U.S. Department of Homeland Security
Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Chicago Field Office
Kenosha County Detention Center
Kenosha, Wisconsin

April 1-3, 2014

COMPLIANCE INSPECTION
KENOSHA COUNTY DETENTION CENTER
CHICAGO FIELD OFFICE
TABLE OF CONTENTS
INSPECTION PROCESS
Report Organization .............................................................................................................1
Inspection Team Members ...................................................................................................1
EXECUTIVE SUMMARY ...........................................................................................................3
OPERATIONAL ENVIRONMENT
Detainee Relations ...............................................................................................................7
ICE 2000 NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................8
Detainee Grievance Procedures ...........................................................................................9
Food Service ......................................................................................................................10
Medical Care ......................................................................................................................12

INSPECTION PROCESS
The U.S. Immigration and Customs Enforcement (ICE), Office of Professional
Responsibility (OPR), Office of Detention Oversight (ODO) conducts broad-based compliance
inspections to determine a detention facility’s overall compliance with the applicable ICE
National Detention Standards (NDS) or Performance-Based National Detention
Standards (PBNDS), and ICE policies. ODO bases its compliance inspections around specific
detention standards, also referred to as core standards, which directly affect detainee health,
safety, and well-being. Inspections may also be based on allegations or issues of high priority or
interest to ICE executive management.
Prior to an inspection, ODO reviews information from various sources, including the Joint Intake
Center (JIC), Enforcement and Removal Operations (ERO), detention facility management, and
other program offices within the U.S. Department of Homeland Security (DHS). Immediately
following an inspection, ODO hosts a closeout briefing at which all identified deficiencies are
discussed in person with both facility and ERO field office management. Within days, ODO
provides ERO a preliminary findings report, and later, a final report, to assist in developing
corrective actions to resolve identified deficiencies.

REPORT ORGANIZATION
ODO’s compliance inspection reports provide executive ICE and ERO leadership with an
independent assessment of the overall state of ICE detention facilities. They assist leadership in
ensuring and enhancing the safety, health, and well-being of detainees and allow ICE to make
decisions on the most appropriate actions for individual detention facilities nationwide.
ODO defines a deficiency as a violation of written policy that can be specifically linked to ICE
detention standards, ICE policies, or operational procedures. Deficiencies in this report are
highlighted in bold and coded using unique identifiers. Recommendations for corrective actions
are made where appropriate. The report also highlights ICE’s priority components, when
applicable. Priority components have been identified for the 2008 and 2011 PBNDS; priority
components have not yet been identified for the NDS. Priority components, which replaced the
system of mandatory components, are designed to better reflect detention standards that ICE
considers of critical importance. These components have been selected from across a range of
detention standards based on their importance to factors such as health and safety, facility
security, detainee rights, and quality of life in detention. Deficient priority components will be
footnoted, when applicable. Comments and questions regarding this report should be forwarded
to the Deputy Division Director, OPR ODO.

INSPECTION TEAM MEMBERS

(b)(6), (b)(7)c

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Special Agent (Team Lead)
Special Agent
Management and Program Analyst
Inspections and Compliance Specialist
Special Assistant
Contractor
1

ODO
ODO
ODO
ODO
ODO
Creative Corrections

Kenosha County Detention Center
ERO Chicago

(b)(6), (b)(7)c

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Contractor
Contractor

Creative Corrections
Creative Corrections

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Kenosha County Detention Center
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EXECUTIVE SUMMARY
ODO conducted a compliance inspection of the Kenosha County Detention Center (KCDC) in
Kenosha, Wisconsin, from April 1 to 3, 2014. KCDC, which opened in 1998, is owned and
operated by the Kenosha County Sheriff’s Department. ERO began housing detainees at KCDC
in August 2002 under an intergovernmental service agreement between the County of Kenosha
and the U.S. Marshals Service. Male and female detainees of all security classification levels
(Levels I-III) are detained at the facility for periods in excess of 72 hours. The inspection
evaluated KCDC’s compliance with
the 2000 NDS.
Capacity and Population Statistics

The ERO Field Office
Director (FOD), in Chicago, Illinois,
is responsible for ensuring facility
compliance with the NDS and ICE
policies. There are no ICE
employees physically located at
KCDC. An ERO Detention Service
Manager (DSM) is assigned to
KCDC.

Quantity

Total Bed Capacity

604

Detainee Bed Capacity

210

Average Daily ICE Detainee Population

161

Average Length of Stay (Days)

39

Male Detainee Population Count (04/01/2014)

135

Female Detainee Population Count (04/01/2014)

4

The Kenosha County Sheriff is the highest-ranking official at KCDC and is responsible for
oversight of daily facility operations. The Sheriff supervises a staff of(b)(7)e The County of
Kenosha provides food service. Advanced Correctional Healthcare (ACH) and the Kenosha
Visiting Nurses Association (KVNA) provide medical services. KCDC holds no accreditations.
In December 2011, ODO conducted an inspection of KCDC under the NDS. Among the 12
standards reviewed by ODO, seven were in full compliance. ODO found a total of
eight deficiencies in the remaining five standards.
During this inspection, ODO reviewed 19 NDS, 16 of which were found fully compliant. Three
deficiencies were identified in the following standards: Detainee Grievance Procedures (1), Food
Service (1), and Medical Care (1). ODO made one recommendation regarding facility policy
and procedures.
This report details all deficiencies and refers to specific, relevant sections of the 2000 NDS.
ODO will provide ERO a copy of this report to assist in developing corrective actions to resolve
all identified deficiencies. ODO discussed these deficiencies with KCDC and ICE personnel
during the on-site inspection and at a subsequent closeout briefing conducted on April 3, 2014.
Detainees arriving at KCDC are initially classified by ERO at the Chicago Field Office using the
Risk Classification Assessment tool. KCDC honors ERO’s classification determinations, unless
additional information is obtained during a background check. Detainees receive medical and
mental health screenings, uniforms, personal hygiene items, and both the ICE National Detainee
Handbook and facility handbook upon arrival to KCDC. Videos on orientation, mental health
and “Know Your Rights” are available to detainees.

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The law library at KCDC is a multi-purpose room with a computer containing a current version
of LexisNexis, a printer and a telephone for calls to attorneys. The law library is accessible
seven days a week from 9 a.m. to 9:30 p.m. A laptop computer with LexisNexis is provided to
detainees housed in special management units upon request.
Policies and procedures are in place to ensure detainees have the opportunity to send and receive
correspondence. There is no limit to the amount of mail a detainee may send or receive. The
facility handbook addresses the mailing procedures. Both the handbook and notices in the
housing units describe correspondence procedures.
KCDC policy and the facility handbook address informal, formal and emergency grievances, the
availability of assistance in filing a grievance, procedures for appeal, and the opportunity to file
officer misconduct complaints. Detainees are able to file grievances by submitting forms to
officers or by placing them in a locked box. KCDC management maintains an electronic
grievance log. Seventy-eight formal grievances were filed in the 12 months preceding the
inspection and they were all addressed in a timely manner. ODO reviewed a sampling of 30
detainee grievances and found all 30 involved a variety of issues.1 Ten of the grievances alleged
staff misconduct or harassment and ODO found that these grievances were not forwarded to ICE.
No concerning trends were noticed among the 30 grievances.
The facility provides each detainee with a copy of the ICE National Detainee Handbook and the
facility handbook in English or Spanish, as appropriate. The facility handbook contains
information regarding facility rules, sanctions, the disciplinary system, mail, visiting procedures,
the grievance system, services, programs, and medical care, in accordance with the ICE NDS.
Each detainee signs and dates a receipt for the handbook.
KCDC staff is encouraged to informally resolve minor infractions. Graduated severity scales for
prohibited acts and disciplinary consequences are in place. Prohibited acts are classified as
Levels I through IV, with IV being the most serious. Detainee rights under the disciplinary
system, to include appeal rights, are addressed in the facility handbook.
ODO observed a high level of sanitation at KCDC. Detainees clean within their assigned
housing units according to a schedule posted in each unit. Cleaning supplies are stored in a
locked closet accessible only to staff, and cleaning solutions are dispensed using an automated
system.
The food service operation is managed by the County of Kenosha. Staffing consists of a food
service administrator (FSA), a cook supervisor(b)(7)ecooks and a crew of inmate workers. No
detainees work in food service. All staff and inmate workers receive pre-employment medical
clearances. Menus are approved by a registered dietician based on a complete nutritional
analysis. ODO inspected the kitchen and found it clean and orderly. The FSA and other KCDC
supervisors inspect the food service area on a daily and weekly basis. An official inventory of
stores on-hand is not conducted annually with a food service staff member and a member of the
financial management staff.
1

The grievance topics were as follows: allegations of staff misconduct or harassment (10), medical care (9), food
service (5), mail (2), property (1), law library (1), Commissary (1), complaints about county inmates (1).

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Property is inventoried during intake at Kenosha County Jail (KCJ). Detainees are provided
receipts for their items, which are placed in sealed brown bags and transported with them to
KCDC. Upon arrival at KCDC, the sealed property bags are stored in a locked room in the
admissions area, which is accessible only to admissions staff and supervisors.
ODO confirmed there were no detainee hunger strikes during the 12 months preceding this
inspection. KCDC policy on hunger strikes addresses the management of hunger strikes in
accordance with the NDS.
The Director of Correctional Health2 is a registered nurse (RN) employed by KVNA. The
Director of Correctional Health serves as the administrative health authority for KCDC and KCJ.
The medical director, a physician with ACH, provides clinical oversight. Mental health services
are provided by a contract psychologist and a licensed social worker, and dental services are
provided by a contract dentist. RNs conduct sick call within 24 to 48 hours, and follow
physician-approved protocols. Medical staff uses telephonic interpretation services to
communicate with detainees with limited English proficiency. ODO confirmed staff credentials
are current and primary source verified.
Initial medical and mental health screenings are performed by trained officers at KCJ before
transfer to KCDC. According to the Director of Correctional Health, KCDC only accepts
detainees with no identified medical or mental health conditions and detainees with stable,
managed chronic conditions. Detainees at KCDC receive hands-on physical examinations
conducted by RNs and the physician. Examination results are reviewed by the physician within
14 days of admission. KCDC does not perform dental screenings on detainees within 14 days of
admission.
A KCDC staff member is designated as a Prison Rape Elimination Act (PREA) coordinator. All
facility staff, including volunteers and contractors, is trained in PREA. The training includes a
National Institute of Corrections video on sexual abuse and assault. During a tour of the facility,
ODO observed PREA and Department of Homeland Security Office of Inspector General (OIG)
Hotline information posted in all detainee housing units and in the intake area. ODO confirmed
the facility handbook provides general information on filing misconduct complaints and includes
an address for the OIG and OIG Hotline number. According to facility staff and a review of
records in the Joint Integrity Case Management System, no sexual abuse or assault complaints
were filed by detainees at KCDC during the 12 months preceding this inspection.
The H-West Housing Unit at KCDC is a designated Special Management Unit (SMU) for male
detainees assigned to administrative and disciplinary segregation. The SMU has 22 singleoccupancy cells, each with one bed bolted to the floor, a sink and toilet combination, and a desk
with attached stool bolted to the floor and wall. ODO found the cells clean, adequately
ventilated, temperature controlled, well-lit, and maintained in a sanitary condition. Indoor and
outdoor recreation areas are attached to the SMU. There were two males housed in
administrative segregation at the time of the inspection.

2

The Director of Correctional Health is equivalent to the Health Services Administrator.

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The G-West Housing Unit at KCDC has four cells designated for females in administrative and
disciplinary segregation. Each cell contains one bed bolted to the floor, a sink and toilet
combination, and a desk with attached stool bolted to the floor and wall. ODO found the cells
clean, adequately ventilated, temperature controlled, well lit, and maintained in a sanitary
condition. An outdoor recreation yard is attached to the SMU. Females in segregation use
indoor and outdoor recreation areas available to the general population, but on an alternate
schedule. There were no females housed in the segregation unit at the time of the inspection.
A review of facility procedures and discussions with supervisory staff confirmed administrative
segregation at the facility is a non-punitive form of separation from the general population when
the presence of the detainee in general population poses a threat to self, other detainees, staff,
property, or the security and orderly operation of the facility.
ERO staff visits all housing units on a weekly basis. Schedules for weekly ERO visits are clearly
posted in English and Spanish in each housing unit. The FOD has written policies and
procedures in place to ensure and document that ICE supervisory and non-supervisory personnel
conduct frequent unannounced and unscheduled visits. Visits are documented on Facility
Liaison Visit Checklists and in housing unit logbooks.
Screening for suicide potential occurs during intake. No detainees were placed on suicide watch
or attempted suicide during the 12 months preceding this inspection. Per policy, detainees
determined at-risk for suicide are immediately referred to health care staff for further evaluation.
Inspection of the cell used for suicide watch confirmed it is free of objects or structures that
could facilitate a suicide attempt. Procedures for monitoring detainees on suicide watch address
all requirements of the NDS.
Detainees have reasonable and equitable access to telephones at KCDC. The telephone
availability ratio is approximately five detainees per telephone. Detainees are given emergency
messages and allowed to return emergency telephone calls without delay.
KCDC policy provides procedures for detainees to establish an advance directive for health care
in accordance with applicable law. The policy also addresses organ donation, terminal illness,
death notification procedures, and the release of remains, in accordance with the standard.
There is a comprehensive use-of-force policy at KCDC that addresses all requirements of the
NDS. KCDC reported three use-of-force incidents in 2013 and two in 2014, all of which
involved immediate force. Surveillance video from fixed security cameras was available for four
of the five incidents. The incident not recorded occurred in the dining room where there are no
cameras. This unrecorded incident was the only occasion when OC spray was deployed. ODO
reviewed the four video recordings and written documentation in all five cases. Detailed
incident reports from all staff involved, medical examinations, and after action reviews were
completed. In the case where OC spray was deployed, decontamination procedures were
followed for all impacted detainees. Decontamination included showers and provision of fresh
clothing. The review of both the video and written reports substantiated compliance with the
NDS and facility policy. Documentation reflects appropriate ERO notification in all five cases.

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OPERATIONAL ENVIRONMENT
DETAINEE RELATIONS
ODO interviewed 13 randomly-selected detainees (ten males and three females). Detainees were
informed their participation was voluntary.3 None of the detainees expressed concerns regarding
detention services, such as access to the law library and legal materials, issuance and
replenishment of hygiene items, recreation, religious services, visitation, the detainee handbook,
or the grievance system.
One male detainee complained about having blurred vision while trying to read. ODO reviewed
the detainee’s medical file and found that on February 28, 2014, the facility gave the detainee
over the counter reading glasses. After having received the glasses, the detainee complained his
vision remained blurred. On April 3, 2014, ERO approved a request to send the detainee to an
outside eye specialist.
Two female detainees complained about not being able to access the ICE detainee hotline
number. ODO investigated the issue and found the ICE detainee hotline could be called via the
speed dial numbers instead of using the full number listed on the ICE poster. ODO
recommended making a second copy of the telephone directions and placing them directly on the
phones in addition to the instructions previously posted on the wall in the housing unit. Facility
management posted instructions at each phone, and this eliminated confusion. On the final day
of the inspection, ODO confirmed both detainees could access the hotline number via speed dial
using the directions posted on the phones.

3

One female detainee declined to be interviewed by ODO.

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ICE 2000 NATIONAL DETENTION STANDARDS
ODO reviewed a total of 19 NDS and found KCDC fully compliant with the following 16
standards:
1. Access to Legal Material
2. Admission and Release
3. Correspondence and Other Mail
4. Detainee Classification System
5. Detainee Handbook
6. Disciplinary System
7. Environmental Health and Safety
8. Funds and Personal Property
9. Hunger Strikes
10. Special Management Unit – Administrative Segregation
11. Special Management Unit – Disciplinary Segregation
12. Staff-Detainee Communication
13. Suicide Prevention and Intervention
14. Telephone Access
15. Terminal Illness, Advanced Directives, and Death
16. Use of Force
As the standards above were compliant at the time of the inspection, a synopsis for these
standards is not included in this report.
ODO found three deficiencies in the following three standards:
17. Detainee Grievance Procedures
18. Food Service
19. Medical Care
Findings for these standards are presented in the remainder of this report.

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DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedure standard at KCDC to determine if a process to
submit formal or emergency grievances exists, and responses are provided in a timely manner,
without fear of reprisal. In addition, the review was conducted to determine if detainees have an
opportunity to appeal responses, and if accurate records are maintained, in accordance with the
ICE NDS.
KCDC’s policies and detainee handbook both address informal and formal grievance processes,
emergency grievances, the availability of assistance in filing a grievance, procedures for appeal,
and the opportunity to file a complaint about officer misconduct. Detainees have the opportunity
to file a grievance by submitting a grievance form to the housing unit officers or by placing the
grievance form in a locked box near the facility dining room. Detainees can appeal a grievance
to the grievance committee, which consists of the facility administrator, one facility sergeant and
one facility corporal. If the detainee is dissatisfied with the outcome, he/she can appeal the
grievance directly with ICE. This information is specified in the detainee handbook.
The facility maintains an electronic grievance log. Grievance forms and responses are kept in
the detention file. ODO reviewed the grievance log for the past year and found a total of 78
grievances filed. ODO reviewed 30 of the 78 grievances and found they involved a variety of
issues and were all addressed by facility staff. The grievance topics for the 30 included:
allegations of staff misconduct or harassment (10), medical care (9), food service (5), mail (2),
property (1), law library (1), Commissary (1), complaints about county inmates (1). No
concerning trends were noticed among the 30 grievances.
ODO carefully reviewed the ten grievances alleging staff misconduct and harassment and found
KCDC staff responded to all in a timely manner. However, staff failed to forward copies to ICE
for investigation (Deficiency DGP-1). KCDC staff stated the reason was that they did not
consider the grievances to be staff misconduct.
There were two separate occasions in which several detainees and county inmates filed
grievances about the food. The first incident occurred on December 26, 2013 where one housing
unit complained of the food tasting and smelling bad. ODO followed up on this issue and
confirmed that the food service staff tasted the food trays on this day and there was no issue with
the food and that no other housing unit complained. The second incident occurred on February
27, 2014, and detainees complained about the pasta salad being frozen. ODO looked into the
issue and found that the pasta salad was put into a blast chiller which caused the food to freeze.
It was an isolated incident and error on the part of the food service staff.

STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with ICE NDS, Detainee Grievance Procedures, section (III)(F), the FOD must
ensure, “CDFs and IGSA facilities must forward detainee grievances alleging officer misconduct
to ICE. ICE will investigate every allegation of officer misconduct.”

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FOOD SERVICE (FS)
ODO reviewed the Food Service standard at KCDC to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner, in accordance with the ICE NDS. ODO
toured the facility, inspected the food service area, observed meal preparation and service,
reviewed policy and documentation, and interviewed staff.
The KCDC food service operation is managed by employees of Kenosha County. Staffing
consists of an FSA, a cook supervisor, and(b)(7)ecooks. The staff is supported by a crew of county
inmate workers. No detainees work in food service. All staff and inmate workers receive preemployment medical clearances. ODO observed food service personnel wearing clean uniforms,
hair nets, and gloves, with frequent hand washing and changing of gloves.
Menus are approved by a registered dietician based on a complete nutritional analysis.
Procedures are in place for approval of religious diets; however, no detainees were receiving
religious diets at the time of the inspection. Seven detainees were receiving medically ordered
diabetic meals at the time of the inspection; seven other detainees were on no-meat special diets.
The facility has three dining rooms, each of which can accommodate 72 detainees. KCDC uses
the “blind-feeding” technique, which involves placement of food on trays by staff in the kitchen,
and issuance to detainees in the adjacent dining room through a tray slot. ODO observed three
officers in each dining room during the meal period, one of whom was stationed at the tray slot.
Immediately after the meal period, inmate workers were observed cleaning and sanitizing the
dining room.
ODO observed food service operations during the inspection. Food service staff frequently tests
food temperatures using digital food thermometers. Food temperatures are recorded at the time
of preparation and service, and are maintained within the range required by the NDS. ODO used
a food thermometer to confirm temperatures met NDS requirements. Prepared food is
immediately placed in thermal units for placement on the serving line, which maintains the
appropriate temperature between preparation and service. ODO sampled the Tuesday lunch
meal and found the food to be hot, of satisfactory taste, and in portions consistent with the menu.
The kitchen is clean and orderly. A cleaning schedule established by the FSA is posted that
includes the required frequency of cleaning according to equipment group. The FSA inspects the
food service area on a daily and weekly basis. Non-food service KCDC supervisors also inspect
weekly, and the City of Kenosha Division of Environmental Health conducts a bi-annual
inspection. Documentation confirmed completion of the inspections. The most recent
comprehensive inspection by the City of Kenosha Division of Environmental Health was
completed on March 18, 2014, with no violations cited.
ODO observed knives and sharps were secured on a shadow board in a separate room accessible
only to staff. Documentation reflects use of this equipment is logged by food service staff, and
the logs are checked by security staff. When in use, knives are tethered to work stations.
The food service area has ample, secured storage areas, walk-in coolers, and freezers. Inspection
of logs reflected that temperature readings for the refrigerators, freezers, and dishwasher water
are taken three times daily. Items in the dry storage area are well organized and labeled with the
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date of receipt. A stock rotation schedule is in place, and a quarterly inventory is maintained by
the FSA. However, an official inventory of stores on-hand is not conducted annually with a food
service staff member and a member of the financial management staff (Deficiency FS-1).
Completion of annual inventories with a member of the financial management staff validates the
accuracy of quarterly inventories conducted by the FSA.

STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with ICE NDS, Food Service, section (III)(J)(6), the FOD must ensure, “For
accurate accounting of all food and supplies, a perpetual inventory record is insufficient. An
official inventory of stores on hand must be taken annually with a food service staff member and
a member of the financial management staff.”

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MEDICAL CARE (MC)
ODO reviewed the Medical Care standard at KCDC to determine if detainees have access to
healthcare and emergency services to meet health needs in a timely manner, in accordance with
the ICE NDS. ODO reviewed policies, interviewed staff, inspected 64 detainee medical records,
toured all areas where medical services are provided, and observed sick call procedures.
KCDC holds no accreditations. The Director of Correctional Health is an RN employed by
KVNA, who serves as the administrative health authority for KCDC and KCJ.4 . Additional
staff provided by KVNA includes (b)(7)e full-time and (b)(7)epart-time RNs, (b)(7)e full-time LPNs,
and(b)(7)e ull-time clerical assistants. Nurses on rotation between KCJ and KCDC provide on-site
coverage at KCDC 18 hours daily. The medical director is a physician with ACH who provides
services under contract. The physician is on-site once a week, and on call 24 hours a day, seven
days a week. The physician sees a minimum of ten patients daily and stays onsite as long as
needed. Mental health services are provided by a contract psychologist and a licensed social
worker who are each on-site four to six hours a week. Dental services are provided by a contract
dentist who works as needed. ODO confirmed staff credentials are current and primary source
verified. The Director of Correctional Health stated KCDC only accepts detainees with no
identified medical or mental health conditions, and detainees with stable, managed chronic
conditions.
The clinic consists of two examination rooms, a pharmacy, a lab, an administration room and a
medical records room. Medical records are secured and accessible only to medical staff. There
is a separate waiting area with a restroom and a drinking fountain. KCDC does not have a
negative pressure room; therefore, detainees requiring respiratory isolation are transferred to KCJ
or the local hospital. Medical staff uses the Language Line and AT&T telephone interpretation
services for detainees with limited English proficiency. ODO observed the access numbers for
interpretation services posted in the medical intake area at KCJ and in the KCDC clinic. KCDC
has contracts with Kenosha Memorial Hospital, St. Catherine’s Hospital, and Aurora Hospital.
Emergency response service is provided by the Kenosha Fire Department. The clinic was
adequately sized and equipped to provide health care services for the detainee population at
KCDC. The clinic allows for patient privacy.
Detainees undergo medical and mental health screening and sign general consent for treatment
statements during processing at KCJ. Screening is performed by officers trained to perform the
function, and screening forms are reviewed by an RN before transfer to KCDC. Screening for
TB by way of PPD skin testing is completed by nursing staff at KCJ, with chest X-rays
performed at KCDC for detainees with a current or past positive PPD result. Radiology services
are provided by Mobilex USA under contract. All 64 detainee medical records reviewed by
ODO documented intake screening and TB screening in accordance with the NDS. Signed
consent forms were present in all cases.
Detainees receive hands-on physical examinations conducted by registered nurses and the
physician at KCDC. The physician reviews all 14 days of intake, in accordance with the NDS.
Documentation of training and proficiency testing for physical examinations was present in the
4

The Director of Correctional Health is equivalent to the Health Services Administrator.

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training records of all registered nurses. Dental screenings are not performed within 14 days of
arrival (Deficiency MC-1). The Director of Correctional Health Care stated detainees who have
dental complaints are scheduled for an appointment with the dentist at KCJ. Dental screenings
within 14 days of admission serve the critical purpose of pro-actively identifying any dental
needs requiring attention.
At the time of the review, 13 detainees were enrolled in the chronic care clinic. A review of
medical records confirmed ongoing treatment and routine monitoring. There were three
detainees on psychotropic medication, all of whom signed informed consent specific to their
medication.
Detainees access medical services by completing sick call request forms available in English and
Spanish and depositing them in a secured box in the housing units. Nursing staff check the
boxes and triage the requests three times daily. RNs conduct sick call within 24 to 48 hours, and
follow physician-approved protocols. KCDC has a co-pay program; however, ODO confirmed it
is not applicable to detainees.
Diamond Pharmaceutical Services provides detainee medication in blister packs. Nurses
administer medications in the housing units using medication carts. ODO confirmed the
medication carts are well organized, and documentation reflects the carts are inventoried three
times a day between shifts.
Training records for all medical staff and(b)(7)erandomly selected correctional staff confirmed
current training in first aid, four-minute response, cardiopulmonary resuscitation, and use of an
automated external defibrillator (AED). Inspection found a total of 17 first aid kits located
throughout KCDC, including each housing unit, the admission and release area, the food service
area, the clinic, and on crash carts. The AED is located outside central control and
documentation reflects the Director of Correctional Health conducts monthly serviceability
checks. ODO verified first aid kits and crash carts are inventoried monthly by nursing staff and
are properly secured when not in use.

STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE NDS, Medical Care, section (III)(E), the FOD must ensure, “An
initial dental screening exam should be performed within 14 days of the detainee’s arrival. If no
on-site dentist is available, the initial dental screening may be performed by a physician,
physician’s assistant or nurse practitioner.”

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