HomeMy WebLinkAbout20113091.tiff Justice Services Division
18 6 I - 2 0 I I 1008 9th Street - P.O. Box 758
Greeley, CO 80632
Phone: (970) 336-7227
��J '� Fax: (970) 392-4677
WEL ► O NTY
u
November 22, 2011
MEMORANDUM
To: Board of County Commissioners
From: Doug Erler, Director
Re: 2011 Audit of ICCS (Community Corrections)
Consent Agenda---Communications Only
Enclosed for your review is a copy of the final report prepared by the Division of Criminal
Justice (DCJ) of a Full Scope audit of Intervention Community Corrections Services (ICCS)
conducted in January 2011.
The Weld County Community Corrections Board and this writer reviewed the audit findings at
their meeting held on November 22, 2011. All partially compliant and the one non-compliant
finding(s) made by DCJ upon ICCS were discussed as well as ICCS's Corrective Action Plan
submitted to the DCJ (also enclosed). The consensus expressed by all at this meeting is that
ICCS has made considerable strides over the past two years to deliver sustainable community
corrections services in Weld County and that the work of the Board and by my Division has
helped to improve these services. The Board expressed confidence in ICCS and encouraged
them to review all findings and suggestions made by the DCJ to ensure overall successful
implementation.
Thank you.
l'CruvuoI iCn wua
is-5- aDI i 2011-3091
- 1 os Division of Criminal Justice
Jeanne M.Smith,Director
70
0 Kipling St.
Suite 1000
COLORADO Denver,CO 80215-5865
(303)239-4442
DEPARTMENT FAX(303)239-4491
OF PUBLIC SAFETY
October 6, 2011
Ms. Dionne Grinde
ICCS—Weld
1101 H Street
Greeley, CO 80631
Dear Ms. Grinde:
Enclosed is the final report for the audit of the Intervention Community Corrections Services —
Weld residential program,conducted in January 2011. The DCJ/OCC requires that the program
submit a corrective action plan addressing each finding considered to be Noncompliant or
Partially Compliant. The corrective action plan describes,in an established format,the strategies
and controls developed (or to be developed) by the program to correct each finding. The plan
must illustrate and describe in detail the controls implemented to prevent or significantly reduce
the risk of re-occurrence.
• The format to be used for the corrective action plan is as follows:
1: Briefly describe the finding.
2: Describe, in detail, the controls to be implemented that convey a reasonable assurance
that the risk for re-occurrence has been eliminated or significantly reduced.
3: For each finding, establish a date for full implementation of the corrective measure(s).
John W.Hlckenlooper
GOVERNOR
James H.Davis4: Identify the individual(s) responsible for implementation of the corrective measures.
EXECUTIVE DIRECTOR
Colorado Stale 5: Attach a copy of ALL relevant policies and procedures, regardless of whether revisions
Patrol
were required.
Colorado Bureau
of Investigation
Division of Please submit the corrective action plan to the DCJ/OCC no later than November 7,2011. If you
Criminal Justice have any questions, or are in need of any assistance, please do not hesitate to contact me at
Office of Preparedness, (303) 239-4461.
Security,and Fire Safety
Sincerely,
DCJ
• Valarie Schamper
Community Corrections Auditor
Home Page: hop://dcj.state.co.us/
E-Mail: jeanne.smith@cdps.state.co.us
COLORADO DEPARTMENT
OF
PUBLIC SAFETY
•
CAI
Colorado Department of Public Safety
•
Division of Criminal Justice
Report of Audit
Findings & Recommendations
for
Intervention Community Corrections Services
Weld(ICCS-Weld)
Prepared by:
The Division of Criminal Justice
Office of Community Corrections
October 2011
•
�C ! t Alice4414, •
Glenn Tapia, Program Director
Colorado Department of Public Safety
Division of Criminal Justice
Office of Community Corrections
Valarle Schamper, Auditor
Colorado Department of Public Safety
Division of Criminal Justice
Office of Community Corrections
Christine Schmid, Staff
Colorado Department of Public Safety
Division of Criminal Justice
Office of Community Corrections
Mindy Miklos, Staff
Colorado Department of Public Safety
Division of Criminal Justice
Office of Community Corrections
ShawnDee Ingo, Staff
Colorado Department of Corrections •
Doug Erler, Staff
19th JD Community Corrections Board
Colleen Flack, Member
19th JD Community Corrections Board
Kevin Nelan, Member
19th JD Community Corrections Board/Colorado Judicial Department
Mary Nagler, Staff
Colorado Judicial Department
•
1
• AUTHORITY
The Division of Criminal Justice(DCJ) is mandated to conduct performance audits through the following:
• Statutory authority pursuant to C.R.S. §17-27-108 (2)(b);
• Section T in the contract established between the Nineteenth Judicial District Community Corrections
Board (Board) and the State of Colorado, with subcontractor responsibilities incorporated in the
contract between the Board and its local program(s).
REPORT DISTRIBUTION
Pursuant to C.R.S. §17-27-108 (2)(b), copies of this report have been distributed to ICCS-Weld
management, the Department of Corrections, Division of Adult Parole, Community Corrections and
Youthful Offender System, the Nineteenth Judicial District Community Corrections Board, and the
Nineteenth Judicial District Probation Department.
PURPOSE,METHODOLOGY & SCOPE
The Colorado Department of Public Safety's Division of Criminal Justice/Office of Community
Corrections (DCJ/OCC) initiated this full audit of the ICCS-Weld residential program in an effort to
determine the facility's compliance with the Colorado Community Corrections Standards (C.C.C.S.), as
revised in July 2007 and 2010. When appropriate, required changes and recommendations regarding
• compliance with the Standards are provided.
Audit procedures include tests of documentary evidence, data analysis, observations and internal control
review, as well as interviews and discussions with program management, program staff and offenders.
Compliance with C.C.C.S. was tested in the following areas:
• Personnel
• Management Control
• Security
• Case Management
Audit Notice Date 01/03/11
Dates of on-site visit 01/17/11 —01/21/11
Date Scope 10/01/09—01/17/11
Number of case files requested 27
Number of case files provided 22
Number of case files removed 5*
*These files were removed once an adequate sample was selected for review.
The results of the auditor's findings are outlined in the following document. Data has been accumulated
• through a collection of quantitative and qualitative observations.
2
MEASUREMENT •
Compliance with the Standards is described at three levels:
• Compliant (85% - 100%)
• Partially Compliant (70% - 84%)
• Noncompliant (69% or below)
Standards compliance ratings of 85% or above will not be addressed in the report. Compliance with other
Standards is addressed more extensively within the body of the report. Some Standards may not have
been sufficiently reviewed to determine compliance or non-compliance, in such cases, an "NR" will be
noted on the chart. Some Standards may not apply to the program, in such cases, an "NA" will be noted
on the chart. In some cases, there may be brief observations noted within the text of the audit report.
The Compliance Summary table provides an overall summary of the program's compliance with the
Standards that were reviewed in this audit. The column titled Score Band Rating refers to the formal
results of the 2011 ratings of the Colorado Community Corrections Standards. In this process, each
Standard was rated by subject matter experts (SME) on its expected impact on public safety, offender
management, and offender treatment. Standards rated in Bands A and B are among the Standards that
the SME panel believed to be the most important across the three dimensions.
PROGRAM AND AUDIT OVERVIEW
Intervention Community Corrections Services (ICCS) began operations in Weld County on June 30, •
2008. The program was initially housed at the Weld County Jail, but moved to a new county-owned
building in June 2010. Early on, ICCS-Weld experienced some instability in the Program Director
position. However, Dionne Grinde was appointed Director in September 2009 and has since established
stable and effective leadership.
ICCS-Weld is a non-profit residential facility that houses both male and female Transition and Diversion
offenders. At the time of our audit, ICCS-Weld was providing regular residential services to 163
offenders (121 male, 42 female).
ICCS-Weld provides several additional in-house services to offenders. Clinical staff provide on-site
cognitive-behavioral and substance abuse treatment as well as mental health screens for offenders once
these services have been clinically indicated. Additionally, Community Education Outreach (CEO)
provides in-house educational and employment services to offenders. The Help, Information, and
Resources for Employment (H.I.R.E.) program provides one-on-one job skills and employment assistance
to ICCS residents. These additional programs and support significantly increase ICCS-Weld's ability to
effectively serve its population.
As indicated in the Compliance Summary on pages 4-6, overall the program rated Compliant in 84% of
the Standards tested; 15% of the Standards were rated as Partially Compliant; and 1% were rated as
Noncompliant. Findings were relatively equally distributed across the four score bands.
•
3
0 ICCS-WELD COMPLIANCE SUMMARY
B 2-040 Background Check 95
A 2-070 Ethical Relationships V 7
B 2-080 Staff Criminal Conduct V
B 2-100 Staff Orientation Training 100 J
B 2-101 PREA Training NA
B 2-110 Staff Annual Training 100 V
A 2-111 Sex Offender Supervision V 7
Training
D 2-120 Ancillary and 100 V
Administrative Training
C 2-130 Training Events
B 2-140 Case Manager Education
B 2-150 Program Administrator J
Education
B 2-151 Security Staff Education 80 V 7
B 2-152 Staff Age Requirement 100 V
B 2-160 Volunteers V
A 3-010 Policy and Procedure V 8
Manual
• B 3-020 Monthly Staff Meetings V
B 3-030 Acceptance Criteria V
B 3-060 Program Compliance
C 3-070 Receiving Offenders V
A 3-080 Supervision of Sex V
Offenders
B 3-090 Victim Notification
C 3-WO DNA Testing 100 V '
B 3-110 Family/Community V
Activities
B 3-120 Disciplinary Hearings V 8
B 3-130 Grievance/Appeals J 8
Procedure
D 3-140 CCIB Compliance V 8
C 3-150 Referral Agency Reports
B 3-160 Offender Time Credits V 9 ,
C 3-170 Incident Notification V
B 3-171 PREA Notification NA
C 3-180 Systematic File Review 9
B 3-190 Self-Audits of Operations 4 9
and Programming
B 3-191 Unannounced Facility J
Checks
C 3-200 Organized Information V
Collection
C 3-210 Documentation NI
• D 3-230 Administrative Review
B 4-010 Offender Advisement 95 J
•
B 4-011 PREA Advisement NA
C 4-030 Health Inventory 95 V
4
-:z''''-',77-3C;;-', _ -- •
B 4-040 Medication
C 4-050 Staff Response to Medical V
Emergencies
A 4-080 Substance Abuse Testing 4
B 4-090 Confirming Positive Test 100 d
Results _
B 4-100 Entry Urine Samples 100
A 4-110 Interim Urine Samples 99 1
B 4-120 Exit Urine Samples 100 d
A 4-130 BA's and UA's For Alcohol 98 4 -
B 4-150 isolation/Observation of V
Offenders _
A 4-160 Random Off-Site V- 10
Monitoring
A 4-161 Job Search Accountability 4 10
A 4-170 Passes 4
A 4-171 Furloughs d 10
B 4-180 Law Enforcement Contact 4
B 4-181 On-Grounds Surveillance 1
B 4-182 Off-Grounds Surveillance a
B 4-190 Use of Physical Force 4
B 4-200 Random Headcounts 4 10
B 4-210 Recording Authorized VIII
` Absences
A 4-220 Contraband V-
_
B 4-240 Security Staff Staffing 4
Pattern
B 4-260 Escape 4
C 5-150 Property and Safety 1
B 6-010 Case Record d
C 6-040 Release of Information 82 V 12
B 6-060 Assignment of Case V
Manager
B 6-070 Weekly Meetings 99 V
B 6-080 Chronological or Progress 1
Notes
A 6-090 Assessments 98 J
A 6-100 Supervision Plan 4 12
B 6-110 Structured Progress V 12
Feedback
• B 6-120 Movement of Offenders V
B 6-130 Employment Services J
C 6-140 Educational Review V-
C . 6-150 Offender Treatment
A 6-160 Offender Treatment
Monitoring
B 6-161 Treatment Services for DOC V
Clients
A 6-162 Treatment Services for Sex 4 III
Offenders
A 6-163 Treatment Services for V
Domestic Violence
5
J
•
A 6-164 Treatment Services for
Mental ������
Illness
A 6-165 Treatment Services for _lel_--
Substance Abuse
B Sum Termination/Transfer _�__-
m.
B 6-180 Offender Bud:et --illIlln_- 13
C 6-190 Financial Transactions --al=- 13
B 6-220Drivin• Privile•es NA ---_,
Totals by Band
Band A 19 15 79% 3 16% 1 5%
• Band B 43 38 88% 5 12% 0 0%
Band C 15 12 80% 3 20% 0 0% '
Band D 3 2 67% 1 33% 0 0%
•
6
Colorado Community Corrections Standards
Section 2-000
Personnel Standards
• 2-070 Ethical Relationships—Compliant
The audit revealed no evidence of any inappropriate relationships between staff and offenders.
However, some staff interviewed indicated that they were not clear on the specifics of the program's
policies regarding ethical relationships.
• 2-111 Sex Offender Supervision Training—Compliant
All three case management staff members supervising sex offenders had training in all of the topical
areas required. However,two of these staff members did not receive training until after they had already
begun supervising sex offenders.
• 2-151 Security Staff Education—Partially Compliant(80%)
All personnel in the sample appeared to meet the education/experiential requirements. However,
personnel files often did not contain evidence that the education and/or experience of the applicants had
been verified by program management. Of the five security personnel files reviewed, four were missing
verification of education requirements. Of these four,one was hired after the implementation of the new
Standards requiring verification of applicants' education. Therefore four of five files (80%) were
compliant.
REQUIRED CORRECTIVE ACTION No. 1:
ICCS-Weld must improve personnel practices by ensuring evidence of education/experience verification
is maintained in personnel files (C.C.C.S. 2010 ed.).
RECOMMENDATION
Program administration should consider ongoing training with staff regarding ethical relationship policies
and practices. Additionally, in the future case managers should be provided appropriate training prior to
supervising sex offenders.
•
7
1 Colorado Community Corrections Standards
Section 3-000
Management Control Standards
• 3-010 Policy and Procedure Manual—Partially Compliant
Most policies and procedures sampled were well written. However, some policies were missing
associated procedures, such as actual methods for conducting internal audits of security related
processes (sign-outs, headcounts, etc.). Some policies and procedures did not address critical pieces of
the relevant Standard (e.g., the job search accountability policies and procedures do not require that
locations be verified within two working days; assessment policies do not require that the ASUS-R and
TxRW be rescored when there is a change in intensity of supervision or treatment due to new substance
abuse; the supervision plan policies do not require that staff document reasons why a plan varies from
assessment-identified needs). Additionally, the program did not yet have a policy developed addressing
the new Structured Progress Feedback Standard.
• 3-120 Disciplinary Hearings— Compliant
Generally disciplinary procedures and documentation seemed sufficient. However, the quantity of
write-ups seemed excessive and the reasons for them rather rigid. For example, offenders who were
laid-off were all given written warnings for changing their employment status without prior approval
even though the lay-off was due to no fault of the offender(e.g. seasonal work). Offenders were written
up for other seemingly innocuous reasons such as fraternization for being polite and saying "excuse
me" to an offender of the opposite sex. Additionally, offenders were regularly written up for not
ensuring that staff completed certain tasks such as conducting UAs or BAs.
Programs should use caution when providing sanctions for behaviors that could be seen as pro-social in
other environments. In addition, overuse of sanctions for trivial behaviors can result in unintended
consequences. While sanctions play an important role in shaping offender behavior, the overuse of
sanctions for minor, or petty, offenses can render more serious sanctions less effective. Furthermore,
offenders should not be written up for legitimate situations over which they have no control.
• 3-130 Grievance/Appeals Procedure— Compliant
Most grievance responses appeared timely, but were often insufficient and/or dismissive. Many
responses indicated that the program would look into an issue, but no follow-up or final disposition was
documented. Several valid grievances were not given due consideration and well-reasoned arguments
were ignored.
Acknowledging legitimate grievances provides clients with the opportunity to feel heard and models
appropriate conflict resolution practices. These strategies are imperative for the effective management
of offender behavior and have been shown to improve the overall attitude of clients regarding
supervision and sanctions.
• 3-140 CCIB Compliance—Partially Compliant
• Of the 21 Community Corrections Information and Billing records reviewed, mistakes were found in
ten. Data errors were found primarily in the areas of finances such as restitution, earnings and
subsistence.
8
•
3-160 Offender Time Credits —Partially Compliant S
Program policies indicated that sentences outlined in months should be computed as 30 days for each
month. This would mean that at the end of each year, the sentence would be 5 days short. Policies also
did not address how the program intended to determine progress in the five areas outlined by Statute or
how many points will be awarded within each category. Instead policy directs that the loss of earned
time will be based on the class of any rule infractions received. Case file reviews demonstrated that the
program was in fact awarding too few earned time days based on specific infractions without regard to
the offender's compliance in the other five categories outlined in statute.
While earned time computations were being submitted to the Courts upon termination, they were not
being submitted via the statutorily required DCJ earned time computation form. Additionally, transition
offenders were being required to read and sign the diversion earned time policies even though time
credit procedures for DOC offenders are significantly different.
• 3-180 Systematic File Review—Partially Compliant
The majority of initial and final case file audits were present and timely. However, these audits
consisted of checklists used to document intake and termination processes. These checklists did not
include a complete review of all relevant Standards documentation as required.
• 3-190 Self-Audits of Operations and Programming—Partially Compliant
The program has a process for documented auditing of all required areas, except sign-out logs. Some
audit processes do not address all elements of a particular Standard. For instance, off-site monitoring
audits review for compliance with weekly requirements, but not monthly compliance. Similarly, audits
of BAs and pat searches look for one per calendar week while the Standard requires one every 7 days.
REQUIRED CORRECTIVE ACTION No. 2:
ICCS-Weld must improve internal controls by:
A. Revising policies and procedures to ensure they address all Standards requirements and instruct staff
as to how to complete required tasks.
B. Developing processes to ensure that all information reported in CCIB is accurate.
C. Ensuring that earned time credits are awarded in accordance with statute, noting the changes made to
earned time statutes via Senate Bill 11-254.
D. Ensuring all internal auditing is conducted and documented in accordance with Standards.
RECOMMENDATION
Program administration should change disciplinary processes to reflect the appropriate use of sanctions
with minor offenses. Disciplinary policies should be reviewed to ensure that legitimate situations which •
are outside of the control of the offender are not counted as violations. Additionally, grievance procedures
should be modified to acknowledge the offenders' perspective and valid grievances.
9
Colorado Community Corrections Standards
Section 4-000
Security Standards
Whereabouts Monitoring Standards
• 4-160 Random Off-Site Monitoring—Partially Compliant
Of the 37 months reviewed, 95% (35) had the required two work verifications and 95% (35) had the
required two pass verifications. Of the 175 weeks reviewed, 89% (156) met the requirement that each
offender be monitored at least once each week. The average of these three percentages results in an
overall compliance score of 93%.
Many of the reviewed case files reflected that the program could not confirm that offenders were at
their prescribed locations (i.e., negative monitors). Frequently, no evidence of follow-up to explain
these discrepancies could be found in the files, raising the possibility that the true locations of some
offenders were unknown for several hours at a time.
Monitor documentation is insufficient as it does not include the specific location at which the offender
was monitored or the method by which the monitor was conducted.
• 4-161 Job Search Accountability—Compliant
• ICCS-Weld was doing an excellent job of conducting daily job search verifications long before the
implementation of the revised Standards. Shortly after the implementation of the revised Standards,
ICCS-Weld also began documenting proof of contact. However, documentation of proof of contact was
somewhat inconsistent in the files reviewed. Additionally,job search locations were generally not pre-
approved by program staff as required. Program policies and procedures had not yet been revised in
accordance with the requirements of the 2010 Standards.
• 4-171 Furloughs—Noncompliant
Across the 12 furloughs reviewed the program conducted a total of 22 verifications, though a minimum
of 36 were required. The program appeared to require that offenders do a physical check-in at the
facility once or twice during any furlough. A total of 17 check-ins occurred during the 12 furloughs. If
you include these check-ins as furlough monitors, 17 gaps were found that exceeded the twelve hour
mark. Those gaps exceeding twelve hours were on average 16 hours and 20 minutes long (excluding
offender check-ins, gaps averaged 20 hours and 14 minutes long).
While visual contact with the offender has value, the brief offender check-ins at the facility were not
staff initiated and did not negate the program's responsibility for verifying the offender while in the
community. Additionally, verifications were not sufficiently random as 20 of the 22 verifications were
conducted between approximately 12:00 AM and 2:00 AM.
• 4-200 Random Headcounts—Partially Compliant
ICCS-Weld conducted headcounts every two hours and therefore counts were quite predictable.
Headcount documentation did not include offenders'expected return time.
10
•
REQUIRED CORRECTIVE ACTION No.3: •
ICCS-Weld must improve offender-monitoring practices by:
A. Modifying the information documented related to off-site monitors in compliance with Standards.
B. Conducting appropriate inquiries and thoroughly documenting explanations when an offender cannot
be confirmed at their prescribed location.
C. Implementing new policies and procedures to ensure pre-approval of offender job search locations
and the consistent provision of proof of contact in accordance with the Colorado Community
Corrections Standards(2010).
D. Significantly increasing oversight and internal auditing of furlough monitoring activities to ensure
compliance with frequency requirements.
E. More effectively randomizing the timing of offender headcounts and ensuring documentation of
such counts is complete.
COMMENT& RECOMMENDATION
ICCS requires that offenders report to the security desk daily to inquire whether they are scheduled for a
"service" such as pat searches, UAs and/or BAs. Staff will then look up the offender in E*Trac and if a
service is scheduled, staff will conduct it. Staff rarely initiate services on their own. Instead they wait for
the offender to inquire. This creates two problems. First, if an offender misses a scheduled service, they
get written up for not inquiring about that service. Staff are not held accountable for failing to perform the
task. Second, offenders know exactly when they will be subject to a service, namely: whenever they ask
to be. Therefore offenders can easily hand off contraband prior to approaching security, knowing they
will not be searched until they specifically inquire about services. Alternatively, an offender may hold on
to the contraband and simply take the write up for failing to check-in with security. Similar issues arise
with UAs and BAs. If an offender knows that they cannot pass a urinalysis they can simply not check-in
with security and take the write up for missing a service, rather than risking the more severe consequences
of a positive UA. Staff will then reschedule the service for another day, and the process will begin again.
DCJ/OCC considers the performance of services such as contraband searches, UAs, BAs, etc. to be the
responsibility of program staff. If ICCS-Weld intends to continue the check-in practice discussed above, it
is imperative that policies also require the regular performance of staff initiated services. This check-in
process alone allows too much freedom for offenders to escape detection.
11
Colorado Community Corrections Standards
Section 6-000
Case Management Standards
Miscellaneous Documentation Standards
• 6-040 Release of Information —Partially Compliant(82%)
Eighteen of 22 (82%) files contained all required releases of information. Releases were missing for
external treatment providers and, in the case of sex offenders, polygraph examiners. Some information
intended to be released was inappropriate based on the role of the entity to which the information was
meant to be released.
REQUIRED CORRECTIVE ACTION No.4:
ICCS-Weld must ensure that releases of information are appropriate and completed for all appropriate
entities.
Assessment and Treatment Standards
• 6-100 Supervision Plan—Partially Compliant
• Twenty one of 22 master supervision plans were completed on time.
Fourteen of 22 offenders reviewed scored a 4a or higher on the TxRW. However, most offenders in the
sample were assigned a lesser level of substance abuse treatment (i.e. WOP) without corresponding
documentation discussing the reason for this inconsistency.
Many offenders were required to attend relapse prevention (appropriate for offenders in later stages of
change relative to their substance abuse treatment needs) prior to cognitive-behavioral substance abuse
treatment (designed for offenders in early stages of change relative to their substance abuse treatment
needs). Some offenders were only assigned relapse prevention, while others were assigned cognitive-
behavioral substance abuse treatment concurrent with relapse prevention.
• 6-110 Structured Progress Feedback—Compliant
All required monthly progress reports were present and timely. However at the time of the audit, ICCS-
Weld had not yet begun to develop a process that would meet the requirements or intent of the new
Structured Progress Feedback Standard.
REQUIRED CORRECTIVE ACTION No. 5:
To provide assessment and treatment of offenders in accordance with the Colorado Community
Corrections Standards, ICCS-Weld must:
•
12
A. Create individualized supervision plans that properly address assessed substance abuse treatment •
needs. The program should also reconsider the practice of assigning early-stage cognitive behavioral
therapy at the same time as relapse prevention.
B. Develop a process by which to provide offenders with monthly structured progress feedback in
accordance with the Colorado Community Corrections Standards(2010).
Offender Finance Standards
• 6-180 Offender Budget—Partially Compliant
ICCS-Weld created master budgets each time an offender's employment or pay changed. While most
expected budgets were found, often these budgets did not reflect fiscal realities. Specifically, often
budgets included expenses greater than earnings, leaving offenders with a negative balance for each
paycheck received.
Offenders periodically turned in withdrawal requests in order to pay toward expenses as necessary.
While program staff indicated that they checked these requests against master budgets to ensure
compliance, this review was not documented. Similarly staff indicated that they reviewed receipts to
ensure monies were used for their requested purpose, but this review also was not documented.
• 6-190 Financial Transactions—Partially Compliant
ICCS-Weld did not handout printed monthly financial statements. Instead, offenders had access to their •
account information at any time through the use of offender E*Trac kiosks. However, the design of the
detail ledger in E*Trac does not meet the requirements of the Standard(i.e. credits, debits and balances
for subsistence, restitution, in-house treatment and savings). As such, at times it was difficult to
decipher the financial information contained in E*Trac.
REQUIRED CORRECTIVE ACTION No. 6:
ICCS-Weld must improve its financial documentation and tracking process by:
A. Developing a budgeting process that includes realistic obligations and holds offenders accountable.
B. Ensuring that financial statements include credits, debits and balances for all relevant obligations.
M
13
►CCS-Weld Corrective Action Plan I
• C intervention
spr� community
1 Corrections
jServices
CORRECTIVE ACTION PLAN
STANDARD: 2-151 —Security Staff Education
All security staff shall have, at a minimum, a GED or high school diploma. Verification of
education shall be documented in personnel files.
FINDING: Partially Compliant(80%)
All personnel in the sample appeared to meet the education/experiential requirements.
However, personnel files often did not contain evidence that the education and/or
experience of the applicants had been verified by program management. Of the five security
personnel files reviewed, four were missing verification of education requirements. Of these
four,one was hired after the implementation of the new Standards requiring verification of
applicants' education. Therefore four of five files(80%) were compliant.
CONTROLS TO BE Every new security staff member will provide a copy of their GED or diploma for their
IMPLEMENTED: personnel file. Current security staff was required to provide copies of their GED or
diplomas to update all personnel files.
DATE FOR November 1, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Security Staff Supervisor(Eli Bueno), Administrative
.RESPONSIBLE: Coordinator(Denise Hehn)
STANDARD: 3-010 Policy and Procedure Manual
The program shall maintain a current policy and procedure manual, readily accessible to all
staff,that describes the purpose, philosophy, programs, services and operating procedures of
the program. The manual shall address all requirements, programs or services delineated by
these Standards. The program shall operate in accordance with this manual and all staff
shall be familiar with its contents. The manual shall be reviewed at least annually by the
governing authority or program administrator, and updated when necessary. The program
shall outline a system to ensure that changes in program policies and procedures are
reviewed prior to their implementation with any state agency or local community
corrections board that will be affected by the change.
FINDING: Partially Compliant
Most policies and procedures sampled were well written. However, some policies were
missing associated procedures, such as actual methods for conducting internal audits of
security related processes(sign-outs, headcounts, etc.). Some policies and procedures did
not address critical pieces of the relevant Standard(e.g., the job search accountability
policies and procedures do not require that locations be verified within two working days;
assessment policies do not require that the ASUS-R and TxRW be rescored when there is a
change in intensity of supervision or treatment due to new substance abuse; the supervision
plan policies do not require that staff document reasons why a plan varies from assessment-
identified needs). Additionally, the program did not yet have a policy developed addressing
the new Structured Progress Feedback Standard.
I
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 2
CONTROLS TO BE
IMPLEMENTED: The policies and procedures have been updated to include specific procedures for all staff to
da
follow regarding facility auditing and case manager requirements. Supplemental
documentation has been added to appropriate policies to provide further guidance for staff III
members. Policy and Procedures have been updated to reflect the modifications/additions of
the Standards. ICCS has developed a new policy addressing Structured Progress Feedback
that has incorporated the criminogenic needs,goals of the client, client strengths, conditions
of placement, as well as feedback from the client. The case manager supervisor will provide
in-service training to fully train staff on utilizing these feedback sessions to be beneficial for
the client and case manager.
DATE FOR November 1, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Security
RESPONSIBLE: Supervisor(Elisha Bueno)
STANDARD: 3-140-CCIB Compliance
The program is responsible for entering complete and accurate offender information into the
Community Corrections Information and Billing(CCIB) system. All data shall be entered in
accordance with contract and sub-contract requirements. Data must be entered into CCIB
within 5 weekdays (including holidays) of the offender's arrival at the facility. Offender
movements (e.g., jail, hospital, etc.) must be entered into CCIB within 5 weekdays
(including holidays) of the movement. The offender record must be terminated and
completed within 5 weekdays (including holidays) of the discharge date. Corrections to
offender records impacting bills already processed must be approved in writing by the
appropriate community corrections board and the DCJ Office of Community Corrections.
FINDING: Partially Compliant
Of the 21 Community Corrections Information and Billing records reviewed, mistakes wer
ill
found in ten. Data errors were found primarily in the areas of finances such as restitution,
earnings and subsistence.
CONTROLS TO BE During the termination audits, the auditor will thoroughly review the financial section for
IMPLEMENTED: accuracy. The auditor will then be required to sign off on the file acknowledging review of
the finances specifically. The case manager supervisor will provide additional in-service
training to the case managers to ensure that each one is calculating and reporting accurate
information in the financial section. Policy 346 has been updated with the file closeout
procedure regarding CCIB compliance.
DATE FOR November 1, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Manager Team Leader(Kim Brown), Case Managers
STANDARD: 3-160—Offender Time Credits
The program shall have written policies and procedures and established practices for the
calculation of time credit or sentence reduction for offenders in accordance with procedures
outlined by the Department of Corrections for Transition offenders, or as specified in
Colorado Revised Statutes, as amended, for directly-sentenced offenders. A current copy of
this calculation shall be maintained in the offender's individual case file.
FINDING: Partially Compliant
Program policies indicated that sentences outlined in months should be computed as 30 days
for each month. This would mean that at the end of each year, the sentence would be 5 days
short. Policies also did not address how the program intended to determine progress in the
five areas outlined by Statute or how many points will be awarded within each category.
Instead policy directs that the loss of earned time will be based on the class of any rule
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley, co 80631 fax: (970)584-2525
t
ICCS-Weld Corrective Action Plan 3
infractions received. Case file reviews demonstrated that the program was in fact awarding
• too few earned time days based on specific infractions without regard to the offender's
compliance in the other five categories outlined in statute.
While earned time computations were being submitted to the Courts upon termination, they
were not being submitted via the statutorily required DCJ earned time computation form.
Additionally, transition offenders were being required to read and sign the diversion earned
time policies even though time credit procedures for DOC offenders are significantly
different.
CONTROLS TO BE Clients who receive community corrections sentences in months will be calculated using 30
IMPLEMENTED: and 31 day months. Calculation of days will be reviewed during the intake case file review
to ensure the client will be serving their full sentence. Final sentence calculation will be
conducted by the program administrator before allowing the client to discharge his/her
sentence.
The Earned Time Guidelines have been updated to reflect the amount of days eligible to be
awarded to each category as described in Statute. The case manager supervisor will
complete an in-service training regarding awarding earned time. Disciplinary actions will
not be a sole reason for not granting earned time for a particular month. The case manager
will be required to document the reasons as to why earned time is being granted or not
granted. During the intake process, only Diversion clients will be explained the Earned
Time Guidelines and required to sign acknowledging ICCS' policy.
DATE FOR November t, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Managers
STANDARD: 3-180—Systematic File Review
All active individual offender case records shall be audited no earlier than 15 days after
admission, but within the first 45 days of admission. At a minimum,the records shall be
audited to assure all documentation required by Standards is present, including admission
documents, assessments, supervision plans and revisions and chronological notes, in the
appropriate order prescribed by agency policy and procedures. A similar audit of the file
shall be completed within 30 days after termination. Review shall be documented in each
case record.
FINDING: Partially Compliant
The majority of initial and final case file audits were present and timely. However,these
audits consisted of checklists used to document intake and termination processes. These
checklists did not include a complete review of all relevant Standards documentation as
required.
CONTROLS TO BE The case manager supervisor and team leader are responsible for the initial and final case
IMPLEMENTED: file audits. An updated audit form has been generated to ensure that cases are being audited
within set timeframes as well as to ensure complete review of all Standards. Policy 346 has
been updated to reflect the final case file audit as well as CCIB compliance.
In the initial audit, the paperwork as well as Etrac information is verified. This audit ensures
that all of the necessary referral and intake paperwork is present.
The final case file audit verifies that all ICCS procedures have been met as well as all
. paperwork present. A final file document order is filled out as part of the process to ensure
all relevant documentation is in the file. CCIB is a large component of the final case file
audit.
DATE FOR November 1, 2011
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley,co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 4
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Manager Team Leader(Kim Brown)
STANDARD: 3-190-Self-Audits of Operations and Programming
The program shall have written policies and procedures that provide for a well-documented
system of regular internal auditing and self-monitoring of operations and programming. The
following functions shall have a documented review or audit by program staff at least once
per month:
(a) Drug and alcohol testing systems
(b) Sign-in/out records
(c)Off-site monitoring records
(d)Contraband inspections and storage
(e) Headcounts
Audit documentation for each of these functions shall be maintained by the program.
The audit documentation shall include recommendations by staff auditor(s) for
enhancements and/or modifications to existing program policies, procedures, and practices
based on internal audit outcomes to ensure compliance with Standards.
FINDING: Partially Compliant
The program has a process for documented auditing of all required areas, except sign-out
logs. Some audit processes do not address all elements of a particular Standard. For
instance, off-site monitoring audits review for compliance with weekly requirements, but
not monthly compliance. Similarly, audits of BAs and pat searches look for one per calendaa
week while the Standard requires one every 7 days.
CONTROLS TO BE The internal audits regarding client services have been updated to ensure that ICCS is
IMPLEMENTED: meeting Standards in regard to specific timeframes for services. Graveyard staff will base
audits on compliance of ICCS Policy and Procedure while maintaining the timeframes
determined within specific Standards. All audits conducted by graveyard security staff are
reviewed by the security supervisor.
The security supervisor is responsible for monitoring sign-out logs to ensure security staff
are signing out residents appropriately. Appropriate sign-out procedures include monitoring
time allotted for pleasure pass [no one can sign out of the facility for more than 16 hours a
day(unless a furlough)] and monitor sign-outs before or after the established curfew times.
The case manager supervisor is responsible for monitoring sign-out logs to ensure case
management is approving appropriate passes. Appropriate passes would be time-limited as
well as limiting the frequency of business or pleasure passes that are to places of business,
and to ensure that the client is eligible for the passes or pass time being taken.
Sign-out logs will be audited on a weekly basis with randomly selected residents. The
reviews will be documented and signed off by each supervisor. Any negative findings in the
self audits will reported to the specific staff member for immediate correction.
DATE FOR November I, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Security Staff Supervisor(Elisha Bueno), Case Manager
RESPONSIBLE: Supervisor(Mark Roberts), Security Staff, Case Managers
STANDARD: 4-160—Random Off-Site Monitoring •
The program shall have written policies and procedures that provide for the random
intervention community corrections services
phone: (970)584-2520 1101 h st.greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 5
monitoring of each residential offender's off-site location. Offenders shall be randomly
• monitored at least once in each calendar week, exclusive of job search and furlough
monitoring. The offender's off-site location shall be monitored with at least two(2)work
and two(2) pass verifications each month. Monitors shall occur while the offender is signed
out to the monitored location unless otherwise specified below.
Acceptable monitoring methods include the following:
(a) Personal contact;
(b) Staff initiated telephone contact with the offender, a known supervisor, treatment
provider or other approved person;
(c) Staff initiated monitors via active GPS enabled ankle monitors;
(d) Staff initiated monitors via active GPS enabled cellular phones including verification of
the offender's voice;
(e) For those locations without reasonable use of a telephone, pagers may be used. Upon
being paged, offenders must immediately contact program staff and staff must verify the
offender's location via caller ID;
(1)Any document that can be easily verifiable as connected to a specific offender and issued
by a person of authority such as medical personnel, government agencies, legal
representatives,etc. Documents must include a legible date and time, and must be provided
to program staff immediately upon return to the facility.
All monitoring documentation shall include the monitoring method,time of the monitor,
date, offender location, signature of the staff, and results of the verification.
All negative monitors shall result in continued documented efforts to contact the offender
•
until such time that the offender's whereabouts are determined or escape procedures are
initiated.
FINDING: Partially Compliant
Of the 37 months reviewed,95%(35) had the required two work verifications and 95% (35)
had the required two pass verifications. Of the 175 weeks reviewed, 89%(156) met the
requirement that each offender be monitored at least once each week. The average of these
three percentages results in an overall compliance score of 93%.
Many of the reviewed case files reflected that the program could not confirm that offenders
were at their prescribed locations (i.e., negative monitors). Frequently, no evidence of
follow-up to explain these discrepancies could be found in the files, raising the possibility
that the true locations of some offenders were unknown for several hours at a time.
Monitor documentation is insufficient as it does not include the specific location at which
the offender was monitored or the method by which the monitor was conducted.
CONTROLS TO BE When conducting off-site verifications, staff will follow-up on all negative verifications. If
IMPLEMENTED: staff is required to leave a message, then staff will continue to try and reach an actual person
in 15 minute intervals. Staff will call emergency contacts, pass list locations,the jail, and/or
hospital to verify with others the resident's possible whereabouts. Should staff not be able to
locate a resident, then the resident will be placed on escape status after two hours of his/her
last contact with staff. All additional attempts at verifications will be documented in Etrac
as unscheduled events. ICCS Policy and Procedures#420 and#430 have been updated to
reflect this finding.
. Security staff has been instructed to document the location, phone number, person, and type
of verification for each off-site verification. All negative and positive verifications will be
documented in Etrac.
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 6
DATE FOR May 19, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Security Supervisor(Elisha Bueno), Security Specialis
RESPONSIBLE:
STANDARD: 4-171 -Furloughs
The program shall have written policies and procedures that govern the practice of issuing
all furloughs whenever the absence exceeds 12 hours exclusive of work passes.
While on furlough, the offender's location will be regularly verified with gaps not to exceed
12 hours. Verifications shall be staff-initiated contact with the offender. Documentation of
verifications shall include offender name, method of verification, date, time, location and
staff signature.
FINDING: Noncompliant
Across the 12 furloughs reviewed the program conducted a total of 22 verifications,though
a minimum of 36 were required. The program appeared to require that offenders do a
physical check-in at the facility once or twice during any furlough. A total of 17 check-ins
occurred during the 12 furloughs. If you include these check-ins as furlough monitors, 17
gaps were found that exceeded the twelve hour mark. Those gaps exceeding twelve hours
were on average 16 hours and 20 minutes long(excluding offender check-ins, gaps
averaged 20 hours and 14 minutes long).
While visual contact with the offender has value, the brief offender check-ins at the facility
were not staff initiated and did not negate the program's responsibility for verifying the
offender while in the community. Additionally, verifications were not sufficiently random
as 20 of the 22 verifications were conducted between approximately 12:00 AM and 2:00
AM. •CONTROLS TO BE For furlough passes, Policy 420 has been updated to address furlough verifications.
IMPLEMENTED: Residents signing out of the facility on a furlough pass, will be monitored at least one time
each shift. Day shift will conduct furlough monitors between 8:00 a.m. and 4:00 p.m.,
swing shift will conduct furlough monitors between 4:00 p.m. and 12:00 a.m., and
graveyard shift will conduct furlough monitors between 12:00 a.m. and 8:00 a.m. At the
beginning of each shift, the security shift lead or designee will generate a report in E*Trac
for"Completed Events", specific to"Furlough Verification." Times of completed Furlough
Verifications will be noted and repeated within 12 hours of the previous shifts verification.
The graveyard shift will audit the required monitors once per week and file the audit report
to the security supervisor.
DATE FOR May 19, 2011
IMPLEMENTATION: y
INDIVIDUALS Program Director(Dionne Grinde), Security Supervisor(Elisha Bueno), Security Specialists
RESPONSIBLE:
STANDARD: 4-200—Random Headcounts
There shall be at least 4 random headcounts conducted during each 8-hour period at
residential programs, during which each offender's physical presence or itinerary will be
observed. A record shall be made of the time and date of such counts and signed by the staff
member conducting the count. The expected return time of offenders off facility grounds at
the time of the count shall be included in headcount documentation.
FINDING: Partially Compliant
ICCS-Weld conducted headcounts every two hours and therefore counts were quite
predictable.
Headcount documentation did not include offenders' expected return time.
CONTROLS TO BE The facility head counts have been updated to reflect the expected return time of clients who
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 7
IMPLEMENTED: are signed out of the facility. Security staff has been informed to randomize their head ill counts within their specific shifts. This is to reduce the amount of predictability of head
counts. Security staff will increase their presence by walking around the facility between
head counts. The security supervisor or designee will audit the counts on a weekly basis to
verify that staff is conducting head counts at different times each night in addition to
meeting the minimum number of head counts.
DATE FOR November 1, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Security Supervisor(Elisha Bueno), Security Specialists
RESPONSIBLE:
STANDARD: 6-040—Release of Information
The program shall have written policies and procedures that govern the release of
information to third parties. The program's "Release of Information Form" shall address
circumstances under which releases are permitted and restrictions on the type of information
to be released. Staff and agents of the program shall have clear instructions on the release of
information to third parties.
The structure and identification of information to be placed on the form must include, but is
not
limited to:
(a)Name of person, agency or organization requesting information
(b)Name of person, agency or organization releasing information
(c)The specific information to be disclosed
(d)The purpose or need for the information
• (e) Expiration date
(t) Date consent form is signed
(g) Signature of the offender
(h) Signature of individual witnessing offender's signature
Copies of the consent form shall be maintained in the offender's file.
FINDING: Partially Compliant(82%)
Eighteen of 22(82%)files contained all required releases of information. Releases were
missing for external treatment providers and, in the case of sex offenders, polygraph
examiners. Some information intended to be released was inappropriate based on the role of
the entity to which the information was meant to be released.
CONTROLS TO BE Case managers working with offense specific cases are having clients sign releases of
IMPLEMENTED: information for the polygraph examiners. All files for offense specific clients have been
updated to include of a release for the polygrapher.
Case managers are reviewing the releases of information to ensure only appropriate
information is being released/requested regarding the client. Release of Information will be
updated if additional information is needed that was not necessary at the time of the initial
release.
DATE FOR February 1, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Managers
t STANDARD: 6-100—Supervision Plan
Case managers shall formulate a personalized supervision plan for each offender that
specifies supervision approaches. The case manager and the offender shall plan the
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 8
interventions targeted to address particular criminogenic needs and referral agency
treatment requests. Supervision plans shall include measurable criteria of expected positive
behavior and accomplishments and a time schedule for achievement. Both residential and
non residential original supervision plans shall be completed, signed, and dated by both theill
case manager and the offender within 15 working days of the offender's program entry date.
The supervision plan must be tied to the Standardized Offender Assessment - Revised
(SOA-R)and to evaluation outcome. The recommended type of supervision plan is a
problem-oriented format that separately identifies each of:
(a) The offender's key behavioral problems
(b) Short-range behavioral objectives that address the above problem
(c) Specific steps the offender needs to take in the immediate future to accomplish the
established objectives
(d)The specific steps the case manager will take to assist and/or hold the offender
accountable
for accomplishment of identified objectives
Staff must document reasons why supervision plans vary from identified needs.
Supervision plans shall be revised, if indicated, by case developments including, but not
limited to, a significant delay in treatment attendance and a change in treatment intensity
and/or treatment type. Any modifications to the supervision plan or expectations of the
offender shall be personally reviewed with the offender and a written record of the
modifications shall be made in the case record, and signed and dated by the offender and
case manager.
FINDING: Partially Compliant
Twenty one of 22 master supervision plans were completed on time. Fourteen of 22
offenders reviewed scored a 4a or higher on the TxRW. However, most offenders in the •
sample were assigned a lesser level of substance abuse treatment(i.e. WOP) without
corresponding documentation discussing the reason for this inconsistency. Many offenders
were required to attend relapse prevention (appropriate for offenders in later stages of
change relative to their substance abuse treatment needs)prior to cognitive-behavioral
substance abuse treatment(designed for offenders in early stages of change relative to their
substance abuse treatment needs). Some offenders were only assigned relapse prevention,
while others were assigned cognitive behavioral substance abuse treatment concurrent with
relapse prevention.
CONTROLS TO BE HB-1352 has recently been implemented that has greatly benefited clients in obtaining the
IMPLEMENTED: treatment level needed based on his/her initial scores. The case manager who is assigned to
the file will review all the requirements of the client's program and adjust treatment as
necessary. It is important that the client attends all treatment necessary(such as Domestic
Violence, Offense Specific,etc.) in addition to the substance abuse treatment. Case
managers will thoroughly document the reason as to why a client is not attending the
treatment level based on the initial score.
ICCS is collaborating with two treatment agencies in the Greeley area. After much
discussion with the agencies, we are working closer to ensure that clients are being referred
to the appropriate treatment. Strategies for Self Improvement and Change (SSIC) is
provided only by one treatment provider while Relapse Prevention is provided by one
treatment provider. The cognitive behavioral classes at Creative Counseling do not have a
substance abuse component and are solely about criminal behaviors and thinking errors.
ICCS continues to teach both agencies what the SOA-R is and the requirements of the •
treatment levels.
DATE FOR November 1, 2011
intervention community corrections services
phone: (970)584-2520 1101 h st.greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 9
IMPLEMENTATION:01 INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Managers
STANDARD: 6-180—Offender Budget
As the offender receives funds (for example, earnings,gifts or tax refunds)the program
must assist the offender in developing a budget to distribute monies properly among
financial obligations.
Essential expenses shall be paid first and include:
(a)Court ordered child support
(b) Subsistence(rent)
(c)Treatment(group or individual treatment fees, polygraphs)
(d)Medical expenses(doctor appointments, medication)
(e)Transportation (bus tokens or passes, bicycle maintenance)
(f) Employment expenses(equipment and clothing)
The remainder of the offender's income after the"essential expenses"have been paid shall
be divided among the listed obligations by approximately the listed percentages:
(a)Restitution—40% (restitution and court costs)
(b) Savings—40%(for savings for independent living)
(c) Personal expenses—20% (leisure, family, clothing)
• The program shall document justification for exceptions in the client's budget. The written
budget shall be signed and dated by the offender and case manager and maintained in the
case record. To ensure offender accountability, receipts and bank statements must be
reviewed by program staff as necessary.
FINDING: Partially Compliant
ICCS-Weld created master budgets each time an offender's employment or pay changed.
While most expected budgets were found, often these budgets did not reflect fiscal realities.
Specifically, often budgets included expenses greater than earnings, leaving offenders with
a negative balance for each paycheck received.
Offenders periodically turned in withdrawal requests in order to pay toward expenses as
necessary. While program staff indicated that they checked these requests against master
budgets to ensure compliance,this review was not documented. Similarly staff indicated
that they reviewed receipts to ensure monies were used for their requested purpose, but this
review also was not documented.
CONTROLS TO BE Case managers have been generating two separate budgets that demonstrate what their
IMPLEMENTED: income will provide for as well as what the client needs to be earning in order to cover the
essential costs. This helps show the client what the income is going towards and how much
extra they are putting into savings each month.
The client's request for monies is matched with their budget(based on actual income). If the
request is approved,the client is required to show receipt of the check. The case manager
will initial next to the withdrawal request to acknowledge review of the receipt. During the
case manager meeting, case managers are documenting thorough notes in the budget section
as to the budget and requests. The case manager reviews all pay stubs and modifies the
budget as needed.
DATE FOR November 1, 2011
IMPLEMENTATION:
intervention community corrections services
phone: (970)584-2520 1101 h st.greeley, co 80631 fax: (970)584-2525
ICCS-Weld Corrective Action Plan 10
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Managers •
STANDARD: 6-190—Financial Transactions
The program shall have policies and procedures and established practices for the individual
recording of financial transactions related to placement in the program(such as earnings,
taxes, court ordered child support, subsistence fees, restitution, fines, treatment fees and
savings). Monthly statements, signed and dated by the offender and staff, shall be provided
to each offender and shall include credits, debits and balances for the following obligations
(if applicable): subsistence, restitution, treatment fees paid to the program and savings held
by the program. A final financial statement shall be provided to the offender upon
successful termination. A copy shall be maintained in the offender's case record. Receipts
for monies collected by the program shall be provided to the offender.
FINDING: Partially Compliant
ICCS-Weld did not handout printed monthly financial statements. Instead, offenders had
access to their account information at any time through the use of offender E*Trac kiosks.
However,the design of the detail ledger in E*Trac does not meet the requirements of the
Standard(i.e. credits,debits and balances for subsistence, restitution, in-house treatment
and savings). As such,at times it was difficult to decipher the financial information
contained in E*Trac.
CONTROLS TO BE The monthly case review has been updated to show the credits, debits,and balances for
IMPLEMENTED: restitution, subsistence,treatment, income, and savings for each month.The case review
also shows the client how much as been paid to each of these categories during their
program. The case manager is providing clients with their detailed ledger during the
monthly review of their program. The client is informed upon entry that he/she may ask
their respective case manager for a print out of their account at any time. ICCS is working to
separate the detailed ledger to better distinguish between the categories listed above. A
program will need to be developed for E*trac.
DATE FOR November 1, 2011
IMPLEMENTATION:
INDIVIDUALS Program Director(Dionne Grinde), Case Manager Supervisor(Mark Roberts), Case
RESPONSIBLE: Managers, E*trac Programmer
•
intervention community corrections services
phone: (970)584-2520 1101 h st. greeley, co 80631 fax: (970)584-2525
Hello