PREA AUDIT REPORT
☐ Interim ☒ Final
COMMUNITY CONFINEMENT FACILITIES
Date of report: July 22, 2016
Auditor Information
Auditor name: Robert Lainer
Address: P. O. Box 452, Blackshear Ga. 31516
Email: [email protected]
Telephone number: 912-281-1525
Date of facility visit: Click here to enter text.
Facility Information
Facility name: Renaissance WEST
Facility physical address: 466 West Main St., Waterbury CT 06702
Facility mailing address: (if different from above) Click here to enter text.
Facility telephone number: 203-591-8010
The facility is:
☐ Federal
☐ State
☐ County
☐ Military
☐ Municipal
☐ Private for profit
☒ Private not for profit
Facility type:
☒ Community treatment center
☐ Community-based confinement facility
☐ Halfway house
☐ Alcohol or drug rehabilitation center
☐ Mental health facility
☐ Other
Name of facility’s Chief Executive Officer: Joseph Riker
Number of staff assigned to the facility in the last 12 months: 8
Designed facility capacity: 50
Current population of facility: 38
Facility security levels/inmate custody levels: Click here to enter text.
Age range of the population: 18+
Name of PREA Compliance Manager: Click here to enter text.
Title: Click here to enter text.
Email address: Click here to enter text.
Telephone number: Click here to enter text.
Agency Information
Name of agency: CT Renaissance, Ince
Governing authority or parent agency: (if applicable) Click here to enter text.
Physical address: 350 Fairfield Ave, SUITE 701, Bridgeport, CT 06604
Mailing address: (if different from above) Click here to enter text.
Telephone number: 203-336-5225
Agency Chief Executive Officer
Name: Joseph Riker
Title: CEO
Email address: [email protected]
Telephone number: 203-336-5225 x2220
Agency-Wide PREA Coordinator
Name: Grace Gaynor
Title: Director of Quality Improvement
Email address: [email protected]
Telephone number: 203-336-5225 x2108
PREA Audit Report
1
PREA Audit Report
2
AUDIT FINDINGS
NARRATIVE
The audit of the Connecticut Renaissance West residential program was conducted on June 28, 2016. Prior to the on-site
audit the facility posted the Notice of PREA Audit instructing interested parties to contact the PREA Auditor (contact
information provided). These notices were posted throughout the facility in areas accessible to residents, staff, visitors and
contractors. The auditor did not receive any correspondence as a result of those notices. The Agency PREA Coordinator
provided flash drives 30 days prior to the PREA Audit. The flash drive was very organized facilitating the review. The PreAudit Questionnaire was provided with detailed information documented. The flash drives contained CT Renaissance Policies
and Procedures as well as any supporting documentation. The auditor reviewed the provided information and requested
additional clarification and documentation. The PREA Coordinator was always very responsive to any request and continued
to be responsive during the on-site audit and following the audit. The interactions before, during and after the audit
confirmed that this PREA Coordinator is a true professional and takes sexual safety and PREA very seriously. She has
completed virtually every training related to PREA on line through the National Institute of Corrections as well as educating
herself on PREA through webinars from the PREA Resource Center. The policies developed reflect attention to detail and
these were comprehensive and again documented policies and procedures that complied with the requirements of the
standards. Interaction with the Renaissance West Program Director was always positive and she too was very responsive and
professional in correspondence and in providing everything the auditor requested.
By prior agreement the auditor arrived at CT Renaissance West to interview overnight shift prior to their departing the
facility. The auditor was met by the Program Director who has communicated with the auditor prior to the on-site audit.
Because this program is relatively small all of the overnight shift were interviewed.
Following those interviews, the auditor randomly selected staff and residents to be interviewed. Specialized staff, where
applicable, was interviewed as well. The Connecticut Renaissance Chief Executive Officer was interviewed prior to this audit
as was they Human Resources staff and the Agency’s PREA Coordinator.
The auditor and Program Director met briefly to discuss the PREA Audit Process. Interviews with staff continued following
the briefing.
A tour of the facility was conducted later in the afternoon at the conclusion of interviews. The first floor houses the staff
office, medication room, dining area and clinician offices. The second floor has 8 bedrooms (one single room, 2 triple
occupancy rooms and 5 double occupancy rooms with private bathrooms. There is also a laundry room, conference room
and office. The third floor houses 8 bedrooms including 1 single occupancy room, 1 triple occupancy room and 6 double
occupancy rooms. The fourth floor has 9 bedrooms, including 2 single occupancy rooms, 1 triple and 6 double occupancy
rooms. The supervisor’s office is also on this floor. This tour confirmed that residents have access to PREA information
throughout the program. Additionally, they have access to privacy while dressing, showering and using the restrooms.
Restrooms and showers had doors on them preventing viewing. Rooms consisted of multiple occupancy with the exception
of a couple of single rooms. Cameras were strategically located and positioned throughout the program. Several solid doors
out of view of a camera were observed. It was recommended that signs restricting access be posted on these doors and that
staff conducting unannounced rounds as well as other security rounds check these areas to deter sexual activity. A number
of residents were observed with cell phones. These phones are allowed by the facility and just give residents another way of
reporting through an unimpeded and confidential manner outside the facility anytime they need to. Additionally, most of the
residents are working or attending programming outside the facility and would have yet another way to report.
Following interviews, reviews of additional documentation and records and a tour of the facility, at the end of the day, an
exit briefing was conducted with the Program Director. The PREA Coordinator was involved in the exit briefing via phone. The
facility had no issues with complying with the PREA Standards and will be receiving a final report within 30 days of the on-site
audit.
PREA Audit Report
2
DESCRIPTION OF FACILITY CHARACTERISTICS
Connecticut Renaissance West located in Waterbury, Connecticut, houses a Level III.5 intermediate/long term residential
treatment program. Located in Waterbury, CT., this program serves male clients, eighteen years and older referred by the
Connecticut Court Support Services Division and Federal Probation.
The Renaissance West Drug Treatment Program offers a wide range of services to each client, including individual, family and
group counseling, psycho-educational programming, life skills, self-help meetings and formal referrals to community
agencies based on individual needs.
Working closely with the legal system, this program employs a three-phase approach aimed at gradually returning clients to
the community. Length of stay is individualized with the average being three to six months. The goals of the program are to
return clients to the community with housing, employment and an aftercare plan.
The rated capacity for this community based facility is 50 residents. The facility employs 17 staff who has contact with
residents.
PREA Audit Report
3
SUMMARY OF AUDIT FINDINGS
The audit process was designed to assess and determine compliance with the PREA Community Confinement Standards.
Essentially the process consisted of reviewing policies and procedures provided by the company and other documentation
related to specific standards, observations made during the tour and throughout the on-site audit process, interviewing staff
from all shifts and residents from all living units, contractors, and company staff. Staff interviews included both specialized
staff, as applicable and randomly selected staff from all shifts. The process also included reviewing both programs Pre-Audit
Questionnaires. The process also included reviewing additional documentation that was requested. The auditor reviewed
each standard and applied the verbiage of the standard, no more and no less, to determine whether or not the programs
were in compliance with a standard.
In addition to randomly selected staff, eight specialized staff interviews were conducted. Interviews with the Agency’s Chief
Executive Officer, who also explained the contracting process, the agency’s Human Resources Staff and the agency’s PREA
Coordinator were conducted previously. In this program staff performs additional duties therefore some of the interviews
involved the same staff.
Interviews with staff confirmed that they have been trained in PREA and were aware of the facility and agency’s zero
tolerance policy. They were also aware of the need to report every suspicion, allegation, knowledge and report of sexual
abuse, sexual harassment and retaliation, including reports of inmates being at substantial risk of imminent sexual abuse.
Staff consistently reported they have been trained to take everything seriously and report it and let the investigators take it
from there. Staff was also very articulate about their responsibilities as first responders.
Interviews with residents indicated they have been provided information on PREA including the facility’s zero tolerance for
all forms of sexual activity, sexual harassment and retaliation for reporting. Residents have multiple ways to report and were
aware of them. They are allowed to have their own cell phones and most of the residents have phones enabling them to
access the outside world for reporting at any time of the day or night. Too, most of the residents are out in the community
on an almost daily basis going to work, attending programs, looking for work and/or on passes. Residents in both facilities
indicated they would report to staff because they trust them and believe they would take appropriate action.
The auditor reviewed samples of documents that had been previously requested. The PREA Coordinator and the Program
Director provided everything that was requested and the documentation that was provided prior to the audit and during the
audit, as well as interviews and observations, were used to determine compliance with each standard.
The auditor reviewed 39 Standards from the Community Confinement Standards and all of the standards were determined
to be in compliance.
Number of standards exceeded: 0
Number of standards met: 39
Number of standards not met: 0
Number of standards not applicable: 0
PREA Audit Report
4
Standard 115.211 Zero tolerance of sexual abuse and sexual harassment; PREA Coordinator
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Connecticut Renaissance Policy requires a Zero Tolerance for any form of sexual misconduct including sexual abuse. The
reviewed policies promulgated by the company appropriately and comprehensively describe the companies approach to
prevention, detection, responding and reporting to sexual abuse and sexual harassment. The agency’s commitment to
sexual safety is clearly demonstrated in the policies, procedures and also the appointment of an agency PREA Coordinator
who reports to the CEO. The commitment of this staff person to implementing the PREA Standards to ensure sexual safety in
Connecticut Renaissance Programs including Renaissance Central and Renaissance West located in Waterbury, Connecticut.
Reviewed acknowledgment statements for both residents and staff indicated that they are all being provided information
related to the agency’s PREA Policy and Zero Tolerance for all forms of sexual abuse, sexual harassment and retaliation.
Interviews:
An interview with the PREA Coordinator confirmed that she is very knowledgeable, highly competent and very dedicated to
implementing the PREA Standards in the Renaissance programs. She related that she receives the complete support of the
Chief Executive Officer, once again, highlighting the commitment of this company to the sexual safety of the residents. The
CEO, in an interview also assured the auditor of his commitment to Zero Tolerance and to PREA and to the support of his
PREA Coordinator. Interviews with randomly selected staff representing all shifts as well as specialized staff confirmed that
staff are well aware of and committed to Zero Tolerance as well. It was evident that the Program Director was
knowledgeable of PREA and committed to the sexual safety of her clients. Staff consistently was able to articulate the
training they have received in PREA and in the Zero Tolerance Policy. Interviewed residents were aware of the Zero
Tolerance policy, their rights to be free from sexual abuse, sexual harassment and retaliation for reporting. They stated they
received information about it upon admission and that it was posted everywhere.
Standard 115.212 Contracting with other entities for the confinement of residents
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
PREA Audit Report
5
corrective actions taken by the facility.
Summary:
The facility does not contract with any other entity for housing residents. The facility is a contracted program funded by
DMHAS and CSSD.
Interviews:
The Connecticut Renaissance CEO related that the DMHAS and CSSD monitor the facility and program frequently.
Standard 115.213 Supervision and monitoring
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
The CT Renaissance West staffing plan is predicated upon a maximum capacity of 50 residents. There are currently 17
employees who may have direct contact with the residents.
CT Renaissance Policy requires each Connecticut Renaissance Residential Drug Treatment and Community Work Release
facility contracted with CSSD, to maintain adequate staffing and supervision to ensure the safety and well-being of the
residents. Each Program Director is required to develop a staffing plan. The staffing plan will be reviewed and assessed for
resident sexual safety at least annually by the PREA Coordinator (or designee) and the Program Director. The staffing plan
will be kept in the PREA binder at each site in the COD (Counselor on Duty/Security) office and a copy will be submitted to
the PREA Coordinator.
The reviewed policy requires that the following are considered in developing and in annually reviewing the staff plan:
1) The physical layout of the facility.
2) The composition of the resident population
3) The use of the pop-sheet to identify and monitor any residents identified as vulnerable victims (VV) or sexually
aggressive (SA)
4) Prevalence of substantiated and unsubstantiated incidents of sexual abuse and/or harassment.
Each facility maintains a staffing plan based upon the determined staffing needs required to ensure a safe environment that
is properly monitored and supervised. The plan is maintained by the Program Director. Deviations from the staff schedule or
staffing plan are required to be documented. This includes documentation of changes in personnel coverage, changes in
assigned time frames and/changes in the required staffing pattern. Communication of staff changes will be made via email,
in the staff communication log as well as posting in the “counselor-on-duty” office.
PREA Audit Report
6
Whenever necessary, but no less frequently than once each year, Connecticut Renaissance shall assess for each Residential
Drug Treatment and Community Work Release facility staffing patterns and determine if any adjustments need to be made.
The assessment of the staffing plan will be documented. The assessment will be used to identify adjustments that need to
be made to ensure sexual safety of residents and protection from retaliation if reports are received or an investigation
conducted.
The use of Video Monitoring Systems is utilized to enhance supervision and monitoring of the residents and the facilities.
Assessment of video monitoring needs shall also take place at least annually or more frequently as needs arise. Assessment
shall include, analyzing the number of cameras, the placement of cameras, monitoring and dependability of monitoring
systems.
The reviewed 2016 Staffing Plan documented staffing based on contractual guidelines. CT Renaissance West is authorized a
Program Director, a Unit Supervisor, an Intake Coordinator, three full time Clinicians, one part time Clinician, three full time
Case Managers, three part time Case Aides, one full time Night Monitor and one part time Night Monitor.
The plan addresses the deployment of staff to ensure safety and supervision. Program staff conduct full facility tours every
hour during all shifts to visually observe the status of each client and to check any blind spots not covered by camera view.
Full facility tours are every two hours during first shift and every hour during second and third shifts to visually observe the
status of each resident and to check any blind spots not covered by camera view. The pat down search area is equipped with
a camera.
Staffing ratios are 1:10 on first shift, 1:25 with assistance being provided by the Unit Supervisor and 1:25 on the overnight
shift. Minimum staffing on a typical day shift is one Case Manager, two Clinicians, one Intake Coordinator and one Director.
Minimum staffing for second shift is two Case Aides and a Unit Supervisor while the overnight shift consists of one Night
Monitor and one Securitas Employee who is responsible for overnight security checks at the facility.
The plan describes the video monitoring and recording system. Intercoms are also accessible in various parts of the facility.
The reviewed plan indicates a thoughtful process and one that gives serious consideration to sexual safety of residents. This
is evidenced in the deployment of staff, technology and physical rounds to deter inappropriate and prohibited activity.
Documentation through PREA Committee Agendas indicated the staffing plan is discussed at least monthly. Agendas were
provided for December 2015, two meeting agendas in January and again one in February. These agendas listed the staffing
plan as an item to be discussed.
Interviews:
Interviews with the agency’s Chief Executive Officer, the PREA Coordinator and the Program Director indicated that the
facility takes PREA prevention and supervision of residents seriously. All of them were aware of the requirements for an
annual staffing plan review and were able to articulate the areas they would be addressing in that review. Their comments
and discussions were consistent with the standards and again, indicated that this Company takes sexual safety seriously. The
Program Director related that her minimal staffing is two staff in the building at all times. To meet the minimum, she stated
she would call in off duty staff.
Standard 115.215 Limits to cross-gender viewing and searches
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
PREA Audit Report
7
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Connecticut Renaissance Polices for both Connecticut Renaissance Central and Renaissance West prohibit cross
gender strip and body cavity searches as well as pat down searches. Additionally, residents in both programs have
access to restrooms with doors that close to provide privacy while using the restroom and showers with shower
curtains providing an additional measure of privacy.
Observations made during the tour of both programs confirmed that residents in this facility have a high degree of
privacy and are not in view of staff, either male or female.
Interviews:
All of the interviewed staff related that females are not permitted to search male residents, including pat
searches. They related that there are always enough male staff available to do so and if one is not immediately
available the female staff will stay with the resident until the male staff arrives. Female staff are allowed to ask
the resident to turn his pockets inside out and to “wand” him for contraband but a prohibited from touching the
resident. Interviewed residents related they had never been searched by a female staff nor had they ever seen a
female staff search a male. They did describe the “wanding” procedures but stated the females never touch a
male. Staff also related that residents are never naked in full view of opposite gender staff.
Standard 115.216 Residents with disabilities and residents who are limited English proficient
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Connecticut Renaissance Policy prohibits the use of residents as interpreters in matters regarding allegations of sexual
abuse/harassment during an internal investigation, unless the delay could compromise the resident’s safety. Both
Renaissance Central and West have identified staff members for Spanish speaking individuals who would be able to provide
interpreter assistance as needed. The Agency will provide materials related to the zero-tolerance policy in the language of
current limited English proficient residents. The facilities have access to alternative language lines for additional interpretive
PREA Audit Report
8
services. Information regarding access to the Language Line is available in the PREA Binder available through the program
Director or in the COD (Counselor on Duty/Security) office. In the case of a LEP client (limited English proficiency) or disabled
person unable to read and/or understand the written PREA policy, a staff member will read the PREA policy and elicit
responses to confirm that the person understands the policy. Someone who is severely disabled may meet the program’s
exclusionary criteria for admission.
Interviews:
Interviews with staff indicated they would use an inmate interpreter in “emergency” situations however absent an
emergency they would not. Staff indicated they thought the facilities would have access to professional interpretive
services. None of the interviewed offenders were either disabled or limited English proficient.
Standard 115.217 Hiring and promotion decisions
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Connecticut Renaissance requires that an individual must be free of any criminal proceedings including but not limited to
current / active involvement in a criminal case, pending criminal charges or be on probation or parole at the time of
application. Applicants with criminal backgrounds must be approved by a second level Supervisor prior to the extension of a
job offer. Renaissance may hold contracts with stakeholders/funding sources in specific programs that may prohibit the
employment of any individual with a substance abuse or criminal history.
CT Renaissance Policy, applicable to both facilities, states that the agency will not knowingly hire, appoint, or promote
anyone who may have contact with individuals in the custody of the Judicial Branch or the Department of Correction, who
has been convicted of, has engaged in, or has attempted to engage in sexual activity in the community facilitated by force,
overt or implied threats of force, or coercion or if the victim did not consent or was unable to consent; or has been civilly or
administratively adjudicated to have engaged in the activity describe above.
An employment application asks about current pending charges, prior convictions, whether or not the individual is or was on
probation or parole and an additional question asks if the applicant is a registered sexual offender and has the applicant ever
perpetrated sexual abuse of harassment.
Additionally, CT Renaissance facilities will consider any prior reported incidents of sexual harassment in determining
whether to hire, appoint, or promote an individual who may have contact with a person in the custody of the Judicial Branch
or the Department of Correction. Prior to an employment offer being made to a potential internal or external candidate
reference checks and a criminal background check are conducted. Information obtained through a reference and criminal
background check is considered for employment purposes if relevant to the position being applied.
Criminal Record Checks shall be completed prior to hire and every 5 years thereafter for all potential employees, volunteers,
PREA Audit Report
9
interns and contractors.
A private vendor conducts the background checks for Renaissance. The following checks are made as a part of that process.
These include the following: Inspector General, Homeland Security, GSA/SDN/DFAC, Court Search Record, Social Trace and
Driver’s History. When asked about conducting a national check through NCIC in case an applicant did not disclose all of the
places he/she had lived the Renaissance Human Resources staff checked with the vendor who explained that that was the
purpose of the social trace. This check, according to the vendor, would alert the company of places of prior residence to
ensure checks could them be made with that state as well.
The Reference Check will utilize the signed Reference Check Authorization and Release of Information Form and consist of
the following: 1. Assessing the accuracy of information provided on the application/resume; 2. Personal or professional
character references; 3. Educational History; 4. Prior Employers; 5. Other Relevant Sources. 6. Will include an inquiry as to
whether the candidate engaged in any substantiated allegations of sexual abuse or resigned during the pendency of an
investigation of alleged sexual abuse.
Omissions on the part of the employee, volunteer, intern or contractor or the provision of materially false information, shall
be grounds for termination.
A review of five personnel files indicated that applicants had completed the applicant questions as well as background
checks. Checks included Inspector General, Homeland Security, GSA/SDN/OFAC, Court Search Record, Social Tracing and
Driver’s History.
Interviews:
An interview with the HR Staff at the central officer was conducted via phone. The hiring process from posting of a vacancy,
through the application process, interview process and background check process was explained. The HR Staff clarified a
question about the vendor checking only the state identified as where an applicant reported residing. The question was
what if an applicant was not truthful in reporting residences? The clarification from the vendor through the HR staff was that
the social tracing identifies any states the applicant has resided in previously. At that point then crime information checks
would be in those states identified as residences or former residences of applicants.
Standard 115.218 Upgrades to facilities and technologies
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
There have been no upgrades to the facility apart from renovations in the restrooms, weight room and medical. Additional
cameras were also added to the facility. In installing cameras and in planning for modifications of existing structures, PREA is
definitely considered.
PREA Audit Report
10
Interviews:
The Facility Program Manager related that the only upgrades to the facility have been the addition of three cameras. There
are currently 21 cameras strategically located throughout the facility. The Agency’s CEO related that that agency had always
had cameras in the facility and installed a camera inside the front door for the protection of staff. He also related that this
facility was designed to limit blind spots. Interviews with the Renaissance Chief Executive Officer and the PREA Coordinator
indicated that they would certainly consider the requirements of PREA and sexual safety in any future modifications or
expansions of either the physical plant or video monitoring systems. The CEO indicated that Renaissance has always
considered cameras important in supervising and ensuring the safety of residents.
Standard 115.221 Evidence protocol and forensic medical examinations
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Renaissance Policy governing Central and West, required that victims of sexual abuse receive 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.
The company also promulgated operating procedures for ensuring this. The procedures stated that victims of sexual abuse
will be taken to the local emergency room for a forensic exam following a sexual assault. Forensic examinations are required
to be performed by Sexual Assault Forensic Examiners (SAFEs) or Sexual Assault Nurse Examiners (SANEs) where possible. If
the area hospitals do not have available SAFE or SANEs then the examination can be performed by other qualified medical
practitioners.
The program has a Memorandum of Understanding with Safe Haven, an organization providing advocates and crisis
intervention services for residents of both CT Renaissance Central and West. Additionally, Safe Haven has a toll free hotline
and a local number enabling residents to access them at any time, 24/7 without impediment. The organization also related
in an interview and in the MOA that it has a protocol with both St. Mary’s and Waterbury Hospitals that offers victims the
support of a sexual abuse counselor after a sexual assault.
Renaissance Policy, MEDICAL AND MENTAL HEALTH CARE FOR VICTIMS OF SEXUAL ABUSE requires that upon receiving a
report of alleged sexual abuse or sexual harassment, CT Renaissance Central Staff are required to promptly connect the
victim with emotional support services including a mental health evaluation and, as appropriate treatment planning,
recommended treatment services and referrals for continued care following discharge.
CT Renaissance offers all victims of sexual abuse access to forensic medical examinations without financial cost, where
evidentiary or medically appropriate.
Victims from Renaissance West will be referred to a victim advocate at a rape crisis center. The agency provided the auditor
PREA Audit Report
11
a Memorandum of Agreement between Connecticut Renaissance and Safe Haven of Greater Waterbury. The agreement
states that, at a client’s request the advocacy organization will allow for a sexual assault crisis counselor/advocate to
accompany and support the victim throughout the forensic exam and investigatory interviews and provide emotional
support, crisis intervention and referrals as request by the victim. Safe Haven also agreed to collaborate for continuity of
care and discharge planning for clients who are victims of sexual assault or sexual abuse. Safe Haven also agreed to provide
free, confidential and empowerment based sexual assault crisis and advocacy services, including a 24-hour hotline,
individual counseling, medical and legal accompaniment and support and community education and training as needed.
The Sex Haven Information Posting provides information related to the hotline, medical advocacy, legal advocacy, adult
advocacy and a host of other services for the community.
Interviews:
Interviewed staff related that in the event of a sexual assault or sexual abuse incident the victim would immediately be
taken to the emergency room of the local hospital to receive any treatment as a result of the assault and a forensic exam to
collect evidence. Staff related that a victim advocate from Safe Haven would accompany the resident throughout the
process providing emotional support as needed, if requested. An interview with a staff person from Safe Haven confirmed
the services offered via the Memorandum of Agreement between Safe Haven and Connecticut Renaissance.
Standard 115.222 Policies to ensure referrals of allegations for investigations
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Connecticut Renaissance Policy requires investigations into allegations of sexual abuse and sexual harassment and these
investigations are required to be done promptly, thoroughly, and objectively for all allegations including third-party and
anonymous reports.
The agency requires that investigations are to be conducted by law enforcement for sexual abuse reports. Internal reviews
and investigations of reports of sexual harassment incidents will be reviewed and coordinated by the PREA Coordinator. The
PREA Coordinator, Program Director or designee is responsible for contacting the State Police Department to initiate a
criminal investigation when appropriate. Law enforcement will take the lead role in investigations for sexual abuse and CTR
staff will cooperate with such investigations and endeavor to remain informed about the progress of the investigation.
There were no allegations of sexual abuse during the past 12 months however there was one allegation of sexual
harassment. This allegation was made by a staff person who overheard how another resident was sexually harassing another
resident. Appropriate actions were taken to separate the two, make appropriate notifications and to ensure an investigation
was conducted. The Agency PREA Coordinator conducted the investigation which was substantiated. Documentation
confirmed the resident was placed on a different floor from the alleged perpetrator and separated until and investigation
could be conducted. The alleged perpetrator was removed from the program.
Interviews:
PREA Audit Report
12
Randomly selected staff related that they are required to make a report of any suspicion, allegation, report or knowledge of
an incident of sexual abuse or sexual harassment. They also related that these incidents would be investigated. The Program
Director stated the Connecticut State Police would be responsible for conducting investigations at Renaissance West. When
asked who would be responsible for conducting investigations, most of the staff were aware that the investigations would
be conducted by the Connecticut State Police. Some thought the PREA Coordinator would investigate.
Standard 115.231 Employee training
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
The Company’s PREA Coordinator has been extremely proactive in implementing PREA. She, on her own initiative,
completed five PREA related courses on line through the National Institute of Corrections, including Communicating with
LGBTI Offenders, Behavioral Health in Confinement Settings, PREA Coordinator, Investigating Sexual Abuse in Confinement
Settings, Creating A Safe Space and Victim Services in Confinement Settings in addition to watching applicable webinars on
the PREA Resource Center website. CT Renaissance requires that staff must attend training in all agency policies related to
and associated with PREA. This training is conducted annually and all staff and the administration is required to attend. The
training includes CT Renaissance’s stance on zero tolerance for sexual abuse and sexual harassment; How to fulfill
responsibilities for prevention, detection, reporting and response to sexual abuse and harassment policies & procedures;
Employee and client rights to be free of sexual abuse and harassment; the dynamics of sexual abuse and harassment within
the criminal population and confinement facilities; Common reactions from victims; How to detect and respond to signs of
threatened and actual sexual abuse; How to avoid inappropriate relationships with clients; How to communicate effectively
and professionally with clients, including lesbian, gay, bisexual, transgender, intersex or gender non- conforming residents
and How to comply with relevant laws related to mandatory reporting of sexual abuse to outside authorities.
Samples of acknowledgment forms, signed by staff indicating that they are being trained in PREA, were provided for review.
Staff interviews also confirmed that staff are being trained. The results of their interviews indicated that they are
knowledgeable of PREA. They also were able to describe how and when they received their training.
Samples of staff NIC Certificates of Training in a variety of topics were provided documented additional training. This
additional training plus the training confirmed through PREA Acknowledgments, training documents and interviews indicate
training that exceeds the minimum requirements.
Interviews:
100 percent of the interviewed staff, both randomly selected and specialized, reported that they receive training on-line via
power point presentations and through facilitator based training where they receive instruction and hand-outs related to
PREA. They reviewed the 11 topics required by the standards and indicated they are trained in all of them. They also signed
acknowledgments indicating they were trained and understood the contents of the training related to PREA. In the
interviews they were especially strong and articulate in the zero tolerance policy and in actions they would take as first
PREA Audit Report
13
responders.
Standard 115.232 Volunteer and contractor training
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
All applicants accepted as Volunteers or Interns have a complete orientation and training period that includes at a minimum
client rights, security and confidentiality regulations, emergency procedures, lines of communication and authority,
information regarding insurance coverage, information about personal risks and liability, and all agency policies and
procedures including the agencies zero-tolerance policy for sexual abuse or unlawful sexual harassment and PREA policies.
Volunteers / Interns are provided the opportunity to attend internal workshop and seminars.
CT Renaissance Policy related to volunteers and contractors states that the agency has adopted a Zero-Tolerance policy of
sexual abuse and sexual harassment within its residential facilities. The intent of PREA is to ensure a safe, humane and
secure environment, free of the threat of sexual abuse and sexual harassment of all residents and staff/volunteers
/contractors/interns/families of residents and visitors.
Volunteers are instructed that they have an obligation to maintain clear boundaries with residents during their visits as
volunteers or while conducting business in the facility. Volunteers are advised that there is absolutely no sexual contact
permitted in the facility and that any sexual contact between a resident and a contractor is considered sexual abuse and is a
reportable incident.
The acknowledgment statement continues to state that because sexual harassment and sexual abuse is against the agency’s
policy, volunteers and contractors who become aware of such are advised to immediately report to any CTR staff member,
the Program Director, or the Agency’s PREA Coordinator.
Volunteers and contractors sign an orientation acknowledgment to indicate that they have received this information and
agree to abide by the CT Renaissance Policy.
Multiple examples were provided to demonstrate that contractors were provided this information.
Interviews:
PREA Audit Report
14
There are no volunteers at that program and the contractors serving this program are primarily vendors who have no
contact or supervised but incidental contact with residents. One contractor, the contracted security staff was interviewed at
both Central and West. These staff were knowledgeable of PREA and were able to articulate awareness of the agency’s Zero
Tolerance Policy as well as their responsibilities for reporting all allegations, knowledge or reports and suspicions of sexual
abuse.
Standard 115.233 Resident education
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Residents are provided PREA related information within 72 hours of arrival at the facility. This information includes
information explaining CT Renaissance’s zero-tolerance policy regarding sexual abuse and sexual harassment, how to report
incidents or suspicions of sexual abuse or sexual harassment, their rights to be free from sexual abuse and sexual
harassment and to be free from retaliation for reporting such incidents and the review process. This information is
provided as a refresher whenever a resident is transferred to another facility.
Residents receive a brochure with PREA related information upon entrance to the facility. The brochure is essentially the
“What You Should Know” brochure. It discusses PREA, its purpose, CT Renaissance Zero Tolerance for all forms of sexual
abuse and sexual harassment, how to report to the CT PREA Coordinator as well as other means for reporting. Reporting
methods included the following: tell any staff member, call the CT State Police (number provided), call the statewide CT
Sexual Assault Crisis Services (toll free numbers provided) as well as calling the PREA Coordinator (numbers provided). They
sign an acknowledgment that they have read and understand the CT Renaissance PREA Policy, acknowledge that the agency
has a zero tolerance for all forms of sexual abuse and sexual harassment as well as how to report it if it occurred and that
they may report without fear of retaliation. An additional acknowledgment indicates that the resident has understood the
material contained in the CT Renaissance Handbook that includes an entire page related to PREA. Clients are advised that all
allegations will be taken seriously and investigated and that the facility will attempt to keep them sexually safe. Steps to
protect the resident are also included.
PREA Related posters were observed posted throughout the facility as well, once again keeping PREA before the residents as
well as providing them contacts for reporting, along with phone numbers.
Interviews with residents and along with multiple examples of signed acknowledgments that were provided confirmed that
residents are provided information and educated in the Zero Tolerance Policy, their rights, how to report, information
related to outside advocacy services and other information.
Interviews:
PREA Audit Report
15
Interviews with 10 randomly selected residents indicated that they were provided PREA related information on admission.
They were knowledgeable of the zero tolerance policy as well as multiple ways to report. Too, when asked how they could
report they related multiple ways they could report including telling a staff member. Virtually all of the residents had cell
phones and are able to access the “outside world” anytime they want to make a report if needed. They also stated that
PREA information is posted throughout the program advising them how to report and how to access an outside agency to
report allegations of sexual abuse.
Standard 115.234 Specialized training: Investigations
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance West is a community based residential program contracted with the Connecticut Court Support Services
Division. Incidents that are or appear to be criminal are referred to the Connecticut State Police while administrative
investigations are conducted by the PREA Coordinator who has received the specialized training conducted on line by the
National Institute of Corrections. A Certificate documenting the specialized training was provided.
The Connecticut State Police conduct sexual abuse investigations for the facility. Internal investigations into allegations of
sexual harassment may be referred to the State Police however the PREA Coordinator, along with the Program Director,
would conduct an administrative investigation and provide the results of the investigation to the agency’s CEO who will
ultimately make a determination about the case.
Interviews:
An interview with the PREA Coordinator indicated that she has completed the NIC Specialized Training for Conducting
Investigations in Confinement Settings and is very knowledgeable of the investigatory process. She related that criminal
investigations may be conducted by the Connecticut State Police. She indicated that she would conduct administrative
investigations and was able to describe the process and indicated that the standard for substantiating a case of sexual abuse
or sexual harassment would be a preponderance of the evidence.
Standard 115.235 Specialized training: Medical and mental health care
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
PREA Audit Report
16
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
There is no medical staff in this program. Mental Health staff has completed the on-line specialized training provided
through the National Institute of Corrections.
Interviews:
There is no medical staff in this program. Mental Health Staff have completed the on-line specialized training provided
through the National Institute of Corrections.
Standard 115.241 Screening for risk of victimization and abusiveness
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance policy requires that all residents are assessed during the intake and evaluation process, either the same day
but not later than 72 hours of admission for their risk of being sexually abused by other residents or sexually abusive toward
other residents. CT Renaissance programs utilize a screening tool to determine a level of risk for abusiveness and/or
victimization.
The reviewed PREA Screening assessment process and form considers prior acts of sexual abuse, prior convictions for violent
offenses, and history of prior institutional violence or sexual abuse, as known to the agency, in assessing residents, for risk of
being sexually abusive.
The reviewed PREA Assessment tool considers the following criteria in determining risk of victimization:






Whether the resident has a mental physical, or developmental disability
Age of the resident
Physical build of the resident
Whether the resident has previously been incarcerated
Whether the resident’s criminal history is exclusively non-violent
Whether the resident has prior convictions for sex offenses against an adult or child
PREA Audit Report
17



Whether the resident is or perceived to be gay, lesbian, bisexual, transgender, intersex, or gender nonconforming.
Whether the resident has previously experienced sexual victimization
The resident’s own perception of vulnerability
If the resident is identified from the screening as a vulnerable victim (VV) or as sexually aggressive (SA) these designations
will be noted on the POP sheet to assist the staff in monitoring them. The POP sheet is just a “working” alert sheet for the
supervising staff. It does not contain the reasons for an alert but is a means of ensuring that staff are more cognizant of
watching these residents and providing more supervision.
Within 30 days of admission, the program reassesses the resident’s risk of victimization for abusiveness based upon any
additional relevant information received by the facility since the intake screening. A resident’s risk level will also be
reassessed when warranted due to a referral, request, and incident of sexual abuse or receipt of additional information that
bears on the resident’s risk of sexual victimization or abusiveness.
Residents are not being disciplined for refusing to answer, or for not disclosing complete information.
Information received as a result of the assessment is used in determining service needs and ensuring the safety of the
resident. The PREA Screening Assessment tool is scored and utilized to make informed housing, bed, work, education,
monitoring and program treatment or service decisions, recommendations or assignments.
Each of the programs, CT Renaissance Central and West have developed plans for making bed decisions when a
determination has been made that a resident may be at risk for victimization or that a potential abuser is being housed.
Bed placements for transgender or intersex residents shall be based on concerns for the resident’s health and safety. The
facility has not had any transgender or intersex resident’s however their own view of safety is given serious consideration in
making bed placements however the programs do not place lesbian, gay, bisexual, transgender or intersex residents in
dedicated areas solely on the basis of such identification or status, unless such placement is in a dedicated area. In the event
a transgender or intersex resident is admitted to the facility their views for their own safety will be considered and
documented in the case record.
Transgender and intersex residents will be given the opportunity to shower separately from other residents. From a service
perspective at risk residents would be engaged in non-intrusive monitoring and offered support or treatment services as
deemed appropriate.
Interviews:
Interviews with staff who conduct victimization/abusiveness screening indicated that residents are screened during the
intake process. They related that they utilize a standard instrument for conducting the assessment that is conducted in
private. The screening process considers information provided prior to the resident’s admission into the facility as well as
the assessment tool and observations made during the intake process. Staff related they would use the information from
the screening and assessment process to determine the safest place to house a resident. They indicated that there is a single
occupancy room(s) that can be used for this purpose. Staff also related that they have not had anyone who was at a
heightened risk for either abusiveness or victimization but are aware of what actions to take should they have a resident
who score high for either.
Standard 115.242 Use of screening information
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
PREA Audit Report
18
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
After conducting the screening, the facility uses this information to inform housing, bed, work, education, and program
assignments with the goal of keeping all offenders safe and free from sexual abuse.
Although neither program has identified anyone at a heightened risk for either abuse or victimization, staff responsible for
screening are aware of their plans for housing at risk residents insofar as possible in the program. This includes the
utilization of single occupancy rooms and placing them in rooms, if needed, with residents who are not identified as high
risks for abusiveness.
Staff also use the information to alert staff on the “POP” monitoring sheet. This sheet will not divulge confidential
information but is used to alert staff that a particular resident requires more monitoring and observation, both visually and
via video monitoring. If needed to protect the resident a transfer to another program may be considered.
Interviews:
An interview with staff who perform screening for victimization and abusiveness stated they would use the information from
the risk screening to make the best decisions for housing the resident, including ensuring that the resident with a higher risk
for being a victim is not placed in a room with a resident scoring high on abusiveness. They also stated that if a resident
reported prior victimization the resident would be referred for a follow up with mental health.
Standard 115.251 Resident reporting
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Residents of both Connecticut Renaissance Central and West are able to access multiple ways to report both internally and
externally. In addition to the toll free hotline, residents have access to the Safe Haven toll free number as well. The resident
handbooks provide information on PREA and encourage residents to report to any staff member, through an incident report
or contacting the agency’s PREA Coordinator. Posters are placed throughout the facility providing reporting information.
Residents are able to report to staff that they may feel comfortable with, by filing a grievance, calling a family member, tell
their attorneys if they have one, tell a friend or drop a note with the Program Director or other staff. Residents have access
to visitation and phone calls.
PREA Audit Report
19
Posters are placed throughout the facility encouraging “End the Silence” and numbers are provided for reporting.
Almost all of the residents of both programs either had a cell phone or had access to cell phones in addition to the program
phones to make reports at any time.
Too, a number of these residents are out in the community searching for jobs, working or on passes enabling them to access
the community where they could make a report.
Residents of the Renaissance West Program have multiple ways to report and have access to the community through work,
appointments and passes as well as through phones in the facility and personal cell phones.
Interviews:
Residents were able to articulate multiple ways for reporting sexual abuse, sexual harassment or retaliation if it occurred.
The most common response, when asked how they would report, was that they would tell a staff member. They also stated
they could tell a family member or drop a request to see staff. They all were aware of the hotline number and stated they
would be given access to the telephones for reporting via the hotline. All or most of the residents of both programs have cell
phones or have access to a friend who has a cell phone for making a report at any time. Some of the residents reported they
go on passes and search for jobs in the community. These events provide opportunities for residents to easily make reports.
Residents said they are informed how to report in the resident handbook and through posters throughout the facility and
were told during orientation.
Standard 115.252 Exhaustion of administrative remedies
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Residents have access to the grievance system as a means of reporting allegations of sexual abuse or sexual harassment.
Policy requires that residents are not subject to any adverse action by a staff member for using the grievance process.
Residents may file a grievance by placing it in a locked receptacle which will be examined daily by the unit administrator.
There are three forms of grievances in both programs. These include medical, emergency and non-emergency. Reports of
sexual abuse or sexual harassment would be treated as an emergency grievance. Essentially the grievance process would
stop when it alleges sexual abuse or sexual harassment; staff would immediately respond and investigate the allegations.
Interviews:
Interviews with inmates indicated they could use the grievance process if they needed to report an incident of sexual abuse.
They related this would not be the first way they would report but it was one way they could should they decide to use it.
They stated they could give the grievance to any staff member or put it in a grievance box. They also believed that staff
would respond to the grievance and take it seriously.
PREA Audit Report
20
Standard 115.253 Resident access to outside confidential support services
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance has a Memorandum of Agreement with Safe Haven of Greater Waterbury. The MOA is an agreement for
providing services to both Renaissance West and Central. This agency makes available counselors/advocates and community
based services. These services include allowing a sexual assault crisis counselor/advocate to accompany and support the
victim throughout the forensic exam process and investigatory interviews and provide emotional support, crisis intervention,
information and referrals as requested by the victim. Information related to accessing these services is posted throughout
the facility and easily accessible to residents. That information is located on the brochure provided to the residents at intake.
Interviewed residents stated that if they had a legal representative they would be able to have the attorney visit the facility
or they could make telephone contact with them as needed. They indicated that the CT Renaissance programs would not
impede their access to legal services.
Interviews:
Interviews with the PREA Coordinator and staff at Safe Haven indicated that they are aware of the CT Renaissance programs.
Safe Haven staff related that they would provide advocacy services in the event a resident had to go for a forensic exam or
to provide advocacy services as needed. Interviewed residents related that they had not needed any outside advocacy
services but were sure there was an agency or organization they could call to access it. I asked them if they had received that
information on the brochure or it was posted in the living units and they said there was information about an organization
posted but they were just not sure what it was. They all said if they needed it, they would be able to access that information.
Standard 115.254 Third-party reporting
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
PREA Audit Report
21
Summary:
CT Renaissance Policy, Reporting of Sexual Abuse and Sexual Harassment provides for third party reports and states that
clients will be informed that when third party services are used for reporting purposes the agency will be made aware of
reports of sexual abuse and harassment. The agency will pursue a coordinated response accordingly and as necessary.
A client / resident may submit a report verbally or in writing and may submit it to a staff member, administrator or third
party that is not the subject of the complaint. Third parties, including fellow residents, staff members, family members,
attorneys, and outside advocates are permitted to assist clients / residents in filing requests for administrative remedies
relating to allegations of sexual abuse, and shall also be permitted to file such requests on behalf of residents. If a third party
files such a request on behalf of a resident, the facility may request, as a condition of processing the request that the alleged
victim agree to have the request filed on his / her behalf. If the resident declines to have the request processed on his / her
behalf, CT Renaissance shall document such decision.
There were no allegations of sexual abuse or sexual assault in the past 12 months therefore there were no third party
reports.
Interviews:
All of the interviewed staff mentioned third party reporting as a way inmates could report allegations of sexual abuse and
sexual harassment. Residents also, when discussing the multiple ways they could report allegations, stated that they could
tell another resident or a relative who could make the report for them. Staff stated that regardless of the manner in which a
report is made they would take it seriously and report it. Interviewed investigative staff related that reports from third party
reports would be investigated just like any other investigation.
Standard 115.261 Staff and agency reporting duties
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance and CT Renaissance West requires all staff to report immediately and initiate a coordinated response to any
knowledge, suspicion, or information regarding an incident of sexual abuse or harassment that may have taken place against
a client by another client, employee, volunteer, intern or contractor.
Residents are encouraged to report and are provided a safe means of reporting such abuse. Anyone who reports an
allegation of sexual abuse or harassment may do so without fear of reprisal.
Staff are required to report to their next level Supervisor and the agency’s PREA Coordinator any knowledge or suspicion of
sexual abuse and/or harassment against a client / resident by another client/resident, employee, volunteer, intern or
PREA Audit Report
22
contractor. Retaliation by other residents or staff for reporting sexual abuse or sexual harassment; and, staff neglect or
violation of responsibilities that may have contributed to such incidents should also be reported.
The facility reported that there has been one allegation or report of sexual abuse, sexual harassment or of retaliation of
either staff or residents during the past 12 months. The report involved an allegation by a resident that another resident was
sexually harassing him. The report was made by a staff member as a result of a staff member hearing a resident make a
sexually harassing comment to another resident. Staff responded immediately and moved the resident to another floor in
the facility away from the alleged perpetrator. An immediate investigation was conducted. The facility documented
monitoring the resident for retaliation and documented contacts with him as a result of this allegation. The resident
continued to report to staff that he was feeling safe and was not experiencing any retaliation as a result of the report.
Interviews:
Interviews with all staff, including randomly selected, as well as specialized staff, confirmed that all of them are aware of
their responsibilities to report any suspicion, allegation, knowledge or information regarding sexual abuse or sexual
harassment and retaliation. Staff indicated that they have a zero tolerance policy and that they take all suspicions and
allegations seriously. Staff related they would report it verbally immediately to their supervisor followed up with a written
report not later than the end of the shift. Interviews with the Program Director and PREA Coordinator also confirmed the
expectations. They also confirmed that these reports would be investigated with the Connecticut State Police investigating
allegations that appear to be criminal while the PREA Coordinator would be responsible for conducting administrative
investigations.
Standard 115.262 Agency protection duties
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Both CT Renaissance Central and Renaissance West do not use any form of segregation. Residents who may make a report
of imminent sexual abuse would be separated from the potential perpetrator. The Program Director in consultation with her
supervisors would make a determination of how best to protect the resident. The stated expectation is that the threatened
resident may be placed in a single occupancy room while the alleged perpetrator may be removed from the program.
The facility PAQ indicated that there have been no occasions during the past 12 months where a resident reported that he
was at risk of imminent sexual abuse. There was a case in which a resident was being sexually harassed. Staff immediately
separated the resident and moved him to another floor away from the alleged perpetrator. Action was immediate and the
resident was monitored for retaliation as well. This was documented.
Interviews:
Staff consistently reported that they would take a report that a resident who was at substantial risk of imminent sexual
abuse seriously and would make an immediate report and either keep the resident with them until a resolution could be
PREA Audit Report
23
achieved or would take the resident to another location separated and apart from the alleged potential abuser or abusers
and kept safe. They indicated that their responses would essentially be the same as their responses as first responders. The
Program Director related that the resident would be placed in a single occupancy room with monitoring at least every 15
minutes. She also related that DOC would be notified to help determine the most appropriate placement for the resident.
Standard 115.263 Reporting to other confinement facilities
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance Central and West are required to report any allegations received from a resident that he had been sexually
abused at another facility. Policy requires that notification be done within 72 hours after receiving the allegation. When this
occurs, policy requires that the Program Director inform the CT Renaissance PREA Coordinator, who will document the
notifications. Additionally, when the CT Renaissance programs receive a report that a resident is alleging that he was
sexually abused at a CT Renaissance program, the administration is required to also report and investigate the allegation and
cooperate with any investigations.
The Pre-Audit questionnaires indicated that neither facility had received allegations either from a resident alleging abuse at
another facility or from another facility reporting an allegation of a sexual abuse occurring at either Central or West.
Interviews:
Interviews with the Agency’s PREA Coordinator and both program directors (at both Central and West) confirmed that they
are aware that they are required to notify the sending facility’s director any time a resident alleges sexual abuse at another
facility. They indicated they would report by contacting the sending facility’s administrator and document the contact. They
related that they would also initiate and cooperate with any investigation any time a resident alleged sexual abuse while at
either of the CT Renaissance Programs. All of the interviewed staff related they had not received any allegations either
alleging abuse at the CT Renaissance Central or West programs. The Program Director and PREA Coordinator stated that
they have not received any allegations from other facilities.
Standard 115.264 Staff first responder duties
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
PREA Audit Report
24
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
First responders duties are identified in the agency’s policy require the following: 1) upon learning of an allegation that a
resident was sexually abused; the first staff person to receive the information notifies the Program Director and immediately
separates the alleged victim and abuser. 2) Staff calls law enforcement in cases of alleged sexual abuse and closes off and
secures the crime scene until law enforcement arrives. 3) Staff ask the alleged victim and the alleged abuser not to take any
actions that could destroy physical evidence, including, washing, brushing teeth, changing clothes, urinating, defecating,
smoking, drinking or eating. 4) The Program Director or first responder, if the Director is not available, notifies the PREA
Coordinator and the referral source. 5) The PREA Coordinator will take the lead, providing direction and to coordinate
activities to ensure care to the victim.
Interviews:
Most of the interviewed staff were knowledgeable of their responsibilities as first responders and could articulate the steps
they would take on being informed of an allegation of sexual abuse. Every staff member said they would notify their
supervisor and immediately remove the victim to a safe place away from the perpetrator. When prompted they also were
able to relate their roles in protecting the evidence, including sealing off the potential crime scene and informing residents
not to take a shower, brush their teeth, eat, or use the bathroom.
Standard 115.265 Coordinated response
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
The CT Renaissance Policy, Reviewing and Responding to Allegations of Sexual Abuse and/or Sexual Harassment, requires all
staff to report it immediately and initiate a coordinated response to any knowledge, suspicion or information regarding an
incident of sexual abuse or harassment. The coordinated response identifies the roles of the first responder, investigators
and the agency PREA Coordinator. Staff are aware of their individual roles. The local hospitals are available to provide
forensic examiners and Safe Haven is available for providing support services to the victim.
Interviews:
Interviews indicated that staff are aware of their duties as first responders. They also understand the roles of each of the
responders identified in CT Renaissance Policy. There has been only one case of sexual harassment reported at Renaissance
PREA Audit Report
25
West and staff responses, as documented were consistent with the coordinated response.
Standard 115.266 Preservation of ability to protect residents from contact with abusers
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance Employees are not members of a union. This was confirmed during an interview with the agency Chief
Executive Officer. Employees are governed by the company’s personnel policies and staff can be placed on no contact or
removed from the facility without impediment. Sanctions would be in compliance with Renaissance’s personnel policies.
Interviews:
The agency Chief Executive Officer stated in an interview that his employees are not unionized therefore there is no
collective bargaining involved. He related that his company has high expectations regarding ethics and that staff are made
aware of the codes of ethics. He related that staff would most likely be placed on administrative leave pending an
investigation and that if an allegation for sexual abuse is substantiated, in consultation with human resources, the most
likely sanction would be termination.
Standard 115.267 Agency protection against retaliation
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Both facilities have a zero tolerance for any form of retaliation against any employee, contractor, intern, volunteer or
individual in the custody of the Judicial Branch or Department of Correction because they reported an incident of sexual
abuse or sexual harassment or because they cooperated with an investigation. Staff and residents are encouraged to report
PREA Audit Report
26
it if it occurs. If it occurs and observed or known staff at CT Renaissance Central and West will take necessary measures to
ensure that residents or staff are protected and all known incidents of retaliation or reports of retaliation will be
investigated. Connecticut Renaissance requires that the PREA Coordinator and Human Resources Staff will monitor the
conduct and treatment of employees and individuals in custody and will remedy any discovered retaliation.
IF an allegation of sexual harassment is made the PREA Coordinator in cooperation with the appropriate Program Director or
designee develop a plan to prevent and/or monitor any acts of retaliation against someone who reports an incident or
cooperates in an investigation of an allegation of sexual harassment or sexual abuse.
Retaliation monitoring will continue for at least 90 days following a report of sexual abuse and may continue beyond 90 days
if additional monitoring indicates a continued need. All Monitoring will include monitoring the conduct and treatment of
residents or staff who may have reported sexual abuse.
Efforts to fulfill monitoring obligations will be documented and controlled by the PREA Coordinator.
The reviewed PAQ indicated there was one allegation of sexual harassment. The resident was separated from the alleged
perpetrator and moved to another floor away from him. Staff stayed in communication with the alleged victim and
documented their monitoring efforts to ensure the resident was safe and had not experienced retaliation. The resident
reported he was ok and was not experiencing any form of retaliation. The perpetrator was removed from the program.
Interviews:
An interview with the PREA Coordinator indicated that from the moment an allegation is made, the staff is made aware of
the situation (without specific details) and given direction to monitor the clients involved to prevent retaliation. For
example, an additional staff member may be placed in a general area where clients congregate during free time. The client
that made the allegation will be offered to move his room and asked what would help him feel more comfortable and safe.
All requests for room changes or floor changes will be considered and requests will be honored provided it is feasible (as in
the situation that occurred at WEST, the client was given a private room on a different floor from the alleged perpetrator).
Again in the situation at WEST, in the investigation and interview process the client who made the allegation was offered the
PREA Coordinator’s phone number to contact at any time if he felt he was experiencing retaliation from staff or clients.
Interviews are documented and incorporated into the review process. Also, when interviewing other clients in addition to
the alleged perpetrator they are reminded of the zero tolerance of retaliation and that all staff are present to prevent and
report any acts of retaliation. Other residents are encouraged to report to staff or call the PREA Coordinator if they are
concerned about behaviors of retaliation.
Standard 115.271 Criminal and administrative agency investigations
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
PREA Audit Report
27
The Connecticut State Police is the agency with the authority to investigate all allegations of sexual abuse that occurs within
CT Renaissance Facilities/Programs. Every allegation is required to be reported as soon as practical to the Connecticut State
Police, the Agency’s PREA Coordinator and the company’s Chief Executive Officer. If an allegation involved an employee,
Renaissance Human Resources staff would be contacted as well. All staff of Renaissance will assist the State Police as
needed. The PREA Coordinator will work with the Connecticut State Police and, if needed, the Connecticut Department of
Correction.
Internal investigations of allegations of sexual harassment are conducted promptly, thoroughly and objectively, consistent
with company policy. When an allegation of sexual harassment is made, the PREA Coordinator will initiate and coordinate
the investigation process. The internal administrative investigation will include whether the incident of sexual harassment or
retaliation was the result of employee misconduct or negligence. Human Resources serves as the reviewing authority for all
allegations of sexual harassment or retaliation involving a CT Renaissance employee and an individual in the custody of the
Judicial Branch.
There was one investigation conducted in the past 12 months. That investigation, conducted by the PREA Coordinator, was
the result of an allegation of sexual harassment. The allegation was substantiated.
Interviews:
The agency PREA Coordinator has completed the NIC on line Specialized training, “Conducting Investigations in confinement
settings.” When asked about the process for conducting administrative investigations she related that she would begin the
investigation process immediately even on weekends. She described the entire process for conducting administrative
investigations including taking statements, conducting interviews, reviewing video surveillance cameras, checking in the
offender database to see more about the offender’s history. She said she would be objective in her investigation. The
investigation would result in a written report. Prior to making a determination the PREA Coordinator would consult with the
Chief Executive Officer who after consultation with company human resources staff would make a determination as to
whether the allegations were substantiated, unsubstantiated or unfounded. The standard for making that determination is a
preponderance of the evidence.
Standard 115.272 Evidentiary standard for administrative investigations
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
The PREA Coordinator conducts administrative investigations for CT Renaissance. She has completed the on-line specialized
training provided by the National Institute of Corrections. In an interview she related that the standard for substantiating a
case of sexual abuse or sexual harassment is the preponderance of the evidence. She related that the agency imposes no
stricter criteria or standard than the preponderance of the evidence.
CT Renaissance policy requires that the PREA Coordinator initiates and coordinates the investigation process for all
PREA Audit Report
28
administrative investigations. Policy also requires then that the Human Resources Department serves as the reviewing
authority for all allegations of sexual harassment or retaliation involving a CT Renaissance employee and an individual in the
custody of the Judicial Branch.
There was one allegation of sexual harassment in the past 12 months and no allegations of sexual abuse in the past 12
months.
Interviews:
The PREA Coordinator reported that the standard used in determining whether or not a case was substantiated would be
the preponderance of the evidence.
Standard 115.273 Reporting to residents
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
There has been one allegation of sexual harassment during the past 12 months requiring an investigation.
CT Renaissance policy requires that following a review into a client/resident’s allegation of sexual abuse the PREA
Coordinator informs the resident as to whether the allegations has been determined to be substantiated, unsubstantiated or
unfounded. The resident is required to be informed (unless the alleged sexual abuse was determined to be unfounded)
when the staff member is no longer assigned within the resident’s unit; the staff member is no longer employed at the
facility and when the agency learns that the staff member has been indicted on a charge related to sexual abuse within the
facility or when the agency learns that the staff member has been convicted on a charge related to sexual abuse within the
facility.
Following a resident’s allegation that he/she has been sexually abused by another resident, the facility will inform the
alleged victim when the agency learns that the alleged abuser has been indicted on a charge related to sexual abuse within
the facility; or the agency learns that the alleged abuser has been convicted on a charge related to sexual abuse within the
facility.
Notifications will be documented in maintained in a file by the PREA Coordinator. Policy states too that the agency’s
obligation to report back to victims is terminated if the resident is released from the agency’s custody.
There was one case of alleged sexual harassment made during the past twelve months. The alleged victim was separated
from the perpetrator and moved to another floor. Retaliation was monitored and the resident reported he was safe and was
not experiencing retaliation. The facility documented that they reported to the resident that the allegations were
determined to have been substantiated inasmuch as the alleged perpetrator admitted making inappropriate comments to
the resident and stated he would not do it again. The incident was also reviewed in compliance with policy.
PREA Audit Report
29
Interviews:
The PREA Coordinator and Program Director were able to articulate the agency’s policy requiring notification to residents
following the investigation and give an example of an actual case involving an allegation of sexual harassment.
Standard 115.276 Disciplinary sanctions for staff
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Agency Policy states that staff are subject to disciplinary sanctions up to and including termination for violating agency
sexual abuse or sexual harassment policies. It also requires that the sanctions for violations of agency policies relating to
sexual abuse or sexual harassment other than actually engaging in sexual abuse must be commensurate with the nature and
circumstances of the acts committed. The staff member’s disciplinary history and the sanctions imposed for comparable
offenses by other staff with similar histories is taken into consideration.
Termination is the presumptive disciplinary sanction for staff who have engaged in sexual abuse.
Terminations for violations of agency sexual abuse or sexual harassment policies, or resignations by staff who would have
been terminated if not for their resignation, are reported to law enforcement agencies, unless the activity was clearly not
criminal and to any relevant licensing bodies.
There have been no allegations of sexual abuse, sexual harassment or retaliation involving a staff in the past 12 months.
Interviews:
The Agency’s CEO stated that CT Renaissance has a strong Code of Ethics component to employment. Staff who violate the
facility’s sexual abuse or sexual harassment policy may be placed on administrative leave until the conclusion of an
investigation. If the allegations are substantiated the presumptive sanction would be termination.
Standard 115.277 Corrective action for contractors and volunteers
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
PREA Audit Report
30
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance policy requires that any contractor or volunteer who engages in sexual abuse are prohibited from contact
with residents and shall be reported to law enforcement agencies, unless the activity was clearly not criminal, and to
relevant licensing bodies.
The facility, if they had received such an allegation, would take appropriate remedial measures, and consider whether to
prohibit further contact with residents, in the case of any other violation of agency sexual abuse or sexual harassment
policies by a contractor or volunteer.
Interviews:
The Program Director stated that there are no volunteers at the facility however contractors would be removed from the
facility and terminated if needed. An investigation would be conducted and following the results of the investigations,
decisions would be made about the continued use of the contractor however until a decision is made, the contractor would
be removed from having contact with any resident.
Standard 115.278 Disciplinary sanctions for residents
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Clients / Residents are subject to disciplinary sanctions pursuant to a formal disciplinary process following an administrative
finding that the resident engaged in resident-on-resident sexual abuse or following a criminal finding of guild for residenton-resident sexual abuse. Sanctions would be commensurate with the nature and circumstances of the abuse committed,
the resident’s disciplinary history, and the sanctions imposed from comparable offenses by other residents with similar
histories. All disciplinary processes would consider whether a resident’s mental disabilities or mental illness contributed to
his/her behavior when determining what type of sanction, if any, should be imposed.
CT Renaissance may impose upon the abuser, therapy, counseling and other interventions as appropriate designed to
address and correct underlying reasons or motivations for the abuse.
Renaissance may impose disciplinary sanctions on a client / resident for sexual contact with staff only upon a finding that the
staff member did not consent to such contact. Disciplinary actions, as a result of a report of sexual abuse made in good faith
PREA Audit Report
31
based upon a reasonable belief that the alleged conduct occurred, shall not constitute falsely reporting an incident or lying,
even if a review does not establish evidence sufficient to substantiate the allegation.
CT Renaissance West prohibits all sexual activity between residents and will follow up with disciplinary action for such
activity. CT Renaissance will not deem such activity to constitute sexual abuse if it is determined that the activity is not
coerced. Determination of appropriate disciplinary actions shall be a collaborative effort between CT Renaissance and the
referral source.
There have been no allegations of sexual abuse during the past 12 months at this program. There was one allegation of
sexual harassment. The perpetrator was removed from the program.
Interviews:
The Program Director related that the referral source would be notified regarding any allegation of sexual abuse or sexual
harassment. The most likely sanction would be removal from the program and placement in another facility, at the direction
of the Court Support Services Division. If the allegations were criminal, then the sanction would be determined by the court
system.
Standard 115.282 Access to emergency medical and mental health services
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Victims of sexual abuse at either CT Renaissance Center or CT Renaissance West would be provided and would receive
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.
Upon receiving a report of alleged sexual abuse or sexual harassment, CT Renaissance West will promptly connect the victim
with emotional support services including a mental health evaluation and, as appropriate, treatment planning,
recommended treatment services and referrals for continued care following discharge.
CT Renaissance Central and West offer all victims of sexual abuse access to forensic medical examinations without financial
cost, where evidentiary or medically appropriate. These examinations are performed by Sexual Assault Forensic Examiners
(SAFEs) or Sexual Assault Nurse Examiners (SANEs) where possible. If the area hospitals do not have available SAFE or SANEs
then the examination can be performed by other qualified medical practitioners.
Both CT Renaissance programs, Central and West, are covered by a Memorandum of Agreement with Safe Haven to provide
advocacy services. Services include accompanying the victim throughout the forensic process and as well as any
investigatory interviews or court proceedings.
PREA Audit Report
32
Both Renaissance Programs, Central and West, are covered by a Memorandum of Agreement with Safe Haven to provide
advocacy services. Services include accompanying the victim throughout the forensic process and as well as any
investigatory interviews or court proceedings.
A referral for treatment services will be provided to the victim. The Agency does not provide specialized treatment services
for victims of sexual assault. They will be referred to outside sources for medical and mental health services.
Emergency services are provided through the St. Mary’s or Waterbury Hospitals. Forensic exams would be provided at either
of these hospitals.
Interviews:
Interviews with staff confirmed that routine services would be provided either in the community at the community health
center or in one of the area hospitals. The Program Director and PREA Coordinator related that emergency services and
forensic exams for CT Renaissance Central and West would be provided at either the St. Mary’s or Waterbury Hospitals.
Standard 115.283 Ongoing medical and mental health care for sexual abuse victims and abusers
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Ongoing medical and mental health care services are provided at the New Haven Correctional Center or through the
Community Health Center depending on the resident’s status and/or referral source. Crisis intervention services are
provided at Safe Haven.
Interviews:
The CT Renaissance Programs, Central and West, do not provide medical care and do not have any health care or mental
health staff on staff. Services would be provided either at the New Haven Correctional Center or the Community Health
Center.
Standard 115.286 Sexual abuse incident reviews
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
PREA Audit Report
33
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance West conducts a sexual abuse incident review at the conclusion of every sexual abuse report and
administrative investigation of sexual harassment allegations, including where the allegation has not been substantiated,
unless the allegation has been unfounded.
Incident reviews occur within 30 days of the conclusion of the investigation. The review team composed of the PREA
Coordinator, Program Director, Direct Care staff and medical or mental health practitioners. The review team considers
whether the allegation or administrative review indicates a need to change policy or practice to better prevent, detect, or
respond to sexual abuse; whether the incident or allegation was motivated by race; ethnicity; gender identity; lesbian, gay,
bisexual, transgender, or intersex identification, status, or perceived status; or gang affiliation; or was motivated or
otherwise caused by other group dynamics at the facility. Additionally, the team would examine the area in the facility
where the incident allegedly occurred to assess whether physical barriers in the area may enable abuse. They would also
assess the adequacy of staffing levels in that area during different shifts; assess whether monitoring technology should be
deployed or augmented to supplement supervision by staff and prepare a report of its findings, including but not necessarily
limited to determinations made by the review team along with any recommendations for improvement. Review team
reports are required to be submitted to the Chief Executive Officer, Board of Directors and PREA Coordinator. CT
Renaissance West will implement recommendations for improvement or document reasons for not doing so.
There was one incident in which a resident was being sexually harassed at Renaissance West. The results of the investigation
indicated the allegation was substantiated. Documentation was provided to confirm the resident was notified of the results
of the investigation.
Interviews:
Interviews with the PREA Coordinator and team members confirmed that all incidents will be reviewed in compliance with
policy. The PREA Coordinator related that the team consists of the Program Director, Direct Care Staff and Medical/Mental
Health practitioners, as available.
Standard 115.287 Data collection
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
PREA Audit Report
34
CT Renaissance has policies in place to ensure the collection of accurate, uniform data for every allegation of sexual abuse at
facilities. A set of standards shall be established to track occurrences and their circumstances. Data will be aggregated
quarterly and reviewed by the agency’s Safety Committee. Annually, the data will be submitted to the Board of Directors for
review. The incident based data collected shall include at a minimum the data necessary to answer all questions from the
most recent version of the survey of Sexual Violence conducted by the Department of Justice.
CT Renaissance Central and Renaissance West are required to maintain, review and collect data as needed from all available
incident based documents including reports, investigation files sexual abuse incident reviews and upon request, CT
Renaissance will provide all aggregated data from the previous calendar year to the Department of Justice. Neither CT
Renaissance West has had one allegation of sexual harassment and no allegations of sexual abuse or retaliation however
processes are in place for collecting and reporting data.
Interviews:
The PREA Coordinator is more than knowledgeable of all of the PREA Standards and is aware of the requirements of the
provisions of this standard as well. She related that there have been no requests for any information for the U.S. Justice
Department Survey of Sexual Violence Form SSV-5.
Standard 115.288 Data review for corrective action
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
CT Renaissance reviews data collected and aggregated in order to assess and improve the effectiveness of its sexual abuse
prevention, detection and response policies, practices and training. Including; Identifying problem areas; Taking corrective
action on an ongoing basis; Preparing an annual report of its findings and corrective actions for each facility as well as the
agency as a whole. Such report shall include a comparison of the current year’s data and corrective actions with those from
prior years and shall provide an assessment of the agency’s progress in addressing sexual abuse.
Data and associated annual reports shall be reviewed by CT Renaissances’ Leadership and made available through the
agency’s website. CT Renaissance may redact specific material from the reports when publication would present a clear and
specific threat to the safety and security of a facility. The nature of the material redacted would need to be indicated.
Interviews:
The PREA Coordinator and the Renaissance Chief Executive Officer related that they would be reviewing any collected data
to identify frequency of incidents, types of incidents and results of investigations and would utilize the collected data to
improve the facility’s or company’s approach to prevention, detection, response and reporting of PREA related incidents and
sexual safety.
PREA Audit Report
35
Standard 115.289 Data storage, publication, and destruction
☐
Exceeds Standard (substantially exceeds requirement of standard)
☒
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period)
☐
Does Not Meet Standard (requires corrective action)
Auditor discussion, including the evidence relied upon in making the compliance or non-compliance
determination, the auditor’s analysis and reasoning, and the auditor’s conclusions. This discussion
must also include corrective action recommendations where the facility does not meet standard. These
recommendations must be included in the Final Report, accompanied by information on specific
corrective actions taken by the facility.
Summary:
Company policy requires that data and associated reports on sexual abuse and sexual harassment shall be securely retained.
CT Renaissance shall post annually all aggregated sexual abuse data from its programs readily available to the public through
its website. Prior to making data available, all personal identifiers shall be removed. CT Renaissance shall maintain sexual
abuse data collected for at least 10 years after the date of the initial collection unless Federal, State or local law requires
otherwise.
AUDITOR CERTIFICATION
I certify that:
☒
The contents of this report are accurate to the best of my knowledge.
☒
No conflict of interest exists with respect to my ability to conduct an audit of the agency under
review, and
☒
I have not included in the final report any personally identifiable information (PII) about any
inmate or staff member, except where the names of administrative personnel are specifically
requested in the report template.
_
July 22, 2016
Auditor Signature
PREA Audit Report
Date
36