survey on Sexual Violence. Data are obtained
___________________________________________
from multiple sources, including reports, investigation files, and
sexual abuse incident reviews. The agency also obtains incident___________________________________________
based and aggregated data from every community corrections
___________________________________________
facility with which it contracts.
___________________________________________
___________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you review, analyze, and use
Data review for corrective action (DC-3): The agency reviews, analyzes,
all sexual abuse data to assess and
and uses all sexual abuse data, including incident-based and aggregated
improve the effectiveness of your sexual
data, to assess and improve the effectiveness of its sexual abuse prevention,
detection, and response policies, practices, and training. Using these data,
abuse prevention, detection, and
the agency identifies problem areas, including any racial dynamics
response
policies,
practices,
and
underpinning patterns of sexual abuse, takes corrective action on an
training?
ongoing basis, and, at least annually, prepares a report of its findings and
o Does this review identify problem
corrective actions for each facility as well as the agency as a whole. The
annual report also includes a comparison of the current year’s data and
areas
(including
any
racial
corrective actions with those from prior years and provides an assessment
dynamics, underlying patterns of
of the agency’s progress in addressing sexual abuse. The agency’s report is
sexual abuse, issues with particular
approved by the agency head, submitted to the appropriate governing body,
physical locations or times of day),
and made readily available to the public through its Web site or, if it does
not have one, through other means. The agency may redact specific
and take corrective action on an
material from the reports when publication would present a clear and
ongoing basis?
specific threat to the safety and security of a facility, but it must indicate
 Do you compare data from your annual
the nature of the material redacted.
report to data from the previous year?
o Do you provide an assessment of your progress?
 Is your annual data available to the public or on line?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-32

PREA Cost Impact Analysis

Questions:
 Is your sexual abuse data properly stored,
Data storage, publication, and destruction (DC-4): The
securely retained, and protected?
agency ensures that the collected sexual abuse data are
properly stored, securely retained, and protected. The agency
o What medium (electronic or paper) and where is
makes all aggregated sexual abuse data, including from
it stored?
facilities under its direct control and those with which it
o Unless otherwise authorized by local or state
contracts, readily available to the public at least annually
law, do you retain it for at least 10 years?
through its Web site or, if it does not have one, through other
means. Before making aggregated sexual abuse data publicly
Notes:________________________________________
available, the agency removes all personal identifiers from the
______________________________________________
data. The agency maintains sexual abuse data for at least 10
______________________________________________
years after the date of its initial collection unless Federal,
______________________________________________
State, or local law allows for the disposal of official
information in less than 10 years.
______________________________________________
______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #7: Background Checks for Hiring and Promotions
Questions:


Do you and your contractors
Hiring and promotion decisions (PP-6): The agency or facility does not hire or
contact all prior institutional
promote anyone who has engaged in sexual abuse in an institutional setting or who
has engaged in sexual activity in the community facilitated by force, the threat of
employers for information on
force, or coercion. Consistent with Federal, State, and local law, the agency or
substantiated allegations of sexual
facility makes its best effort to contact all prior institutional employers for
abuse?
information on substantiated allegations of sexual abuse and must run criminal
 Do you and your contractors run
background checks for all applicants and employees being considered for
promotion and examine and carefully weigh any history of criminal activity at work
criminal background checks for all
or in the community, including convictions or adjudications for domestic violence,
applicants and employees being
stalking, and sex offenses. The agency or facility also asks all applicants and
considered for promotion?
employees directly about previous misconduct during interviews and reviews.
Notes:__________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #8: Triennial Auditing of the NPREC standards
Questions:
 What types of audits and/or accreditations
do you undergo on a periodic basis?
o Would any of these be similar to what you
would expect for a PREA audit?
Notes:______________________________________
____________________________________________
____________________________________________
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Appendix D- Questionnaire/Community Corrections

Audits of standards (AU-1): The public agency ensures that all
community corrections facilities, including contract facilities and
pretrial, probation, and parole agencies are audited to measure
compliance with the PREA standards. Audits must be conducted at
least every three years by independent and qualified auditors. The
public or contracted agency allows the auditor to enter and tour
facilities, review documents, and interview staff and
defendants/offenders, as deemed appropriate by the auditor, to
conduct comprehensive audits. The public agency ensures that the
report of the auditor’s findings and the public or contracted
agency’s plan for corrective action (DC-3) are published on the
appropriate agency’s Web site if it has one or are otherwise made
readily available to the public.

D-33

PREA Cost Impact Analysis
_____________________________________________________________________________________________

Major Topic #9: Screening for Risk of Sexual Victimization and Abusiveness
Questions:
 Are all defendant/offenders screened
Screening for risk of victimization and abusiveness (SC-1): All
during intake to assess their risk of
defendants/offenders are screened during intake to assess their risk of being sexually
being sexually abused by other
abused by other defendants/offenders or sexually abusive toward other
defendant/offenders or having the
defendants/offenders. Employees must review information received with the
defendant/offender as well as discussions with the defendant/offender. Employees
potential to be sexually abusive
must conduct this screening using a written screening instrument tailored to the
towards other defendant/offenders?
gender of the population being screened. Although additional factors may be
 Do you have a written screening
considered, particularly to account for emerging research and the agency’s or
instrument tailored to the gender of
facility’s own data analysis, screening instruments must contain the criteria
described below. For defendants/offenders under the age of 18 or applicable age of
the population being screened?
majority within that jurisdiction, screening must be conducted by medical or mental
 For defendants/offenders under the
health practitioners. If the facility does not have medical or mental health
age of 18, are screenings conducted
practitioners available, these young defendants/offenders are given an opportunity to
by medical or mental health
participate in screenings in private.
practitioners?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you use the screening information to inform
Use of screening information (SC-2): Employees use information
housing, bed, work, education, and program
from the risk screening (SC-1) to inform housing, bed, work,
assignments with the goal of keeping separate
education, and program assignments. In many community
corrections facilities, it is difficult, if not impossible, to keep
those defendant/offenders at high risk of being
defendants/offenders totally separate or segregated from each
sexually victimized from those at high risk of
other. However, the facility can determine, based on the screening
being sexually abusive?
information, whether a particular defendant/offender should
o If yes, please explain.
receive greater supervision, should have more frequent contact
with staff, or is more appropriately housed in some alternative type
 In Community Corrections facilities, it may be
of placement. The facility makes individualized determinations
difficult, if not impossible, to separate
about how to ensure the safety of each defendant/offender.
defendants/offenders. In this event, does your
Lesbian, gay, bisexual, transgender, or other genderfacility provide vulnerable defendants/offenders
nonconforming defendants/offenders are not placed in particular
housing assignments solely on the basis of their sexual orientation,
with increased supervision and/or more frequent
genital status, or gender identity.
contact with staff?
Notes:______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
___________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-34

PREA Cost Impact Analysis
Major Topic #10: Contract Modifications and/or Policy and Procedure Updates
Questions:


Do you contract with other agencies or
Contracting with other entities for the confinement of defendant/offenders
facilities for the housing or supervision of
(PP-2): If public community corrections agencies contract for housing or
supervision of their defendants/offenders, they do so only with private
defendants/offenders?
agencies or other entities, including nonprofit or other government
o If so, how many facilities?
agencies, committed to eliminating sexual abuse, as evidenced by their
o What will it take to ensure these
adoption of and compliance with the PREA standards. Any new contracts
agencies/facilities are in compliance?
or contract renewals include the entity’s obligation to adopt and comply
with the PREA standards and specify that the public agency will monitor
o Will this require any contract
the entity’s compliance with these standards as part of its monitoring of the
modifications?
entity’s performance. Only in emergency circumstances, in which all
o Do
you
think
any
contract
reasonable attempts to find a private agency or other entity in compliance
modifications, as a result of PREA,
with the PREA standards have failed, should a contract be entered into with
an entity that fails to comply with these standards. The public agency must
would result in greater costs to you?
document these efforts.
Notes:_________________________________
______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
o Do you maintain or attempt to enter into
Agreements with outside public entities and community service providers
memoranda of understanding (MOUs)
(RP-2): The agency or facility maintains or attempts to enter into written
or other agreements with an outside
memoranda of understanding (MOUs) or other agreements with an
outside public entity or office that is able to receive and immediately
public entity or office that is able to 1)
forward defendant/offender reports of sexual abuse to agency or facility
receive and immediately forward inmate
heads (RE-1). The agency also maintains or attempts to enter into MOUs
reports of sexual abuse to facility heads,
or other agreements with community service providers that are able to: (1)
2) provide inmates with confidential
provide defendants/offenders with confidential emotional support services
related to sexual abuse and (2) help victims of sexual abuse during their
emotional support services related to
transition from a community corrections facility into the community. The
sexual abuse, and 3) help victims of
agency or facility maintains copies of written agreements or
sexual abuse during their transition from
documentation showing attempts to enter into agreements.
incarceration to the community?
o Who currently provides these services (if anyone)?
o Do you have any MOUs with them?
 If not, how much would it cost to develop these MOUs?
 If not possible to establish a MOU, do you document the attempt to enter an agreement?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-35

PREA Cost Impact Analysis
Questions:
Agreements with outside law enforcement agencies (RP-3): If an agency or
 Do you conduct your own criminal
facility does not have the legal authority to conduct criminal investigations or has
investigations or is it an outside legal
elected to permit an outside agency to conduct criminal or administrative
authority?
investigations of staff or defendants/offenders, the agency or facility maintains or
o If outside, who is it?
attempts to enter into a written MOU or other agreement specific to investigations
of sexual abuse with the law enforcement agency responsible for conducting
o Do you have a written agreement
investigations. If the agency or facility confines defendants/offenders under the
or an MOU with them?
age of 18 or applicable age of majority within that jurisdiction, or other
 If not, how much would it cost
defendants/offenders who fall under State and local vulnerable persons statutes,
to develop these MOUs?
the agency or facility maintains or attempts to enter into an MOU with the
designated State or local services agency with the jurisdiction and authority to
 If not possible to establish a
conduct investigations related to the sexual abuse of vulnerable persons within
MOU, do you document the
community corrections facilities. When the agency or facility already has an
attempt to enter an agreement?
existing agreement or long-standing policy covering responsibilities for all
 If applicable, does it cover
criminal investigations, including sexual abuse investigations, it does not need to
enter into a new agreement. The agency or facility maintains a copy of the written
vulnerable persons (e.g., under
agreement or documentation showing attempts to enter into an agreement.
18 years of age)?
Notes:______________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
Agreements with the prosecuting authority (RP-4): The
 Who are the authorities that prosecute violations?
agency or facility maintains or attempts to enter into a
o Do you have a MOU with them?
written MOU or other agreement with the authority
 If not, how much would it cost to develop
responsible for prosecuting violations of criminal law. The
these MOUs?
agency or facility maintains a copy of the written
agreement or documentation showing attempts to enter
 If not possible to establish a MOU, do you
into an agreement.
document the attempt to enter an agreement?
Notes:___________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #11: Accommodating Special Needs
Questions:
 Do you ensure that defendant/offenders who
Accommodating defendant/offenders with special needs (PP-5):
The agency or facility ensures that defendants/offenders who are
are LEP, deaf, or disabled are able to report sexual
limited English proficient (LEP), deaf, or disabled are able to
abuse to staff directly through interpretive
report sexual abuse to staff directly, through interpretive
technology or through non-defendant/offender
technology, or through nondefendant/offender interpreters.
interpreters?
Accommodations are made to convey all writ-ten information
about sexual abuse policies, including how to report sexual
o What services and tools do you employ?
abuse, verbally to defendants/offenders who have limited
 What interpretive technology do you use?
reading skills or who are visually impaired.
 Do you provide services for the mentally
disabled?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-36

PREA Cost Impact Analysis
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #1: Medical Exams
Questions:
 Are Forensic medical exams provided free of
Evidence protocol and forensic medical exams (RP-1): The agency or
charge to the victim?
facility follows a uniform evidence protocol that maximizes the potential for
o Who provides the exams?
obtaining usable physical evidence for administrative proceedings and
criminal prosecutions. The protocol must be adapted from or otherwise based
o Who bears the cost?
on the 2004 U.S. Department of Justice’s Office on Violence Against
Notes:__________________________________
Women publication ―A National Protocol for Sexual Assault Medical
_______________________________________
Forensic Examinations, Adults/Adolescents,‖ subsequent updated editions, or
_______________________________________
similarly comprehensive and authoritative protocols developed after 2004. As
part of the agency’s or facility’s evidence collection protocol, the agency or
_______________________________________
facility refers all victims of defendant/offender-on-defendant/offender
_______________________________________
sexually abusive penetration or staff-on-defendant/offender sexually abusive
_______________________________________
penetration to forensic medical exams performed by qualified forensic
_______________________________________
medical examiners. Forensic medical exams are provided free of charge to
the victim. The agency or facility makes available or provides referrals to a
_______________________________________
victim advocate to accompany the victim through the forensic medical exam
_______________________________________
process.
_______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #2: Conducting Investigations
Questions:
 Do you investigate all third-party reports of sexual
Third-party reporting (RE-4): The agency or facility
abuse?
receives and investigates all third-party reports of sexual
abuse (IN-1). At the conclusion of the investigation, the
Notes:_____________________________________________
agency or facility notifies in writing the third-party
__________________________________________________
individual who reported the abuse and the
__________________________________________________
defendant/offender named in the third-party report of the
__________________________________________________
outcome of the investigation. The agency or facility
distributes publicly information on how to report sexual
__________________________________________________
abuse on behalf of a defendant/offender.
__________________________________________________
__________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you notify victims and/or other complainants
Duty to investigate (IN-1): The agency or facility
in writing of investigation outcomes and any
investigates all allegations of sexual abuse, including
disciplinary or criminal sanctions, regardless of the
third-party and anonymous reports, and notifies victims
and/or other complainants in writing of investigation outsource of the allegation?
comes and any disciplinary or criminal sanctions,
 Are all investigations carried through to completion,
regardless of the source of the allegation. All
regardless of whether the alleged abuser or victim
investigations are carried through to completion,
remains at the facility?
regardless of whether the alleged abuser or victim
remains at the facility or under supervision.
Notes:___________________________________________
_________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-37

PREA Cost Impact Analysis
Questions:
 Are allegations of sexual abuse substantiated if
supported by a preponderance of the evidence?

Evidence standard for administrative investigations (IN3): Allegations of sexual abuse are substantiated if
supported by a preponderance of the evidence or a lesser
standard if allowed under agency or facility policy or
State law.

Notes:____________________________________________
_________________________________________________
_________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #3: Conducting Mental and Medical Health Evaluations and Providing Care
Questions:
 Does the facility/jurisdiction provide
Ongoing medical and mental health care fox sexual abuse victims and
ongoing medical and/or mental health
abusers (MM-2): The facility provides ongoing medical and/or mental
evaluations and treatment to all known
health evaluation and treatment to all known victims of sexual abuse. The
abusers of sexual abuse?
evaluation and treatment of sexual abuse victims must include
appropriate follow-up services, treatment plans, and, when necessary,
Notes:__________________________________
referrals for continued care following their release from a community
_______________________________________
corrections facility. The level of medical and mental health care provided
_______________________________________
to defendant/offender victims must match the community level of care
_______________________________________
generally accepted by the medical and mental health professional
communities. The facility conducts a mental health evaluation of all
_______________________________________
known abusers and provides treatment, as deemed necessary by qualified
_______________________________________
mental health practitioners.
_______________________________________
_____________________________________________________________________________________________

Minor Topic #4: Confidential Reporting
Questions:
 How do victims confidentially report
Defendant/offender reporting (RE-1): The agency or facility provides
sexual abuse (in multiple ways)?
multiple internal ways for defendants/offenders to report easily,
 Are there means to report sexual abuse to an
privately, and securely sexual abuse, retaliation by other
outside public entity?
defendants/offenders or staff for reporting sexual abuse, and staff
neglect or violation of responsibilities that may have contributed to an
o Who is it?
incident of sexual abuse. The agency or facility also provides at least
o Does this entity charge a fee for such
one way for defendants/offenders to report the abuse to an outside
services?
pubic entity or office not affiliated with the agency that has agreed to
Notes:____________________________________
receive reports and forward them to the agency or facility head (RP-2),
except when a defendant/offender requests confidentiality. Staff accepts
__________________________________________
reports made verbally, in writing, anonymously, and from third parties
__________________________________________
and immediately puts into writing any verbal reports.
__________________________________________
__________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-38

PREA Cost Impact Analysis
Questions:
 Please explain your policies/procedures for the
Exhaustion of administrative remedies (RE-2): Under agency or
exhaustion of administrative remedies available to
facility policy, a defendant/offender has exhausted his or her
an defendant/offender.
administrative remedies with regard to a claim of sexual abuse
either (1) when the agency or facility makes a final decision on
o Does it cover a 90 day period (unless you have
the merits of the report of abuse (regardless of whether the report
made a final determination earlier)?
was made by the defendant/offender, made by a third party, or
o Does it cover a 48 hours requirement after an
forwarded from an outside official or office) or (2) when 90 days
defendant/offender has notified any agency
have passed since the report was made, whichever occurs sooner.
A report of sexual abuse triggers the 90-day exhaustion period
staff member of his or her need for protection?
regardless of the length of time that has passed between the abuse
Notes:_______________________________________
and the report. A defendant/offender seeking immediate
____________________________________________
protection from imminent sexual abuse will be deemed to have
____________________________________________
exhausted his or her administrative remedies 48 hours after
notifying any agency or facility staff member of his or her need
____________________________________________
for protection.
____________________________________________
____________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Community Corrections

D-39

PREA Cost Impact Analysis

Lockups
Prison Rape Elimination Act (PREA) Cost Impact Analysis
Office of Justice Programs / Department of Justice
Site Visit Discussion Questionnaire
Version: Lockups
During this study led by Booz Allen Hamilton, several standards published by the National Prison Rape Elimination
Commission (NPREC) have led to increased attention and discussion whereas others have less of an impact. The
objective of this data gathering effort is to quantify, in monetary terms, the impact of the standards that may result in
the greatest impact on your operations, policies, and procedures. Responses gathered will inform the Attorney
General of the Department of Justice as he makes a final decision on the implementation of guidelines and
regulations due to be published in the summer of 2010. Please note that the data we gather will not be held to an
expectation of confidentiality and that by contract, information will be provided to the Office of Justice Programs by
name of organization.
The list below highlights twelve major topics followed by three minor topics as they relate to cost impacts or
difficulties with implementing the NPREC standards.

Major Topic #1: Cross-gender Pat Down Searches
Questions:
Limits to cross-gender viewing and searches (PP-5):
 Except in the case of an emergency, does your
Except in the case of emergency, the agency prohibits
jurisdiction/facility prohibit cross-gender pat downs?
cross-gender strip and visual body cavity searches.
o If not, what are the major reasons? Such as:
Except in the case of emergency or other
 A labor market that drives hiring opportunities?
extraordinary or unforeseen circumstances, the agency
restricts law enforcement staff from viewing detainees
 State or Federal mandates for equal opportunity
of the opposite gender who are nude or performing
employment?
bodily functions and similarly restricts cross-gender
 Union concerns?
pat down searches. Any examination to determine the
o How would male/female staffing levels need to be
genital status of a detainee must be conducted in a
private setting by a medical practitioner and only
altered to prohibit cross-gender pat downs searches?
when the genital status is unknown to the agency.
o Would you consider adjusting your pat down policy to
comply with this standard? Specifically how?
o Are there other policies that you could employ to comply with this standard? How would you do this and
what are the risks?
Notes:____________________________________________________________________________ _________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #2: Inmate/Resident Supervision Physical Supervision
Questions:
 Over the past few years have you seen a variation or
significant increase in the number of sexual abuse
allegations made, either detainee-on-detainee or staff-ondetainee?
o Are you able to provide historical data regarding
sexual abuse statistics prevalent in your

Appendix D- Questionnaire/Lockups

Detainee supervision (PP-3): Law enforcement staff
provides the detainee supervision necessary to protect
detainees from sexual abuse. The upper management
officials responsible for reviewing critical incidents must
examine areas in the lockup where sexual abuse has
occurred to assess whether physical barriers may have
enabled the abuse, the adequacy of staffing levels in
those areas during different shifts, and the need for
monitoring technology to supplement law enforcement
staff supervision (DC-1). When problems or needs are
identified, the agency takes corrective action (DC-3).

D-40

PREA Cost Impact Analysis
jurisdiction/facility (e.g., BJSs Survey on Sexual Violence, Form SSV-IA)?
 Does your historical data suggest a decrease, increase, or flat rate of sexual abuse incidents?
 If a problem is/was evident, what is the best method for reducing sexual abuse incidents in your
facility?
 Please explain how you would go about implementing these changes.
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #3: Inmate/Resident Supervision - Technical Supervision
Questions:
 Does your jurisdiction/facility currently have video monitoring in
Assessment and Use of Monitoring
place?
Technology (PP-8): The agency uses video
o If so, do you believe your jurisdiction/facility is adequately
monitoring systems and other cost-effective
suited to reduce sexual abuse incidents?
and appropriate technology to supplement its
sexual abuse prevention, detection, and
o Please explain its coverage, review and archiving.
response efforts. The agency assesses, at least
o If it is not considered sufficient, what cost would you estimate
annually, the feasibility of and need for new
for this technology?
or additional monitoring technology and
develops a plan for securing such technology.
 Do you employ other methods of technology supervision (e.g.,
Radio Frequency Identification bracelets)?
 Do you annually assess the feasibility of your currently technology, including developing a plan for securing
new technology?
o If not, do you anticipate a cost associated with conducting this assessment?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #4: PREA Coordinator
Questions:
 Does your jurisdiction/facility have a PREA Coordinator to develop,
implement, and oversee efforts to comply with the PREA standards?
o Note: The PREA coordinator may be a full or part-time
position.
o Have you considered the cost of the PREA coordinator
including base salary plus benefits?

Zero tolerance of sexual abuse (PP-1): The
agency has a written policy mandating zero
tolerance toward all forms of sexual abuse
and enforces that policy by ensuring all of its
facilities comply with the PREA standards.
The agency employs or designates a PREA
coordinator to develop, implement, and
oversee agency efforts to comply with the
PREA standards.

Notes:_____________________________________________________
__________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Lockups

D-41

PREA Cost Impact Analysis
Major Topic #5: Training and Education
Questions:
 Do you provide training to all employees
Employee and volunteer training (TR-1): The agency trains all lockup
employees and any volunteers who have contact with detainees to be able to
and volunteers on sexual abuse
fulfill their responsibilities under agency sexual abuse prevention, detection,
prevention, detection, and response
and response policies and procedures; the PREA standards; and under relevant
policies and procedures; the PREA
Federal, State, and local law. The agency trains all lockup employees and
standards; and relevant Federal, State,
volunteers who have contact with detainees to communicate effectively and
professionally with all detainees. Current lockup employees and volunteers are
and local law?
educated as soon as possible following the agency’s adoption of the PREA
o What are the means of training?
standards, and the agency provides periodic refresher information to all lockup
Class-room/
Computer
based?
employees and volunteers to ensure that they know the agency’s most current
What is the length?
sexual abuse policies and procedures. The agency maintains written
documentation showing lockup employee and volunteer signatures verifying
o Who
provides
the
training?
that they understand the training they have received.
Employees or contractors?
 Do you provide periodic refresher
information to all employees?
o How frequently do you provide refresher training?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do employees notify all detainees of the agency’s
Detainee, attorney, contractor, and inmate worker notification of
zero-tolerance policy?
the agency’s zero-tolerance policy (TR-2): Employees notify all
detainees of the agency’s zero-tolerance policy regarding sexual
o Does the facility ensure that attorneys,
abuse during intake. The agency ensures that attorneys,
contractors, and inmate workers are informed of
contractors, and inmate workers are informed of the agency’s
the agency’s zero-tolerance policy upon entering
zero-tolerance policy regarding sexual abuse upon entering the
lockup.
the lockup?
Notes:_________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you ensure sexual abuse training has been
Specialized training: Investigations (TR-3): In addition to the general
training provided to all employees and volunteers (TR-1), the agency
provided to investigators specifically conducting
ensures that law enforcement staff who investigate sexual abuse in
investigations in confinement settings?
lockups have received comprehensive and up-to-date training in
o Where do they get their training?
conducting such investigations in confinement settings. Specialized
o How do you ensure the training meets the
training must include techniques for interviewing sexual abuse victims,
proper use of Miranda- and Garrity-type warnings, sexual abuse
PREA standard?
evidence collection in confinement settings, and the criteria and
evidence required to substantiate a case for administrative action or
prosecution referral. The agency maintains written documentation that
investigators have completed the required specialized training in
conducting sexual abuse investigations.

Appendix D- Questionnaire/Lockups

D-42

PREA Cost Impact Analysis
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
____________________________

Major Topic #6: Victim Advocacy
Questions:
 Do you provide a victim advocate to
Evidence protocol and forensic medical exams (RP-1): When investigating
accompany the victim through the
allegations of sexual abuse in a lockup, the agency follows a uniform evidence
forensic medical exam process?
protocol that maximizes the potential for obtaining usable physical evidence
o Who would provide this service? A
for administrative proceedings and criminal prosecutions. The protocol must be
current employee or outside entity?
adapted from or otherwise based on the 2004 U.S. Department of Justice’s
Office on Violence Against Women publication ―A National Protocol for
Notes:_______________________________
Sexual Assault Medical Forensic Examinations, Adults/Adolescents,‖ subse____________________________________
quent updated editions, or similarly comprehensive and authoritative protocols
____________________________________
developed after 2004. As part of the agency’s evidence collection protocol, all
____________________________________
victims of detainee-on-detainee sexually abusive penetration or staff-ondetainee sexually abusive penetration are provided with access and
____________________________________
transportation to a community medical provider served by qualified forensic
____________________________________
medical examiners. Forensic medical exams are provided free of charge to the
____________________________________
victim. The agency makes available a victim advocate to accompany the
____________________________________
victim through the forensic medical exam process.
____________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #7: Gathering, Reviewing, and Reporting Sexual Abuse Data
Questions:
 Do you have a review team to evaluate each incident of sexual abuse?
o Do you prepare a report for each sexual
Sexual abuse incident reviews (DC-1): The agency treats all instances of
abuse incident?
sexual abuse as critical incidents to be examined by a group of upper
o Does the report consider whether
management officials, with input from line supervisors and investigators.
incidents were motivated by racial or
The review team evaluates each incident of sexual abuse to identify any
other group dynamics at the facility?
policy, training, or other issues related to the incident that indicate a need to
o Does
this
report
include
change policy or practice to better prevent, detect, and/or respond to
recommendations for improvement?
incidents of sexual abuse. The review team also considers whether
incidents were motivated by racial or other group dynamics at the lockup.
Notes:__________________________________
When incidents are determined to be motivated by racial or other group
_______________________________________
dynamics, upper management officials immediately notify the agency head
_______________________________________
and begin taking steps to rectify those underlying problems. The sexual
_______________________________________
abuse incident review takes place at the conclusion of every sexual abuse
_______________________________________
investigation, unless the allegation was determined to be unfounded. The
_______________________________________
review team prepares a report of its findings and recommendations for
improvement and submits it to the agency head.
_______________________________________
_______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Lockups

D-43

PREA Cost Impact Analysis
Questions:
 Do you prepare an annual report on aggregated
Data collection (DC-2):
sexual abuse data using a standardized instrument
The agency collects accurate, uniform data for every reported
and set of definitions (e.g., BJS survey on sexual
incident of sexual abuse using a standardized instrument and
set of definitions. The agency aggregates the incident-based
violence)?
sexual abuse data at least annually. The incident-based data
o Does it include contracted facilities?
collected includes, at a minimum, the data necessary to
Notes:________________________________________
answer all questions from the most recent version of the BJS
______________________________________________
Survey on Sexual Violence. Data are obtained from multiple
sources, including reports, investigation files, and sexual
______________________________________________
abuse incident reviews. The agency also obtains incident______________________________________________
based and aggregated data from every agency with which it
______________________________________________
contracts for the confinement of its detainees.
______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you review, analyze, and use all sexual
Data review for corrective action (DC-3):
abuse data to assess and improve the
The agency reviews, analyzes, and uses all sexual abuse data, including
effectiveness of your sexual abuse
incident-based and aggregated data, to assess and improve the
effectiveness of its sexual abuse prevention, detection, and response
prevention, detection, and response policies,
policies, practices, and training. Using these data, the agency identifies
practices, and training?
problem areas, including any racial or other group dynamics
o Does this review identify problem areas
underpinning patterns of sexual abuse, takes corrective action on an
(including
any
racial
dynamics,
ongoing basis, and, at least annually, prepares a report of its findings
and corrective actions for each lockup as well as the agency as a whole.
underlying patterns of sexual abuse,
The annual report also includes a comparison of the current year’s data
issues with particular physical locations
and corrective actions with those from prior years and provides an
or times of day), and take corrective
assessment of the agency’s progress in addressing sexual abuse. The
action on an ongoing basis?
agency’s report is approved by the agency head, submitted to the
appropriate legislative body, and made readily available to the public
 Do you compare data from your annual report
through its Web site or, if it does not have one, through other means.
to data from the previous year?
The agency may redact specific material from the reports when
o Do you provide an assessment of your
publication would present a clear and specific threat to the safety and
progress?
security of an agency, but it must indicate the nature of the material
redacted.
 Is your annual data available to the public or
on line?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Lockups

D-44

PREA Cost Impact Analysis
Questions:
Data storage, publication, and destruction (DC-4): The
 Is your sexual abuse data properly stored, securely
agency ensures that the collected sexual abuse data are
retained, and protected?
properly stored, securely retained, and protected. The
o What medium (electronic or paper) and where is it
agency makes all aggregated sexual abuse data, from
stored?
lockups under its direct control and those entities with
which it contracts, readily available to the public at least
o Unless otherwise authorized by local or state law, do
annually through its Web site or, if it does not have one,
you retain it for at least 10 years?
through other means. Before making aggregated sexual
Notes:____________________________________________
abuse data publicly available, the agency removes all
__________________________________________________
personal identifiers from the data. The agency maintains
sexual abuse data for at least 10 years after the date of its
__________________________________________________
initial collection unless Federal, State, or local law allows
__________________________________________________
for the disposal of official information in less than 10
__________________________________________________
years.
__________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________

Major Topic #8: Background Checks for Hiring and Promotions
Questions:
 Do you and your contractors contact all
prior institutional employers for
Hiring and promotion decisions (PP-7): The agency does not hire or promote
anyone who has engaged in sexual abuse in an institutional setting or who has
information on substantiated allegations
engaged in sexual activity in the community facilitated by force, the threat of
of sexual abuse?
force, or coercion. Consistent with Federal, State, and local law, the agency
 Do you and your contractors run
makes its best effort to contact all prior institutional employers for
criminal background checks for all
information on substantiated allegations of sexual abuse; must run
criminal background checks for all applicants and employees being
applicants
and
employees
being
considered for promotion; and must examine and carefully weigh any history
considered for promotion?
of criminal activity at work or in the community, including convictions for
Notes:_______________________________
domestic violence, stalking, and sex offenses. The agency also asks all
____________________________________
applicants and employees directly about previous misconduct during interviews
and reviews.
____________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #9: Triennial Auditing of the NPREC standards
Questions:
 What types of audits and/or accreditations do you
undergo on a periodic basis?
o Would any of these be similar to what you would
expect for a PREA audit?
Notes:___________________________________________
________________________________________________
________________________________________________
________________________________________________
________________________________________________

Appendix D- Questionnaire/Lockups

Audits of standards (AU-1): The public agency ensures that
all of its lockups, including contract facilities, are audited to
measure compliance with the PREA standards. Audits must be
conducted at least every three years by independent and
qualified auditors. The public or contracted agency allows the
auditor to enter and tour lockups, review documents, and
interview staff and detainees, as deemed appropriate by the
auditor, to conduct comprehensive audits. The public agency
ensures that the report of the auditor’s findings and the public
or contracted agency’s plan for corrective action (DC-3) are
published on the appropriate agency’s Web site if it has one or
are otherwise made readily available to the public.

D-45

PREA Cost Impact Analysis
Major Topic #10: Screening for Risk of Sexual Victimization and Abusiveness
Questions:
 Are all detainees screened during
Heightened protection for vulnerable detainees (PP-4): Any intake screening or
intake (and at all subsequent
assessment includes consideration of a detainee’s potential vulnerability to sexual
classification reviews) to assess their
abuse. When vulnerabilities are identified, law enforcement staff provides
risk of being sexually abused by
heightened protection to vulnerable detainees, which may require continuous direct
sight and sound supervision or single-cell housing. Absent intake screenings or
other inmates or having the potential
assessments, any time a law enforcement staff member observes any physical or
to be sexually abusive towards other
behavioral characteristics of a detainee that suggest he or she may be vulnerable to
inmates?
sexual abuse, the staff member provides sufficient protection to that detainee to
 Absent
intake
screenings
or
prevent sexual abuse.
assessments, do staff members
provide sufficient protection to a detainee that is observed to have any physical or behavioral characteristics that
suggest he or she may be vulnerable to sexual abuse?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #11: Contract Modifications and/or Policy and Procedure Updates
Questions:
 Do you contract with other agencies or facilities for
the confinement of detainees?
Contracting with other entities for the confinement of
o If so, how many facilities?
detainees (PP-2):
If law enforcement agencies contract for the confinement of
o What will it take to ensure these
their detainees, they do so only with private agencies or other
agencies/facilities are in compliance?
entities, including other government agencies, committed to
o Will this require any contract modifications?
eliminating sexual abuse in their lockups, as evidenced by
o Do you think any contract modifications, as a
their adoption of and compliance with the PREA standards.
Any new contracts or contract renewals include the entity’s
result of PREA, would result in greater costs to
obligation to adopt and comply with the PREA standards and
you?
specify that the law enforcement agency will monitor the
Notes:__________________________________________
entity’s compliance with these standards as part of its
_______________________________________________
monitoring of the entity’s performance.
_______________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Lockups

D-46

PREA Cost Impact Analysis
Questions:
 Do you conduct your own criminal
Agreements with outside law enforcement agencies (RP-2):
investigations or is it an outside legal
If an agency has elected to permit another law enforcement agency to
authority?
conduct criminal or administrative investigations of allegations of sexual
o If outside, who is it?
abuse in its lockups, the agency maintains or attempts to enter into a
written memorandum of understanding (MOU) or other agreement
o Do you have an MOU with them?
specific to investigations of sexual abuse in lockups with the outside law
 If not, how much would it cost to
enforcement agency responsible for conducting investigations. If the
develop these MOUs?
agency confines detainees under the age of 18 or other detainees who fall
 If not possible to establish a MOU,
under State and local vulnerable persons statutes, the agency maintains or
attempts to enter into an MOU with the designated State or local services
do you document the attempt to
agency with the jurisdiction and authority to conduct investigations
enter an agreement?
related to the sexual abuse of vulnerable persons within confinement
 If applicable, does it cover
facilities. When the agency already has an existing agreement or longvulnerable persons (e.g., under 18
standing policy covering responsibilities for all criminal investigations,
including sexual abuse investigations, it does not need to enter into a new
years of age)?
agreement. The agency maintains a copy of the agreement or
Notes:__________________________________
documentation showing attempts to enter into an agreement.
_______________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
 Who are the authorities that prosecute violations?
Agreements with the prosecuting authority (RP-3):
o Do you have a MOU with them?
The agency maintains or attempts to enter into a
 If not, how much would it cost to develop these
written MOU or other agreement with the authority responsible for prosecuting violations of
MOUs?
criminal law. The agency maintains a copy of the
 If not possible to establish a MOU, do you document
agreement or documentation showing attempts to
the attempt to enter an agreement?
enter into an agreement.
Notes:________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Major Topic #12: Accommodating Special Needs
Questions:
 Do you ensure that detainees who are LEP, deaf, or
disabled are able to report sexual abuse to staff directly
through interpretive technology or through non-detainee
interpreters?
o What services and tools do you employ?
 What interpretive technology do you use?
 Do you provide services for the mentally
disabled?
Notes:_____________________________________________

Appendix D- Questionnaire/Lockups

Accommodating inmates with special needs (PP-6):
The agency ensures that detainees who are LEP, deaf, or
disabled are able to report sexual abuse to staff directly,
through interpretive technology, or through nondetainee interpreters. Accommodations are made to
convey all written information about sexual abuse
policies, including how to report sexual abuse, verbally
to detainees who have limited reading skills or who are
visually impaired.

D-47

PREA Cost Impact Analysis
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #1: Medical Exams
Questions:
 Are Forensic medical exams provided free of
charge to the victim?
o Who provides the exams?
o Who bears the cost?
Notes:___________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________
_________________________________________

Evidence protocol and forensic medical exams (RP-1): When
investigating allegations of sexual abuse in a lockup, the agency follows
a uniform evidence protocol that maximizes the potential for obtaining
usable physical evidence for administrative proceedings and criminal
prosecutions. The protocol must be adapted from or otherwise based on
the 2004 U.S. Department of Justice’s Office on Violence Against
Women publication ―A National Protocol for Sexual Assault Medical
Forensic Examinations, Adults/Adolescents,‖ subsequent updated
editions, or similarly comprehensive and authoritative protocols
developed after 2004. As part of the agency’s evidence collection
protocol, all victims of detainee-on-detainee sexually abusive penetration
or staff-on-detainee sexually abusive penetration are provided with
access and transportation to a community medical provider served by
qualified forensic medical examiners. Forensic medical exams are
provided free of charge to the victim. The agency makes available a
victim advocate to accompany the victim through the forensic medical
exam process.

Minor Topic #2: Conducting Investigations
Questions:
Third-party reporting (RE-3): The agency receives and
 Do you investigate all third-party reports of sexual abuse?
investigates all third-party reports of sexual abuse (IN-1).
At the conclusion of the investigation, the agency notifies
Notes:____________________________________________
in writing the third-party individual who reported the
__________________________________________________
abuse and the detainee named in the third-party report of
__________________________________________________
the outcome of the investigation. The agency publicly
__________________________________________________
distributes or posts information on how to report sexual
abuse on behalf of a detainee.
__________________________________________________
_____________________________________________________________________________________________
Questions:
 Do you notify victims and/or other complainants in
Duty to investigate (IN-1): The agency investigates all
allegations of sexual abuse, including third-party and
writing of investigation outcomes and any disciplinary
anonymous reports, and notifies victims and other
or criminal sanctions, regardless of the source of the
complainants in writing of investigation outcomes and
allegation?
any disciplinary or criminal sanctions, regardless of the
 Are all investigations carried through to completion,
source of the allegation. All investigations are carried
through to completion, regardless of whether the alleged
regardless of whether the alleged abuser or victim
abuser or victim remains at the lockup.
remains at the facility?
Notes:___________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Lockups

D-48

PREA Cost Impact Analysis
Questions:


Are allegations of sexual abuse substantiated if supported
by a preponderance of the evidence?

Evidence standard for administrative investigations (IN3): Allegations of sexual abuse are substantiated if
supported by a preponderance of the evidence.

Notes:_____________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Minor Topic #3: Confidential Reporting
Questions:
 How do victims confidentially report sexual
Detainee reporting (RE-1): The agency provides multiple ways for
detainees to report easily, privately, and securely sexual abuse,
abuse (in multiple ways)?
retaliation by other detainees or staff for reporting sexual abuse, and
 Are there means to report sexual abuse to an
staff neglect or violation of responsibilities that may have contributed
outside public entity?
to an incident of sexual abuse. Staff accepts reports made verbally, in
o Who is it?
writing, anonymously, and from third parties and immediately puts into
writing any verbal reports.
o Does this entity charge a fee for such
services?
Notes:________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Questions:
Exhaustion of administrative remedies (RE-2): Under agency
 Please explain your policies/procedures for the
policy, a detainee has exhausted his or her administrative
exhaustion of administrative remedies available to
remedies with regard to a claim of sexual abuse either (1) when
a detainee.
the agency makes a final decision on the merits of the report of
abuse (regardless of whether the report was made by the detainee,
o Does it cover a 90 day period (unless you
made by a third party, or forwarded from an outside official or
have made a final determination earlier)?
office) or (2) when 90 days has passed since the report was made,
o Does it cover a 48 hours requirement after a
whichever occurs sooner. A report of sexual abuse triggers the 90detainee has notified any agency staff
day exhaustion period regardless of the length of time that has
passed between the abuse and the report. A detainee seeking
member of his or her need for protection?
immediate protection from imminent sexual abuse will be deemed
Notes:______________________________________
to have exhausted his or her administrative remedies 48 hours
____________________________________________
after notifying any agency staff member of his or her need for
____________________________________________
protection.
____________________________________________
_____________________________________________________________________________________________

Appendix D- Questionnaire/Lockups

D-49

PREA Cost Impact Analysis

Appendix E – Data Reports
Jails and Prisons

Cost Impact Study Questionnaire
[Adult Prisons and Jails]
BOOZ ALLEN HAMILTON

[The following questionnaire consists of two parts. Part I identifies Nation Prison Rape Elimination Commission (NPREC) standards that require
an estimated cost impact (if any), accompanied by a detailed explanation of that cost impact or reason for being in compliance. Part II identifies
Appendix E - Data Reports/Prisons and Jails

E-1

PREA Cost Impact Analysis
the remaining standards outlined by NPREC to gauge a level of compliance and a detailed reason for those standards that the jurisdiction may find
to be noncompliant with.]

Part I. The objective of Part I is to obtain quantifiable cost data for each standard that impacts your day-to-day operations. Before providing a response to each
question below, please reference the Standard column and review the definition of each standard (found in the questionnaire and the NPREC Standards
Prevention, Detection, Response, and Monitoring of Sexual Abuse in Adult Prisons and Jails). This form has been pre-populated using the information we
gathered during our site visit to your facility/jurisdiction. Each standard is labeled as compliant "Y" or noncompliant "N." For quality control purposes, please
review and validate the explanation provided for both ―Y‖ and ―N‖ standards. For those standards with an "N", please provide a cost estimate in the ―Cost
Impact‖ column with an explanation supporting your cost estimate and assumptions. If there are multiple costs for one standard, please itemize your costs. All
cost estimates should be best guesses and do not have to be supported with detailed documentation but should adhere to a test of reasonability.

#

Standard

Question

1

PP-4

Except in the case of an emergency, does your jurisdiction/facility prohibit cross-gender pat downs?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




2

PP-3

How would male/female staffing levels need to be altered to prohibit cross-gender pat down
searches?
Would this require an increased level of effort (LOE)?
Are there other policies, besides altering staffing levels, that could be employed?

If a problem of sexual abuse is evident in your jurisdiction/facility, what is the best method for
reducing the number of incidents through physical supervision?
Have you considered:



Would an increased LOE be necessary in order to provide adequate physical supervision?
Can you get by with a workforce realignment to meet the same objective?

Appendix E - Data Reports/Prisons and Jails

E-2

PREA Cost Impact Analysis
#

Standard

Question

3

PP-7

Does your jurisdiction/facility currently have video monitoring in place? If you feel this technology
is not adequately suited to reduce sexual abuse incidents, what is the associated cost?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




4

PP-7

What would it cost to purchase and install monitoring technology in trouble areas?
Is this enhanced technology directly related to reducing the incidence of sexual abuse?
Would you consider employing other methods of technology supervision (e.g., Radio Frequency
Identification Bracelets)? If so, what would be the cost impact of such technology?
Do you annually assess the feasibility of your current technology, including developing a plan for
securing new technology?
Have you considered:



5

PP-1

Is there a cost associated with the LOE necessary for management to meet yearly and assess and
develop a plan for securing new technology?
Would you contract out for this assessment?

Does your jurisdiction/facility have a PREA coordinator to comply with the PREA standards?
Have you considered:




6

TR-1

A PREA coordinator is a full-time position in the governing body of the State prison systems
and agencies that operate large jails (more than 500 inmates) but may be a part-time position in
jurisdictions that operate medium (101-500) and small jails (100 inmates or fewer).
Have you considered the cost of the PREA coordinator including base salary plus benefits?

Do you provide training to all employees on sexual abuse prevention, detection, and response policies
and procedures; the PREA standards; and relevant Federal, State, and local law?
Have you considered:





What are the means of training? Class-room/computer based? Consider the LOE of an
instructor and materials or the cost associated with the implementation of a web-based module.
Have you reviewed appendix B of the NPREC standards that lays out the training requirements
Are all employees (including office administrators) included in your training?
Do you provide periodic refresher training to employees? How frequently? What’s the cost
impact associated with this recurring training?

Appendix E - Data Reports/Prisons and Jails

E-3

PREA Cost Impact Analysis
#

Standard

Question

7

TR-2

Do you provide training to all volunteers and contractors who have contact with inmates on sexual
abuse prevention, detection, and response policies and procedures; the PREA standards; and relevant
Federal, State, and local law?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



8

TR-3

Will the training be provided by the employees or contractors?
What are the means of training? Class-room/computer based? Consider the LOE of an
instructor, cost of materials, and/or the cost associated with a web-based module.
 Is periodic refresher training provided to volunteers and contractors? What’s the cost impact?
Within a reasonably brief period of time following the intake process, does your agency provide
comprehensive education to inmates regarding their right to be free from sexual abuse, from
retaliation for reporting abuse, the dynamics of sexual abuse in confinement, the common reactions of
sexual abuse victims, and agency sexual abuse response policies and procedures?
Have you considered:


9

TR-4

What is the cost of educating current inmates on the agency’s adoption of PREA standards?
Have you considered the cost of materials and LOE of an instructor or web-based development?
 How do you deliver training and/or education? Class room? Computer? Handbook?
 What is the cost of providing refresher training?
 How do you deliver refresher training and how frequently? Do you have TV monitors that
provide video loops of educational material in common areas?
 Have you considered the size of the population when estimating a cost to educate all inmates?
 Is education provided to all inmates, including LEP, deaf, visual, or otherwise disabled?
Do you ensure sexual abuse training has been provided to investigators specifically conducting
investigations in confinement settings?
Have you considered:




Where do they get their training? Does it cover confinement settings?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?
Does your training for investigators include techniques for interviewing sexual abuse victims,
proper use of Miranda- and Garrity-type warnings, sexual abuse evidence collection in
confinement settings, and the criteria and evidence required to substantiate a case for
administrative action or prosecution referral?

Appendix E - Data Reports/Prisons and Jails

E-4

PREA Cost Impact Analysis
#

Standard

Question

10

TR-5

Do you ensure your full and part-time medical and mental health care practitioners have been trained
on how to detect and assess signs of sexual abuse and that all medical practitioners are trained on how
to preserve physical evidence of sexual abuse?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



11

RP-1

Where do they get their training?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?

Do you provide a victim advocate to accompany the victim through the forensic medical exam
process?
Have you considered:



12

RE-3

Who would provide this service? A current employee or outside entity?
What services are located in your town, county or state? Does it include non-profits, religious
organizations, or community service providers?
 Have you considered hiring staff or contracting out on a per incident basis?
Are inmates provided access to outside victim advocate services?
Have you considered:





Are there posters or pamphlets with this information around the facility jurisdiction?
Who provides this outside victim advocacy support? What services are located in your town,
county or state? Non-profits, religious organizations, or community service providers?
Is there a fee borne by you for these services or is it provided by the state, county, or other nonprofit service (state-level sexual assault coalition or its local affiliates)?
Does your facility ensure that communications with such advocates are private, confidential, and
privileged, to the extent allowable by Federal, State, and local law and are inmates informed,
prior to giving them access, of the extent to which these communications will be kept private,
confidential, and privileged?

Appendix E - Data Reports/Prisons and Jails

E-5

PREA Cost Impact Analysis
#

Standard

Question

13

DC-1

Do you have a review team to evaluate each incident of sexual abuse?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:

14

DC-2

 Do you prepare a report for each incident and include recommendations for improvement?
 What is the LOE cost required to assemble a review team and evaluate each incident?
Do you prepare an annual report on aggregated sexual abuse data using a standardized instrument and
set of definitions (e.g., BJS survey on sexual violence)?
Have you considered:

15

DC-3

 Does it include contracted facilities?
 Is an increased LOE necessary to aggregate, compare year-over-year, and standardize data?
Do you review, analyze, and use all sexual abuse data to assess and improve the effectiveness of your
sexual abuse prevention, detection, and response policies, practices, and training?
Have you considered:


16

DC-4

Is your annual data available to the public (e.g., when requested or through FOIA) or online? If
posting data online, how much effort would it require of your staff?
 Based on the volume of incidents, is it necessary to increase the LOE to review incident data?
 Does this review identify problem areas (including any racial dynamics) and take action?
 Do you provide an assessment of your progress?
Is your sexual abuse data properly stored, securely retained, and protected?
Have you considered:



Is it (electronic or paper) and where is it stored? In a locked container or password protected?
Have you considered the cost associated with server maintenance and potential upgrades to your
IT system to ensure data is stored securely for a minimum of 10 years?

Appendix E - Data Reports/Prisons and Jails

E-6

PREA Cost Impact Analysis
#

Standard

Question

17

PP-6

Do you and your contractors contact all prior institutional employers for information on substantiated
allegations of sexual abuse?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



18

PP-6

Have you considered costs associated with the LOE required to comply with the standard?
Would you offer contingency hires followed up by phone calls to previous institutional
employers (to ease the burden of this standard)?
 How many phone calls would you need to make?
Do you and your contractors run criminal background checks for all applicants and employees being
considered for promotion?
Have you considered:





19

AU-1

Large staffing populations serve as a cost driver for conducting background checks.
Have you considered the cost of a background check on a per incident basis?
How many promotions/new-hires are estimated per year?
Who conducts your background investigations? Is there a cost?

What would be the cost impact of conducting an audit to measure compliance with the PREA
standards at least every three years at every facility, including contracted facilities?
Have you considered:




Is there a cost associated with the LOE necessary for auditors to conduct their assessment?
Is there a cost associated with conducting audits such as the ACA audit or PbS audit?
Does your state or any other higher authority perform routine audits of your facility/jurisdiction?
Do you pay for them?

Appendix E - Data Reports/Prisons and Jails

E-7

PREA Cost Impact Analysis
#

Standard

Question

20

SC-1

Are all inmates screened during intake (and at all subsequent classification reviews) to assess their
risk of being sexually abused by other inmates or having the potential to be sexually abusive towards
other inmates?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


21

SC-2

Do you have a written screening instrument tailored to the gender of the population being
screened? Is there a cost associated with developing or modifying a tool to include PREArelated questions?
 Have you considered the LOE necessary to develop a screening process if your
jurisdiction/facility has yet to formalize a process on par with the NPREC standards?
Do you use the screening information to inform housing, bed, work, education, and program
assignments with the goal of keeping separate those inmates at high risk of being sexually victimized
from those at high risk of being sexually abusive?
Have you considered:



22

PP-2

Does this require an increased LOE?
Who would perform this assessment?

Do you contract with other agencies or facilities for the confinement of inmates? If so, do you ensure
these contracted agencies or facilities adhere to PREA guidelines?
Have you considered:




If so, how many facilities?
Will this require any contract modifications, and if so, will it result in a greater cost to you?
Are these entities private or public? If public, would they be subject to PREA compliance also?

Appendix E - Data Reports/Prisons and Jails

E-8

PREA Cost Impact Analysis
#

Standard

Question

23

RP-2

Do you maintain or attempt to enter into memoranda of understanding (MOUs) or other agreements
with an outside public entity or office that is able to 1) receive and immediately forward inmate
reports of sexual abuse to facility heads, 2) provide inmates with confidential emotional support
services related to sexual abuse, and 3) help victims of sexual abuse during their transition from
incarceration to the community?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




24

RP-3

Who currently provides these services (if anyone)?
Do you have any MOU’s with them? If not, how much would it cost to develop these MOUs?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
Do you conduct your own criminal investigations or is it an outside legal authority?
Have you considered:




25

RP-4

If outside, who is it?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
 If applicable, does it cover vulnerable persons (e.g., under 18 years of age)?
Who are the authorities that prosecute violations?
Have you considered:




If prosecutions are conducted by state agencies, is there a statute that authorizes this service?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?

Appendix E - Data Reports/Prisons and Jails

E-9

PREA Cost Impact Analysis
#

Standard

Question

26

PP-5

Do you ensure that inmates who are LEP, deaf, or disabled are able to report sexual abuse to staff
directly through interpretive technology or through non-inmate interpreters?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




27

RP-1

What services and tools do you employ? Is there a LOE cost?
What interpretive technology will you use? Is there a cost impact?
Do you provide services for the mentally disabled? Do you have a medical or mental health
staff that would provide these services? Is there a LOE cost for these services?

Are forensic medical exams provided free of charge to the victim?
Have you considered:



28

RE-4

Who provides the exams?
Who bears the cost associated with giving these exams?

Do you investigate all third-party reports of sexual abuse?
Have you considered:



29

IN-1

Based on the number of incidents investigated in the past, is there a LOE cost?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Do you investigate all allegations of sexual abuse and notify victims and/or other complaints in
writing of investigation outcomes and any disciplinary or criminal sanctions, regardless of the source
of the allegation? Are these investigations carried through to completion, regardless of whether the
alleged abuser or victim remains at the facility?
Have you considered:



Based on the number of incidents investigated in the past, is an increased LOE necessary to
ensure that an investigation is conducted for all allegations of sexual abuse?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Appendix E - Data Reports/Prisons and Jails

E-10

PREA Cost Impact Analysis
#

Standard

Question

30

IN-3

Are allegations of sexual abuse substantiated if supported by a preponderance of the evidence?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


31

MM-3

Is an increased LOE necessary in order to substantiate claims of abuse?

Does the facility/jurisdiction conduct a mental health evaluation and provide ongoing medical and/or
mental health evaluations and treatment to all known users of sexual abuse?
Have you considered:



32

RE-1

What would be the cost associated with a mental health evaluation?
Would an increased LOE be necessary in order to provide medical and mental health
practitioners that would conduct these evaluations?

How do victims confidentially report sexual abuse (in multiple ways)? Are there means to report
sexual abuse to an outside public entity?
Have you considered:


33

RE-2

What means are available to report sexual abuse (e.g., drop boxes, toll free numbers, talking
with an officer, contacting an outside entity)?
 Are any verbal reports immediately put into writing?
 If an outside entity, who would provide this service and is there a fee for providing such a
service?
 Would this cost be charged on a per incident basis?
What is your policy/procedure for the exhaustion of administrative remedies available to an inmate?
Do you ensure that this covers a 90-day period (unless you have made a final determination earlier)
and does it cover a 48 hours requirement after an inmate has notified any agency staff member of his
or her need for protection?
Have you considered:


A cost associated with creating or revising a policy and/or procedure to include attorney fees or
additional litigation costs (if quantifiable)?

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Adult Prisons and Jails, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Prisons and Jails

E-11

PREA Cost Impact Analysis
Part II. For each standard/question below, please provide a response to whether or not your jurisdiction is compliant and provide an explanation of the reason
for answering compliant or noncompliant. For further information on each standard, please reference the NPREC Standards Prevention, Detection, Response,
and Monitoring of Sexual Abuse in Adult Prisons and Jails.

#

Standard

Question

1

PP-1

Does your agency have a written policy mandating zero tolerance towards all forms of sexual abuse and
enforces that policy by ensuring all its facilities comply with the PREA standards?

2

PP-4

At your agency, do medical practitioners conduct examinations of transgender individuals to determine
their genital status only in private settings and only when an individual’s genital status is unknown?

3

PP-4

Does your facility prohibit cross-gender strips and visual body cavity searches?

4

PP-6

Does your agency intentionally not hire or promote anyone who has engaged in sexual abuse in an
institutional setting or in the community facilitated by force, the threat of force, or coercion?

5

PP-6

Does your agency examine and carefully weigh any history of criminal activity at work or in the
community, including convictions for domestic violence, stalking, and sex offenses?

6

RP-1

Does your facility follow an evidence protocol adapted from the 2004 U.S. Department of Justice’s Office
on Violence Against Women publication ―A National Protocol for Sexual Assault Medical Forensic
Examinations, Adults/Adolescents‖, subsequent updated editions, or similarly comprehensive and
authoritative protocols developed after 2004? http://www.ncjrs.gov/pdffiles1/ovw/206554.pdf

7

RP-3

Do you have legal authority to conduct investigations within your facility?

8

SC-2

Does your facility make individualized determinations about how to ensure the safety of each inmate.
Including whether lesbian, gay, bisexual, transgender, or other gender-nonconforming inmates are placed
in particular facilities, units, or wings solely on the basis of their sexual orientation, genital status, or
gender identity.

9

SC-2

Are inmates at high risk for sexual victimization placed in segregated housing only as a last resort and
then only until an alternative means of separation from likely abusers can be arranged?

Appendix E - Data Reports/Prisons and Jails

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-12

PREA Cost Impact Analysis
#

Standard

Question

10

SC-2

In your facility, does risk of sexual victimization limit access to programs, education, and work
opportunities?

11

RE-4

At the conclusion of an investigation, does your facility notify in writing the third-party individual who
reported the abuse and the inmate named in the report of the outcome of the investigation?

12

RE-4

Does your facility publicly distribute information on how to report sexual abuse on behalf of an inmate?

13

OR-1

Does your agency policy require that all staff members immediately report any knowledge, suspicion, or
information they receive regarding an incident of sexual abuse, retaliation against inmates or staff who
reported abuse; and any staff neglect related to an incident of sexual abuse or retaliation?

14

OR-1

Does your agency policy require that staff not reveal any information related to a sexual abuse report to
anyone other than those who need to know, to make treatment, investigation, and other security and
management decisions?

15

OR-1

At your agency, are medical and mental health practitioners required to report sexual abuse and inform
inmates of their duty to report the abuse at the initiation of services, unless otherwise precluded by
Federal, State, or local law?

16

OR-1

At your agency, is it required that the facility head report an incident involving a victim less than 18 years
of age to the designated State or local services agency under applicable mandatory reporting laws?

17

OR-2

When your facility receives an allegation that an inmate was sexually abused while confined at another
facility, does the head of your facility notify in writing the head of the facility where the alleged abuse
occurred and ensure that the allegation is or was investigated?

18

OR-3

At your agency, when a sexual abuse incident has occurred and the collection of physical evidence is still
possible, do the first security staff to the scene conduct the following:

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

1)
2)
3)

19

OR-3

separate the alleged victim and abuser
seal and preserve any crime scene(s)
instruct the victim not to take any actions that could destroy physical evidence, including
washing, brushing teeth, changing clothes, urinating, defecating, smoking, drinking, or eating?
At your agency, if the first staff responder is a non-security staff member, is he or she required to instruct
the victim not to take any actions that could destroy physical evidence and then notify security staff?

Appendix E - Data Reports/Prisons and Jails

E-13

PREA Cost Impact Analysis
#

Standard

Question

20

OR-4

Does you agency ensure the coordination of all actions taken in response to an incident of sexual abuse
among staff first responders, medical and mental health practitioners, investigators, and facility
leadership?

21

OR-4

Does your facility’s coordinated response ensure that victims receive all necessary immediate and ongoing
medical, mental health, and support services and that investigators are able to obtain usable evidence to
substantiate allegations and hold perpetrators accountable?

22

OR-5

Does your agency protect all inmates and staff who report sexual abuse or cooperate with sexual abuse
investigations from retaliation by other inmates or staff, including housing changes or transfers, the
removal of any contact between the alleged abuser and victim, and/or the offering of emotional support
services?

23

OR-5

Does your agency monitor, for at least 90 days, the conduct and/or treatment of inmates or staff that have
reported sexual abuse or cooperated with investigations, and identify and discuss with inmates and staff
any changes that may suggest possible retaliation by inmates or staff?

24

DI-1

At your agency, is staff subject to disciplinary sanctions up to and including termination when sexual
abuse policies have been violated?

25

DI-1

At your agency, is termination the presumptive disciplinary sanction for staff members who have engaged
in sexually abusive contact or penetration?

26

DI-2

At your agency, are inmates subject to disciplinary sanctions pursuant to a formal disciplinary process
following an administrative ruling that the inmate engaged in inmate-on-inmate sexual abuse or following
a criminal finding of guilt for such sexual abuse?

27

DI-2

At your agency, do sanctions commensurate with the nature and circumstances of the abuse committed,
the inmate’s disciplinary history, and comparable offenses by other inmates with similar histories?

28

DI-2

Does your agency’s disciplinary process consider whether an inmate’s mental disabilities or mental illness
contributed to his or her behavior when determining what type of sanction, if any, should be imposed?

Appendix E - Data Reports/Prisons and Jails

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-14

PREA Cost Impact Analysis
#

Standard

Question

29

DI-2

At your agency, do possible sanctions include interventions designed to address and correct underlying
reasons or motivation for the abuse, such as requiring the offending inmate to participate in therapy,
counseling, or other programs?

30

MM-1

Does your agency have qualified medical or mental health practitioners to ask inmates about prior sexual
victimization and abusiveness during medical and mental health reception and intake screenings?

31

MM-1

If an inmate discloses any prior sexual victimization or abusiveness during a medical or mental health
reception or intake screening, does the practitioner provide the appropriate referral for treatment?

32

MM-1

Does your agency strictly limit any information related to sexual victimization or abusiveness that
occurred in an institutional setting to medical and mental health practitioners and other staff, as required
by agency policy and Federal, State, or local law, to inform treatment plans and security and management
decisions, including housing, bed, work, education, and program assignments?

33

MM-1

At your agency, do medical and mental health practitioners obtain informed consent from inmates before
reporting information about prior sexual victimization that did not occur in an institutional setting, unless
the inmate is under the age of 18?

34

MM-2

Do victims of sexual abuse have timely, unimpeded access to emergency medical treatment and crisis
intervention services, the nature and scope of which are determined by medical and mental health
practitioners according to their professional judgment. And, if so, are these services free to the victim?

35

MM-2

Do staff first responders take preliminary steps to protect a victim and notify appropriate staff or
community medical and mental health practitioners if your facility does not have medical or mental health
practitioners or they are not on duty at the time a report of recent abuse is made?

36

DC-1

Does the report consider whether incidents were motivated by racial or other group dynamics at the
facility?

37

IDFF

Does your agency treat immigrant inmates the same as citizen inmates?

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Adult Prisons and Jails, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Prisons and Jails

E-15

PREA Cost Impact Analysis

Juvenile Facilities

Cost Impact Study Questionnaire
[Juvenile Facilities]
BOOZ ALLEN HAMILTON

[The following questionnaire consists of two parts. Part I identifies Nation Prison Rape Elimination Commission (NPREC) standards that require
an estimated cost impact (if any), accompanied by a detailed explanation of that cost impact or reason for being in compliance. Part II identifies
the remaining standards outlined by NPREC to gauge a level of compliance and a detailed reason for those standards that the jurisdiction may find
to be noncompliant with.]
Appendix E - Data Reports/Juvenile Facilities

E-16

PREA Cost Impact Analysis

Appendix E - Data Reports/Juvenile Facilities

E-17

PREA Cost Impact Analysis
Part I. For each question below, please reference the Standard column and review the standard(s) definition (found in the NPREC Standards Prevention,
Detection, Response, and Monitoring of Sexual Abuse in Juvenile Facilities) before offering a response. If your jurisdiction/facility is compliant, please respond
with a ―Y‖ in the Compliant? column and provide a detailed explanation of reason for being compliant in the last column. (Please note: You do not need to
provide a cost impact if you find your jurisdiction/facility to be in compliance.) Otherwise, please respond with a ―N‖ in the Compliant? column and
provide an estimated cost impact accompanied by a detailed explanation of the projected cost after considering points made in the Question column.

#

Standard

Question

1

PP-4

Except in the case of an emergency, does your jurisdiction/facility prohibit cross-gender pat downs?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




2

PP-3

How would male/female staffing levels need to be altered to prohibit cross-gender pat down
searches?
Would this require an increased level of effort (LOE)?
Are there other policies, besides altering staffing levels, that could be employed?

If a problem of sexual abuse is evident in your jurisdiction/facility, what is the best method for
reducing the number of incidents through physical supervision?
Have you considered:



3

PP-7

Would an increased LOE be necessary in order to provide adequate physical supervision?
Can you get by with a workforce realignment to meet the same objective?

Does your jurisdiction/facility currently have video monitoring in place? If you feel this technology is
not adequately suited to reduce sexual abuse incidents, what is the associated cost?
Have you considered:




What would it cost to purchase and install monitoring technology in trouble areas?
Is this enhanced technology directly related to reducing the incidence of sexual abuse?
Would you consider employing other methods of technology supervision (e.g., Radio Frequency
Identification Bracelets)? If so, what would be the cost impact of such technology?

Appendix E - Data Reports/Juvenile Facilities

E-18

PREA Cost Impact Analysis
#

Standard

Question

4

PP-7

Do you annually assess the feasibility of your current technology, including developing a plan for
securing new technology?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


5

PP-1

Is there a cost associated with the LOE necessary for management to meet yearly and assess and
develop a plan for securing new technology?
 Would you contract out for this assessment?
Does your jurisdiction/facility have a PREA coordinator to comply with the PREA standards?
Have you considered:




6

TR-1

A PREA coordinator is a full-time position in the governing body of the State prison systems and
agencies that operate large jails (more than 500 residents) but may be a part-time position in
jurisdictions that operate medium (101-500) and small jails (100 residents or fewer).
Have you considered the cost of the PREA coordinator including base salary plus benefits?

Do you provide training to all employees on sexual abuse prevention, detection, and response policies
and procedures; the PREA standards; and relevant Federal, State, and local law?
Have you considered:


7

TR-2

What are the means of training? Class-room/computer based? Consider the LOE of an
instructor and materials or the cost associated with the implementation of a web-based module.
 Have you reviewed appendix B of the NPREC standards that lays out the training requirements?
 Are all employees (including office administrators) included in your training?
 Do you provide periodic refresher training to employees? How frequently? What’s the cost
impact associated with this recurring training?
Do you provide training to all volunteers and contractors who have contact with residents on sexual
abuse prevention, detection, and response policies and procedures; the PREA standards; and relevant
Federal, State, and local law?
Have you considered:




Will the training be provided by the employees or contractors?
What are the means of training? Class-room/computer based? Consider the LOE of an
instructor, cost of materials, or the cost associated with a web-based module.
Is periodic refresher training provided to volunteers and contractors? What’s the cost impact?

Appendix E - Data Reports/Juvenile Facilities

E-19

PREA Cost Impact Analysis
#

Standard

Question

8

TR-3

Within a reasonably brief period of time following the intake process, does your agency provide
comprehensive education to residents regarding their right to be free from sexual abuse and to be free
from retaliation for reporting abuse, the dynamics of sexual abuse in confinement, the common
reactions of sexual abuse victims, and agency sexual abuse response policies and procedures?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


9

TR-4

What is the cost of educating current residents on the agency’s adoption of PREA standards?
Have you considered the cost of materials and LOE of an instructor or web-based development?
 How do you deliver training and/or education? Class-room? Computer? Handbook?
 What is the cost of providing refresher training?
 How do you deliver refresher training and how frequently? Do you have TV monitors that
provide video loops of educational material in common areas?
 Have you considered the size of the population when estimating a cost to educate all residents?
 Is education provided to all residents, including LEP, deaf, visual, or otherwise disabled?
Do you ensure sexual abuse training has been provided to investigators specifically conducting
investigations in confinement settings?
Have you considered:



10

TR-5

Where do they get their training? Does it cover confinement settings?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?
 Does your training for investigators include techniques for interviewing sexual abuse victims,
proper use of Miranda or Garrity-type warnings, sexual abuse evidence collection in confinement
settings, and the criteria and evidence required to substantiate a case for administrative action or
prosecution referral?
Do you ensure your full and part-time medical and mental health care practitioners have been trained
on how to detect and assess signs of sexual abuse and that all medical practitioners are trained on how
to preserve physical evidence of sexual abuse?
Have you considered:



Where do they get their training?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?

Appendix E - Data Reports/Juvenile Facilities

E-20

PREA Cost Impact Analysis
#

Standard

Question

11

RP-1

Do you provide a victim advocate to accompany the victim through the forensic medical exam
process?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



12

RE-3

Who would provide this service? A current employee or outside entity?
What services are located in your town, county, or state? Does it include non-profits, religious
organizations, or community-services providers?
 Have you considered hiring staff or contracting out on a per incident basis?
Are residents provided access to outside victim advocate services?
Have you considered:





13

DC-1

Are there posters or pamphlets with this information around the facility jurisdiction?
Who provides this outside victim advocacy support? What services are located in your town,
county or state? Non-profits, religious organizations, or community service providers?
Is there a fee borne by you for these services or is it provided by the state, county, or other nonprofit service (state-level sexual assault coalition or its local affiliates)?
Does your facility ensure that communications with such advocates are private, confidential, and
privileged, to the extent allowable by Federal, State, and local law and are inmates informed,
prior to giving them access, of the extent to which these communications will be kept private,
confidential, and privileged?

Do you have a review team to evaluate each incident of sexual abuse?
Have you considered:

14

DC-2

 Do you prepare a report for each incident and include recommendations for improvement?
 What is the LOE cost required to assemble a review team and evaluate each incident?
Do you prepare an annual report on aggregated sexual abuse data using a standardized instrument and
set of definitions (e.g., BJS survey on sexual violence)?
Have you considered:



Does it include contracted facilities?
Is an increased LOE necessary to aggregate, compare year-over-year, and standardize data?

Appendix E - Data Reports/Juvenile Facilities

E-21

PREA Cost Impact Analysis
#

Standard

Question

15

DC-3

Do you review, analyze, and use all sexual abuse data to assess and improve the effectiveness of your
sexual abuse prevention, detection, and response policies, practices, and training?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


16

DC-4

Is your annual data available to the public (e.g., when requested or through FOIA) or online? If
posting data online, how much effort would it require of your staff?
 Based on the volume of incidents, is it necessary to increase the LOE to review incident data?
 Does this review identify problem areas (including any racial dynamics) and take action?
 Do you provide an assessment of your progress?
Is your sexual abuse data properly stored, securely retained, and protected?
Have you considered:



17

PP-6

Is it electronic or paper and where is it stored? In a locked container or password protected?
Have you considered the cost associated with server maintenance and potential upgrades to your
IT system to ensure data is stored securely for a minimum of 10 years?

Do you and your contractors contact all prior institutional employers for information on substantiated
allegations of sexual abuse?
Have you considered:



18

PP-6

Have you considered costs associated with the LOE required to comply with the standard?
Would you offer contingency hires followed up by phone calls to previous institutional
employers (to ease the burden of this standard)?
 How many phone calls would you need to make?
Do you and your contractors run criminal background checks for all applicants and employees being
considered for promotion?
Have you considered:





Large staffing populations serve as a cost driver for conducting background checks.
Have you considered the cost of a background check on a per incident basis?
How many promotions/new-hires are estimated per year?
Who conducts your background investigations? Is there a cost?

Appendix E - Data Reports/Juvenile Facilities

E-22

PREA Cost Impact Analysis
#

Standard

Question

19

AU-1

What would be the cost impact of conducting an audit to measure compliance with the PREA
standards at least every three years at every facility, including contracted facilities?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




20

AP-1

Is there a cost associated with the LOE necessary for auditors to conduct their assessment?
Is there a cost associated with conducting audits such as the ACA audit or PbS audit?
Does your state or any other higher authority perform routine audits of your facility/jurisdiction?
Do you pay for them?

Are all residents screened during intake (and at all subsequent classification reviews) to assess their
risk of being sexually abused by other residents or having the potential to be sexually abusive towards
other residents?
Have you considered:


21

AP-2

Do you have a written screening instrument tailored to the gender of the population being
screened? Is there a cost associated with developing or modifying a tool to include PREArelated questions?
 Have you considered the LOE necessary to develop a screening process if your
jurisdiction/facility has yet to formalize a process on par with the NPREC standards?
Do you use the screening information to inform housing, bed, work, education, and program
assignments with the goal of keeping separate those residents at high risk of being sexually victimized
from those at high risk of being sexually abusive?
Have you considered:



22

PP-2

Does this require an increased LOE?
Who would perform this assessment?

Do you contract with other agencies or facilities for the confinement of inmates? If so, do you ensure
these contracted agencies or facilities adhere to PREA guidelines?
Have you considered:




If so, how many facilities?
Will this require any contract modifications, and if so, will it result in a greater cost to you?
Are these entities private or public? If public, would they be subject to PREA compliance also?

Appendix E - Data Reports/Juvenile Facilities

E-23

PREA Cost Impact Analysis
#

Standard

Question

23

RP-2

Do you maintain or attempt to enter into memoranda of understanding (MOUs) or other agreements
with an outside public entity or office that is able to 1) receive and immediately forward resident
reports of sexual abuse to facility heads, 2) provide residents with confidential emotional support
services related to sexual abuse, and 3) help victims of sexual abuse during their transition from
incarceration to the community?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




24

RP-3

Who currently provides these services (if anyone)?
Do you have any MOU’s with them? If not, how much would it cost to develop these MOUs?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
Do you conduct your own criminal investigations or is it an outside legal authority?
Have you considered:




25

RP-4

If outside, who is it?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
 If applicable, does it cover vulnerable persons (e.g., under 18 years of age)?
Who are the authorities that prosecute violations?
Have you considered:




If prosecutions are conducted by state agencies, is there a statute that authorizes this service?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?

Appendix E - Data Reports/Juvenile Facilities

E-24

PREA Cost Impact Analysis
#

Standard

Question

26

PP-5

Do you ensure that residents who are LEP, deaf, or disabled are able to report sexual abuse to staff
directly through interpretive technology or through non-resident interpreters?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




27

RP-1

What services and tools do you employ? Is there a LOE cost?
What interpretive technology will you use? Is there a cost?
Do you provide services for the mentally disabled? Do you have medical or mental health staff
that would provide these services? Is there a LOE cost for these services?

Are forensic medical exams provided free of charge to the victim?
Have you considered:



28

RE-4

Who provides the exams?
Who bears the cost associated with giving these exams?

Do you investigate all third-party reports of sexual abuse?
Have you considered:



29

IN-1

Based on the number of incidents investigated in the past, is there a LOE cost?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Do you investigate all allegations of sexual abuse and notify victims and/or other complaints in
writing of investigation outcomes and any disciplinary or criminal sanctions, regardless of the source
of the allegation? Are these investigations carried through to completion, regardless of whether the
alleged abuser or victim remains at the facility?
Have you considered:



Based on the number of incidents investigated in the past, is an increased LOE necessary to
ensure that an investigation is conducted for all allegations of sexual abuse?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Appendix E - Data Reports/Juvenile Facilities

E-25

PREA Cost Impact Analysis
#

Standard

Question

30

IN-3

Are allegations of sexual abuse substantiated if supported by a preponderance of the evidence?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


31

MM-3

Is an increased LOE necessary in order to substantiate claims of abuse?

Does the facility/jurisdiction provide ongoing medical and/or mental health evaluations and treatment
to all known users of sexual abuse?
Have you considered:



32

RE-1

What would be the cost associated with a mental health evaluation?
Would an increased LOE be necessary in order to provide medical and mental health
practitioners that would conduct these evaluations?

How do victims confidentially report sexual abuse (in multiple ways)? Are there means to report
sexual abuse to an outside public entity?
Have you considered:


33

RE-2

What means are available to report sexual abuse (e.g., drop boxes, toll-free numbers, talking with
an officer, contacting an outside entity)?
 Are any verbal reports immediately put into writing?
 If an outside entity, who would provide this service and is there a fee for providing such a
service?
 Would this cost be charged on a per incident basis?
What is your policy/procedure for the exhaustion of administrative remedies available to a resident?
Do you ensure that this covers a 90-day period (unless you have made a final determination earlier)
and does it cover a 48 hours requirement after a resident has notified any agency staff member of his
or her need for protection?
Have you considered:


A cost associated with creating or revising a policy and/or procedure to include attorney fees or
additional litigation costs (if quantifiable)?

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Juvenile Facilities, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Juvenile Facilities

E-26

PREA Cost Impact Analysis

Part II. For each standard/question below, please provide a response to whether or not your jurisdiction is compliant and provide an explanation of the reason
for answering compliant or noncompliant. For further information on each standard, please reference the NPREC Standards Prevention, Detection, Response,
and Monitoring of Sexual Abuse in Adult Prisons and Jails.

#

Standard

Question

1

PP-1

Does your agency have a written policy mandating zero tolerance towards all forms of sexual abuse and enforces
that policy by ensuring all its facilities comply with the PREA standards?

2

PP-4

At your agency, do medical practitioners conduct examinations of transgender individuals to determine their
genital status only in private settings and only when an individual’s genital status is unknown?

Appendix E - Data Reports/Juvenile Facilities

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-27

PREA Cost Impact Analysis
#

Standard

Question

3

PP-4

Does your facility prohibit cross-gender strips and visual body cavity searches?

4

PP-6

Does your agency intentionally not hire or promote anyone who has engaged in sexual abuse in an institutional
setting or in the community facilitated by force, the threat of force, or coercion?

5

PP-6

Does your agency directly inquire about, during interviews and reviews, and examine and carefully weigh any
history of criminal activity at work or in the community, including convictions for domestic violence, stalking,
and sex offenses?

6

RP-1

Does your facility follow an evidence protocol adapted from the 2004 U.S. Department of Justice’s Office on
Violence Against Women publication ―A National Protocol for Sexual Assault Medical Forensic Examinations,
Adults/Adolescents‖, subsequent updated editions, or similarly comprehensive and authoritative protocols
developed after 2004? http://www.ncjrs.gov/pdffiles1/ovw/206554.pdf

7

RP-3

Do you have legal authority to conduct investigations within your facility?

8

AP-2

Does your facility make individualized determinations about how to ensure the safety of each resident, including
whether lesbian, gay, bisexual, transgender, or other gender-nonconforming residents are placed in particular
facilities, units, or wings, solely on the basis of their sexual orientation, genital status, or gender identity?

9

AP-2

Are residents at high risk for sexual victimization placed in segregated housing only as a last resort and then only
until an alternative means of separation from likely abusers can be arranged?

10

AP-2

In your facility, does risk of sexual victimization limit access to programs, education, and work opportunities?

11

RE-4

At the conclusion of an investigation, does your facility notify, in writing, the third-party individual who reported
the abuse and the inmate named in the report of the outcome of the investigation?

12

RE-4

Does your facility publicly distribute information on how to report sexual abuse on behalf of an inmate?

13

OR-1

Does your agency policy require that all staff members immediately report any knowledge, suspicion, or
information they receive regarding an incident of sexual abuse, retaliation against residents or staff who reported
abuse; and any staff neglect related to an incident of sexual abuse or retaliation?

Appendix E - Data Reports/Juvenile Facilities

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-28

PREA Cost Impact Analysis
#

Standard

Question

14

OR-1

Does your agency policy require that staff not reveal any information related to a sexual abuse report to anyone
other than those who need to know, to make treatment, investigation, and other security and management
decisions?

15

OR-1

At your agency, are medical and mental health practitioners required to report sexual abuse and inform residents
of their duty to report the abuse at the initiation of services, unless otherwise precluded by Federal, State, or local
law?

16

OR-1

At your agency, is it required that the facility head report an incident involving a victim younger than 18 years of
age to the designated State or local services agency under applicable mandatory reporting laws?

17

OR-2

When your facility receives an allegation that a resident was sexually abused while confined at another facility,
does the head of the facility where the report was made notify in writing the head of the facility where the alleged
abuse occurred, and ensure that the allegation is or was investigated?

18

OR-3

At your agency, when a sexual abuse incident has occurred and the collection of physical evidence is still
possible, do the first security staff to the scene conduct the following:

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

4)
5)
6)

separate the alleged victim and abuser
seal and preserve any crime scene(s)
instruct the victim not to take any actions that could destroy physical evidence, including washing,
brushing teeth, changing clothes, urinating, defecating, smoking, drinking, or eating?
At your agency, if the first staff responder is a non-security staff member, is he or she required to instruct the
victim not to take any actions that could destroy physical evidence and then notify security staff?

19

OR-3

20

OR-4

Does you agency ensure the coordination of all actions taken in response to an incident of sexual abuse are
coordinated among staff first responders, medical and mental health practitioners, investigators, and facility
leadership?

21

OR-4

Does your facility’s coordinated response ensure that victims receive all necessary immediate and ongoing medical, mental health, and support services and that investigators are able to obtain usable evidence to substantiate
allegations and hold perpetrators accountable?

22

OR-5

Does your agency protect all residents and staff who report sexual abuse or cooperate with sexual abuse
investigations from retaliation by other residents or staff, including housing charges or transfers, the removal of
any contact between the alleged abuser and victim, and the offering of emotional support services?

Appendix E - Data Reports/Juvenile Facilities

E-29

PREA Cost Impact Analysis
#

Standard

Question

23

OR-5

Does your agency monitor, for at least 90 days, the conduct and/or treatment of residents or staff that have
reported sexual abuse or cooperated with investigations, and identify and discuss with inmates and staff any
changes that may suggest possible retaliation, and if necessary, take immediate steps to protect the inmate or
staff?

24

DI-1

At your agency, is staff subject to disciplinary sanctions up to and including termination when sexual abuse
policies have been violated?

25

DI-1

At your agency, is termination the presumptive disciplinary sanction for staff members who have engaged in
sexually abusive contact or penetration?

26

DI-2

At your agency, are residents subject to disciplinary sanctions pursuant to a formal disciplinary process following
an administrative ruling that the resident engaged in resident-on-resident sexual abuse or following a criminal
finding of guilt for such sexual abuse?

27

DI-2

At your agency, do sanctions commensurate with the nature and circumstances of the abuse committed, the
resident’s disciplinary history, and comparable offenses by other residents with similar histories?

28

DI-2

Does your agency’s disciplinary process consider whether an resident’s mental disabilities or mental illness contributed to his or her behavior when determining what type of sanction, if any, should be imposed?

29

DI-2

At your agency, do possible sanctions include interventions designed to address and correct underlying reasons
or motivation for the abuse, such as requiring the offending resident to participate in therapy, counseling, or other
programs?

30

MM-1

Does your agency have qualified medical or mental health practitioners to ask residents about prior sexual
victimization and abusiveness during medical and mental health reception and intake screenings?

31

MM-1

If a resident discloses any prior sexual victimization or abusiveness during a medical or mental health reception
or intake screening, does the practitioner provide the appropriate referral for treatment?

32

MM-1

Does your agency strictly limit any information related to sexual victimization or abusiveness that occurred in an
institutional setting to medical and mental health practitioners and other staff, as required by agency policy and
Federal, State, or local law, to inform treatment plans and security and management decisions, including housing,
bed, work, education, and program assignments?

Appendix E - Data Reports/Juvenile Facilities

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-30

PREA Cost Impact Analysis
#

Standard

Question

33

MM-1

At your agency, do medical and mental health practitioners obtain informed consent from residents before reporting information about prior sexual victimization that did not occur in an institutional setting, unless the
resident is under the age of 18?

34

MM-2

Do victims of sexual abuse have timely, unimpeded access to emergency medical treatment and crisis
intervention services, the nature and scope of which are determined by medical and mental health practitioners
according to their professional judgment, and, if so, are these services free to the victim?.

35

MM-2

Do staff first responders take preliminary steps to protect the victim and notify appropriate staff or community
medical and mental health practitioners, if your facility does not have medical or mental health practitioners or
they are not on duty at the time a report of recent abuse is made?

36

DC-1

Does the report consider whether incidents were motivated by racial or other group dynamics at the facility?

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Juvenile Facilities, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Juvenile Facilities

E-31

PREA Cost Impact Analysis

Community Corrections

Cost Impact Study Questionnaire
[Community Corrections]
BOOZ ALLEN HAMILTON

[The following questionnaire consists of two parts. Part I identifies Nation Prison Rape Elimination Commission (NPREC) standards that require
an estimated cost impact (if any), accompanied by a detailed explanation of that cost impact or reason for being in compliance. Part II identifies
the remaining standards outlined by NPREC to gauge a level of compliance and a detailed reason for those standards that the jurisdiction may find
to be noncompliant with.]
Appendix E - Data Reports/Community Corrections

E-32

PREA Cost Impact Analysis

Appendix E - Data Reports/Community Corrections

E-33

PREA Cost Impact Analysis
Part I. For each question below, please reference the Standard column and review the standard(s) definition (found in the NPREC Standards Prevention,
Detection, Response, and Monitoring of Sexual Abuse in Community Corrections) before offering a response. If your jurisdiction/facility is compliant, please
respond with a ―Y‖ in the Compliant? column and provide a detailed explanation of reason for being compliant in the last column. (Please note: You do not
need to provide a cost impact if you find your jurisdiction/facility to be in compliance.) Otherwise, please respond with a ―N‖ in the Compliant? column
and provide an estimated cost impact accompanied by a detailed explanation of the projected cost after considering points made in the Question column.

#

Standard

Question

1

PP-4

Except in the case of an emergency, does your jurisdiction/facility prohibit cross-gender pat downs?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




2

PP-3

How would male/female staffing levels need to be altered to prohibit cross-gender pat down
searches?
Would this require an increased level of effort (LOE)?
Are there other policies, besides altering staffing levels, that could be employed?

If a problem of sexual abuse is evident in your jurisdiction/facility, what is the best method for
reducing the number of incidents through physical supervision?
Have you considered:



3

PP-1

Would an increased LOE be necessary in order to provide adequate physical supervision?
Can you get by with a workforce realignment to meet the same objective?

Does your jurisdiction/facility have a PREA coordinator to comply with the PREA standards?
Have you considered:




A PREA coordinator is a full-time position in the governing body of the State prison systems and
agencies that operate large jails (more than 500 offenders) but may be a part-time position in
jurisdictions that operate medium (101-500) and small jails (100 offenders or fewer).
Have you considered the cost of the PREA coordinator including base salary plus benefits?

Appendix E - Data Reports/Community Corrections

E-34

PREA Cost Impact Analysis
#

Standard

Question

4

TR-1

Do you provide training to all employees on sexual abuse prevention, detection, and response policies
and procedures; the PREA standards; and relevant Federal, State, and local law?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


5

TR-2

What are the means of training? Class-room/computer based? Consider the LOE of an instructor
and materials or the cost associated with the implementation of a web-based module.
 Have you reviewed Appendix B of the NPREC standards that lays out the training requirements?
 Are all employees (including office administrators) included in your training?
 Do you provide periodic refresher training to employees? How frequently? What’s the cost
impact associated with this recurring training?
Do you provide training to all volunteers and contractors who have contact with offenders on sexual
abuse prevention, detection, and response policies and procedures; the PREA standards; and relevant
Federal, State, and local law?
Have you considered:



6

TR-3

Will the training be provided by the employees or contractors?
What are the means of training? Class-room/computer based? Consider the LOE of an
instructor, cost of materials, or the cost associated with a web-based module.
 Is periodic refresher training provided to volunteers and contractors? What’s the cost impact?
Within a reasonably brief period of time following the intake process, does your agency provide
comprehensive education to offenders regarding their right to be free from sexual abuse, from
retaliation for reporting abuse, the dynamics of sexual abuse in confinement, the common reactions of
sexual abuse victims, and agency sexual abuse response policies and procedures?
Have you considered:








What is the cost of educating current offenders on the agency’s adoption of PREA standards?
Have you considered the cost of materials and LOE of an instructor or web-based development?
How do you deliver training and/or education? Class room? Computer? Handbook?
What is the cost of providing refresher training?
How do you deliver refresher training and how frequently?
Do you have TV monitors that provide video loops of educational material in common areas?
Have you considered the size of the population when estimating a cost to educate all offenders?
Is education provided to all offenders, including LEP, deaf, visual, or otherwise disabled?

Appendix E - Data Reports/Community Corrections

E-35

PREA Cost Impact Analysis
#

Standard

Question

7

TR-4

Do you ensure sexual abuse training has been provided to investigators specifically conducting
investigations in confinement settings?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



8

TR-5

Where do they get their training? Does it cover confinement settings?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?
 Does your training for investigators include techniques for interviewing sexual abuse victims,
proper use of Miranda and Garrity-type warnings, sexual abuse evidence collection in
confinement settings, and the criteria and evidence required to substantiate a case for
administrative action or prosecution referral?
Do you ensure your full and part-time medical and mental health care practitioners have been trained
on how to detect and assess signs of sexual abuse and that all medical practitioners are trained on how
to preserve physical evidence of sexual abuse?
Have you considered:



9

RP-1

Where do they get their training?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?

Do you provide a victim advocate to accompany the victim through the forensic medical exam
process?
Have you considered:




Who would provide this service? A current employee or outside entity?
What services are located in your town, county, or state? Does it include non-profits, religious
organizations, or community services providers?
Have you considered hiring staff or contracting out on a per incident basis?

Appendix E - Data Reports/Community Corrections

E-36

PREA Cost Impact Analysis
#

Standard

Question

10

RE-3

Are offenders provided access to outside victim advocate services?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:





11

DC-1

Are there posters or pamphlets with this information around the facility jurisdiction?
Who provides this outside victim advocacy support? What services are located in your town,
county, or state? Non-profits, religious organizations, or community service providers?
Is there a fee borne by you for these services or is it provided by the state, county, or other nonprofit service (state-level sexual assault coalition or its local affiliates)?
Does your facility ensure that communications with such advocates are private, confidential, and
privileged, to the extent allowable by Federal, State, and local law and are offenders informed,
prior to giving them access, of the extent to which these communications will be kept private,
confidential, and privileged?

Do you have a review team to evaluate each incident of sexual abuse?
Have you considered:

12

DC-2

 Do you prepare a report for each incident and include recommendations for improvement?
 What is the LOE cost required to assemble a review team and evaluate each incident?
Do you prepare an annual report on aggregated sexual abuse data using a standardized instrument and
set of definitions (e.g., BJS survey on sexual violence)?
Have you considered:


13

DC-3

Does it include contracted facilities?
Is an increased LOE necessary to aggregate and standardize data?

Do you review, analyze, and use all sexual abuse data to assess and improve the effectiveness of your
sexual abuse prevention, detection, and response policies, practices, and training?
Have you considered:





Is your annual data available to the public (e.g., when requested or through FOIA) or online? If
posting data online, how much effort would it require of your staff?
Based on the volume of incidents, is it necessary to increase the LOE to review incident data?
Does this review identify problem areas (including any racial dynamics) and take action?
Do you provide an assessment of your progress?

Appendix E - Data Reports/Community Corrections

E-37

PREA Cost Impact Analysis
#

Standard

Question

14

DC-4

Is your sexual abuse data properly stored, securely retained, and protected?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



15

PP-6

Is it electronic or paper and where is it stored? In a locked container or password protected?
Have you considered the cost associated with server maintenance and potential upgrades to your
IT system to ensure data is stored securely for a minimum of 10 years?

Do you and your contractors contact all prior institutional employers for information on substantiated
allegations of sexual abuse?
Have you considered:



16

PP-6

Have you considered costs associated with the LOE required to comply with the standard?
Would you offer contingency hires followed up by phone calls to previous institutional employers
(to ease the burden of this standard)?
 How many phone calls would you need to make?
Do you and your contractors run criminal background checks for all applicants and employees being
considered for promotion?
Have you considered:





17

AU-1

Large staffing populations serve as a cost driver for conducting background checks.
Have you considered the cost of a background check on a per incident basis?
How many promotions/new-hires are estimated per year?
Who conducts your background investigations? Is there a cost?

What would be the cost impact of conducting an audit to measure compliance with the PREA
standards at least every three years at every facility, including contracted facilities?
Have you considered:




Is there a cost associated with the LOE necessary for auditors to conduct their assessment?
Is there a cost associated with conducting audits such as the ACA audit or PbS audit?
Does your state or any other higher authority perform routine audits of your facility/jurisdiction?
Do you pay for them?

Appendix E - Data Reports/Community Corrections

E-38

PREA Cost Impact Analysis
#

Standard

Question

18

SC-1

Are all offenders screened during intake (and at all subsequent classification reviews) to assess their
risk of being sexually abused by other offenders or having the potential to be sexually abusive towards
other offenders?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


19

SC-2

Do you have a written screening instrument tailored to the gender of the population being
screened? Is there a cost associated with developing or modifying a tool to include PREA-related
questions?
 Have you considered the LOE necessary to develop a screening process if your
jurisdiction/facility has yet to formalize a process on par with the NPREC standards?
Do you use the screening information to inform housing, bed, work, education, and program
assignments with the goal of keeping separate those offenders at high risk of being sexually victimized
from those at high risk of being sexually abusive?
Have you considered:



20

PP-2

Does this require an increased LOE?
Who would perform this assessment?

Do you contract with other agencies or facilities for the confinement of offenders? If so, do you
ensure these contracted agencies or facilities adhere to PREA guidelines?
Have you considered:




If so, how many facilities?
Will this require any contract modifications, and if so, will it result in a greater cost to you?
Are these entities private or public? If public, would they be subject to PREA compliance also?

Appendix E - Data Reports/Community Corrections

E-39

PREA Cost Impact Analysis
#

Standard

Question

21

RP-2

Do you maintain or attempt to enter into memoranda of understanding (MOUs) or other agreements
with an outside public entity or office that is able to 1) receive and immediately forward offender
reports of sexual abuse to facility heads, 2) provide offenders with confidential emotional support
services related to sexual abuse, and 3) help victims of sexual abuse during their transition from
incarceration to the community?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




22

RP-3

Who currently provides these services (if anyone)?
Do you have any MOU’s with them? If not, how much would it cost to develop these MOUs?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
Do you conduct your own criminal investigations or is it an outside legal authority?
Have you considered:




23

RP-4

If outside, who is it?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
 If applicable, does it cover vulnerable persons (e.g., under 18 years of age)?
Who are the authorities that prosecute violations?
Have you considered:




If prosecutions are conducted by state agencies, is there a statute that authorizes this service?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?

Appendix E - Data Reports/Community Corrections

E-40

PREA Cost Impact Analysis
#

Standard

Question

24

PP-5

Do you ensure that offenders who are LEP, deaf, or disabled are able to report sexual abuse to staff
directly through interpretive technology or through non-offender interpreters?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




25

RP-1

What services and tools do you employ? Is there a LOE cost?
What interpretive technology will you use? Is there a cost?
Do you provide services for the mentally disabled? Do you have a medical or mental health staff
that would provide these services? Is there a LOE cost for these services?

Are forensic medical exams provided free of charge to the victim?
Have you considered:



26

RE-4

Who provides the exams?
Who bears the cost associated with giving these exams?

Do you investigate all third-party reports of sexual abuse?
Have you considered:



27

IN-1

Based on the number of incidents investigated in the past, is there a LOE cost?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Do you investigate all allegations of sexual abuse and notify victims and/or other complaints in writing
of investigation outcomes and any disciplinary or criminal sanctions, regardless of the source of the
allegation? Are these investigations carried through to completion, regardless of whether the alleged
abuser or victim remains at the facility?
Have you considered:



Based on the number of incidents investigated in the past, is an increased LOE necessary to
ensure that an investigation is conducted for all allegations of sexual abuse?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Appendix E - Data Reports/Community Corrections

E-41

PREA Cost Impact Analysis
#

Standard

Question

28

IN-3

Are allegations of sexual abuse substantiated if supported by a preponderance of the evidence?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


29

MM-2

Is an increased LOE necessary in order to substantiate claims of abuse?

Does the facility/jurisdiction provide ongoing medical and/or mental health evaluations and treatment
to all known users of sexual abuse?
Have you considered:



30

RE-1

What would be the cost associated with a mental health evaluation?
Would an increased LOE be necessary in order to provide medical and mental health practitioners
that would conduct these evaluations?

How do victims confidentially report sexual abuse (in multiple ways)?
Have you considered:


31

RE-2

What means are available to report sexual abuse (e.g., drop boxes, toll-free numbers, talking with
an officer, contacting an outside entity)?
 Are any verbal reports immediately put into writing?
 If an outside entity, who would provide this service and is there a fee for providing such a
service?
 Would this cost be charged on a per incident basis?
What is your policy/procedure for the exhaustion of administrative remedies available to an offender?
Do you ensure that this covers a 90-day period (unless you have made a final determination earlier)
and does it cover a 48 hours requirement after an offender has notified any agency staff member of his
or her need for protection?
Have you considered:


A cost associated with creating or revising a policy and/or procedure to include attorney fees or
additional litigation costs (if quantifiable)?

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Community Corrections, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Community Corrections

E-42

PREA Cost Impact Analysis

Part II. For each standard/question below, please provide a response to whether or not your jurisdiction is compliant and provide an explanation of the reason
for answering compliant or noncompliant. For further information on each standard, please reference the NPREC Standards Prevention, Detection, Response,
and Monitoring of Sexual Abuse in Adult Prisons and Jails.

Appendix E - Data Reports/Community Corrections

E-43

PREA Cost Impact Analysis

#

Standard

Question

1

PP-1

Does your agency have a written policy mandating zero tolerance towards all forms of sexual abuse
and enforces that policy by ensuring all its facilities comply with the PREA standards?

2

PP-4

At your agency, do medical practitioners conduct examinations of transgender individuals to
determine their genital status only in private settings and only when an individual’s genital status is
unknown?

3

PP-4

Does your facility prohibit cross-gender strips and visual body cavity searches?

4

PP-6

Does your agency intentionally not hire or promote anyone who has engaged in sexual abuse in an
institutional setting or in the community facilitated by force, the threat of force, or coercion?

5

PP-6

Does your agency directly inquire about, during interviews and reviews, and examine and carefully
weigh any history of criminal activity at work or in the community, including convictions for
domestic violence, stalking, and sex offenses?

6

RP-1

Does your facility follow an evidence protocol adapted from the 2004 U.S. Department of Justice’s
Office on Violence Against Women publication ―A National Protocol for Sexual Assault Medical
Forensic Examinations, Adults/Adolescents‖, or subsequent updated editions, or similarly
comprehensive and authoritative protocols developed after 2004?
http://www.ncjrs.gov/pdffiles1/ovw/206554.pdf

7

RP-3

Do you have the legal authority to conduct investigations within your facility?

8

SC-2

Does your facility make individualized determinations about how to ensure the safety of each
offender, including whether lesbian, gay, bisexual, transgender, or other gender-nonconforming
inmates are placed in particular facilities, units, or wings solely on the basis of their sexual
orientation, genital status, or gender identity.

9

SC-2

Are offenders at high risk for sexual victimization placed in segregated housing only as a last resort
and then only until an alternative means of separation from likely abusers can be arranged?

Appendix E - Data Reports/Community Corrections

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-44

PREA Cost Impact Analysis
#

Standard

Question

10

SC-2

In your facility, does risk of sexual victimization limit access to programs, education, and work
opportunities?

11

RE-4

At the conclusion of an investigation, does your facility notify in writing the third-party individual
who reported the abuse and the offender named in the report of the outcome of the investigation?

12

RE-4

Does your facility publicly distribute information on how to report sexual abuse on behalf of an
offender?

13

OR-1

Does your agency policy require that all staff members immediately report any knowledge, suspicion,
or information they receive regarding an incident of sexual abuse, retaliation against offenders, or
staff who reported abuse; and any staff neglect related to an incident of sexual abuse or retaliation?

14

OR-1

Does your agency policy require that staff not reveal any information related to a sexual abuse report
to anyone other than those who need to know, to make treatment, investigation, and other security
and management decisions?

15

OR-1

At your agency, are medical and mental health practitioners required to report sexual abuse and
inform offenders of their duty to report the abuse at the initiation of services, unless otherwise
precluded by Federal, State, or local law?

16

OR-1

At your agency, is it required that the facility head report an incident involving a victim less than 18
years of age to the designated State or local services agency under applicable mandatory reporting
laws?

17

OR-2

When your facility receives an allegation that an offender was sexually abused while confined at another facility, does the head of your facility notify in writing the head of the facility where the alleged
abuse occurred, and ensure that the allegation is or was investigated?

18

OR-3

At your agency, when a sexual abuse incident has occurred and the collection of physical evidence is
still possible, do the first security staff to the scene conduct the following:
7)
8)
9)

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

separate the alleged victim and abuser
seal and preserve any crime scene(s)
instruct the victim not to take any actions that could destroy physical evidence, including
washing, brushing teeth, changing clothes, urinating, defecating, smoking, drinking, or eating?

Appendix E - Data Reports/Community Corrections

E-45

PREA Cost Impact Analysis
#

Standard

Question

19

OR-3

At your agency, if the first staff responder is a non-security staff member, is he or she required to
instruct the victim not to take any actions that could destroy physical evidence and then notify
security staff?

20

OR-4

Does your agency ensure the coordination of all actions taken in response to an incident of sexual
abuse among staff first responders, medical and mental health practitioners, investigators, and facility
leadership?

21

OR-4

Does your facility’s coordinated response ensure that victims receive all necessary immediate and
ongoing medical, mental health, and support services and that investigators are able to obtain usable
evidence to substantiate allegations and hold perpetrators accountable?

22

OR-5

Does your agency protect all offenders and staff who report sexual abuse or cooperate with sexual
abuse investigations from retaliation by other offenders or staff, including housing changes or
transfers, the removal of any contact between the alleged abuser and victim, and the offering of
emotional support services?

23

OR-5

Does your agency monitor, for at least 90 days, the conduct and/or treatment of offenders or staff that
have reported sexual abuse or cooperated with investigations, and identify and discuss with inmates
and staff any changes that may suggest possible retaliation, and if necessary, take immediate steps to
protect the offender or staff member?

24

DI-1

At your agency, is staff subject to disciplinary sanctions up to and including termination when sexual
abuse policies have been violated?

25

DI-1

At your agency, is termination the presumptive disciplinary sanction for staff members who have
engaged in sexually abusive contact or penetration?

26

DI-2

At your agency, are offenders subject to disciplinary sanctions pursuant to a formal disciplinary
process following an administrative ruling that the offender engaged in offender-on-offender sexual
abuse or following a criminal finding of guilt for such sexual abuse?

27

DI-2

At your agency, do sanctions commensurate with the nature and circumstances of the abuse
committed, the offender’s disciplinary history, and comparable offenses by other offenders with
similar histories?

Appendix E - Data Reports/Community Corrections

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

E-46

PREA Cost Impact Analysis
#

Standard

Question

28

DI-2

Does your agency’s disciplinary process consider whether an offender’s mental disabilities or mental
illness contributed to his or her behavior when determining what type of sanction, if any, should be
imposed?

29

DI-2

At your agency, do possible sanctions include interventions designed to address and correct
underlying reasons or motivation for the abuse, such as requiring the offending offender to participate
in therapy, counseling, or other programs?

30

MM-1

Do victims of sexual abuse have timely, unimpeded access to emergency medical treatment and crisis
intervention services, the nature and scope of which are determined by medical and mental health
practitioners according to their professional judgment, and, if so, are these services free to the victim
and regardless of whether the victim names the abuser?

31

MM-1

If the community corrections facility does not have medical or mental health practitioners or they are
not on duty at the time a report of recent abuse is made, staff first responders take preliminary steps to
protect the victim (OR-3) and immediately notify appropriate staff or community medical and mental
health practitioners.

Compliant?
(Y/N)

Explanation of reason for being
compliant or noncompliant

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Community Corrections, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Community Corrections

E-47

PREA Cost Impact Analysis

Lockups

Cost Impact Study Questionnaire
[Lockups]
BOOZ ALLEN HAMILTON

[The following questionnaire consists of two parts. Part I identifies Nation Prison Rape Elimination Commission (NPREC) standards that require
an estimated cost impact (if any), accompanied by a detailed explanation of that cost impact or reason for being in compliance. Part II identifies
the remaining standards outlined by NPREC to gauge a level of compliance and a detailed reason for those standards that the jurisdiction may find
to be noncompliant with.]
Appendix E - Data Reports/Lockups

E-48

PREA Cost Impact Analysis

Appendix E - Data Reports/Lockups

E-49

PREA Cost Impact Analysis
Part I. For each question below, please reference the Standard column and review the standard(s) definition (found in the NPREC Standards Prevention,
Detection, Response, and Monitoring of Sexual Abuse in Lockups) before offering a response. If your jurisdiction/facility is compliant, please respond with a
―Y‖ in the Compliant? column and provide a detailed explanation of reason for being compliant in the last column. (Please note: You do not need to provide
a cost impact if you find your jurisdiction/facility to be in compliance.) Otherwise, please respond with a ―N‖ in the Compliant? column and provide an
estimated cost impact accompanied by a detailed explanation of the projected cost after considering points made in the Question? column.

#

Standard

Question

1

PP-5

Except in the case of an emergency, does your jurisdiction/facility prohibit cross-gender pat downs?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




2

PP-3

How would male/female staffing levels need to be altered to prohibit cross-gender pat down
searches?
Would this require an increased level of effort (LOE)?
Are there other policies, besides altering staffing levels, that could be employed?

If a problem of sexual abuse is evident in your jurisdiction/facility, what is the best method for
reducing the number of incidents through physical supervision?
Have you considered:

3

PP-8

 Would an increased LOE be necessary in order to provide adequate physical supervision?
 Can you get by with a workforce realignment to meet the same objective?
Does your jurisdiction/facility currently have video monitoring in place? If you feel this technology
is not adequately suited to reduce sexual abuse incidents, what is the associated cost?
Have you considered:




What would it cost to purchase and install monitoring technology in trouble areas?
Is this enhanced technology directly related to reducing the incidence of sexual abuse?
Would you consider employing other methods of technology supervision (e.g., Radio Frequency
Identification Bracelets)? If so, what would be the cost impact of such technology?

Appendix E - Data Reports/Lockups

E-50

PREA Cost Impact Analysis
#

Standard

Question

4

PP-8

Do you annually assess the feasibility of your current technology, including developing a plan for
securing new technology?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



5

PP-1

Is there a cost associated with the LOE necessary for management to meet yearly and assess and
develop a plan for securing new technology?
Would you contract out for this assessment?

Does your jurisdiction/facility have a PREA coordinator to comply with the PREA standards?
Have you considered:




6

TR-1

A PREA coordinator is a full-time position in the governing body of the State prison systems
and agencies that operate large jails (more than 500 detainees) but may be a part-time position in
jurisdictions that operate medium (101-500) and small jails (100 detainees or fewer).
Have you considered the cost of the PREA coordinator including base salary plus benefits?

Do you provide training to all employees and volunteers on sexual abuse prevention, detection, and
response policies and procedures; the PREA standards; and relevant Federal, State, and local law?
Have you considered:


7

TR-2

What are the means of training? Class-room/computer based? Consider the LOE of an
instructor and materials or the cost associated with the implementation of a web-based module.
 Have you reviewed appendix A of the NPREC standards that lays out the training requirements?
 Are all employees (including office administrators) included in your training?
 Do you provide periodic refresher training to employees and volunteers? How frequently?
What’s the cost impact associated with this recurring training?
Do employees notify all detainees of the agency’s zero-tolerance policy regarding sexual abuse during intake?
Have you considered:


The agency ensures that attorneys, contractors, and inmate workers are informed of the agency’s
zero-tolerance policy regarding sexual abuse upon entering the lockup. Is there a cost associated
with this increased LOE?

Appendix E - Data Reports/Lockups

E-51

PREA Cost Impact Analysis
#

Standard

Question

8

TR-3

Do you ensure sexual abuse training has been provided to investigators specifically conducting
investigations in confinement settings?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




9

RP-1

Where do they get their training? Does it cover confinement settings?
If you are responsible for training your own investigators, have you considered the cost of
materials and LOE of an instructor or web-based development?
Does your training for investigators include techniques for interviewing sexual abuse victims,
proper use of Miranda- and Garrity-type warnings, sexual abuse evidence collection in
confinement settings, and the criteria and evidence required to substantiate a case for
administrative action or prosecution referral?

Do you provide a victim advocate to accompany the victim through the forensic medical exam
process?
Have you considered:




10

DC-1

Who would provide this service? A current employee or outside entity?
What services are located in your town, county, or state? Does it include non-profits, religious
organizations, or community service providers?
Have you considered hiring staff or contracting out on a per incident basis?

Do you have a review team to evaluate each incident of sexual abuse?
Have you considered:

11

DC-2

 Do you prepare a report for each incident and include recommendations for improvement?
 What is the LOE cost required to assemble a review team and evaluate each incident?
Do you prepare an annual report on aggregated sexual abuse data using a standardized instrument and
set of definitions (e.g., BJS survey on sexual violence)?
Have you considered:



Does it include contracted facilities?
Is an increased LOE necessary to aggregate and standardize sexual abuse data?

Appendix E - Data Reports/Lockups

E-52

PREA Cost Impact Analysis
#

Standard

Question

12

DC-3

Do you review, analyze, and use all sexual abuse data to assess and improve the effectiveness of your
sexual abuse prevention, detection, and response policies, practices, and training?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


13

DC-4

Is your annual data available to the public (e.g., when requested or through FOIA) or online? If
posting data online, how much effort would it require of your staff?
 Based on the volume of incidents, is it necessary to increase the LOE to review each incident?
 Does this review identify problem areas (including any racial dynamics) and take action?
 Do you provide an assessment of your progress?
Is your sexual abuse data properly stored, securely retained, and protected?
Have you considered:



14

PP-7

Is it electronic or paper and where is it stored? In a locked container or password protected?
Have you considered the cost associated with server maintenance and potential upgrades to your
IT system to ensure data is stored securely for a minimum of 10 years?

Do you and your contractors contact all prior institutional employers for information on substantiated
allegations of sexual abuse?
Have you considered:



15

PP-7

Have you considered costs associated with the LOE required to comply with the standard?
Would you offer contingency hires followed up by phone calls to previous institutional
employers (to ease the burden of this standard)?
 How many phone calls would you need to make?
Do you and your contractors run criminal background checks for all applicants and employees being
considered for promotion?
Have you considered:





Large staffing populations serve as a cost driver for conducting background checks.
Have you considered the cost of a background check on a per incident basis?
How many promotions/new-hires are estimated per year?
Who conducts your background investigations? Is there a cost?

Appendix E - Data Reports/Lockups

E-53

PREA Cost Impact Analysis
#

Standard

Question

16

AU-1

What would be the cost impact of conducting an audit to measure compliance with the PREA
standards at least every three years at every facility, including contracted facilities?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




17

PP-4

Is there a cost associated with the LOE necessary for auditors to conduct their assessment?
Is there a cost associated with conducting audits such as the ACA audit or PbS audit?
Does your state or any other higher authority perform routine audits of your facility/jurisdiction?
Do you pay for them?

Are all detainees screened during intake (and at all subsequent classification reviews) to assess their
risk of being sexually abused by other detainees or having the potential to be sexually abusive
towards other detainees?
Have you considered:




18

PP-2

Do you have a written screening instrument tailored to the gender of the population being
screened? Is there a cost associated with developing or modifying a tool to include PREArelated questions?
Have you considered the LOE necessary to develop a screening process if your
jurisdiction/facility has yet to formalize a process on par with the NPREC standards?

Do you contract with other agencies or facilities for the confinement of inmates? If so, do you ensure
these contracted agencies or facilities adhere to PREA guidelines?
Have you considered:




If so, how many facilities?
Will this require any contract modifications, and if so, will it result in a greater cost to you?
Are these entities private or public? If public, would they be subject to PREA compliance also?

Appendix E - Data Reports/Lockups

E-54

PREA Cost Impact Analysis
#

Standard

Question

19

RP-2

Do you conduct your own criminal investigations or is it an outside legal authority?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:




20

RP-3

If outside, who is it?
Do you have a MOU with them? If not, how much would it cost to develop a MOU?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?
 If applicable, does it cover vulnerable persons (e.g., under 18 years of age)?
Who are the authorities that prosecute violations?
Have you considered:




21

PP-6

If prosecutions are conducted by state agencies, is there a statute that authorizes this service?
Do you have a MOU with them? If not, how much would it cost to develop?
If not possible to establish a MOU, do you document the attempt to enter an agreement? Is there
a cost impact associated with the LOE required to document this attempt?

Do you ensure that detainees who are LEP, deaf, or disabled are able to report sexual abuse to staff
directly through interpretive technology or through non-detainee interpreters?
Have you considered:




22

RP-1

What services and tools do you employ? Is there a LOE cost?
What interpretive technology will you use? Is there a cost?
Do you provide services for the mentally disabled? Do you have a medical or mental health
staff that would provide these services? Is there a LOE cost for these services?

Are forensic medical exams provided free of charge to the victim?
Have you considered:



Who provides the exams?
Who bears the cost associated with giving these exams?

Appendix E - Data Reports/Lockups

E-55

PREA Cost Impact Analysis
#

Standard

Question

23

RE-3

Do you investigate all third-party reports of sexual abuse?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:



24

IN-1

Based on the number of incidents investigated in the past, is there a LOE cost?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Do you investigate all allegations of sexual abuse and notify victims and/or other complaints in
writing of investigation outcomes and any disciplinary or criminal sanctions, regardless of the source
of the allegation? Are these investigations carried through to completion, regardless of whether the
alleged abuser or victim remains at the facility?
Have you considered:



25

IN-3

Based on the number of incidents investigated in the past, is an increased LOE necessary to
ensure that an investigation is conducted for all allegations of sexual abuse?
Should this LOE be based on a case-by-case basis or in terms of a staff increase?

Are allegations of sexual abuse substantiated if supported by a preponderance of the evidence?
Have you considered:


26

RE-1

Is an increased LOE necessary in order to substantiate claims of abuse?

How do victims confidentially report sexual abuse (in multiple ways)?
Have you considered:





What means are available to report sexual abuse (e.g., drop boxes, toll-free numbers, talking
with an officer, contacting an outside entity)?
Are any verbal reports immediately put into writing?
If an outside entity, who would provide this service and is there a fee?
Would this cost be charged on a per incident basis?

Appendix E - Data Reports/Lockups

E-56

PREA Cost Impact Analysis
#

Standard

Question

27

RE-2

What is your policy/procedure for the exhaustion of administrative remedies available to a detainee?
Do you ensure that this covers a 90-day period (unless you have made a final determination earlier)
and does it cover a 48 hours requirement after an inmate has notified any agency staff member of his
or her need for protection?

Compliant?
(Y/N)

Cost
Impact ($)

Detailed explanation of cost impact
or reason for being compliant

Have you considered:


A cost associated with creating or revising a policy and/or procedure to include attorney fees?

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Lockups, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Lockups

E-57

PREA Cost Impact Analysis

Part II. For each standard/question below, please provide a response to whether or not your jurisdiction is compliant and provide an explanation of the reason
for answering compliant or noncompliant. For further information on each standard, please reference the NPREC Standards Prevention, Detection, Response,
and Monitoring of Sexual Abuse in Adult Prisons and Jails.

#

Standard

Question

1

PP-1

Does your agency have a written policy mandating zero tolerance towards all forms of sexual abuse and
enforces that policy by ensuring all its facilities comply with the PREA standards?

2

PP-7

Does your agency intentionally not hire or promote anyone who has engaged in sexual abuse in an
institutional setting or in the community facilitated by force, the threat of force, or coercion?

Appendix E - Data Reports/Lockups

Compliant?
(Y/N)

Explanation of reason for being compliant or
noncompliant

E-58

PREA Cost Impact Analysis
#

Standard

Question

3

PP-7

Does your agency directly inquire about, during interviews and reviews, and examine and carefully weight
any history of criminal activity at work or in the community, including convictions for domestic violence,
stalking, and sex offenses?

4

RP-1

Does your facility follow an evidence protocol adapted from the 2004 U.S. Department of Justice’s Office
on Violence Against Women publication ―A National Protocol for Sexual Assault Medical Forensic
Examinations, Adults/Adolescents‖, subsequent updated editions, or similarly comprehensive and
authoritative protocols developed after 2004? http://www.ncjrs.gov/pdffiles1/ovw/206554.pdf

5

RP-3

Do you have legal authority to conduct investigations within your facility?

6

RE-3

At the conclusion of an investigation, does your facility notify in writing the third-party individual who
reported the abuse and the inmate named in the report of the outcome of the investigation?

7

RE-3

Does your facility publicly distribute information on how to report sexual abuse on behalf of an inmate?

8

OR-1

Does your agency policy require that all staff members immediately report, according to agency policy,
any knowledge, suspicion, or information they receive regarding an incident of sexual abuse, retaliation
against detainees or staff who reported abuse; and any staff neglect related to an incident of sexual abuse
or retaliation?

9

OR-1

Does your agency policy require that staff not reveal any information related to a sexual abuse report to
anyone other than those who need to know, to make treatment, investigation, and other security and
management decisions?

10

OR-1

At your agency, is it required that the facility head report an incident involving a victim under 18 years of
age to the designated State or local services agency under applicable mandatory reporting laws?

11

OR-2

When your facility receives an allegation that a detainee was sexually abused while confined at another
facility, does the head of the facility where the report was made notify in writing the head of the facility
where the alleged abuse occurred, and ensure that the allegation is or was investigated?

Appendix E - Data Reports/Lockups

Compliant?
(Y/N)

Explanation of reason for being compliant or
noncompliant

E-59

PREA Cost Impact Analysis
#

Standard

Question

12

OR-3

At your agency, when a sexual abuse incident has occurred and the collection of physical evidence is still
possible, do the first security staff to the scene conduct the following:

Compliant?
(Y/N)

Explanation of reason for being compliant or
noncompliant

10) separate the alleged victim and abuser
11) seal and preserve any crime scene(s)
12) instruct the victim not to take any actions that could destroy physical evidence, including
washing, brushing teeth, changing clothes, urinating, defecating, smoking, drinking, or eating?
At your agency, if the first staff responder is a non-security staff member, is he or she required to instruct
the victim not to take any actions that could destroy physical evidence and then notify security staff?

13

OR-3

14

OR-4

Does you agency ensure the coordination of all actions taken in response to an incident of sexual abuse
among staff first responders, medical and mental health practitioners, investigators, and facility
leadership?

15

OR-4

Does your facility’s coordinated response ensure that victims receive all necessary immediate and ongoing
medical, mental health, and support services and that investigators are able to obtain usable evidence to
substantiate allegations and hold perpetrators accountable?

16

OR-5

Does your agency protect all detainees and staff who report sexual abuse or cooperate with sexual abuse
investigations from retaliation by other detainees or staff, including housing changes or transfers, the
removal of any contact between the alleged abuser and victim, and the offering of emotional support
services?

17

OR-5

Does your agency monitor, for at least 90 days, the conduct and/or treatment of detainees or staff that
have reported sexual abuse or cooperated with investigations, and identify and discuss with detainees and
staff any changes that may suggest possible retaliation, and if necessary, take immediate steps to protect
the detainee or staff?

18

DI-1

At your agency, is staff subject to disciplinary sanctions up to and including termination when sexual
abuse policies have been violated?

19

DI-1

At your agency, is termination the presumptive disciplinary sanction for staff members who have engaged
in sexually abusive contact or penetration?

Appendix E - Data Reports/Lockups

E-60

PREA Cost Impact Analysis
#

Standard

Question

20

DI-2

At your agency, are detainees subject to disciplinary sanctions pursuant to a formal disciplinary process
following an administrative ruling that the detainee engaged in detainee-on-detainee sexual abuse or
following a criminal finding of guilt for such sexual abuse?

21

DI-2

At your agency, do sanctions commensurate with the nature and circumstances of the abuse committed,
the detainee’s disciplinary history, and comparable offenses by other detainees with similar histories?

22

DI-2

Does your agency’s disciplinary process consider whether a detainee’s mental disabilities or mental illness
contributed to his or her behavior when determining what type of sanction, if any, should be imposed?

23

DI-2

At your agency, do possible sanctions include interventions designed to address and correct underlying
reasons or motivation for the abuse, such as requiring the offending detainee to participate in therapy,
counseling, or other programs?

24

MM-1

Do victims of sexual abuse have timely, unimpeded access to emergency medical treatment and crisis
intervention services, the nature and scope of which are determined by medical and mental health
practitioners according to their professional judgment.

25

MM-1

Are treatment services provided free of charge to the victim and regardless of whether the victim names
the abuser?

26

MM-1

If the community corrections facility does not have medical or mental health practitioners or they are not
on duty at the time a report of recent abuse is made, staff first responders take preliminary steps to protect
the victim (OR-3) and immediately notify appropriate staff or community medical and mental health
practitioners.

27

DC-1

Does the report consider whether incidents were motivated by racial or other group dynamics at the
facility?

Compliant?
(Y/N)

Explanation of reason for being compliant or
noncompliant

Source: Standards for the Prevention, Detection, Response, and Monitoring of Sexual Abuse in Lockups, the National Prison Rape Elimination Commission.

Appendix E - Data Reports/Lockups

E-61

PREA Cost Impact Analysis

Appendix F - Standards Summary
Adult Prisons and Jails

National Standards
Adult Prisons and Jails
I. PREVENTION AND RESPONSE PLANNING
Prevention Planning (PP)
PP1 - Zero tolerance of sexual abuse
The agency has a written policy mandating zero tolerance toward all forms of sexual abuse and
enforces that policy by ensuring all of its facilities comply with the NPREC standards. The
agency employs or designates a PREA coordinator to develop, implement, and oversee agency
efforts to comply with the NPREC standards.
PP2 - Contracting with other entities for the confinement of inmates
If public correctional agencies contract for the confinement of their inmates, they do so only
with private agencies or other entities, including other government agencies, committed to
eliminating sexual abuse in their facilities, as evidenced by their adoption of and compliance
with the NPREC standards. Any new contracts or contract renewals include the entity’s
obligation to adopt and comply with the NPREC standards and specify that the public agency
will monitor the entity’s compliance with these standards as part of its monitoring of the entity’s
performance.
PP3 - Inmate supervision
Security staff provides the inmate supervision necessary to protect inmates from sexual abuse.
The upper management officials responsible for reviewing critical incidents must examine areas
in the facility where sexual abuse has occurred to assess whether physical barriers may have
enabled the abuse, the adequacy of staffing levels in those areas during different shifts, and the
need for monitoring technology to supplement security staff supervision (DC1). When problems
or needs are identified, the agency takes corrective action (DC3).

Appendix F - Standards Summary

F-1

PREA Cost Impact Analysis
PP4 - Limits to Cross-Gender Viewing and Searches
Except in the case of emergency, the facility prohibits cross-gender strip and visual body cavity
searches. Except in the case of emergency or other extraordinary or unforeseen circumstances,
the facility restricts non-medical staff from viewing inmates of the opposite gender who are
nude or performing bodily functions and similarly restricts cross-gender pat down searches.
Medical practitioners conduct examinations of transgender individuals to determine their genital
status only in private settings and only when an individual’s genital status is unknown.
PP5 - Accommodating inmates with special needs
The agency ensures that inmates who are limited English proficient (LEP), deaf, or disabled are
able to report sexual abuse to staff directly, through interpretive technology, or through noninmate interpreters. Accommodations are made to convey all written information about sexual
abuse policies, including how to report sexual abuse, verbally to inmates who have limited
reading skills or who are visually impaired.
PP6- Hiring and promotion decisions
The agency does not hire or promote anyone who has engaged in sexual abuse in an institutional
setting or who has engaged in sexual activity in the community facilitated by force, the threat of
force, or coercion. Consistent with Federal, State, and local law, the agency makes its best effort
to contact all prior institutional employers for information on substantiated allegations of sexual
abuse; must run criminal background checks for all applicants and employees being considered
for promotion; and must examine and carefully weigh any history of criminal activity at work or
in the community, including convictions for domestic violence, stalking, and sex offenses. The
agency also asks all applicants and employees directly about previous misconduct during
interviews and reviews.
PP7 - Assessment and Use of Monitoring Technology
The agency uses video monitoring systems and other cost-effective and appropriate technology
to supplement its sexual abuse prevention, detection, and response efforts. The agency assesses,
at least annually, the feasibility of and need for new or additional monitoring technology and
develops a plan for securing such technology.
Response Planning (RP)
RP1 - Evidence protocol and forensic medical exams
The agency follows a uniform evidence protocol that maximizes the potential for obtaining
usable physical evidence for administrative proceedings and criminal prosecutions. The protocol
must be adapted from or otherwise based on the 2004 U.S. Department of Justice’s Office on
Violence Against Women publication ―A National Protocol for Sexual Assault Medical
Forensic Examinations, Adults/Adolescents,‖ subsequent updated editions, or similarly
comprehensive and authoritative protocols developed after 2004. As part of the agency’s
evidence collection protocol, all victims of inmate-on-inmate sexually abusive penetration or
Appendix F - Standards Summary

F-2

PREA Cost Impact Analysis
staff-on-inmate sexually abusive penetration are provided access to forensic medical exams
performed by qualified forensic medical examiners. Forensic medical exams are provided free
of charge to the victim. The facility makes available a victim advocate to accompany the victim
through the forensic medical exam process.
RP2 - Agreements with outside public entities and community service providers
The agency maintains or attempts to enter into memoranda of understanding (MOUs) or other
agreements with an outside public entity or office that is able to receive and immediately
forward inmate reports of sexual abuse to facility heads (RE-1). The agency also maintains or
attempts to enter into MOUs or other agreements with community service providers that are able
to: (1) provide inmates with confidential emotional support services related to sexual abuse and
(2) help victims of sexual abuse during their transition from incarceration to the community
(RE3, MM3). The agency maintains copies of agreements or documentation showing attempts
to enter into agreements.
RP3 - Agreements with outside law enforcement agencies
If an agency does not have the legal authority to conduct criminal investigations or has elected
to permit an outside agency to conduct criminal or administrative investigations of staff or
inmates, the agency maintains or attempts to enter into a written MOU or other agreement
specific to investigations of sexual abuse with the law enforcement agency responsible for
conducting investigations. If the agency confines inmates under the age of 18 or other inmates
who fall under State and local vulnerable persons statutes, the agency maintains or attempts to
enter into an MOU with the designated State or local services agency with the jurisdiction and
authority to conduct investigations related to the sexual abuse of vulnerable persons within
confinement facilities. When the agency already has an existing agreement or long-standing
policy covering responsibilities for all criminal investigations, including sexual abuse
investigations, it does not need to enter into a new agreement. The agency maintains a copy of
the agreement or documentation showing attempts to enter into an agreement.
RP4- Agreements with the prosecuting authority
The agency maintains or attempts to enter into a written MOU or other agreement with the
authority responsible for prosecuting violations of criminal law. The agency maintains a copy of
the agreement or documentation showing attempts to enter into an agreement.
II. PREVENTION
Training and Education (TR)
TR1 - Employee training
The agency trains all employees to be able to fulfill their responsibilities under agency sexual
abuse prevention, detection, and response policies and procedures; the NPREC standards; and
relevant Federal, State, and local law. The agency trains all employees to communicate
effectively and professionally with all inmates. Additionally, the agency trains all employees on
Appendix F - Standards Summary

F-3

PREA Cost Impact Analysis
an inmate’s right to be free from sexual abuse, the right of inmates and employees to be free
from retaliation for reporting sexual abuse, the dynamics of sexual abuse in confinement, and
the common reactions of sexual abuse victims. Current employees are educated as soon as
possible following the agency’s adoption of the NPREC standards, and the agency provides
periodic refresher information to all employees to ensure that they know the agency’s most
current sexual abuse policies and procedures. The agency maintains written documentation
showing employee signatures verifying that employees understand the training they have
received.
TR2 - Volunteer and contractor training
The agency ensures that all volunteers and contractors who have contact with inmates have been
trained on their responsibilities under the agency’s sexual abuse prevention, detection, and
response policies and procedures; the NPREC standards; and relevant Federal, State, and local
law. The level and type of training provided to volunteers and contractors is based on the
services they provide and level of contact they have with inmates, but all volunteers and
contractors who have contact with inmates must be notified of the agency’s zero-tolerance
policy regarding sexual abuse. Volunteers must also be trained in how to report sexual abuse.
The agency maintains written documentation showing volunteer and contractor signatures
verifying that they understand the training they have received.
TR3 - Inmate education
During the intake process, staff informs inmates of the agency’s zero-tolerance policy regarding
sexual abuse and how to report incidents or suspicions of sexual abuse. Within a reasonably
brief period of time following the intake process, the agency provides comprehensive education
to inmates regarding their right to be free from sexual abuse and to be free from retaliation for
reporting abuse, the dynamics of sexual abuse in confinement, the common reactions of sexual
abuse victims, and agency sexual abuse response policies and procedures. Current inmates are
educated as soon as possible following the agency’s adoption of the NPREC standards, and the
agency provides periodic refresher information to all inmates to ensure that they know the
agency’s most current sexual abuse policies and procedures. The agency provides inmate
education in formats accessible to all inmates, including those who are LEP, deaf, visually
impaired, or otherwise disabled as well as inmates who have limited reading skills. The agency
maintains written documentation of inmate participation in these education sessions.
TR4 - Specialized training: Investigations
In addition to the general training provided to all employees (TR1), the agency ensures that
agency investigators conducting sexual abuse investigations have received comprehensive and
up-to-date training in conducting such investigations in confinement settings. Specialized
training must include techniques for interviewing sexual abuse victims, proper use of Mirandaand Garrity-type warnings, sexual abuse evidence collection in confinement settings, and the
criteria and evidence required to substantiate a case for administrative action or prosecution
referral. The agency maintains written documentation that investigators have completed the
required specialized training in conducting sexual abuse investigations.
Appendix F - Standards Summary

F-4

PREA Cost Impact Analysis
TR5 - Specialized training: Medical and mental health care
The agency ensures that all full- and part-time medical and mental health care practitioners
working in its facilities have been trained in how to detect and assess signs of sexual abuse and
that all medical practitioners are trained in how to preserve physical evidence of sexual abuse.
All medical and mental health care practitioners must be trained in how to respond effectively
and professionally to victims of sexual abuse and how and to whom to report allegations or
suspicions of sexual abuse. The agency maintains documentation that medical and mental health
practitioners have received this specialized training.
Screening for Risk of Sexual Victimization and Abusiveness (SC)
SC1 - Screening for risk of victimization and abusiveness
All inmates are screened during intake, during the initial classification process, and at all
subsequent classification reviews to assess their risk of being sexually abused by other inmates
or sexually abusive toward other inmates. Employees must conduct this screening using a
written screening instrument tailored to the gender of the population being screened. Although
additional factors may be considered, particularly to account for emerging research and the
agency’s own data analysis, screening instruments must contain the criteria described below. All
screening instruments must be made available to the public upon request.
SC2 - Use of screening information
Employees use information from the risk screening (SC1) to inform housing, bed, work,
education, and program assignments with the goal of keeping separate those inmates at high risk
of being sexually victimized from those at high risk of being sexually abusive. The facility
makes individualized determinations about how to ensure the safety of each inmate. Lesbian,
gay, bisexual, transgender, or other gender-nonconforming inmates are not placed in particular
facilities, units, or wings solely on the basis of their sexual orientation, genital status, or gender
identity. Inmates at high risk for sexual victimization may be placed in segregated housing only
as a last resort and then only until an alternative means of separation from likely abusers can be
arranged. To the extent possible, risk of sexual victimization should not limit access to
programs, education, and work opportunities.
III. DETECTION AND RESPONSE
Reporting (RE)
RE1 - Inmate reporting
The facility provides multiple internal ways for inmates to report easily, privately, and securely
sexual abuse, retaliation by other inmates or staff for reporting sexual abuse, and staff neglect or
violation of responsibilities that may have contributed to an incident of sexual abuse. The
facility also provides at least one way for inmates to report the abuse to an outside public entity
or office not affiliated with the agency that has agreed to receive reports and forward them to the
facility head (RP2), except when an inmate requests confidentiality. Staff accepts reports made
Appendix F - Standards Summary

F-5

PREA Cost Impact Analysis
verbally, in writing, anonymously, and from third parties and immediately puts into writing any
verbal reports.
RE2 - Exhaustion of administrative remedies
Under agency policy, an inmate has exhausted his or her administrative remedies with regard to
a claim of sexual abuse either (1) when the agency makes a final decision on the merits of the
report of abuse (regardless of whether the report was made by the inmate, made by a third party,
or forwarded from an outside official or office) or (2) when 90 days have passed since the report
was made, whichever occurs sooner. A report of sexual abuse triggers the 90-day exhaustion
period regardless of the length of time that has passed between the abuse and the report. An
inmate seeking immediate protection from imminent sexual abuse will be deemed to have
exhausted his or her administrative remedies 48 hours after notifying any agency staff member
of his or her need for protection.
RE3 - Inmate access to outside confidential support services
In addition to providing on-site mental health care services, the facility provides inmates with
access to outside victim advocates for emotional support services related to sexual abuse. The
facility provides such access by giving inmates the current mailing addresses and telephone
numbers, including toll-free hotline numbers, of local, State, and/or national victim advocacy or
rape crisis organizations and enabling reasonable communication between inmates and these
organizations. The facility ensures that communications with such advocates are private,
confidential, and privileged, to the extent allowable by Federal, State, and local law. The facility
informs inmates, prior to giving them access, of the extent to which such communications will
be private, confidential, and/or privileged.
RE4 - Third-party reporting
The facility receives and investigates all third-party reports of sexual abuse (IN1). At the
conclusion of the investigation, the facility notifies in writing the third-party individual who
reported the abuse and the inmate named in the third-party report of the outcome of the
investigation. The facility distributes publicly information on how to report sexual abuse on
behalf of an inmate.
Official Response Following an Inmate Report (OR)
OR1 - Staff and facility head reporting duties
All staff members are required to report immediately and according to agency policy any
knowledge, suspicion, or information they receive regarding an incident of sexual abuse that
occurred in an institutional setting; retaliation against inmates or staff who reported abuse; and
any staff neglect or violation of responsibilities that may have contributed to an incident of
sexual abuse or retaliation. Apart from reporting to designated supervisors or officials, staff
must not reveal any information related to a sexual abuse report to anyone other than those who
need to know, as specified in agency policy, to make treatment, investigation, and other security
and management decisions. Unless otherwise precluded by Federal, State, or local law, medical
Appendix F - Standards Summary

F-6

PREA Cost Impact Analysis
and mental health practitioners are required to report sexual abuse and must inform inmates of
their duty to report at the initiation of services. If the victim is under the age of 18 or considered
a vulnerable adult under a State or local vulnerable persons statute, the facility head must report
the allegation to the designated State or local services agency under applicable mandatory
reporting laws.
OR2 - Reporting to other confinement facilities
When the facility receives an allegation that an inmate was sexually abused while confined at
another facility, the head of the facility where the report was made notifies in writing the head of
the facility where the alleged abuse occurred. The head of the facility where the alleged abuse
occurred ensures the allegation is investigated.
OR3 - Staff first responder duties
Upon learning that an inmate was sexually abused within a time period that still allows for the
collection of physical evidence, the first security staff member to respond to the report is
required to (1) separate the alleged victim and abuser; (2) seal and preserve any crime scene(s);
and (3) instruct the victim not to take any actions that could destroy physical evidence, including
washing, brushing his or her teeth, changing his or her clothes, urinating, defecating, smoking,
drinking, or eating. If the first staff responder is a non-security staff member, he or she is
required to instruct the victim not to take any actions that could destroy physical evidence and
then notify security staff.
OR4 - Coordinated response
All actions taken in response to an incident of sexual abuse are coordinated among staff first
responders, medical and mental health practitioners, investigators, and facility leadership. The
facility’s coordinated response ensures that victims receive all necessary immediate and ongoing
medical, mental health, and support services and that investigators are able to obtain usable
evidence to substantiate allegations and hold perpetrators accountable.
OR5 - Agency protection against retaliation
The agency protects all inmates and staff who report sexual abuse or cooperate with sexual
abuse investigations from retaliation by other inmates or staff. The agency employs multiple
protection measures, including housing changes or transfers for inmate victims or abusers,
removal of alleged staff or inmate abusers from contact with victims, and emotional support
services for inmates or staff who fear retaliation for reporting sexual abuse or cooperating with
investigations. The agency monitors the conduct and/or treatment of inmates or staff who have
reported sexual abuse or cooperated with investigations, including any inmate disciplinary
reports, housing, or program changes, for at least 90 days following their report or cooperation
to see if there are changes that may suggest possible retaliation by inmates or staff. The agency
discusses any changes with the appropriate inmate or staff member as part of its efforts to
determine if retaliation is taking place and, when confirmed, immediately takes steps to protect
the inmate or staff member.

Appendix F - Standards Summary

F-7

PREA Cost Impact Analysis
Investigations (IN)
IN1 - Duty to investigate
The facility investigates all allegations of sexual abuse, including third-party and anonymous
reports, and notifies victims and/or other complainants in writing of investigation outcomes and
any disciplinary or criminal sanctions, regardless of the source of the allegation. All
investigations are carried through to completion, regardless of whether the alleged abuser or
victim remains at the facility.
IN2 - Criminal and administrative agency investigations
Agency investigations into allegations of sexual abuse are prompt, thorough, objective, and
conducted by investigators who have received special training in sexual abuse investigations
(TR4). When outside agencies investigate sexual abuse, the facility has a duty to keep abreast of
the investigation and cooperate with outside investigators (RP3).
IN3 - Evidence standard for administrative investigations
Allegations of sexual abuse are substantiated if supported by a preponderance of the evidence.
Discipline (DI)
DI1 - Disciplinary sanctions for staff
Staff is subject to disciplinary sanctions up to and including termination when staff has violated
agency sexual abuse policies. The presumptive disciplinary sanction for staff members who
have engaged in sexually abusive contact or penetration is termination. This presumption does
not limit agency discretion to impose termination for other sexual abuse policy violations. All
terminations for violations of agency sexual abuse policies are to be reported to law enforcement
agencies and any relevant licensing bodies.
DI2 - Disciplinary sanctions for inmates
Inmates are subject to disciplinary sanctions pursuant to a formal disciplinary process following
an administrative ruling that the inmate engaged in inmate-on-inmate sexual abuse or following
a criminal finding of guilt for inmate-on-inmate sexual abuse. Sanctions are commensurate with
the nature and circumstances of the abuse committed, the inmate’s disciplinary history, and the
sanctions meted out for comparable offenses by other inmates with similar histories. The
disciplinary process must consider whether an inmate’s mental disabilities or mental illness
contributed to his or her behavior when determining what type of sanction, if any, should be
imposed. Possible sanctions also include interventions designed to address and correct
underlying reasons or motivation for the abuse, such as requiring the offending inmate to
participate in therapy, counseling, or other programs.

Appendix F - Standards Summary

F-8

PREA Cost Impact Analysis
Medical and Mental Health Care (MM)
MM1 - Medical and mental health screenings—history of sexual abuse
Qualified medical or mental health practitioners ask inmates about prior sexual victimization
and abusiveness during medical and mental health reception and intake screenings. If an inmate
discloses prior sexual victimization or abusiveness, whether it occurred in an institutional
setting or in the community, during a medical or mental health reception or intake screening, the
practitioner provides the appropriate referral for treatment, based on his or her professional
judgment. Any information related to sexual victimization or abusiveness that occurred in an
institutional setting must be strictly limited to medical and mental health practitioners and other
staff, as required by agency policy and Federal, State, or local law, to inform treatment plans
and security and management decisions, including housing, bed, work, education, and program
assignments. Medical and mental health practitioners must obtain informed consent from
inmates before reporting information about prior sexual victimization that did not occur in an
institutional setting, unless the inmate is under the age of 18.
MM2 - Access to emergency medical and mental health services
Victims of sexual abuse have timely, unimpeded access to emergency medical treatment and
crisis intervention services, the nature and scope of which are determined by medical and mental
health practitioners according to their professional judgment. Treatment services must be
provided free of charge to the victim and regardless of whether the victim names the abuser. If
no qualified medical or mental health practitioners are on duty at the time a report of recent
abuse is made, security staff first responders take preliminary steps to protect the victim (OR3)
and immediately notify the appropriate medical and mental health practitioners.
MM3 - Ongoing medical and mental health care for sexual abuse victims and abusers
The facility provides ongoing medical and/or mental health evaluation and treatment to all
known victims of sexual abuse. The evaluation and treatment of sexual abuse victims must
include appropriate follow-up services, treatment plans, and, when necessary, referrals for
continued care following their release from custody. The level of medical and mental health care
provided to inmate victims must match the community level of care generally accepted by the
medical and mental health professional communities. The facility conducts a mental health
evaluation of all known abusers and provides treatment, as deemed necessary by qualified
mental health practitioners.
IV. MONITORING
Data Collection and Review (DC)
DC1 - Sexual abuse incident reviews
The facility treats all instances of sexual abuse as critical incidents to be examined by a team of
upper management officials, with input from line supervisors, investigators, and medical/mental
health practitioners. The review team evaluates each incident of sexual abuse to identify any
Appendix F - Standards Summary

F-9

PREA Cost Impact Analysis
policy, training, or other issues related to the incident that indicate a need to change policy or
practice to better prevent, detect, and/or respond to incidents of sexual abuse. The review team
also considers whether incidents were motivated by racial or other group dynamics at the
facility. When incidents are determined to be motivated by racial or other group dynamics,
upper management officials immediately notify the agency head and begin taking steps to
rectify those underlying problems. The sexual abuse incident review takes place at the
conclusion of every sexual abuse investigation, unless the allegation was determined to be
unfounded. The review team prepares a report of its findings and recommendations for
improvement and submits it to the facility head.
DC2 - Data collection
The agency collects accurate, uniform data for every reported incident of sexual abuse using a
standardized instrument and set of definitions. The agency aggregates the incident-based sexual
abuse data at least annually. The incident-based data collected includes, at a minimum, the data
necessary to answer all questions from the most recent version of the BJS Survey on Sexual
Violence. Data are obtained from multiple sources, including reports, investigation files, and
sexual abuse incident reviews. The agency also obtains incident-based and aggregated data from
every facility with which it contracts for the confinement of its inmates.
DC3 - Data review for corrective action
The agency reviews, analyzes, and uses all sexual abuse data, including incident-based and
aggregated data, to assess and improve the effectiveness of its sexual abuse prevention,
detection, and response policies, practices, and training. Using these data, the agency identifies
problem areas, including any racial dynamics underpinning patterns of sexual abuse, takes
corrective action on an ongoing basis, and, at least annually, prepares a report of its findings and
corrective actions for each facility as well as the agency as a whole. The annual report also
includes a comparison of the current year’s data and corrective actions with those from prior
years and provides an assessment of the agency’s progress in addressing sexual abuse. The
agency’s report is approved by the agency head, submitted to the appropriate legislative body,
and made readily available to the public through its Web site or, if it does not have one, through
other means. The agency may redact specific material from the reports when publication would
present a clear and specific threat to the safety and security of a facility, but it must indicate the
nature of the material redacted.
DC4 - Data storage, publication, and destruction
The agency ensures that the collected sexual abuse data are properly stored, securely retained,
and protected. The agency makes all aggregated sexual abuse data, from facilities under its
direct control and those with which it contracts, readily available to the public at least annually
through its Web site or, if it does not have one, through other means. Before making aggregated
sexual abuse data publicly available, the agency removes all personal identifiers from the data.
The agency maintains sexual abuse data for at least 10 years after the date of its initial collection
unless Federal, State, or local law allows for the disposal of official information in less than 10
years.
Appendix F - Standards Summary

F-10

PREA Cost Impact Analysis
Audits (AU)
AU1 - Audits of standards
The public agency ensures that all of its facilities, including contract facilities, are audited to
measure compliance with the NPREC standards. Audits must be conducted at least every three
years by independent and qualified auditors. The public or contracted agency allows the auditor
to enter and tour facilities, review documents, and interview staff and inmates, as deemed
appropriate by the auditor, to conduct comprehensive audits. The public agency ensures that the
report of the auditor’s findings and the public or contracted agency’s plan for corrective action
(DC3) are published on the appropriate agency’s Web site if it has one or are otherwise made
readily available to the public.
V. SUPPLEMENTAL STANDARDS FOR FACILITIES WITH
IMMIGRATION DETAINEES
Supplemental Standards (ID)
ID1 - Supplement to RP2: Agreements with outside public entities and community service
providers
Any facility that houses immigration detainees maintains or attempts to enter into memoranda of
understanding (MOUs) or other agreements with one or more local or, if not available, national
organizations that provide legal advocacy and confidential emotional support services for
immigrant victims of crime (RE3, MM3). The agency maintains copies of agreements or
documentation showing attempts to enter into agreements.
ID2 - Supplement to TR1, TR4, and TR-5: Employee training and specialized
Any facility that holds immigration detainees provides special additional training to employees,
including medical and mental health practitioners and investigators. This additional training
includes the following topics: cultural sensitivity toward diverse understandings of acceptable
and unacceptable sexual behavior, appropriate terms and concepts to use when discussing sex
and sexual abuse with a culturally diverse population, sensitivity and awareness regarding past
trauma that may have been experienced by immigration detainees, and knowledge of all existing
resources for immigration detainees both inside and outside the facility that provide treatment
and counseling for trauma and legal advocacy for victims.
ID3 - Supplement to TR-3: Inmate education
Sexual abuse education (TR-3) for immigration detainees is provided at a time and in a manner
that is separate from information provided about their immigration cases, in detainees’ own
languages and in terms that are culturally appropriate, and is conducted by a qualified individual
with experience communicating about these issues with a diverse population.

Appendix F - Standards Summary

F-11

PREA Cost Impact Analysis
ID4 - Detainee handbook
Every detainee is provided with an ICE Detainee Handbook upon admission to the facility, and
a replacement is provided whenever a detainee’s handbook is lost or damaged. The Detainee
Handbook contains notice of the agency’s zero-tolerance policy toward sexual abuse and
contains all the agency’s policies related to sexual abuse, including information about how to
report an incident of sexual abuse and the detainees’ rights and responsibilities related to sexual
abuse. The Detainee Handbook will inform immigration detainees how to contact organizations
in the community that provide sexual abuse counseling and legal advocacy for detainee victims
of sexual abuse. The Detainee Handbook will also inform detainees how to contact the Office
for Civil Rights and Civil Liberties, the Office of the Inspector General (OIG) for the
Department of Homeland Security (DHS), and diplomatic or consular personnel.
ID5 - Supplement to SC1: Screening for risk of victimization and abusiveness
The facility makes every reasonable effort to obtain institutional and criminal records of
immigration detainees in its custody prior to screening for risk of victimization and abusiveness.
Screening of immigration detainees is conducted by employees who are culturally competent.
ID6 - Supplement to SC2: Use of screening information
Any facility that houses both inmates and immigration detainees houses all immigration
detainees separately from other inmates in the facility and provides heightened protection for
immigration detainees who are identified as particularly vulnerable to sexual abuse by other
detainees through the screening process (SC1). To the extent possible, immigration detainees
have full access to programs, education, and work opportunities.
ID7 - Supplement to RE-1: Inmate reporting
The agency provides immigration detainees with access to telephones with free, preprogrammed
numbers to ICE’s Office for Civil Rights and Civil Liberties and the DHS OIG. In addition, the
agency must provide immigration detainees with a list of phone numbers for diplomatic or
consular personnel from their countries of citizenship and access to telephones to contact such
personnel.
ID8 - Supplement to RE3: Inmate access to outside confidential support services
All immigration detainees have access to outside victim advocates who have experience
working with immigration detainees or immigrant victims of crime for emotional support
services related to sexual abuse. The facility provides such access by giving immigration
detainees the current mailing addresses and telephone numbers, including toll-free hotline
numbers, of local, State, and/or national organizations that provide these services and enabling
reasonable communication between immigration detainees and these organizations. The facility
ensures that communications with such advocates is private, confidential, and privileged to the
extent allowable by Federal, State, and local law. The facility informs immigration detainees,
prior to giving them access, of the extent to which such communications will be private,
confidential, and/or privileged.
Appendix F - Standards Summary

F-12

PREA Cost Impact Analysis
ID9 - Protection of detainee victims and witnesses
ICE never removes from the country or transfers to another facility immigration detainees who
report sexual abuse before the investigation of that abuse is completed, except at the detainee
victim’s request. ICE considers releasing detainees who are victims of or witnesses to abuse and
monitoring them in the community to protect them from retaliation or further abuse during the
course of the investigation.
ID10 - Supplement to MM3: Ongoing medical and mental health care for sexual abuse victims
and abusers
All immigration detainees are counseled about the immigration consequences of a positive HIV
test at the time they are offered HIV testing.
ID11 - Supplement to DC-2: Data collection
The facility collects additional data whenever an immigration detainee is the victim or
perpetrator of an incident of sexual abuse in custody. The additional incident-based data
collected indicate whether the victim and/or perpetrator was an immigration detainee, his or her
status at the initiation of the investigation, and his or her status at the conclusion of the
investigation.
Supplemental Standards for Family Facilities (IDFF) - The following standards must be followed
in ICE family facilities.
IDFF1 - Screening of immigration detainees in family facilities (This standard replaces rather
than supplements SC1 and SC2)
Family facilities develop screening criteria to identify those families and family members who
may be at risk of being sexually victimized that will not lead to the separation of families.
Housing, program, educational, and work assignments are made in a manner that protects
families and in all cases prioritizes keeping families together.
IDFF2 - Screening of immigration detainees in family facilities (This standard replaces rather
than supplements SC1 and SC2)
Family facilities develop screening criteria to identify those families and family members who
may be at risk of being sexually victimized that will not lead to the separation of families.
Housing, program, educational, and work assignments are made in a manner that protects
families and in all cases prioritizes keeping families together.
IDFF3 - Investigations in family facilities
Parents are questioned confidentially by investigators about any incident of sexual abuse, away
from their children. A parent or parents are present when a child is questioned by investigators
about any incident of sexual abuse, unless (1) the child has alleged abuse by the parent or (2)
staff suspects abuse by the parent. The decision to exclude a parent from an interview based on
staff suspicion of abuse by that parent is always made by a qualified mental health practitioner.
Appendix F - Standards Summary

F-13

PREA Cost Impact Analysis
IDFF4 - Access to medical and mental health care in family facilities
All family members are offered mental health counseling (as required in MM-2 and MM3)
when one family member is a victim of sexual abuse in the facility. Following an incident of
sexual abuse, parents and adult family members are examined confidentially by medical and
mental health practitioners and away from children. Following an incident of sexual abuse, a
parent or parents are allowed to be present during all medical and mental health examinations of
a minor child, unless (1) that child has alleged sexual abuse by the parent or (2) staff suspects
abuse by the parent. The decision to exclude a parent from an examination based on staff
suspicion of abuse by that parent is always made by a qualified mental health practitioner. In the
event that a child is sexually abused, a qualified mental health practitioner interviews the child
to determine whether either parent was present or aware of the abuse and whether the parent or

Appendix F - Standards Summary

F-14

PREA Cost Impact Analysis

Community Corrections

National Standards
Community Corrections
I. PREVENTION AND RESPONSE PLANNING
Prevention Planning (PP)
PP1 - Zero tolerance of sexual abuse
The agency has a written policy mandating zero tolerance toward all forms of sexual abuse and
enforces that policy by ensuring all of its facilities comply with the NPREC standards. The
agency employs or designates a PREA coordinator to develop, implement, and oversee agency
efforts to comply with the NPREC standards.
PP2 - Contracting to house or supervise defendants/offenders under
community corrections authority
If public correctional agencies contract for housing or supervision of their defendants/offenders,
they do so only with private agencies or other entities, including other government agencies,
committed to eliminating sexual abuse in their facilities, as evidenced by their adoption of and
compliance with the NPREC standards. Any new contracts or contract renewals include the
entity’s obligation to adopt and comply with the NPREC standards and specify that the public
agency will monitor the entity’s compliance with these standards as part of its monitoring of the
entity’s performance.
PP3 - Defendant/offender supervision
Facility staff provides the defendant/offender supervision necessary to protect
defendants/offenders from sexual abuse. The facility administrators and supervisors responsible
for reviewing critical incidents must examine areas in the facility where sexual abuse has
occurred or may be likely to occur to assess whether physical barriers may allow the abuse to go
undetected, the adequacy of staffing levels in those areas during different shifts, and the need for
monitoring technology to supplement facility staff supervision. When problems or needs are
identified, facility administrators and supervisors take corrective action (DC3).
PP4 - Limits to Cross-Gender Viewing and Searches
Except in the case of emergency, the facility prohibits cross-gender strip and visual body cavity
searches. Except in the case of emergency or other extraordinary or unforeseen circumstances,
the facility restricts nonmedical staff from viewing defendants/offenders of the opposite gender
Appendix F - Standards Summary

F-15

PREA Cost Impact Analysis
who are nude or performing bodily functions and similarly restricts cross-gender pat down
searches. Medical practitioners conduct examinations of transgender individuals to determine
their genital status only in private settings and only when an individual’s genital status is
unknown.
PP5 - Accommodating defendants/offenders with special needs
The agency or facility ensures that defendants/offenders who are limited English proficient
(LEP), deaf, or disabled are able to report sexual abuse to staff directly, through interpretive
technology, or through nondefendant/offender interpreters. Accommodations are made to
convey all writ-ten information about sexual abuse policies, including how to report sexual
abuse, verbally to defendants/offenders who have limited reading skills or who are visually
impaired.
PP6- Hiring and promotion decisions
The agency or facility does not hire or promote anyone who has engaged in sexual abuse in an
institutional setting or who has engaged in sexual activity in the community facilitated by force,
the threat of force, or coercion. Consistent with Federal, State, and local law, the agency or
facility makes its best effort to contact all prior institutional employers for information on
substantiated allegations of sexual abuse and must run criminal background checks for all
applicants and employees being considered for promotion and examine and carefully weigh any
history of criminal activity at work or in the community, including convictions or adjudications
for domestic violence, stalking, and sex offenses. The agency or facility also asks all applicants
and employees directly about previous misconduct during interviews and reviews.
Response Planning (RP)
RP1 - Evidence protocol and forensic medical exams
The agency or facility follows a uniform evidence protocol that maximizes the potential for obtaining usable physical evidence for administrative proceedings and criminal prosecutions. The
protocol must be adapted from or otherwise based on the 2004 U.S. Department of Justice’s
Office on Violence Against Women publication ―A National Protocol for Sexual Assault
Medical Forensic Examinations, Adults/Adolescents,‖ subsequent updated editions, or similarly
comprehensive and authoritative protocols developed after 2004. As part of the agency’s or
facility’s evidence collection protocol, the agency or facility refers all victims of
defendant/offender-on-defendant/offender sexually abusive penetration or staff-ondefendant/offender sexually abusive penetration to forensic medical exams performed by
qualified forensic medical examiners. Forensic medical exams are provided free of charge to the
victim. The agency or facility makes available or provides referrals to a victim advocate to
accompany the victim through the forensic medical exam process.
RP2 - Agreements with outside public entities and community service providers
The agency or facility maintains or attempts to enter into written memoranda of understanding
(MOUs) or other agreements with an outside public entity or office that is able to receive and
Appendix F - Standards Summary

F-16

PREA Cost Impact Analysis
immediately forward defendant/offender reports of sexual abuse to agency or facility heads (RE1). The agency also maintains or attempts to enter into MOUs or other agreements with
community service providers that are able to: (1) provide defendants/offenders with confidential
emotional support services related to sexual abuse and (2) help victims of sexual abuse during
their transition from a community corrections facility into the community. The agency or facility
maintains copies of written agreements or documentation showing attempts to enter into
agreements.
RP3 - Agreements with outside law enforcement agencies
If an agency or facility does not have the legal authority to conduct criminal investigations or
has elected to permit an outside agency to conduct criminal or administrative investigations of
staff or defendants/offenders, the agency or facility maintains or attempts to enter into a written
MOU or other agreement specific to investigations of sexual abuse with the law enforcement
agency responsible for conducting investigations. If the agency or facility confines
defendants/offenders under the age of 18 or applicable age of majority within that jurisdiction,
or other defendants/offenders who fall under State and local vulnerable persons statutes, the
agency or facility maintains or attempts to enter into an MOU with the designated State or local
services agency with the jurisdiction and authority to conduct investigations related to the sexual
abuse of vulnerable persons within community corrections facilities. When the agency or facility already has an existing agreement or long-standing policy covering responsibilities for all
criminal investigations, including sexual abuse investigations, it does not need to enter into a
new agreement. The agency or facility maintains a copy of the written agreement or
documentation showing attempts to enter into an agreement.

RP4- Agreements with the prosecuting authority
The agency or facility maintains or attempts to enter into a written MOU or other agreement
with the authority responsible for prosecuting violations of criminal law. The agency or facility
maintains a copy of the written agreement or documentation showing attempts to enter into an
agreement.
II. PREVENTION
Training and Education (TR)
TR1 - Employee training
The agency or facility trains all employees to be able to fulfill their responsibilities under
agency or facility sexual abuse prevention, detection, and response policies and procedures; the
NPREC standards; and under relevant Federal, State, and local law. The agency or facility trains
all employees to communicate effectively and professionally with all defendants/offenders.
Additionally, the agency or facility trains all employees on a defendant/offender’s right to be
free from sexual abuse, the right of defendants/offenders and employees to be free from
retaliation for reporting sexual abuse, the dynamics of sexual abuse, and the common reactions
of sexual abuse victims. Current employees are educated as soon as possible following the
Appendix F - Standards Summary

F-17

PREA Cost Impact Analysis
agency’s or facility’s adoption of the NPREC standards, and the agency or facility provides
periodic refresher information to all employees to ensure that they know the agency’s or
facility’s most current sexual abuse policies and procedures. The agency or facility maintains
written documentation showing employee signatures verifying that employees understand the
training they have received.
TR2 - Volunteer and contractor training
The agency or facility ensures that all volunteers and contractors who have contact through the
agency or facility with defendants/offenders have been trained on their responsibilities under the
agency’s sexual abuse prevention, detection, and response policies and procedures; the NPREC
standards; and relevant Federal, State, and local law. The level and type of training provided to
volunteers and contractors is based on the services they provide and level of contact they have
with defendants/offenders, but all volunteers and contractors who have contact with
defendants/offenders must be notified of the agency’s or facility’s zero-tolerance policy regarding sexual abuse. Volunteers must also be trained in how to report sexual abuse. The agency or
facility maintains written documentation showing volunteer and contractor signatures verifying
that they understand the training they have received.
TR3 - Defendant/offender education
During the intake process into a facility or upon initial stages of supervision, staff informs defendants/offenders of the agency’s or facility’s zero-tolerance policy regarding sexual abuse and
how to report incidents or suspicions of sexual abuse. Within a reasonably brief period of time,
the agency or facility provides comprehensive education to defendants/offenders regarding their
right to be free from sexual abuse and to be free from retaliation for reporting abuse, the dynamics of sexual abuse, the common reactions of sexual abuse victims, and agency or facility sexual
abuse response policies and procedures. Current defendants/offenders are educated as soon as
possible following the agency’s or facility’s adoption of the NPREC standards, and the agency
or facility provides periodic refresher information to all defendants/offenders to ensure that they
know the agency’s or facility’s most current sexual abuse policies and procedures. Periodic refresher training may or may not be necessary in community corrections facilities given the
shorter time period defendants/offenders may reside in these facilities. The agency or facility
provides defendant/offender education in formats accessible to all defendants/offenders,
including those who are LEP, deaf, visually impaired, or otherwise disabled as well as
defendants/offenders who have limited reading skills. All information provided to
defendants/offenders is communicated in a manner that is appropriate for the
defendant/offender’s age and level of cognitive and emotional development. The agency or
facility maintains written documentation of defendant/offender participation in these education
sessions.
TR4 - Specialized training: Investigations
In addition to the general training provided to all employees (TR1), the agency or facility
ensures that investigators employed by the agency or facility and conducting sexual abuse
investigations have received comprehensive and up-to-date training in conducting such
Appendix F - Standards Summary

F-18

PREA Cost Impact Analysis
investigations in community corrections settings. Specialized training must include populationappropriate techniques for interviewing sexual abuse victims, proper use of Miranda- and
Garrity-type warnings, sexual abuse evidence collection in community corrections settings, and
the criteria and evidence required to substantiate a case for administrative action or prosecution
referral. The agency or facility maintains written documentation that investigators have
completed the required specialized training in conducting sexual abuse investigations.
TR5 - Specialized training: Medical and mental health care
The agency or facility ensures that all medical and mental health care practitioners employed or
contracted with by the community corrections or pretrial, probation, or parole agency have been
trained in how to detect and assess signs of sexual abuse and how to preserve physical evidence
of sexual abuse. All medical and mental health care practitioners must be trained in how to
respond effectively and professionally to victims of sexual abuse and how and to whom to
report allegations or suspicions of sexual abuse. The agency or facility maintains documentation
that medical and mental health practitioners have received this specialized training.
Screening for Risk of Sexual Victimization and Abusiveness (SC)
SC1 - Screening for risk of victimization and abusiveness
All defendants/offenders are screened during intake to assess their risk of being sexually abused
by other defendants/offenders or sexually abusive toward other defendants/offenders.
Employees must review information received with the defendant/offender as well as discussions
with the defendant/offender. Employees must conduct this screening using a written screening
instrument tailored to the gender of the population being screened. Although additional factors
may be considered, particularly to account for emerging research and the agency’s or facility’s
own data analysis, screening instruments must contain the criteria described below. For
defendants/offenders under the age of 18 or applicable age of majority within that jurisdiction,
screening must be conducted by medical or mental health practitioners. If the facility does not
have medical or mental health practitioners available, these young defendants/offenders are
given an opportunity to participate in screenings in private. All screening instruments must be
made available to the public upon request.
SC2 - Use of screening information
Employees use information from the risk screening (SC1) to inform housing, bed, work, education, and program assignments. In many community corrections facilities, it is difficult, if not
impossible, to keep defendants/offenders totally separate or segregated from each other.
However, the facility can determine, based on the screening information, whether a particular
defendant/offender should receive greater supervision, should have more frequent contact with
staff, or is more appropriately housed in some alternative type of placement. The facility makes
individualized determinations about how to ensure the safety of each defendant/offender.
Lesbian, gay, bisexual, transgender, or other gender-nonconforming defendants/offenders are
not placed in particular housing assignments solely on the basis of their sexual orientation,
genital status, or gender identity.

Appendix F - Standards Summary

F-19

PREA Cost Impact Analysis
III. DETECTION AND RESPONSE
Reporting (RE)
RE1 - Defendant/offender reporting
The agency or facility provides multiple internal ways for defendants/offenders to report easily,
privately, and securely sexual abuse, retaliation by other defendants/offenders or staff for reporting sexual abuse, and staff neglect or violation of responsibilities that may have contributed to
an incident of sexual abuse. The agency or facility also provides at least one way for
defendants/offenders to report the abuse to an outside pubic entity or office not affiliated with
the agency that has agreed to receive reports and forward them to the agency or facility head
(RP2), except when a defendant/offender requests confidentiality. Staff accepts reports made
verbally, in writing, anonymously, and from third parties and immediately puts into writing any
verbal reports.
RE2 - Exhaustion of administrative remedies
Under agency or facility policy, a defendant/offender has exhausted his or her administrative
remedies with regard to a claim of sexual abuse either (1) when the agency or facility makes a
final decision on the merits of the report of abuse (regardless of whether the report was made by
the defendant/offender, made by a third party, or forwarded from an outside official or office) or
(2) when 90 days have passed since the report was made, whichever occurs sooner. A report of
sexual abuse triggers the 90-day exhaustion period regardless of the length of time that has
passed between the abuse and the report. A defendant/offender seeking immediate protection
from imminent sexual abuse will be deemed to have exhausted his or her administrative
remedies 48 hours after notifying any agency or facility staff member of his or her need for
protection.
RE3 - Defendant/offender access to outside confidential support services
The facility provides defendants/offenders with access to outside victim advocates for emotional
support services related to sexual abuse. The facility provides such access by giving defendants/offenders the current mailing addresses and telephone numbers, including toll-free
hotline numbers, of local, State, and/or national victim advocacy or rape crisis organizations and
enabling reasonable communication between defendants/offenders and these organizations. The
facility ensures that communications with such advocates are private, confidential, and
privileged, to the extent allowable by Federal, State, and local law. The facility informs defendants/offenders, prior to giving them access, of the extent to which such communications
will be private, confidential, and/or privileged.
RE4 - Third-party reporting
The agency or facility receives and investigates all third-party reports of sexual abuse (IN1). At
the conclusion of the investigation, the agency or facility notifies in writing the third-party
individual who reported the abuse and the defendant/offender named in the third-party report of

Appendix F - Standards Summary

F-20

PREA Cost Impact Analysis
the outcome of the investigation. The agency or facility distributes publicly information on how
to report sexual abuse on behalf of a defendant/offender.
Official Response Following an Defendant/offender Report (OR)
OR1 - Staff and facility head reporting duties
All staff members are required to report immediately and according to agency or facility policy
any knowledge, suspicion, or information they receive regarding an incident of sexual abuse that
occurred in a facility setting or while under supervision; retaliation against defendants/offenders
or staff who reported abuse; and any staff neglect or violation of responsibilities that may have
contributed to an incident of sexual abuse or retaliation. Apart from reporting to designated
supervisors or officials, staff must not reveal any information related to a sexual abuse report to
anyone other than those who need to know, as specified in agency or facility policy, to make
treatment, investigation, and other security and management decisions. Unless otherwise precluded by Federal, State, or local law, staff medical and mental health practitioners are required
to report sexual abuse and must inform defendants/offenders of their duty to report at the initiation of services. If the victim is under the age of 18 or applicable age of majority within that
jurisdiction, or considered a vulnerable adult under a State or local vulnerable persons statute,
staff must report the allegation to the designated State or local services agency under applicable
mandatory reporting laws.
OR2 - Reporting to other agencies or facilities
When the agency or facility receives an allegation that a defendant/offender was sexually
abused while in a community corrections facility or while under supervision, the head of the
agency or facility where the report was made notifies in writing the head of the agency or
facility where the alleged abuse occurred. The head of the agency or facility where the alleged
abuse occurred ensures the allegation is investigated.
OR3 - Staff first responder duties
Upon learning that a defendant/offender has alleged sexual abuse within a time period that still
allows for the collection of physical evidence, the first facility staff member to respond to the
report is required to (1) separate the alleged victim and abuser; (2) seal and preserve any crime
scene(s); and (3) instruct the victim not to take any actions that could destroy physical evidence,
including washing, brushing his or her teeth, changing his or her clothes, urinating, defecating,
smoking, drinking, or eating.
OR4 - Coordinated response
All actions taken in response to an allegation of sexual abuse are coordinated among staff first
responders, medical and mental health practitioners, investigators, and agency or facility leadership. The agency’s or facility’s coordinated response ensures that victims receive all necessary
immediate and ongoing medical, mental health, and support services and that investigators are
able to obtain usable evidence to substantiate allegations and hold perpetrators accountable.

Appendix F - Standards Summary

F-21

PREA Cost Impact Analysis
OR5 – Agency or facility protection against retaliation
The agency or facility protects all defendants/offenders and staff who report sexual abuse or
cooperate with sexual abuse investigations from retaliation by other defendants/offenders or
staff. The agency or facility employs multiple protection measures, including housing changes
or transfers for defendant/offender victims or abusers, removal of alleged staff or
defendant/offender abusers from contact with victims, and emotional support services for
defendants/offenders or staff who fear retaliation for reporting sexual abuse or cooperating with
investigations. The agency or facility monitors the conduct and/or treatment of
defendants/offenders or staff who have reported sexual abuse or cooperated with investigations,
including any defendant/offender disciplinary reports, housing changes, or program changes, for
at least 90 days following their report or cooperation to assess changes that may suggest
possible retaliation by defendants/offenders or staff. The agency or facility discusses any
changes with the appropriate defendant/offender or staff member as part of its efforts to
determine if retaliation is taking place and, when confirmed, immediately takes steps to protect
the defendant/offender or staff member.
Investigations (IN)
IN1 - Duty to investigate
The agency or facility investigates all allegations of sexual abuse, including third-party and
anonymous reports, and notifies victims and/or other complainants in writing of investigation
outcomes and any disciplinary or criminal sanctions, regardless of the source of the allegation.
All investigations are carried through to completion, regardless of whether the alleged abuser or
victim remains at the facility or under supervision.
IN2 - Criminal and administrative agency investigations
Agency or facility investigations into allegations of sexual abuse are prompt, thorough,
objective, and conducted by investigators who have received special training in sexual abuse
investigations (TR4). When outside agencies investigate sexual abuse, the agency or facility has
a duty to keep abreast of the investigation and cooperate with outside investigators (RP3).
Investigations include the following elements:
IN3 - Evidence standard for administrative investigations
Allegations of sexual abuse are substantiated if supported by a preponderance of the evidence or
a lesser standard if allowed under agency or facility policy or State law.
Discipline (DI)
DI1 - Disciplinary sanctions for staff
Staff is subject to disciplinary sanctions up to and including termination when staff has violated
agency or facility sexual abuse policies. The presumptive disciplinary sanction for staff
members who have engaged in sexually abusive contact or penetration is termination. This
presumption does not limit agency or facility discretion to impose termination for other sexual
Appendix F - Standards Summary

F-22

PREA Cost Impact Analysis
abuse policy violations. All terminations for violations of agency or facility sexual abuse
policies are to be reported to law enforcement agencies and any relevant licensing bodies.
DI2 - Disciplinary sanctions for defendants/offenders
Defendants/offenders are subject to disciplinary sanctions pursuant to a formal disciplinary
process following an administrative ruling that the defendant/offender engaged in defendant/offender-on-defendant/offender sexual abuse or following a criminal finding of guilt for
defendant/offender-on-defendant/offender sexual abuse. Sanctions are commensurate with the
nature and circumstances of the abuse committed, the defendant/offender’s disciplinary history,
and the sanctions meted out for comparable offenses by other defendants/offenders with similar
histories. The disciplinary process must consider whether a defendant/offender’s mental
disabilities or mental illness contributed to his or her behavior when determining what type of
sanction, if any, should be imposed. Possible sanctions can include discipline within the
community corrections facility, new criminal charges, or referral to authorities who may change
conditions of a defendant/offender’s release status in the community. Sanctions may also
include interventions designed to address and correct underlying reasons or motivation for the
abuse, such as requiring the offending defendant/offender to participate in therapy, counseling,
or other programs. Sanctions and/or interventions for young defendants/offenders must also take
into account the social, sexual, emotional, and cognitive development of the defendant/offender.
Medical and Mental Health Care (MM)
MM1 - Access to emergency medical and mental health services
Victims of sexual abuse have timely, unimpeded access to emergency medical treatment and
crisis intervention services, the nature and scope of which are determined by medical and mental
health practitioners according to their professional judgment. Treatment services must be provided free of charge to the victim and regardless of whether the victim names the abuser. If the
community corrections facility does not have medical or mental health practitioners or they are
not on duty at the time a report of recent abuse is made, staff first responders take preliminary
steps to protect the victim (OR3) and immediately notify appropriate staff or community medical and mental health practitioners.
MM2 - Ongoing medical and mental health care for sexual abuse victims and abusers
The facility provides ongoing medical and/or mental health evaluation and treatment to all
known victims of sexual abuse. The evaluation and treatment of sexual abuse victims must include appropriate follow-up services, treatment plans, and, when necessary, referrals for continued care following their release from a community corrections facility. The level of medical and
mental health care provided to defendant/offender victims must match the community level of
care generally accepted by the medical and mental health professional communities. The facility
conducts a mental health evaluation of all known abusers and provides treatment, as deemed
necessary by qualified mental health practitioners.

Appendix F - Standards Summary

F-23

PREA Cost Impact Analysis
IV. MONITORING
Data Collection and Review (DC)
DC1 - Sexual abuse incident reviews
The agency or facility treats all instances of sexual abuse as critical incidents to be examined by
a team of upper management officials, with input from line supervisors, investigators, and
medical/mental health practitioners. The review team evaluates each incident of sexual abuse to
identify any policy, training, or other issues related to the incident that indicate a need to change
policy or practice to better prevent, detect, and/or respond to incidents of sexual abuse. The
review team also considers whether incidents were motivated by racial or other group dynamics.
When incidents are determined to be motivated by racial or other group dynamics, upper
management officials immediately notify the agency or facility head and begin taking steps to
rectify those underlying problems. The sexual abuse incident review takes place at the conclusion of every sexual abuse investigation, unless the allegation was determined to be unfounded.
The review team prepares a report of its findings and recommendations for improvement and
submits it to the agency or facility head.
DC2 - Data collection
The agency or facility collects accurate, uniform data for every reported incident of sexual abuse
using a standardized instrument and set of definitions. The agency aggregates the incident-based
sexual abuse data at least annually. The incident-based data collected includes, at a minimum,
the data necessary to answer all questions from the most recent version of the BJS Survey on
Sexual Violence. Data are obtained from multiple sources, including reports, investigation files,
and sexual abuse incident reviews. The agency also obtains incident-based and aggregated data
from every community corrections facility with which it contracts.
DC3 - Data review for corrective action
The agency reviews, analyzes, and uses all sexual abuse data, including incident-based and
aggregated data, to assess and improve the effectiveness of its sexual abuse prevention,
detection, and response policies, practices, and training. Using these data, the agency identifies
problem areas, including any racial dynamics underpinning patterns of sexual abuse, takes
corrective action on an ongoing basis, and, at least annually, prepares a report of its findings and
corrective actions for each facility as well as the agency as a whole. The annual report also
includes a comparison of the current year’s data and corrective actions with those from prior
years and provides an assessment of the agency’s progress in addressing sexual abuse. The
agency’s report is approved by the agency head, submitted to the appropriate governing body,
and made readily available to the public through its Web site or, if it does not have one, through
other means. The agency may redact specific material from the reports when publication would
present a clear and specific threat to the safety and security of a facility, but it must indicate the
nature of the material redacted.

Appendix F - Standards Summary

F-24

PREA Cost Impact Analysis
DC4 - Data storage, publication, and destruction
The agency ensures that the collected sexual abuse data are properly stored, securely retained,
and protected. The agency makes all aggregated sexual abuse data, including from facilities under its direct control and those with which it contracts, readily available to the public at least
annually through its Web site or, if it does not have one, through other means. Before making
aggregated sexual abuse data publicly available, the agency removes all personal identifiers
from the data. The agency maintains sexual abuse data for at least 10 years after the date of its
initial collection unless Federal, State, or local law allows for the disposal of official information
in less than 10 years.
Audits (AU)
AU1 - Audits of standards
The public agency ensures that all community corrections facilities, including contract facilities
and pretrial, probation, and parole agencies are audited to measure compliance with the NPREC
standards. Audits must be conducted at least every three years by independent and qualified
auditors. The public or contracted agency allows the auditor to enter and tour facilities, review
documents, and interview staff and defendants/offenders, as deemed appropriate by the auditor,
to conduct comprehensive audits. The public agency ensures that the report of the auditor’s
findings and the public or contracted agency’s plan for corrective action (DC3) are published on
the appropriate agency’s Web site if it has one or are otherwise made readily available to the
public.

Appendix F - Standards Summary

F-25

PREA Cost Impact Analysis

Juvenile Facilities

National Standards
Juvenile Facilities
I. PREVENTION AND RESPONSE PLANNING
Prevention Planning (PP)
PP1 - Zero tolerance of sexual abuse
The agency has a written policy mandating zero tolerance toward all forms of sexual abuse and
enforces that policy by ensuring all of its facilities comply with the NPREC standards. The
agency employs or designates a PREA coordinator to develop, implement, and oversee agency
efforts to comply with the NPREC standards.
PP2 - Contracting with facilities for the confinement of residents
If public correctional agencies contract for the confinement of their residents, they do so only
with private agencies or other entities, including other government agencies, committed to
eliminating sexual abuse in their facilities, as evidenced by their adoption of and compliance
with the NPREC standards. Any new contracts or contract renewals include the entity’s
obligation to adopt and comply with the NPREC standards and specify that the public agency
will monitor the entity’s compliance with these standards as part of its monitoring of the entity’s
performance.
PP3 - Resident supervision
Security staff provides the resident supervision necessary to protect residents from sexual abuse.
The upper management officials responsible for reviewing critical incidents must examine areas
in the facility where sexual abuse has occurred to assess whether physical barriers may have
enabled the abuse, the adequacy of staffing levels in those areas during different shifts, and the
need for monitoring technology to supplement security staff supervision (DC1). When problems
or needs are identified, the agency takes corrective action (DC3).
PP4 - Limits to Cross-Gender Viewing and Searches
Except in the case of emergency, the facility prohibits cross-gender strip and visual body cavity
searches. Except in the case of emergency or other extraordinary or unforeseen circumstances,
the facility restricts non-medical staff from viewing residents of the opposite gender who are
nude or performing bodily functions and similarly restricts cross-gender pat down searches.

Appendix F - Standards Summary

F-26

PREA Cost Impact Analysis
Medical practitioners conduct examinations of transgender individuals to determine their genital
status only in private settings and only when an individual’s genital status is unknown.
PP5 - Accommodating residents with special needs
The agency ensures that residents who are limited English proficient (LEP), deaf, or disabled are
able to report sexual abuse to staff directly, through interpretive technology, or through nonresident interpreters. Accommodations are made to convey all written information about sexual
abuse policies, including how to report sexual abuse, verbally to residents who have limited
reading skills or who are visually impaired.
PP6- Hiring and promotion decisions
The agency does not hire or promote anyone who has engaged in sexual abuse in an institutional
setting or who has engaged in sexual activity in the community facilitated by force, the threat of
force, or coercion. Consistent with Federal, State, and local law, the agency makes its best effort
to contact all prior institutional employers for information on substantiated allegations of sexual
abuse; must run criminal background checks for all applicants and employees being considered
for promotion; and must examine and carefully weigh any history of criminal activity at work or
in the community, including convictions for domestic violence, stalking, and sex offenses. The
agency also asks all applicants and employees directly about previous misconduct during
interviews and reviews.
PP7 - Assessment and Use of Monitoring Technology
The agency uses video monitoring systems and other cost-effective and appropriate technology
to supplement its sexual abuse prevention, detection, and response efforts. The agency assesses,
at least annually, the feasibility of and need for new or additional monitoring technology and
develops a plan for securing such technology.
Response Planning (RP)
RP1 - Evidence protocol and forensic medical exams
The agency follows a uniform evidence protocol that maximizes the potential for obtaining
usable physical evidence for administrative proceedings and criminal prosecutions. The protocol
must be adapted from or otherwise based on the 2004 U.S. Department of Justice’s Office on
Violence Against Women publication ―A National Protocol for Sexual Assault Medical
Forensic Examinations, Adults/Adolescents,‖ subsequent updated editions, or similarly
comprehensive and authoritative protocols developed after 2004. As part of the agency’s
evidence collection protocol, all victims of resident-on-resident sexually abusive penetration or
staff-on-resident sexually abusive penetration are provided access to forensic medical exams
performed by qualified forensic medical examiners. Forensic medical exams are provided free
of charge to the victim. The facility makes available a victim advocate to accompany the victim
through the forensic medical exam process.

Appendix F - Standards Summary

F-27

PREA Cost Impact Analysis
RP2 - Agreements with outside public entities and community service providers
The agency maintains or attempts to enter into memoranda of understanding (MOUs) or other
agreements with an outside public entity or office that is able to receive and immediately
forward resident reports of sexual abuse to facility heads (RE-1). The agency also maintains or
attempts to enter into MOUs or other agreements with community service providers that are able
to: (1) provide residents with confidential emotional support services related to sexual abuse and
(2) help victims of sexual abuse during their transition from incarceration to the community
(RE3, MM3). The agency maintains copies of agreements or documentation showing attempts
to enter into agreements.
RP3 - Agreements with outside law enforcement agencies
If an agency does not have the legal authority to conduct criminal investigations or has elected
to permit an outside agency to conduct criminal or administrative investigations of staff or
residents, the agency maintains or attempts to enter into a written MOU or other agreement
specific to investigations of sexual abuse with the law enforcement agency responsible for
conducting investigations. If the agency confines residents under the age of 18 or other residents
who fall under State and local vulnerable persons statutes, the agency maintains or attempts to
enter into an MOU with the designated State or local services agency with the jurisdiction and
authority to conduct investigations related to the sexual abuse of vulnerable persons within
confinement facilities. When the agency already has an existing agreement or long-standing
policy covering responsibilities for all criminal investigations, including sexual abuse
investigations, it does not need to enter into a new agreement. The agency maintains a copy of
the agreement or documentation showing attempts to enter into an agreement.
RP4- Agreements with the prosecuting authority
The agency maintains or attempts to enter into a written MOU or other agreement with the
authority responsible for prosecuting violations of criminal law. The agency maintains a copy of
the agreement or documentation showing attempts to enter into an agreement.
II. PREVENTION
Training and Education (TR)
TR1 - Employee training
The agency trains all employees to be able to fulfill their responsibilities under agency sexual
abuse prevention, detection, and response policies and procedures; the NPREC standards; and
relevant Federal, State, and local law. The agency trains all employees to communicate
effectively and professionally with all residents. Additionally, the agency trains all employees
on an resident’s right to be free from sexual abuse, the right of residents and employees to be
free from retaliation for reporting sexual abuse, the dynamics of sexual abuse in confinement,
and the common reactions of sexual abuse victims. Current employees are educated as soon as
possible following the agency’s adoption of the NPREC standards, and the agency provides
periodic refresher information to all employees to ensure that they know the agency’s most
Appendix F - Standards Summary

F-28

PREA Cost Impact Analysis
current sexual abuse policies and procedures. The agency maintains written documentation
showing employee signatures verifying that employees understand the training they have
received.
TR2 - Volunteer and contractor training
The agency ensures that all volunteers and contractors who have contact with residents have
been trained on their responsibilities under the agency’s sexual abuse prevention, detection, and
response policies and procedures; the NPREC standards; and relevant Federal, State, and local
law. The level and type of training provided to volunteers and contractors is based on the
services they provide and level of contact they have with residents, but all volunteers and
contractors who have contact with residents must be notified of the agency’s zero-tolerance
policy regarding sexual abuse. Volunteers must also be trained in how to report sexual abuse.
The agency maintains written documentation showing volunteer and contractor signatures
verifying that they understand the training they have received.
TR3 - Resident education
During the intake process, staff informs residents of the agency’s zero-tolerance policy
regarding sexual abuse and how to report incidents or suspicions of sexual abuse. Within a
reasonably brief period of time following the intake process, the agency provides
comprehensive education to residents regarding their right to be free from sexual abuse and to
be free from retaliation for reporting abuse, the dynamics of sexual abuse in confinement, the
common reactions of sexual abuse victims, and agency sexual abuse response policies and
procedures. Current residents are educated as soon as possible following the agency’s adoption
of the NPREC standards, and the agency provides periodic refresher information to all residents
to ensure that they know the agency’s most current sexual abuse policies and procedures. The
agency provides resident education in formats accessible to all residents, including those who
are LEP, deaf, visually impaired, or otherwise disabled as well as residents who have limited
reading skills. The agency maintains written documentation of resident participation in these
education sessions.
TR4 - Specialized training: Investigations
In addition to the general training provided to all employees (TR1), the agency ensures that
agency investigators conducting sexual abuse investigations have received comprehensive and
up-to-date training in conducting such investigations in confinement settings. Specialized
training must include techniques for interviewing sexual abuse victims, proper use of Mirandaand Garrity-type warnings, sexual abuse evidence collection in confinement settings, and the
criteria and evidence required to substantiate a case for administrative action or prosecution
referral. The agency maintains written documentation that investigators have completed the
required specialized training in conducting sexual abuse investigations.
TR5 - Specialized training: Medical and mental health care
The agency ensures that all full- and part-time medical and mental health care practitioners
working in its facilities have been trained in how to detect and assess signs of sexual abuse and
Appendix F - Standards Summary

F-29

PREA Cost Impact Analysis
that all medical practitioners are trained in how to preserve physical evidence of sexual abuse.
All medical and mental health care practitioners must be trained in how to respond effectively
and professionally to victims of sexual abuse and how and to whom to report allegations or
suspicions of sexual abuse. The agency maintains documentation that medical and mental health
practitioners have received this specialized training.
Screening for Risk of Sexual Victimization and Abusiveness (SC)
AP1 - Obtaining information about residents
During intake and periodically throughout a resident’s confinement, employees obtain and use
information about each resident’s personal history and behavior to keep all residents safe and
free from sexual abuse. At a minimum, employees attempt to ascertain information about prior
sexual victimization or abusiveness; sexual orientation and gender identity; current charges and
offense history; age; level of emotional and cognitive development; physical size/stature; mental
illness or mental disabilities; intellectual/developmental disabilities; physical disabilities; and
any other specific information about individual residents that may indicate heightened needs for
supervision, additional safety precautions, or separation from certain other residents. This
information may be ascertained through conversations with residents at intake and medical and
mental health screenings; during classification assessments; and by reviewing court records,
case files, facility behavioral records, and other relevant documentation from the residents’ files.
Medical and mental health practitioners are the only staff permitted to talk with residents to
gather information about their sexual orientation or gender identity, prior sexual victimization,
history of engaging in sexual abuse, mental health status, and mental or physical disabilities. If
the facility does not have medical or mental health practitioners available, residents are given an
opportunity to discuss any safety concerns or sensitive issues privately with another employee.

AP2 - Placement of residents in housing, bed, program, education, and work assignments
Employees use all information obtained about the resident at intake and subsequently to make
placement decisions for each resident on an individualized basis with the goal of keeping all
residents safe and free from sexual abuse. When determining housing, bed, program, education
and work assignments for residents, employees must take into account a resident’s age; the
nature of his or her offense; any mental or physical disability or mental illness; any history of
sexual victimization or engaging in sexual abuse; his or her level of emotional and cognitive
development; his or her identification as lesbian, gay, bisexual, or transgender; and any other
information obtained about the resident (AP1). Residents may be isolated from others only as a
last resort when less restrictive measures are inadequate to keep them and other residents safe,
and then only until an alternative means of keeping all residents safe can be arranged.

Appendix F - Standards Summary

F-30

PREA Cost Impact Analysis
III. DETECTION AND RESPONSE
Reporting (RE)
RE1 - Resident reporting
The facility provides multiple internal ways for residents to report easily, privately, and securely
sexual abuse, retaliation by other residents or staff for reporting sexual abuse, and staff neglect
or violation of responsibilities that may have contributed to an incident of sexual abuse. The
facility also provides at least one way for residents to report the abuse to an outside public entity
or office not affiliated with the agency that has agreed to receive reports and forward them to the
facility head (RP2), except when an resident requests confidentiality. Staff accepts reports made
verbally, in writing, anonymously, and from third parties and immediately puts into writing any
verbal reports.
RE2 - Exhaustion of administrative remedies
Under agency policy, an resident has exhausted his or her administrative remedies with regard
to a claim of sexual abuse either (1) when the agency makes a final decision on the merits of the
report of abuse (regardless of whether the report was made by the resident, made by a third
party, or forwarded from an outside official or office) or (2) when 90 days have passed since the
report was made, whichever occurs sooner. A report of sexual abuse triggers the 90-day
exhaustion period regardless of the length of time that has passed between the abuse and the
report. An resident seeking immediate protection from imminent sexual abuse will be deemed to
have exhausted his or her administrative remedies 48 hours after notifying any agency staff
member of his or her need for protection.
RE3 - Resident access to outside confidential support services
In addition to providing on-site mental health care services, the facility provides residents with
access to outside victim advocates for emotional support services related to sexual abuse. The
facility provides such access by giving residents the current mailing addresses and telephone
numbers, including toll-free hotline numbers, of local, State, and/or national victim advocacy or
rape crisis organizations and enabling reasonable communication between residents and these
organizations. The facility ensures that communications with such advocates are private, to the
extent allowable by Federal, State, and local law. The facility informs residents, prior to giving
them access, of the extent to which such communications will be private, confidential, and/or
privileged. The facility also provides residents with unimpeded access to their attorney or other
legal representation and their families.
RE4 - Third-party reporting
The facility receives and investigates all third-party reports of sexual abuse and refers all thirdparty reports of abuse to the designated State or local services agency with the authority to
conduct investigations into allegations of sexual abuse involving child victims (IN1 and RP4).
At the conclusion of the investigation, the facility notifies in writing the third-party individual
who reported the abuse and the resident named in the third-party report of the outcome of the
Appendix F - Standards Summary

F-31

PREA Cost Impact Analysis
investigation. The facility distributes information on how to report sexual abuse on behalf of a
resident to residents’ parents or legal guardians, attorneys, and the public.
Official Response Following an Resident Report (OR)
OR1 - Staff and facility head reporting duties
All staff members are required to report immediately and according to agency policy and
relevant State or local mandatory child abuse reporting laws any knowledge, suspicion, or
information they receive regarding an incident of sexual abuse that occurred in an institutional
setting; retaliation against residents or staff who reported abuse; and any staff neglect or
violation of responsibilities that may have contributed to an incident of sexual abuse or
retaliation. Apart from reporting to designated supervisors or officials and designated State or
local services agencies, staff must not reveal any information related to a sexual abuse report to
anyone other than those who need to know, as specified in agency policy, to make treatment,
investigation, and other security and management decisions. Medical and mental health
practitioners are required to report sexual abuse to designated supervisors and officials as well
as the designated State or local services agency and must inform residents of their duty to report
at the initiation of services. Upon receiving any allegation of sexual abuse, the facility head
must immediately report the allegation to the agency head, the juvenile court that handled the
victim’s case or the victim’s judge of record, and the victim’s parents or legal guardians, unless
the facility has official documentation showing the parents or legal guardians should not be
notified. If the victim is involved in the child welfare system, the facility head reports to the
victim’s caseworker instead of the victim’s parents or legal guardians.
OR2 - Reporting to other confinement facilities
When the facility receives an allegation that an resident was sexually abused while confined at
another facility, the head of the facility where the report was made notifies in writing the head of
the facility where the alleged abuse occurred. The head of the facility where the alleged abuse
occurred ensures the allegation is investigated.
OR3 - Staff first responder duties
Upon learning that a resident was sexually abused within a time period that still allows for the
collection of physical evidence, the first direct care staff member to respond to the report is
required to 1) separate the alleged victim and abuser; (2) seal and preserve any crime scene(s);
and (3) instruct the victim not to take any actions that could destroy physical evidence, including
washing, brushing his or her teeth, changing his or her clothes, urinating, defecating, smoking,
drinking, or eating. If the first staff responder is a non–direct care staff member, he or she is
required to instruct the victim not to take any actions that could destroy physical evidence and
then notify direct care staff.
OR4 - Coordinated response
All actions taken in response to an incident of sexual abuse are coordinated among staff first
responders, medical and mental health practitioners, investigators, and facility leadership. The
Appendix F - Standards Summary

F-32

PREA Cost Impact Analysis
facility’s coordinated response ensures that victims receive all necessary immediate and ongoing
medical, mental health, and support services and that investigators are able to obtain usable
evidence to substantiate allegations and hold perpetrators accountable.
OR5 - Agency protection against retaliation
The agency protects all residents and staff who report sexual abuse or cooperate with sexual
abuse investigations from retaliation by other residents or staff. The agency employs multiple
protection measures, including housing changes or transfers for resident victims or abusers,
removal of alleged staff or resident abusers from contact with victims, and emotional support
services for residents or staff who fear retaliation for reporting sexual abuse or cooperating with
investigations. The agency monitors the conduct and/or treatment of residents or staff who have
reported sexual abuse or cooperated with investigations, including any resident disciplinary
reports, housing, or program changes, for at least 90 days following their report or cooperation
to see if there are changes that may suggest possible retaliation by residents or staff. The agency
discusses any changes with the appropriate resident or staff member as part of its efforts to
determine if retaliation is taking place and, when confirmed, immediately takes steps to protect
the resident or staff member.
Investigations (IN)
IN1 - Duty to investigate
The facility investigates all allegations of sexual abuse, including third-party and anonymous reports, and notifies victims and/or other complainants in writing of investigation outcomes and
any disciplinary or criminal sanctions, regardless of the source of the allegation. If additional
parties were notified of the allegation (OR1), the facility notifies those parties in writing of
investigation outcomes. All investigations are carried through to completion, regardless of
whether the alleged abuser or victim remains at the facility and regardless of whether the source
of the allegation recants his or her allegation.
IN2 - Criminal and administrative agency investigations
Agency investigations into allegations of sexual abuse are prompt, thorough, objective, and conducted by investigators who have received special training in sexual abuse investigations
involving young victims (TR4). When outside agencies investigate sexual abuse, the facility has
a duty to keep abreast of the investigation and cooperate with outside investigators (RP4).
IN3 - Evidence standard for administrative investigations
Allegations of sexual abuse are substantiated if supported by a preponderance of the evidence.
Discipline (DI)
DI1 - Disciplinary sanctions for staff
Staff is subject to disciplinary sanctions up to and including termination when staff has violated
agency sexual abuse policies. The presumptive disciplinary sanction for staff members who
Appendix F - Standards Summary

F-33

PREA Cost Impact Analysis
have engaged in sexually abusive contact or penetration is termination. This presumption does
not limit agency discretion to impose termination for other sexual abuse policy violations. All
terminations for violations of agency sexual abuse policies are to be reported to law enforcement
agencies and any relevant licensing bodies.
DI2 - Disciplinary sanctions for residents

Residents receive appropriate interventions if they engage in resident-on-resident sexual abuse.
Decisions regarding which types of interventions to use in particular cases, including treatment,
counseling, educational programs, or disciplinary sanctions, are made with the goal of
promoting improved behavior by the resident and ensuring the safety of other residents and
staff. When imposing disciplinary sanctions in lieu of or in addition to other interventions, the
facility informs residents of their rights and responsibilities during the disciplinary process,
including how to appeal sanctions, and only imposes sanctions commensurate with the type of
violation committed and the resident’s disciplinary history. Intervention decisions must take into
account the social, sexual, emotional, and cognitive development of the resident and the
resident’s mental health status.
Medical and Mental Health Care (MM)
MM1 - Medical and mental health intake screenings
During medical and mental health reception and intake screenings, qualified medical or mental
health practitioners talk with residents to ascertain information regarding the resident’s sexual
orientation, gender identity, prior sexual victimization or history of engaging in sexual abuse
(whether it occurred in an institutional setting or in the community), mental health status, and
mental or physical disabilities. Such conversations are conducted in the manner that the medical
or mental health practitioner deems appropriate for each resident in light of the resident’s age
and developmental status according to the practitioner’s professional judgment and use inclusive
language that avoids implicit assumptions about a young person’s sexual orientation. The information obtained during these screenings is strictly limited to medical and mental health practitioners, with information provided to appropriate staff on a need to know basis to the extent
needed to inform all housing, bed, program, education, and work assignments for the resident
(AP2). If a resident discloses prior sexual victimization or abusiveness during a medical or
mental health reception or intake screening, the practitioner reports the abuse according to
agency policy and relevant State or local mandatory child abuse reporting laws (OR1) and
provides the appropriate treatment or referral for treatment, based on his or her professional
judgment.
MM2 - Access to emergency medical and mental health services
Victims of sexual abuse have timely, unimpeded access to emergency medical treatment and
crisis intervention services, the nature and scope of which are determined by medical and mental
health practitioners according to their professional judgment. Treatment services must be
provided free of charge to the victim and regardless of whether the victim names the abuser. If

Appendix F - Standards Summary

F-34

PREA Cost Impact Analysis
no qualified medical or mental health practitioners are on duty at the time a report of recent
abuse is made, security staff first responders take preliminary steps to protect the victim (OR3)
and immediately notify the appropriate medical and mental health practitioners.
MM3 - Ongoing medical and mental health care for sexual abuse victims and abusers
The facility provides ongoing medical and/or mental health evaluation and treatment to all
known victims of sexual abuse. The evaluation and treatment of sexual abuse victims must
include appropriate follow-up services, treatment plans, and, when necessary, referrals for
continued care following their release from custody. The level of medical and mental health care
provided to resident victims must match the community level of care generally accepted by the
medical and mental health professional communities. The facility conducts a mental health
evaluation of all known abusers and provides treatment, as deemed necessary by qualified
mental health practitioners.
IV. MONITORING
Data Collection and Review (DC)
DC1 - Sexual abuse incident reviews
The facility treats all instances of sexual abuse as critical incidents to be examined by a team of
upper management officials, with input from line supervisors, investigators, and medical/mental
health practitioners. The review team evaluates each incident of sexual abuse to identify any
policy, training, or other issues related to the incident that indicate a need to change policy or
practice to better prevent, detect, and/or respond to incidents of sexual abuse. The review team
also considers whether incidents were motivated by racial or other group dynamics at the
facility. When incidents are determined to be motivated by racial or other group dynamics,
upper management officials immediately notify the agency head and begin taking steps to
rectify those underlying problems. The sexual abuse incident review takes place at the
conclusion of every sexual abuse investigation, unless the allegation was determined to be
unfounded. The review team prepares a report of its findings and recommendations for
improvement and submits it to the facility head.
DC2 - Data collection
The agency collects accurate, uniform data for every reported incident of sexual abuse using a
standardized instrument and set of definitions. The agency aggregates the incident-based sexual
abuse data at least annually. The incident-based data collected includes, at a minimum, the data
necessary to answer all questions from the most recent version of the BJS Survey on Sexual
Violence. Data are obtained from multiple sources, including reports, investigation files, and
sexual abuse incident reviews. The agency also obtains incident-based and aggregated data from
every facility with which it contracts for the confinement of its residents.
DC3 - Data review for corrective action

Appendix F - Standards Summary

F-35

PREA Cost Impact Analysis
The agency reviews, analyzes, and uses all sexual abuse data, including incident-based and
aggregated data, to assess and improve the effectiveness of its sexual abuse prevention,
detection, and response policies, practices, and training. Using these data, the agency identifies
problem areas, including any racial dynamics underpinning patterns of sexual abuse, takes
corrective action on an ongoing basis, and, at least annually, prepares a report of its findings and
corrective actions for each facility as well as the agency as a whole. The annual report also
includes a comparison of the current year’s data and corrective actions with those from prior
years and provides an assessment of the agency’s progress in addressing sexual abuse. The
agency’s report is approved by the agency head, submitted to the appropriate legislative body,
and made readily available to the public through its Web site or, if it does not have one, through
other means. The agency may redact specific material from the reports when publication would
present a clear and specific threat to the safety and security of a facility, but it must indicate the
nature of the material redacted.
DC4 - Data storage, publication, and destruction
The agency ensures that the collected sexual abuse data are properly stored, securely retained,
and protected. The agency makes all aggregated sexual abuse data, from facilities under its
direct control and those with which it contracts, readily available to the public at least annually
through its Web site or, if it does not have one, through other means. Before making aggregated
sexual abuse data publicly available, the agency removes all personal identifiers from the data.
The agency maintains sexual abuse data for at least 10 years after the date of its initial collection
unless Federal, State, or local law allows for the disposal of official information in less than 10
years.
Audits (AU)
AU1 - Audits of standards
The public agency ensures that all of its facilities, including contract facilities, are audited to
measure compliance with the NPREC standards. Audits must be conducted at least every three
years by independent and qualified auditors. The public or contracted agency allows the auditor
to enter and tour facilities, review documents, and interview staff and residents, as deemed
appropriate by the auditor, to conduct comprehensive audits. The public agency ensures that the
report of the auditor’s findings and the public or contracted agency’s plan for corrective action
(DC3) are published on the appropriate agency’s Web site if it has one or are otherwise made
readily available to the public.

Appendix F - Standards Summary

F-36

PREA Cost Impact Analysis

Lockups

National Standards
Lockups
I. PREVENTION AND RESPONSE PLANNING
Prevention Planning (PP)
PP1 - Zero tolerance of sexual abuse
The agency has a written policy mandating zero tolerance toward all forms of sexual abuse and
enforces that policy by ensuring all of its facilities comply with the NPREC standards. The
agency employs or designates a PREA coordinator to develop, implement, and oversee agency
efforts to comply with the NPREC standards.
PP2 - Contracting with other entities for the confinement of detainees
If law enforcement agencies contract for the confinement of their detainees, they do so only with
private agencies or other entities, including other government agencies, committed to eliminating sexual abuse in their lockups, as evidenced by their adoption of and compliance with the
NPREC standards. Any new contracts or contract renewals include the entity’s obligation to
adopt and comply with the NPREC standards and specify that the law enforcement agency will
monitor the entity’s compliance with these standards as part of its monitoring of the entity’s
performance.
PP3 - Detainee supervision
Law enforcement staff provides the detainee supervision necessary to protect detainees from
sexual abuse. The upper management officials responsible for reviewing critical incidents must
examine areas in the lockup where sexual abuse has occurred to assess whether physical barriers
may have enabled the abuse, the adequacy of staffing levels in those areas during different
shifts, and the need for monitoring technology to supplement law enforcement staff supervision
(DC1). When problems or needs are identified, the agency takes corrective action (DC3).
PP4 – Heightened protection of vulnerable inmates
Any intake screening or assessment includes consideration of a detainee’s potential vulnerability
to sexual abuse. When vulnerabilities are identified, law enforcement staff provides heightened
protection to vulnerable detainees, which may require continuous direct sight and sound supervision or single-cell housing. Absent intake screenings or assessments, any time a law enforcement staff member observes any physical or behavioral characteristics of a detainee that suggest
Appendix F - Standards Summary

F-37

PREA Cost Impact Analysis
he or she may be vulnerable to sexual abuse, the staff member provides sufficient protection to
that detainee to prevent sexual abuse.
PP5 - Limits to Cross-Gender Viewing and Searches
Except in the case of emergency, the agency prohibits cross-gender strip and visual body cavity
searches. Except in the case of emergency or other extraordinary or unforeseen circumstances,
the agency restricts law enforcement staff from viewing detainees of the opposite gender who
are nude or performing bodily functions and similarly restricts cross-gender pat down searches.
Any examination to determine the genital status of a detainee must be conducted in a private
setting by a medical practitioner and only when the genital status is unknown to the agency.
PP6 - Accommodating detainees with special needs

The agency ensures that detainees who are LEP, deaf, or disabled are able to report sexual
abuse to staff directly, through interpretive technology, or through non-detainee interpreters.
Accommodations are made to convey all written information about sexual abuse policies,
including how to report sexual abuse, verbally to detainees who have limited reading skills
or who are visually impaired.
PP7 - Hiring and promotion decisions

The agency does not hire or promote anyone who has engaged in sexual abuse in an
institutional setting or who has engaged in sexual activity in the community facilitated by
force, the threat of force, or coercion. Consistent with Federal, State, and local law, the
agency makes its best effort to contact all prior institutional employers for information on
substantiated allegations of sexual abuse; must run criminal background checks for all
applicants and employees being considered for promotion; and must examine and carefully
weigh any history of criminal activity at work or in the community, including convictions
for domestic violence, stalking, and sex offenses. The agency also asks all applicants and
employees directly about previous misconduct during interviews and reviews.
PP-8 - Assessment and Use of Monitoring Technology

The agency uses video monitoring systems and other cost-effective and appropriate technology to supplement its sexual abuse prevention, detection, and response efforts. The agency
assesses, at least annually, the feasibility of and need for new or additional monitoring
technology and develops a plan for securing such technology.

Response Planning (RP)
RP1 - Evidence protocol and forensic medical exams

When investigating allegations of sexual abuse in a lockup, the agency follows a uniform
evidence protocol that maximizes the potential for obtaining usable physical evidence for
Appendix F - Standards Summary

F-38

PREA Cost Impact Analysis
administrative proceedings and criminal prosecutions. The protocol must be adapted from
or otherwise based on the 2004 U.S. Department of Justice’s Office on Violence Against
Women publication ―A National Protocol for Sexual Assault Medical Forensic
Examinations, Adults/Adolescents,‖ subsequent updated editions, or similarly
comprehensive and authoritative protocols developed after 2004. As part of the agency’s
evidence collection protocol, all victims of detainee-on-detainee sexually abusive
penetration or staff-on-detainee sexually abusive penetration are provided with access and
transportation to a community medical provider served by qualified forensic medical
examiners. Forensic medical exams are provided free of charge to the victim. The agency
makes available a victim advocate to accompany the victim through the forensic medical
exam process.
RP2 - Agreements with outside law enforcement agencies
If an agency does not have the legal authority to conduct criminal investigations or has elected
to permit an outside agency to conduct criminal or administrative investigations of staff or
inmates, the agency maintains or attempts to enter into a written MOU or other agreement
specific to investigations of sexual abuse with the law enforcement agency responsible for
conducting investigations. If the agency confines inmates under the age of 18 or other inmates
who fall under State and local vulnerable persons statutes, the agency maintains or attempts to
enter into an MOU with the designated State or local services agency with the jurisdiction and
authority to conduct investigations related to the sexual abuse of vulnerable persons within
confinement facilities. When the agency already has an existing agreement or long-standing
policy covering responsibilities for all criminal investigations, including sexual abuse
investigations, it does not need to enter into a new agreement. The agency maintains a copy of
the agreement or documentation showing attempts to enter into an agreement.
RP4- Agreements with the prosecuting authority
The agency maintains or attempts to enter into a written MOU or other agreement with the
authority responsible for prosecuting violations of criminal law. The agency maintains a copy of
the agreement or documentation showing attempts to enter into an agreement.

Appendix F - Standards Summary

F-39

PREA Cost Impact Analysis

II. PREVENTION
Training and Education (TR)
TR1 – Employee and volunteer training
The agency trains all lockup employees and any volunteers who have contact with detainees to
be able to fulfill their responsibilities under agency sexual abuse prevention, detection, and
response policies and procedures; the NPREC standards; and under relevant Federal, State, and
local law. The agency trains all lockup employees and volunteers who have contact with detainees to communicate effectively and professionally with all detainees. Current lockup employees
and volunteers are educated as soon as possible following the agency’s adoption of the NPREC
standards, and the agency provides periodic refresher information to all lockup employees and
volunteers to ensure that they know the agency’s most current sexual abuse policies and procedures. The agency maintains written documentation showing lockup employee and volunteer
signatures verifying that they understand the training they have received.
TR2 - Detainee, attorney, contractor, and inmate worker notification of the agency’s zerotolerance policy

Employees notify all detainees of the agency’s zero-tolerance policy regarding sexual abuse
during intake. The agency ensures that attorneys, contractors, and inmate workers are
informed of the agency’s zero-tolerance policy regarding sexual abuse upon entering the
lockup.
TR3 - Specialized training: Investigations
In addition to the general training provided to all employees (TR1), the agency ensures that
agency investigators conducting sexual abuse investigations have received comprehensive and
up-to-date training in conducting such investigations in confinement settings. Specialized
training must include techniques for interviewing sexual abuse victims, proper use of Mirandaand Garrity-type warnings, sexual abuse evidence collection in confinement settings, and the
criteria and evidence required to substantiate a case for administrative action or prosecution
referral. The agency maintains written documentation that investigators have completed the
required specialized training in conducting sexual abuse investigations.
III. DETECTION AND RESPONSE
Reporting (RE)
RE1 - Detainee reporting

The agency provides multiple ways for detainees to report easily, privately, and securely
sexual abuse, retaliation by other detainees or staff for reporting sexual abuse, and staff
neglect or violation of responsibilities that may have contributed to an incident of sexual

Appendix F - Standards Summary

F-40

PREA Cost Impact Analysis
abuse. Staff accepts reports made verbally, in writing, anonymously, and from third parties
and immediately puts into writing any verbal reports.
RE2 - Exhaustion of administrative remedies

Under agency policy, a detainee has exhausted his or her administrative remedies with
regard to a claim of sexual abuse either (1) when the agency makes a final decision on the
merits of the report of abuse (regardless of whether the report was made by the detainee,
made by a third party, or forwarded from an outside official or office) or (2) when 90 days
has passed since the report was made, whichever occurs sooner. A report of sexual abuse
triggers the 90-day exhaustion period regardless of the length of time that has passed
between the abuse and the report. A detainee seeking immediate protection from imminent
sexual abuse will be deemed to have exhausted his or her administrative remedies 48 hours
after notifying any agency staff member of his or her need for protection.
RE3 - Third-party reporting

The agency receives and investigates all third-party reports of sexual abuse (IN1). At the
conclusion of the investigation, the agency notifies in writing the third-party individual who
reported the abuse and the detainee named in the third-party report of the outcome of the
investigation. The agency publicly distributes or posts information on how to report sexual
abuse on behalf of a detainee.
Official Response Following an Inmate Report (OR)
OR1 - Staff and agency head reporting duties
All staff members are required to report immediately and according to agency policy any knowledge, suspicion, or information they receive regarding an incident of sexual abuse that occurred
in an institutional setting; retaliation against detainees or staff who reported abuse; and any staff
neglect or violation of responsibilities that may have contributed to an incident of sexual abuse
or retaliation. Apart from reporting to designated supervisors or officials, staff must not reveal
any information related to a sexual abuse report to anyone other than those who need to know,
as specified in agency policy, to make treatment and investigation decisions. If the victim is
under the age of 18 or considered a vulnerable adult under a State or local vulnerable persons
statute, the agency head must report the allegation to the designated State or local services
agency under applicable mandatory reporting laws.
OR2 - Reporting to other confinement facilities
When the facility receives an allegation that an inmate was sexually abused while confined at
another facility, the head of the facility where the report was made notifies in writing the head of
the facility where the alleged abuse occurred. The head of the facility where the alleged abuse
occurred ensures the allegation is investigated.
OR3 - Staff first responder duties

Appendix F - Standards Summary

F-41

PREA Cost Impact Analysis
Upon learning that an inmate was sexually abused within a time period that still allows for the
collection of physical evidence, the first security staff member to respond to the report is
required to (1) separate the alleged victim and abuser; (2) seal and preserve any crime scene(s);
and (3) instruct the victim not to take any actions that could destroy physical evidence, including
washing, brushing his or her teeth, changing his or her clothes, urinating, defecating, smoking,
drinking, or eating. If the first staff responder is a non-security staff member, he or she is
required to instruct the victim not to take any actions that could destroy physical evidence and
then notify security staff.
OR4 - Coordinated response
All actions taken in response to an incident of sexual abuse are coordinated among staff first
responders, medical and mental health practitioners, investigators, and facility leadership. The
facility’s coordinated response ensures that victims receive all necessary immediate and ongoing
medical, mental health, and support services and that investigators are able to obtain usable
evidence to substantiate allegations and hold perpetrators accountable.
OR5 - Agency protection against retaliation
The agency protects all detainees and staff who report sexual abuse or cooperate with sexual
abuse investigations from retaliation by other detainees or staff. The agency employs multiple
protection measures, including housing changes or transfers for detainee victims or abusers,
removal of alleged staff or detainee abusers from contact with victims, and emotional support
services for staff members who fear retaliation for reporting sexual abuse or cooperating with
investigations. The agency monitors the conduct and/or treatment of staff who have reported
sexual abuse or cooperated with investigations. When retaliation is determined to be taking
place, the agency takes immediate steps to protect the detainee or staff member.
Investigations (IN)
IN1 - Duty to investigate
The facility investigates all allegations of sexual abuse, including third-party and anonymous
reports, and notifies victims and/or other complainants in writing of investigation outcomes and
any disciplinary or criminal sanctions, regardless of the source of the allegation. All
investigations are carried through to completion, regardless of whether the alleged abuser or
victim remains at the lockup.
IN2 - Criminal and administrative agency investigations
Agency investigations into allegations of sexual abuse are prompt, thorough, objective, and
conducted by investigators who have received special training in sexual abuse investigations
(TR-3). When outside agencies investigate sexual abuse, the agency has a duty to keep abreast
of the investigation and cooperate with outside investigators (RP2).
IN3 - Evidence standard for administrative investigations
Allegations of sexual abuse are substantiated if supported by a preponderance of the evidence.
Appendix F - Standards Summary

F-42

PREA Cost Impact Analysis
Discipline (DI)
DI1 - Disciplinary sanctions for staff
Staff is subject to disciplinary sanctions up to and including termination when staff has violated
agency sexual abuse policies. The presumptive disciplinary sanction for staff members who
have engaged in sexually abusive contact or penetration is termination. This presumption does
not limit agency discretion to impose termination for other sexual abuse policy violations. All
terminations for violations of agency sexual abuse policies are to be reported to appropriate law
enforcement agencies and any relevant licensing bodies.
DI2 - Referrals for prosecution for detainee-on-detainee sexual abuse

When there is probable cause to believe that a detainee sexually abused another detainee,
the agency refers the matter to the appropriate prosecuting authority.
Medical and Mental Health Care (MM)
MM1 - Access to emergency medical and mental health services

Victims of sexual abuse have timely, unimpeded access to emergency medical services
following an incident of sexual abuse, regardless of whether they name an abuser.
Treatment services must be provided free of charge to the victim. The agency is responsible
for ensuring their safe and timely transportation to community medical providers and for
referring victims to appropriate community mental health services.
IV. MONITORING
Data Collection and Review (DC)
DC1 - Sexual abuse incident reviews
The agency treats all instances of sexual abuse as critical incidents to be examined by a group of
upper management officials, with input from line supervisors and investigators. The review
team evaluates each incident of sexual abuse to identify any policy, training, or other issues related to the incident that indicate a need to change policy or practice to better prevent, detect,
and/or respond to incidents of sexual abuse. The review team also considers whether incidents
were motivated by racial or other group dynamics at the lockup. When incidents are determined
to be motivated by racial or other group dynamics, upper management officials immediately
notify the agency head and begin taking steps to rectify those underlying problems. The sexual
abuse incident review takes place at the conclusion of every sexual abuse investigation, unless
the allegation was determined to be unfounded. The review team prepares a report of its findings
and recommendations for improvement and submits it to the agency head.
DC2 - Data collection
The agency collects accurate, uniform data for every reported incident of sexual abuse using a
standardized instrument and set of definitions. The agency aggregates the incident-based sexual
Appendix F - Standards Summary

F-43

PREA Cost Impact Analysis
abuse data at least annually. The incident-based data collected includes, at a minimum, the data
necessary to answer all questions from the most recent version of the BJS Survey on Sexual
Violence. Data are obtained from multiple sources, including reports, investigation files, and
sexual abuse incident reviews. The agency also obtains incident-based and aggregated data from
every agency with which it contracts for the confinement of its detainees.
DC3 - Data review for corrective action
The agency reviews, analyzes, and uses all sexual abuse data, including incident-based and
aggregated data, to assess and improve the effectiveness of its sexual abuse prevention,
detection, and response policies, practices, and training. Using these data, the agency identifies
problem areas, including any racial or other group dynamics underpinning patterns of sexual
abuse, takes corrective action on an ongoing basis, and, at least annually, prepares a report of its
findings and corrective actions for each lockup as well as the agency as a whole. The annual
report also includes a comparison of the current year’s data and corrective actions with those
from prior years and provides an assessment of the agency’s progress in addressing sexual
abuse. The agency’s report is approved by the agency head, submitted to the appropriate
legislative body, and made readily available to the public through its Web site or, if it does not
have one, through other means. The agency may redact specific material from the reports when
publication would present a clear and specific threat to the safety and security of an agency, but
it must indicate the nature of the material redacted.
DC4 - Data storage, publication, and destruction
The agency ensures that the collected sexual abuse data are properly stored, securely retained,
and protected. The agency makes all aggregated sexual abuse data, from lockups under its direct
control and those entities with which it contracts, readily available to the public at least annually
through its Web site or, if it does not have one, through other means. Before making aggregated
sexual abuse data publicly available, the agency removes all personal identifiers from the data.
The agency maintains sexual abuse data for at least 10 years after the date of its initial collection
unless Federal, State, or local law allows for the disposal of official information in less than 10
years.
Audits (AU)
AU1 - Audits of standards
The public agency ensures that all of its lockups, including contract facilities, are audited to
measure compliance with the NPREC standards. Audits must be conducted at least every three
years by independent and qualified auditors. The public or contracted agency allows the auditor
to enter and tour lockups, review documents, and interview staff and detainees, as deemed appropriate by the auditor, to conduct comprehensive audits. The public agency ensures that the
report of the auditor’s findings and the public or contracted agency’s plan for corrective action
(DC3) are published on the appropriate agency’s Web site if it has one or are otherwise made
readily available to the public.

Appendix F - Standards Summary

F-44