BSCC
Ventura County Probation Inspection Rpt (2023-2024 inspection cycle)
Read the report at Ventura County Probation Inspection Rpt ↗
July 18, 2023
Gina Johnson, Chief Probation Officer
Ventura County Probation Department
800 South Victoria Avenue
Ventura, California 93009
2023-2024 COMPREHENSIVE INSPECTION, WELFARE & INSTITUTIONS CODE
SECTIONS 209 & 885, VENTURA COUNTY PROBATION DEPARTMENT DETENTION
FACILITIES
Dear Chief Johnson:
The 2023-2024 Comprehensive Inspection of the Ventura County Probation
Administration Juvenile Facilities (VCPAJF) has been completed. A pre-inspection
briefing was held on Tuesday, February 28, 2023, and the following facilities were
inspected between Monday, July 10, 2023, and Thursday, July 13, 2023:
FACILITY NAME BSCC # FACILITY TYPE
Ventura County Detention Services 7727 JH
Ventura County Commitment Services 7728 CAMP
Ventura County SYTF - Detention 7740 SYTF
Ventura County SYTF - Commitment 7741 SYTF
These inspections were conducted pursuant to Welfare and Institutions Code Sections
209 and 885 to determine compliance with the Minimum Standards for Juvenile Detention
Facilities as outlined in Titles 15 and 24, California Code of Regulations. In addition, Board
of State and Community Corrections (BSCC) staff conducted compliance monitoring
pursuant to Welfare and Institutions Code Sections 209(f) and the federal Juvenile Justice
and Delinquency Prevention Act (JJDPA) requirements for separation between juveniles
and adults.
In addition to inspection(s), Title 15, Section 1313, and its authorizing statute require
annual inspections conducted by a local Health Officer, fire authority having jurisdiction,
county building inspection by an agency designated by the County Board of Supervisors,
County Superintendent of Schools, Juvenile Court, and Juvenile Justice Commission.
The results of those inspections are considered a part of this report.
INSPECTION RESULTS
We identified no items of noncompliance with Title 15 Minimum Standards. Refer to the
attached Title 15 Procedures Checklist for detailed information.
Gina Johnson, Chief Probation Officer
Page 2
No items of noncompliance were identified with Title 24 Minimum Standards. Refer to the
Physical Plant Evaluation (PHY) and Living Area Space Evaluation (LASE) attachments
for information related to Rated Capacity.
Juvenile Justice and Delinquency Prevention Act Compliance Monitoring
No violations of the JJDPA have been identified, and no areas of noncompliance were
noted.
An Exit Briefing with your staff was held on Thursday, July 13, 2023; BSCC staff
presented an inspection overview and discussed technical assistance and best practice
recommendations.
* * *
Please email me at elizabeth.gong@bscc.ca.gov or call (916) 704-2503 if you have any
questions.
Sincerely,
ELIZABETH GONG
Field Representative
Facilities Standards and Operations Division
Enclosures
Cc: Presiding Judge, Ventura County Juvenile Court*
Chair, Juvenile Justice Commission, Ventura County*
Chair, Board of Supervisors, Ventura County*
County Administrator, Ventura County*
Tim Dowler, Chief Deputy Probation Officer, VCPAJF
Carrie Vredenburg, Division Manager, VCPAJF
*Copies of the inspection are available upon request or online at www.bscc.ca.gov.
7727+ Ventura County Probation JH Camp SYTF LTR 23-24
JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7727
FACILITY NAME: Ventura County Probation Agency Juvenile Facility (VCPAJF) FACILITY TYPE: JH
Detention Services
PERSON(S) INTERVIEWED: Gina Johnson, Chief Probation Officer; Tim Dowler, Chief Deputy Probation Officer; Carrie
Vredenburg, Director – Juvenile Facility Programs; Sandy Carrillo, Director, Juvenile Operations; Rebecca Jimenez, Corrections
Service Officer (CSO) III; Chris Martinez, Supervising Deputy Probation Officer (SDPO); Lola Barnette, SDPO; Allysa Hyne,
SDPO; Justin Burdine, CSO III; Adrian Jimenez, CSO II; Chris Mullins, CSO II; Shirley Scott, Wellpath RN; Teresa Vega, Assistant
Principal Ventura County Office of Education; Stephanie Rodriguez, Director Ventura County Office of Education; Nicole Garr,
Counselor Ventura County Office of Education; Stacy Thompson, Ventura County Food Services Manager; Ana Magbitang,
Manager Ventura County Behavior Health; SYTF Youth - Alex, age 17; Joel, age 18, Brayleen, age 23; Jesus, age 22; Rogelio,
age 19; Detetnion - Landon, age 18; Frank, age 17; Axel, age 20.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: July 10-13, 2023
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1313 COUNTY INSPECTION AND EVALUATION
OF BUILDING AND GROUNDS 104.3.2 Required Local Inspections,
On an annual basis, or as otherwise required by law,
The following Inspections apply to the entire
each juvenile facility administrator shall obtain a
VCPAJF Physical Plant, including Detention,
documented inspection and evaluation from the ☒ ☐ ☐ Commitment, and SYTF.
following:
(a) county building inspector or person designated by the
November 1, 2021
Board of Supervisors to approve building safety;
April 11, 2023, 2022
(b) fire authority having jurisdiction, including a fire
clearance as required by Health and Safety Code
☒
☐ ☐ November 15, 2022
Section 13146.1(a) and (b); April 18, 2023
(c) local health officer, inspection in accordance with
Health and Safety Code Section 101045; 2022:
Environmental Health May 5, 2022
Medical/Mental Health December 3, 2021
☒ Nutritional Health April 15, 2022
☐ ☐
2023:
Environmental Health June 8, 2023
Medical/Mental Health November 29, 2022
Nutritional Health July 7, 2023
1 This document is intended for use as a tool during the inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally,
many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please
refer to the complete California Code of Regulations, Title 15, Minimum Standards for Local Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and
text of regulations.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(d) county superintendent of schools on the adequacy
of educational services and facilities as required in ☒ October 26, 2021
☐ ☐
Section 1370; December 7, 2022
(e) juvenile court as required by Section 209 of the
Welfare and Institutions Code; and, ☒ November 5, 2021
☐ ☐
March 14, 2023
(f) the Juvenile Justice Commission as required by
Section 229 of the Welfare and Institutions Code or ☒ December 7, 2021
☐ ☐
Probation Commission as required by Section 240 of the December 6, 2022
Welfare and Institutions Code.
1320 APPOINTMENT AND QUALIFICATIONS
100.1
BSCC Note: Compliance with this section is determined
by receipt of the Chief Probation Officer’s certification
The elements of this regulation are addressed
letter confirming that all elements of regulation are met. in a memorandum completed by Interim Chief
Probation Officer Gina Johnson dated June
20, 2023.
(a) Appointment ☒
☐ ☐
In each juvenile facility there shall be a superintendent,
director or facility manager in charge of its program and
employees. Such superintendent, director, facility
manager and other employees of the facility shall be
appointed by the facility administrator pursuant to
applicable provisions of law.
(b) Employee Qualifications
Each facility shall: 1200.3 Recruitment
(1) recruit and hire employees who possess
☒
☐ ☐
knowledge, skills and abilities appropriate to their job
classification and duties in accordance with
applicable civil service or merit system rules;
(2) require a medical evaluation and physical
examination including tuberculosis screening test
and evaluation for immunity to contagious illnesses ☒ 1200.4 (i) Medical and Psychological Exam
☐ ☐
of childhood (i.e., diphtheria, rubeola, rubella, and
mumps);
100.5 Correction Officer Responsibilities
(3) adhere to the minimum standards for the
302.1 Training Policy
selection and training requirements adopted by the
☒ 302.4 Minimum Training Requirements
Board pursuant to Section 6035 of the Penal Code; ☐ ☐
1200.7 Employment Standards
and
1200.7.1 Standards for Correction Officers
(4) conduct a criminal records review, on each new
employee, and psychological examination in
accordance with Section 1031 of the Government
☒
☐ ☐
1200.4 (g); 1200.71
Code.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(c) Contract personnel, volunteers, and other non-
employees of the facility, who may be present at the
305.2
facility, shall have such clearance and qualifications as
may be required by law, and their presence at the facility
☒
☐ ☐
305.3
shall be subject to the approval and control of the facility
These sections are related to clearance for
manager.
Volunteers/Interns and Support Personnel.
1321 STAFFING
Each juvenile facility shall: 211 Staffing Plan
(a) have an adequate number of personnel sufficient to
☒
carry out the overall facility operation and its ☐ ☐
programming, to provide for safety and security of youth
and staff, and meet established standards and
regulations;
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent 200.3 ⁋ 2 Supervision of Youth
exigent circumstances; 211.3.1 (a)
The facility roster of staff, including mandated
Deputy Probation Officers, and schedules for
all VCPAJF reflect compliance with
regulation. We reviewed staffing for February
and April 2023, as well as schedules leading
up to the on-site inspection, and found youth
are moved to a condensed living unit for the
☒
☐ ☐ purpose of sleeping to accommodate
coverage.
We have had discussions with the agency
and provided technical assistance to identify
the individual space as one 30-bed unit
rather than two 15-bed individual units. The
space would have significant day space for
programming youth in separate areas to
provide classification specific programming
or recreation.
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members;
☒ 211.3.1 (b)
☐ ☐
(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has
☒
211.3.1 (c)
completed the Juvenile Corrections Officer Core Course ☐ ☐
and PC 832 training;
(e) have at least one staff member present on each
living unit whenever there are youth in the living unit;
☒ 211.3.1 (e)
☐ ☐
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(f) have sufficient food service personnel relative to the
number and security of living units, including staff 900 Food Services
qualified and available to: plan menus meeting 900.3 Bullet 2
nutritional requirements of youth; provide kitchen
supervision; direct food preparation and servings; ☒
☐ ☐
conduct related training programs for culinary staff; and
maintain necessary records; or, a facility may serve food
that meets nutritional standards prepared by an outside
source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance,
200.5
transportation, control room, facility security and other
support staff for the efficient management of the facility,
and to ensure that youth supervision staff shall not be ☒
☐ ☐
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to
211.3.1 (f)
temporary variations in staff assignments to meet
☒
special program needs. Staffing shall be in compliance ☐ ☐
with a minimum youth-staff ratio for the following facility
types:
(1) Juvenile Halls
(A) during the hours that youth are awake, one 200.3 ⁋ 2
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
The agency has provided sufficient staffing
for the facility only due to mandated overtime
for the youth supervision staff (JCO’s), core
trained Deputy Probation Officers (DPO’s),
and non-core trained DPO’s who work side
by side with core trained staff. VCPAJF is in
their eleventh 40-hour orientation ‘class’ of
☒ the DPO classification to provide for the
☐ ☐
necessary coverage. Although the agency
meets required ratio per regulation, it is a
daily task for administrators to provide
coverage for call outs of scheduled staff.
We provided technical assistance and
referral information to better plan and audit
the call off coverage, noting this is a
statewide problem for juvenile facilities.
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(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for
☒
☐ ☐ 200.3 ⁋ 2
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an 200.3 ⁋ 3
☒
arrangement has been made for backup support ☐ ☐
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed ☒
☐ ☐
in the facility. 200.3 ⁋ 3
(E) personnel with primary responsibility for other
duties such as administration, supervision of 200.3.1
personnel, academic or trade instruction, clerical, ☒ 200.5
☐ ☐
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- ☐ This facility is not a Special Purpose Juvenile
☐ ☒
awake youth supervision staff member on duty for Hall.
each 10 youth in detention;
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
☐
awake youth supervision staff member on duty for ☐ ☒
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an
☐
arrangement has been made for backup support ☐ ☒
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one This facility is not a Camp.
☐ ☐ ☒
wide-awake youth supervision staff member on
duty for each 15 youth in the camp population;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth present in the facility;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in residence, unless
arrangements have been made for backup ☐ ☐ ☒
support services which allow for immediate
response to emergencies;
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be
given to the size, design, and location of the
camp; types of youth committed to the camp; and
☐ ☐ ☒
the function of the camp in determining the level
of supervision necessary to maintain the safety
and welfare of youth and staff;
(F) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
farm, forestry, kitchen or maintenance shall not
be classified as youth supervision staff positions.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1322 YOUTH SUPERVISION STAFF ORIENTATION
AND TRAINING
300.3 Youth Supervision Orientation
(a) Prior to assuming any responsibilities each youth
supervision staff member shall be properly oriented to 300.3 Bullet 6
their duties, including:
(1) youth supervision duties;
The VCPAJF provides new staff with a
comprehensive orientation and training
program, including a Five Phase process,
starting with a Phase 1, an initial Orientation
of 40 hours. Phase 2 includes Initial Policy
Training; Phase 3 includes Supervision of
Youth with Close Training by the assigned
Training Officer (TO); Phase 4 is Sole
Supervision with Monitoring by the TO and
an assigned mentor/trainer; Phase 5 is
Working Independently with Supervision by
the TO.
☒
☐ ☐
The training curriculum includes evaluation
of the Probationary staff of job skills and
learning progress, both of which are
documented at each Phase. A staff’s
competency is reviewed by facility
administrators prior to the staff receiving
permanent status with the agency.
Due to staffing shortages, the agency is
providing Phase 1 to the Deputy Probation
Officer staff, cored and non-cored, to provide
additional youth supervision.
Additionally, the agency provides a significant
annual staff training curriculum to ensure
competency continues.
(2) scope of decisions they shall make; ☒ 300.3 Bullet 13
☐ ☐
(3) the identity of their supervisor; ☒ 300.3 Bullet 8
☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(4) the identity of persons who are responsible to
them;
☒ 300.3 Bullet 13
☐ ☐
(5) persons to contact for decisions that are beyond
their responsibility; and
☒ 300.3 Bullet 13
☐ ☐
(6) ethical responsibilities.
☒ 300.3 Bullet 2
☐ ☐
(b) Prior to assuming any responsibility for the
supervision of youth, each youth supervision staff
302.5 Training
member shall receive a minimum of 40 hours of facility-
specific orientation, including:
☒ The agency’s Five Phased Training Program
☐ ☐ is a comprehensive effort by tenured facility
staff to ensure new youth supervision staff
are trained in all aspects required to
complete their responsibilities.
(1) individual and group supervision techniques; ☒ 300.3.1 Bullet 1
☐ ☐
(2) regulations and policies relating to discipline and 300.3.1 Bullet 2
rights of youth pursuant to law and the provisions of ☒ ☐ ☐ POC 02.J.1
this chapter;
(3) basic health, sanitation and safety measures; ☒ 300.3.1 Bullet 3
☐ ☐
(4) suicide prevention and response to suicide
☒ 300.3.1 Bullet 4
attempts ☐ ☐
(5) policies regarding use of force, de-escalation
techniques, chemical agents, mechanical and ☒ 300.3.1 Bullet 5
☐ ☐
physical restraints;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(6) review of policies and procedures referencing
☒ 300.3.1 Bullet 10
trauma and trauma-informed approaches; ☐ ☐
(7) procedures to follow in the event of
☒ 300.3.1 Bullet 6
emergencies; ☐ ☐
(8) routine security measures, including facility
☒ 300.3.1 Bullet 11
perimeter and grounds; ☐ ☐
(9) crisis intervention and mental health referrals to
☒ 300.3.1 Bullet 7
mental health services; ☐ ☐
(10) documentation; and ☒ 300.3.1 Bullet 8
☐ ☐
(11) fire/life safety training ☒ 300.3.1 Bullet 9
☐ ☐
(c) Prior to assuming sole supervision of youth, each
youth supervision staff member shall successfully
complete the requirements of the Juvenile Corrections ☒ 302.4 ⁋ 1
☐ ☐
Officer Core Course pursuant to Penal Code Section
6035.
(d) Prior to exercising the powers of a peace officer
youth supervision staff shall successfully complete
training pursuant to Section 830 et seq. of the Penal
☒
☐ ☐ 302.4 ⁋ 2
Code.
1323 FIRE AND LIFE SAFETY
103.5 Training
Whenever there is a youth in a juvenile facility, there
300.3.1 Bullet 9
shall be at least one wide awake person on duty at all ☒
☐ ☐
times who meets the training standards established by
the Board for general fire and life safety which relate
specifically to the facility.
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1324 POLICY AND PROCEDURES MANUAL
102 Policy and Procedures Manual
All facility administrators shall develop, publish, and
102.5 Distribution of Manual
implement a manual of written policies and procedures
103.2 Post Orders (Procedures)
that address, at a minimum, all regulations that are
applicable to the facility. Such a manual shall be made
The VCPAJF has adopted Lexipol Policy and
available to all employees, reviewed by all employees,
☒ Procedures (Post Orders) which include all
and shall be administratively reviewed at a minimum ☐ ☐
required elements in regulation while
every two years, and updated, as necessary. Those
allowing flexibility for changes or
records relating to the standards and requirements set
modifications as necessary.
forth in these regulations shall be accessible to the
Board on request.
The manual shall include:
(a) table of organization, including channels of
communications and a description of job classifications; 100 Organization Structure
100.3 (a) Supervising Probation Officer/
☒ Senior Responsibilities
☐ ☐
100.5 Correction Officer Responsibilities
1102.3 Communications
(b) responsibility of the probation department, purpose
of programs, relationship to the juvenile court, the
101.1 Responsibility and Scope of Juvenile
Juvenile Justice/Delinquency Prevention Commission
☒
Facility
or Probation Committee, probation staff, school ☐ ☐
personnel and other agencies that are involved in
juvenile facility programs;
(c) responsibilities of all employees;
☒ 102.3
☐ ☐
(d) initial orientation and training program for
employees;
☒ 300 Staff Orientation and Training
☐ ☐
(e) initial orientation, including safety and security issues
and anti-discrimination policies, for support staff, 300 Staff Orientation and Training
contract employees, school, mental/behavioral health 304 Health Care Orientation
and medical staff, program providers and volunteers;
☒
☐ ☐ 305 Volunteer and Intern Orientation and
Training
(f) maintenance of record-keeping, statistics and
communication system to ensure:
☒ 304.5
☐ ☐
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(1) efficient operation of the juvenile facility; ☒ 100.1 Purpose and Scope of the Facility
☐ ☐
(2) legal and proper care of youth; ☒ 100.7.2 Agency Responsibility
☐ ☐
(3) maintenance of individual youth's records; ☒ 205.3
☐ ☐
(4) supply of information to the juvenile court and
☒ 205.4
those authorized by the court or by the law; and, ☐ ☐
(5) release of information regarding youth. ☒ 205.4
☐ ☐
305.4 Volunteers/Interns
(g) ethical responsibilities; ☒ 1200.2 Recruitment
☐ ☐
1200.5 Background Check
1201.5.2 (g) Standards of Conduct
300.3.1 Bullet 10
512.4
706.4
1000.3 Programs and Education
(h) trauma-informed approaches; ☒
☐ ☐ The VCPAJF policy includes trauma and
trauma-informed approaches in each
element of facility operations, including
training and orientation of staff, admission,
classification, searches, healthcare, hygiene,
education, and programming.
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300.3.1 Bullet 10
500.1 Admission
1000.3 (m)
1002.6
1003.3 Education
(i) culturally responsive approaches; ☒
☐ ☐
The VCPAJF policy includes cultural
responses in each element of facility
operations, including training and orientation
of staff, admission, classification, hygiene,
education, and programming.
500.5
501.3
513 3; 513.4.3; 513.5; 513.10
605.2
701.6
802.6.1
1000.3 (b)
(j) gender responsive approaches; ☒
☐ ☐
The VCPAJF policy includes gender
responses in each element of facility
operations including training and orientation
of staff, admission, classification, searches,
healthcare, hygiene, education, and
programming.
(k) a non-discrimination provision that provides that all
youth within the facility shall have fair and equal access 605 Non-Discrimination Provision (NDP)
to all available services, placement, care, treatment, and 605.2
benefits, and provides that no person shall be subject to
discrimination or harassment on the basis of actual or
perceived race, ethnic group identification, ancestry, ☒
☐ ☐ The VCPAJF has the NDP posted in all living
national origin, immigration status, color, religion,
units and Intake.
gender, sexual orientation, gender identity, gender
expression, mental or physical disability, or HIV status,
including restrictive housing or classification decisions
based solely on any of the above mentioned categories;
(l) storage and maintenance requirements for any
chemical agents related security devices, and weapons 202 Inventory and Supplies
☒
and ammunition, where applicable; ☐ ☐ 209.3 (i) Weapons Storage
(m) establishment of procedures for collection of Medi-
Cal eligibility information and enrollment of eligible ☒ 500.5.4
☐ ☐
youth; and,
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(n) establishment of a policy that prohibits all forms of
sexual abuse, sexual assault and sexual harassment. 303 Sexual Abuse and Harassment Training
The policy shall include an approach to preventing, 501.6.1 Classification
detecting and responding to such conduct and any 502.4 (n) Orientation
☒
retaliation for reporting such conduct, as well as a ☐ ☐ 503.3 Assessments
provision for reporting such conduct by youth, staff or a 606.5 Grievances
third party. 701.4 (j) Screenings
1325 FIRE SAFETY PLAN
The facility administrator shall consult with the local fire 401 Fire Safety
department having jurisdiction over the facility, or with
the State Fire Marshal, in developing a plan for fire ☒ 401.3 (b)
☐ ☐
safety which shall include, but not be limited to:
(a) a fire prevention plan to be included as part of the
manual of policy and procedures;
(b) monthly fire and life safety inspections by facility
staff with two-year retention of the inspection record;
401.3 (c)
We reviewed Fire and Life Safety Inspections
for the VCPAJF from April 2022 to June 2023.
The agency has a systematic approach to the
inspection in every space of the facility,
recording any non-working or required
elements of space to confirm it is safe for
youth and staff.
☒
☐ ☐
The form includes: Fire Extinguishers, Fire
Alarms, First Aid Kits, Exit/Evacuation
Routes, Storage Areas, Electric/Lighting, Lint
Traps/Dryer Exhaust, Flashlights, Door
Locks, Cameras/Monitors, Panic Alarms,
Radios, Cell Phones, and AED’s. Each area
is checked by one of the CSO III’s. If there is
a required fix or referral to maintenance, it is
tracked by administration to ensure it is
addressed and remedied.
(c) fire prevention inspections as required by Health
and Safety Code Section 13146.1(a) and (b);
401.7
☒
☐ ☐
The last fire inspection for the VCPAJF was
completed on April 18, 2023.
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(d) an evacuation plan;
☒ 403 Evacuation Plan
☐ ☐
(e) documented fire drills not less than quarterly;
401.3 (e)
The agency completes Emergency Fire/
Earthquake or Emergency procedures Drills
monthly. We reviewed documentation for all
drills from April 2022 to June 2023. The
facility conducts monthly drills as a training
mechanism while walking through the facility
☒ to ensure staff individually know how to react
☐ ☐
given an emergency “training” drill.
Documented evacuation drills of youth by
unit occur quarterly, as required by
regulation.
We provided technical assistance to ensure
full evacuations of all youth, at least annually,
as required by VCPAJF Policy 403.4.
(f) a written plan for the emergency housing of youth in
the case of fire; and,
☒ 400.12
☐ ☐
(g) development of a fire suppression pre-plan in
cooperation with the local fire department.
☒ 401.3
☐ ☐
1326 SECURITY REVIEW
Each facility administrator shall develop policies and 209.3
procedures to annually review, evaluate, and document
security of the facility. The review and evaluation shall
include internal and external security, including, but not
limited to, key control, equipment, and staff training. ☒ Chief Probation Officer Gina Johnson
☐ ☐ completed a memo, outlining an
Administrative and Supervisor review of
Security practices was conducted on April
19, 2023, and May 30, 2023.
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1327 EMERGENCY PROCEDURES
The facility administrator shall develop facility-specific 400 Facility Emergencies
policies and procedures for emergencies that shall
include, but not be limited to:
Chief Probation Officer Gina Johnson
completed a memo, outlining an
Administrative and Supervisor review of
Emergency Procedures was conducted on
April 19, 2023, and May 30, 2023.
☒
☐ ☐
It was noted during the meetings several
Emergency Procedures need updating which
is being done now. The agency is compliant
and will forward any new policies or
operational procedures relating to this when
completed.
400.3 (a), (b) and (c)
400.7 Disturbances
(a) escape, disturbances, and the taking of hostages; ☒
☐ ☐ 400.8 Hostages
400.9 Escape
400.3 (d) and (i)
(b) civil disturbance, active shooter and terrorist
☒ 400.7 Disturbances
attack; ☐ ☐
400.6 Active Shooter and Terrorist Attack
400.3 (e)
(c) fire and natural disasters; ☒
☐ ☐ 401
400.3 (f)
(d) periodic testing of emergency equipment; ☒
☐ ☐ 402.5
400.3 (h)
(e) emergency evacuation of the facility; and ☒
☐ ☐ 403
(f) a program to provide all youth supervision staff
☒ 400.13
with an annual review of emergency procedures. ☐ ☐
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1328 SAFETY CHECKS
The facility administrator shall develop and implement 505.3 (a), (b) and (d)
policy and procedures that provide for direct visual
observation of youth at a minimum of every 15 minutes,
at random or varied intervals during hours when youth
We reviewed safety checks for the months of
are asleep or when youth are in their rooms, confined in
December 2022, January, and April 2023 for
holding cells or confined to their bed in a dormitory.
all occupied facility operational units. Overall,
Supervision is not replaced, but may be supplemented
the electronic checks are random, typically
by, an audio/visual electronic surveillance system
between 11 and 15 minutes, recording the
designed to detect overt, aggressive or assaultive
youth room and the total number of youths in
behavior and to summon aid in emergencies. All safety
☒ the unit.
checks shall be documented with the actual time the ☐ ☐
check is completed.
A CSO III now reviews safety checks for all
units, checking for late or missed checks, as
well as patterned checks. The agency had
very few late, missed or patterned checks.
The staff responsible and the circumstance is
recorded in the Supervisors Log to allow the
incident to be formally addressed.
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1329 SUICIDE PREVENTION PLAN
The facility administrator, in collaboration with the 706.4 Suicide Prevention Plan
healthcare and behavioral/mental health administrators,
shall plan and implement written policies and
procedures which delineate a Suicide Prevention Plan.
Youth are administered the MAYSI-2 upon
The plan shall consider the needs of youth experiencing
admission or whenever a significant event
past or current trauma. Suicide prevention responses
occurs while in custody. The assessment tool
shall be respectful and in the least invasive manner
identifies cautions or warnings for behavior
consistent with the level of suicide risk. The plan shall
involving suicidal ideation or tendencies. A
include the following elements:
Classification Questionnaire during booking
to determine appropriate housing and
supervision status also is responsive to this
regulation.
The agency has had three suicide incidents
that resulted in a safety room placement, two
involving one female youth from JH, since
April 2022. One female youth was
☒
transported to the Emergency Room. There
☐ ☐
have been other incidents of youth with a
caution or warning from the MAYSI
assessment, 13 total, that have been referred
to Behavior Health. Youth are placed on
special watch in these situations pending
being seen and/or evaluated by Behavior
Health.
We note Behavior Health has taken a much
more involved and consistent approach to all
intake, assessment, and crisis incidents,
observed by documented responses to
incidents since our last inspection. The
clinicians are proactive and engaged with the
processes and staff engagement for
successful treatment approaches to youth in
crisis.
(a) Suicide prevention training as required in Section
1322, Youth Supervision Staff Orientation, and Training 300.3.1 Bullet 4
and the Juvenile Corrections Officer Core Course.
☒
☐ ☐ 304.5 (e)
(b) Screening, Identification Assessment and
Precautionary Protocols 501.3 Bullet 8
☒
(1) All youth shall be screened for risk of suicide at ☐ ☐ 701.4 (c)
intake and as needed during detention.
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(2) All youth supervision staff who perform intake
processes shall be trained in screening youth for risk ☒
☐ ☐ 501.11 Staff Training in Classification
of suicide.
(3) All youth who have been identified during the
intake screening process to be at risk of suicide shall
☒
701.4 (c)(2)
be referred to behavioral/mental health staff for a ☐ ☐
suicide risk assessment.
(4) Precautionary protocols shall be developed to
ensure the youth’s safety pending the ☒
☐ ☐ 706.5
behavioral/mental health assessment.
(c) Referral process to behavioral/mental health staff for
assessment and/or services. 703.4 ⁋ 2
☒
☐ ☐ 706.3
(d) Procedures for monitoring of youth identified at risk
for suicide. 706.3
☒
☐ ☐ 706.5
(e) Safety Interventions
(1) Procedures to address intervention protocols for ☒
☐ ☐
youth identified at risk for suicide which may include,
but are not limited to:
(A) Housing consideration
☒ 501.3
☐ ☐
706.5 ⁋
1
(B) Treatment strategies including trauma-
informed approaches
☒ 706.4
☐ ☐
(2) Procedures to instruct youth supervision staff
how to respond to youth who exhibit suicidal
FPO.07.F, 6 Caution Status
behaviors.
☒
☐ ☐
FPO.07.F, 2
(f) Communication
(1) The intake process shall include communication
with the arresting officer and family guardians ☒ 701.4, C-1
☐ ☐
regarding the youth’s past or present suicidal
ideations, behaviors or attempts.
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(2) Procedures for clear and current information
sharing about youth at risk for suicide with youth
supervision, healthcare, and behavioral/mental 706.3 ⁋ 1
health staff. ☒ 706.8 ⁋ 1 and 2
☐ ☐
FPO.07.F, 2 (a)
(g) Debriefing of Critical Incidents Related to Suicides or
Attempts
(1) Process for administrative review of the ☒ 706.9 ⁋ 1 Debriefing
☐ ☐
circumstances and responses proceeding, during
and after the critical incident.
(2) Process for a debriefing event with affected
☒ 706.9 ⁋ 2
staff. ☐ ☐
(3) Process for a debriefing event with affected
youth.
☒ 706.9 ⁋ 2
☐ ☐
(h) Documentation
(1) Documentation processes shall be developed to 706.6 Observation Logs
ensure compliance with this regulation
☒
☐ ☐ 706.7 Documentation
Youth identified at risk for suicide shall not be denied the
opportunity to participate in facility programs, services 706.4 ⁋ 2
and activities which are available to other non-suicidal
youth, unless deemed necessary for the safety of the
☒
youth or security of the facility. Any deprivation of ☐ ☐
programs, services or activities for youth at risk of
suicide shall be documented and approved by the
facility manager.
1340 REPORTING OF LEGAL ACTIONS
101.5
Each facility shall submit to the Board a letter of
notification on each legal action, pertaining to conditions ☒
☐ ☐ There are no legal issues pending at the
of confinement, filed against persons or legal entities
VCPAJF.
responsible for juvenile facility operation.
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1341 DEATH AND SERIOUS ILLNESS OR INJURY
OF A YOUTH WHILE DETAINED 518.3 In Custody Death
518.3 ⁋ 3 In Custody Death Notifications
(1) Death of a Youth.
(a) The facility administrator, in cooperation with
the health administrator and the behavioral/mental
health director, shall develop written policies and
☒
☐ ☐
procedures in the event of the death of a youth while
detained, which include notifications to necessary
parties, which may include the Juvenile Court, the
parent, guardian or person standing in loco parentis
and the youth’s attorney of record.
(b) The health administrator, in cooperation with the
facility administrator, shall develop written policies
and procedures to assure there is a medical and 518.4 ⁋ 2
operational review of every in-custody death of a
youth. The review team shall include the facility ☒
☐ ☐
administrator and/or facility manager, the health
administrator, the responsible physician and other
health care and supervision staff who are relevant to
the incident.
(c) The administrator of the facility shall provide to
the Board a copy of the report submitted to the
Attorney General under Government Code Section ☒ 518.3 ⁋ 5
☐ ☐
12525. A copy of the report shall be submitted to the
Board within 10 calendar days after the death.
(d) Upon receipt of a report of the death of a youth
from the administrator, the Board may within 30
The facility administrators are aware of this
calendar days inspect and evaluate the juvenile
facility, jail, lockup or court holding facility pursuant to ☒ regulation.
☐ ☐
the provisions of this subchapter. Any inquiry made
by the Board shall be limited to the standards and
requirements set forth in these regulations.
(2) Serious Illness or Injury of Youth.
(a) The facility administrator, in cooperation with 700.3.1 (b)5
the health administrator, shall develop written
700.3.1 (b)14
policies and procedures for the notification to ☒
☐ ☐
necessary parties, which may include the Juvenile
700.3.1 (b)18 Responsibilities of the Health
Court, the parent, guardian or person standing in
Care Administrator (Illness)
loco parentis and the youth’s attorney of record in the
case of a serious illness or injury of a youth. 801.7 Youth Safety (Injury)
1342 POPULATION ACCOUNTING
Each juvenile facility shall submit required population and ☒ 1101.6.1
profile survey reports to the Board within 10 working days ☐ ☐
after the end of each reporting period, in a format to be
provided by the Board.
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1343 JUVENILE FACILITY CAPACITY (EXCERPT)
When the number of youth detained in a living unit of a 1101.3
juvenile facility exceeds its rated capacity for more than ☒
☐ ☐
fifteen (15) calendar days in a month, the facility
administrator shall provide a crowding report to the
Board in a format provided by the Board.
1350 ADMITTANCE PROCEDURES
The facility administrator shall develop and implement 500.1 Admission
written policies and procedures for admittance of youth
that emphasize respectful and humane engagement
with youth, and reflect that the admission process may
The VCPAJF has a comprehensive
be traumatic to youth who may have already
admission process and includes many
experienced trauma. Policies shall be trauma-informed,
advisements and assessments to assist in
culturally relevant, and responsive to the language and
determining appropriate classification.
literacy needs of youth. In addition to the requirements
These tools articulate detention criteria,
of Sections 1324 and 1430 of these regulations:
housing location, security status, suicidal
tendencies, and the propensity for violence
or victimization. The intake and booking
process provides information to acclimate
the youth to detention as well as orient the
youth to expectations, rights, and rules.
Staff complete a Juvenile Risk Assessment
Tool to determine if detention is appropriate,
with override and mitigation factors. If
☒ detained, the MAYSI-2 Questionnaire and
☐ ☐ Classification Assessment Questionnaire are
administered to assist in placement and any
security status needs. Youth then
acknowledge the Prison Rape Elimination
Act (PREA) policy as it relates to Sexual
Abuse, Harassment, and Assault. The Zero
Tolerance for Gang or Violence is also part of
the admission documents the youth signs to
acknowledge. Added this cycle is the Youth
Bill of Rights and Ombudsman information
provided through the Office of Youth and
Community Restoration.
We reviewed numerous intake and remand
Admission paperwork and documentation
outlining the procedures in policy and
regulation. We found the process is lengthy
and exceeds regulatory requirements to
make the best admission decisions.
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(a) the admittance process shall include:
(1) Access to two free phone calls within one hour of
☒
500.8
admittance in accordance with the provisions of ☐ ☐
Welfare and Institution Code Section 627;
(2) Offer of a shower; ☒ 500.9
☐ ☐
(3) Documented secure storage of personal
☒ 500.7.2
belongings; ☐ ☐
(4) Offer of food upon arrival; ☒ 500.5.5
☐ ☐
(5) Screening for physical and behavioral health
304.6 Initial Youth Screening
and safety issues, intellectual or developmental ☒
☐ ☐ 501.3 Bullet 10
disabilities;
(6) Screening for physical and developmental
disabilities in accordance with Sections 1329, 1413, ☒ 501.3 Bullet 10
☐ ☐
and 1430 of these regulations;
(7) Contact with Regional Center for the
Developmentally Disabled for youth that are
suspected of or identified as having a ☒ 702.7 Last Paragraph
☐ ☐
developmental disability, pursuant to Section 1413;
and,
501.12
(8) Procedures consistent with Section 1352.5. ☒
☐ ☐
802.6.1
(b) juvenile hall administrators shall establish written
criteria for detention that considers the least restrictive ☒
☐ ☐ 500.3 (h)
environment.
(c) juvenile camps and post-dispositional programs in
juvenile halls shall develop policies and procedures that
500.5.3
advise the youth of the estimated length of stay, inform
☒
them of program guidelines and provide written ☐ ☐
screening criteria for inclusion and exclusion from the
program.
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(d) juvenile halls shall develop policies and procedures
that advise any committed youth of the estimated length ☒
☐ ☐ 500.5.3
of his/her stay.
1350.5 SCREENING FOR THE RISK OF SEXUAL
ABUSE
501.3
The facility administrator shall develop and implement 701.4 (j) (1)
written policies and procedures to reduce the risk of
sexual abuse by or upon youth. The policy shall require ☒ The MAYSI-2 and Classification
☐ ☐
facility staff to assess each youth within 72 hours of Questionnaire are responsive to this
admission based on the following information: regulation. Youth also watch a PREA video
and read agency policies on how to report
sexual abuse, assault, or discrimination.
(a) Prior sexual victimization or abusiveness; ☒ 501.3 Bullet 19 and 21
☐ ☐
(b) Gender nonconforming appearance or manner; or
identification as lesbian, gay or bisexual, transgender,
☒
501.3 Bullet 20 and 24
queer or intersex, and whether the youth may, therefore, ☐ ☐
be vulnerable to sexual abuse;
(c) Current charges and offense history; 501.3 Bullet 4-6
☒ ☐ ☐
(d) Age; ☒ 501.3 Bullet 1
☐ ☐
(e) Level of emotional and cognitive development; ☒ 501.3 Bullet 7
☐ ☐
(f) Physical size and stature; ☒ 501.3 Bullet 3
☐ ☐
(g) Mental illness or mental disabilities; ☒ 501.3 Bullet 10 and 13
☐ ☐
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(h) Intellectual or developmental disabilities; ☒ 501.3 Bullet 14
☐ ☐
(i) Physical disabilities; ☒ 501.3 Bullet 12
☐ ☐
(j) The youth’s perception of vulnerability; and, ☒ 501.3 Bullet 22
☐ ☐
(k) Any other specific information about the individual
youth that may indicate heightened needs for
☒ 501.3 Bullets 1-24
supervision, additional safety precautions, or separation ☐ ☐
from certain other youth.
Staff shall ascertain this information through
conversations with the youth during the admittance
501.4
process, medical and behavioral health screenings;
☒
during classification assessments; and by reviewing ☐ ☐
court records, case files, facility behavioral records, and
other relevant documentation from the youth’s files.
The facility administrator shall implement appropriate
controls on the dissemination of information within the
501.3 Last Paragraph
facility relative to responses received pursuant to this
☒
assessment in order to ensure that sensitive information ☐ ☐
is not exploited to the youth’s detriment by staff or other
youth.
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1351 RELEASE PROCEDURES
The facility administrator shall develop and implement 516 Releases
written policies and procedures for release of youth from
custody which provide for:
The process for release from all VCPAJF
programs includes transition planning and
linkage to appropriate community services.
We were provided and reviewed the Ventura
County Community Resource List which
outlines available services in different
geographical areas of the county.
The agency identifies youth needing special
release services in the Multi-Disciplinary
☒
Team (MDT), Critical Care Team (CCT), and
☐ ☐
Treatment Team (TTM) meetings which
occur weekly. Participation includes
representatives from Behavior Health,
Medical, and the VCOE school personnel, as
well as CSO or DPO probation staff.
We reviewed the Release Form, which
includes the youth’s information at booking,
disposition, release authorization, and
signature and identification of the person the
youth is released to. Also included is
acknowledgment of property released to the
youth.
(a) verification of identity/release papers; ☒ 516.3 (a)
☐ ☐
516.3 (d)
(b) return of personal clothing and valuables; ☒
☐ ☐
(c) notification to the youth's parents or guardian; ☒ 516.3 (l)
☐ ☐
(d) notification to the facility health care provider in
accordance with Sections 1408 and 1437 of these ☒
☐ ☐ 516.3 (c) and (m)
regulations, for coordination with outside agencies; and,
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(e) notification of school staff; ☒ 516.3 (n)
☐ ☐
(f) notification of facility mental health personnel. ☒ 516.3 (m)
☐ ☐
The facility administrator shall develop and implement
policies and procedures for post-disposition youth to
516.3 (g) and (n)
coordinate the provision of transitional and reentry
☒
services including, but not limited to, medical and ☐ ☐
behavioral health, education, probation supervision and
community-based services.
The facility administrator shall develop and implement
written policies and procedures for the furlough of youth ☒
☐ ☐ 526.4
from custody.
1352 CLASSIFICATION
The facility administrator shall develop and implement 501 Classification
written policies and procedures on classification of youth
for the purpose of determining housing placement in the
facility.
The Classification Questionnaire used at
Such procedures shall: booking assists staff in determining the most
appropriate placement of youth at admission
and to address observed security or safety
needs of youth.
We reviewed admission documentation,
including this form, and found it to be
☒ consistent with regulation requirements and
☐ ☐ policy. Additionally, youth are re-classified
based on circumstances as they occur while
in the facility via the Critical Case Team
meetings. This is memorialized in the youth’s
electronic file, the Ventura County Integrated
Justice Information System.
It is significant to note the agency works with
medical and behavior health staff to assist in
special classification needs, as well as
reviewing the youth’s behavior which may
prompt a new classification.
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(a) provide for the safety of the youth, other youth,
facility staff, and the public by placing youth in the
501.7
appropriate, least restrictive housing and program
☒
settings. Housing assignments shall consider the need ☐ ☐
for single, double or dormitory assignment or location
within the dormitory;
(b) consider facility populations and physical design of
the facility;
☒ 501.8
☐ ☐
(c) provide that a youth shall be classified upon
admittance to the facility; classification factors shall
501.3
include, but not be limited to: age, maturity,
sophistication, emotional stability, program needs, legal ☒
☐ ☐
status, public safety considerations, medical/mental
health considerations, gender and gender identity of the
youth;
(d) provide for periodic classification reviews, including
provisions that consider the level of supervision and the
501.6.1 Periodic Reviews
youth's behavior while in custody; and,
501.6.2 Staff Initiated Reviews
☒ Classification status is reviewed by the CSO
☐ ☐ III, SDPO and/or the Watch Commander as
necessary to ensure youth are reintegrated
in the least restrictive classification as
necessary based on their security, medical,
or mental health status.
(e) provide that facility staff shall not separate youth from
the general population or assign youth to a single
occupancy room based solely on the youth's actual or 501.10.1 ⁋ 2 Non-Discrimination Provision
perceived race, ethnic group identification, ancestry,
605.2 ⁋ 1 Non-Discrimination Provision
national origin, color, religion, gender, sexual
orientation, gender identity, gender expression, mental ☒
☐ ☐
or physical disability, or HIV status. This section does
not prohibit staff from placing youth in a single
occupancy room at the youth's specific request or in
accordance with Title 15 regulations regarding
separation.
(f) facility staff shall not consider lesbian, gay, bisexual,
transgender, questioning or intersex identification or
status as an indicator of likelihood of being sexually
☒
☐ ☐ 501.10 ⁋ 3
abusive.
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1352.5 TRANSGENDER AND INTERSEX YOUTH.
The facility administrator shall develop written policies 501.12 Transgender and Intersex Youth
and procedures ensuring respectful and equitable ☒
☐ ☐
treatment of transgender and intersex youth. The 501.6.1 ⁋ 2
policies shall provide that:
(a) Facility staff shall respect every youth’s gender
identity and shall refer to the youth by the youth’s
501.12 I-A
preferred name and gender pronoun, regardless of the
youth’s legal name. Facilities may prohibit the use of ☒
☐ ☐
gang or slang names or names that otherwise
compromise facility operations as determined by the
facility manager or designee, and shall document any
decision made on this basis.
(b) Facility staff shall permit youth to dress and present
themselves in a manner consistent with their gender
☒ 501.12 I-B
identity and shall provide youth with the institution’s ☐ ☐
clothing and undergarments consistent with their gender
802.6.1 Clothing Issue
identity.
(c) Facility staff shall house youth in the unit or room that
best meets their individual needs and promotes their
500.6.2
safety and well-being. Staff may not automatically house
youth according to their external anatomy and shall
☒ 501.3 Bullet 9, 19-22
document the reasons for any decision to house youth ☐ ☐
in a unit that does not match their gender identity. In 501.12 I-C
making a housing decision, staff shall consider the
youth’s preferences, as well as any recommendations
from the youth’s health or behavioral health provider.
(d) Facility administrators shall ensure that transgender
and intersex youth have access to medical and
☒ 501.12 I-D
behavioral health providers qualified to provide care and ☐ ☐
treatment to transgender and intersex youth.
702.7 (f)
(e) Consistent with the facility’s reasonable and
necessary security considerations and physical plant,
501.12 I-E
facility staff shall make every effort to ensure the safety ☒
☐ ☐
and privacy of transgender and intersex youth when the
802.11 Showers
youth are using the bathroom or shower, or dressing or
undressing.
Facility staff shall not conduct physical searches of any
youth for the purpose of determining the youth’s
501.12 II-A and B
anatomical sex. Whenever feasible, the facility shall
☒
respect the youth’s preference regarding the gender of ☐ ☐
513.5
the staff member who conducts any search of the youth.
POC.04.F.3
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1353 ORIENTATION
The facility administrator shall develop and implement 502 Youth Orientation
written policies and procedures to orient a youth prior to 502.2
placement in a living area. Both written and verbal
information shall be provided and supplemented with The intake and booking process for all
video orientation if feasible. Provision shall be made to VCPAJF includes a review of facility
provide accessible orientation information to all detained operations, youth rights, and the rules that
youth including those with disabilities, limited literacy, or guide youth through the program. The
English language learners. Orientation shall include Orientation for each facility type includes all
information that addresses: aspects of programming and activities while
detained.
Facility expectations and opportunities are
explained in both verbal and written formats
☒
☐ ☐ to allow a youth to understand the material
while in-custody. The individual program is
outlined in a handbook to promote progress
through positive behavior to earn incentives.
We provided technical assistance to
consolidate the booking forms requiring
youth acknowledgment, relating to the
Ombudsman and Youth Bill of Rights, for a
more streamlined approach and training
opportunity for youth to better understand the
program expectations. The new Youth
Handbook is descriptive as it relates to all
Orientation components.
(a) facility rules including contraband and searches and
disciplinary procedures;
☒ 502.4 (a)
☐ ☐
(b) facility’s system of positive behavior interventions
and supports, including behavior expectations, 502.4 (b)
incentives that youth will receive for complying with ☒ 1009.3 (a) BMP
☐ ☐
facility rules, and consequences that may result when
youth violate the rules of the facility;
(c) age appropriate information that explains the
facility’s policy prohibiting sexual abuse and sexual 502.4 (n)
☒
harassment and how to report incidents or suspicions of ☐ ☐
sexual abuse or sexual harassment;
(d) identification of key staff and their roles;
502.4 (v)
☒
☐ ☐ 1208.7 (a)
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(e) the existence of the grievance procedure, the steps
that must be taken to use it, the youth’s right to be free 502.4 (e)
☒
of retaliation for reporting a grievance, and the name of ☐ ☐
the person or position designated to resolve the issue;
(f) access to legal services and information on the
☒ 502.4 (i)
court process; ☐ ☐
(g) access to routine and emergency health and mental
☒ 502.4 (f)
health care; ☐ ☐
(h) access to education, religious services, and
☒ 502.4 (g)
recreational activities; ☐ ☐
(i) housing assignments; ☒ 502.4 (h)
☐ ☐
(j) opportunity for personal hygiene and daily showers
including the availability of personal care items ☒ 502.4 (d)
☐ ☐
(k) rules and access to correspondence, visits and
telephone use; ☒ 502.4 (c)
☐ ☐
(l) availability of reading materials, programming, and
other activities; ☒ 502.4 (k)
☐ ☐
(m) facility policies on the use of force, use of restraints,
chemical agents and room confinement; ☒ 502.4 (l), (m) and (w)
☐ ☐
(n) immigration legal services; ☒ 502.4 (p)
☐ ☐
(o) emergencies including evacuation procedures; ☒ 502.4 (r)
☐ ☐
(p) non-discrimination policy and the right to be free from
physical, verbal or sexual abuse and harassment by 303.1 (g)
other youth and staff; ☒ 502.4 (n) and (u)
☐ ☐
603.1
(q) availability of services and programs in a language
other than English if appropriate;
☒ 502.4 Last 2 Paragraphs
☐ ☐
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(r) the process for requesting different housing,
education, programming and work assignments;
☒ 502.4 (x)
☐ ☐
(s) a process for which parents/guardians receive
information regarding the youth’s stay in the facility that
at a minimum includes answers to frequently asked ☒ 502.4 (y)
☐ ☐
questions and provides contact information for the
facility, medical, school and mental health; and,
(t) a process by which youth may request access to Title
15 Minimum Standards for Juvenile Facilities.
☒ 502.4 (z)
☐ ☐
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1354 SEPARATION
The facility administrator shall develop and implement 519 Youth Separation
written policies and procedures that address:
519 Second to last ⁋
500.6.2
The VCPAJF agency has a well-documented
practice of recording a youth’s request to
decline participation in unit programs and
activities. There has been some confusion
amongst staff for what is referred to as
‘decliners’ versus those that self-separate for
protective custody reasons.
We reviewed self-separation half sheets,
revealing the youth’s request for non-
participation in an activity or program,
including their signature detailing the reason.
☒
☐ ☐ These are short-term separations and are
well documented.
We also reviewed four incidents of long-term
self-separations that turned into a re-
classification. The incident report or youth’s
signed request to self-separate and notes
from Critical Case Meetings articulated
efforts by staff and/or Behavior Health to
reintegrate the youth. The case logs also
detail unit staff efforts to get a youth back into
programming. These long-term ‘separations’
are a classification the agency is working on
to facilitate needs and activities in an
environment where the youth feels safe to
engage in unit activities. We provided
technical assistance to encourage a ‘re-
branding’ for these youth that is positive-
focused.
(a) separation of youth for reasons that include, but are
not be limited to, medical and mental health conditions, 519 Medical Separation
assaultive behavior, disciplinary consequences and 519.3 Self Separation
protective custody. ☒ 501.7
☐ ☐
600.3.1
601.4
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(b) consideration of positive youth development and
trauma-informed care.
519 ⁋ 3
☒
☐ ☐
501.7.1 ⁋ 1
(c) separated youth shall not be denied normal
privileges available at the facility, except when
necessary to accomplish the objective of separation. 519 ⁋ 4
☒
☐ ☐
501.7.1 ⁋ 2
(d) when the objective of the separation is discipline,
Title 15 Section 1390 shall apply.
519 ⁋ 5
☒
☐ ☐
501.7.1 ⁋ 1
(e) when separation results in room confinement, the
separation shall occur in accordance with Welfare and
Institutions Code Section 208.3 and Section 1354.5 of ☒ ☐ ☐ 519 ⁋ 1
these regulations.
601 Room Confinement
(f) policies and procedures shall ensure a daily review
of separated youth to determine if separation remains
necessary. 519 Last ⁋
☒
☐ ☐
501.7.1 ⁋ 4
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1354.5 ROOM CONFINEMENT
(a) The facility administrator shall develop and 601 Room Confinement (RC)
implement written policies and procedures addressing
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
The VCPAJF agency reported 119 incidents
208.3. The placement of a youth in room confinement
of Room Confinement from April 2022 to
shall be accomplished in accordance with the following
June 2023. This is slightly more than the 50
guidelines:
in 2021, but less than the previous ‘time outs’
recorded in 2018-2019 before the regulation
and legislation were implemented.
After a safety and security-related incident,
staff initiated an RC Log which prompts them
to initiate specific documentation practices
and alerts to senior staff. Agency policy and
procedures include the staff recording
behavior and attempts to remove the youth
from RC status as soon as the threat is
minimized. When this happens, youth must
agree to respond with appropriate behaviors
in a contract format to document the
expectations when removed. In most cases,
the youth return to regular unit activities.
☒
☐ ☐
We reviewed 7 RC incidents and 10 UF
incidents resulting in RC, including 9 youth in
JH, and found the agency utilizes RC for
applicable behavior-related incidents that
pose a safety and security risk to other youth,
staff, or the facility operations.
Staff and supervisors provided appropriate
responses to reintegrate youth to
programming, including behavior health input
and involvement. Safety check logs and
behavior health intervention documentation
was included in the reviewed incidents.
The agency has adopted an early morning
review of youth on RC going into the
following day, in an effort to return the youth
to normal activities as the youth starts their
day.
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(1) Room confinement shall not be used before
other, less restrictive, options have been attempted
and exhausted, unless attempting those options ☒ 601.4 (a)
☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or ☒
☐ ☐ 601.4 (b)
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health ☒
☐ ☐ 601.4 (c)
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room
☒
601.4.5 (a)
confinement for a period of four hours, staff shall do one ☐ ☐
or more of the following:
(1) Return the youth to general population. ☒ 601.4.5 (a) (1)
☐ ☐
(2) Consult with mental health or medical staff. ☒ 601.4.5 (a) (2)
☐ ☐
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate ☒
☐ ☐ 601.4.5 (a) (3)
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following:
☒ 601.4.5 (b)
☐ ☐
(A) Document the reasons for room confinement
and the basis for the extension, the date and time
the youth was first placed in room confinement, ☒ 601.4.5 (b)(1)
☐ ☐
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to ☒
☐ ☐ 601.4.5 (b)(2)
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee ☒
☐ ☐ 601.4.5 (b)(3)
every four hours thereafter.
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(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth
☒
601.1.1
in juvenile facilities and does not apply to normal ☐ ☐
sleeping hours.
(6) This section does not apply to youth or wards in
court holding facilities or adult facilities.
☒
☐ ☐
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional ☒
☐ ☐ 102.2.1
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires 400 Facility Emergencies
a significant departure from normal institutional 400.3.1 Emergency Suspension of
operations, including a natural disaster or facility- Standards
☒
wide threat that poses an imminent and substantial ☐ ☐
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and
501.7.2
protect against the spread of a communicable
disease for the shortest amount of time required to
519 Medical Separation
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an ☒
☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1355 INSTITUTIONAL ASSESSMENT AND PLAN
The facility administrator shall develop and implement 503 Case Management
written policies and procedures for assessment and
case planning.
The VCPAJF agency has an operational
process to complete and update Institutional
Assessments and Plans originally done by
the field DPO with ongoing updates by the
assigned CSO. Documents included the
original case plan with identified risks and
needs and ongoing plans targeting service
delivery for the youth. Educational progress
from Providence School, case notes and
number of hours with Behavior Health
Services, and youth chrono notes from
facility staff all contribute to the overall plan
while the youth is detained.
☒
☐ ☐ The plans are completed by staff and
reviewed by supervisors. The plan
documents education, substance abuse,
aggression, anti-social environments, family,
impulsivity, remorse, and violence,
articulating a plan and discussion points for
each.
We reviewed 10 ongoing IAP’s and 8
Transitional MDTs for 18 youth and found
each had an individualized plan, including the
most significant areas to address with
targeted services. The plans are reviewed
every 30 days to show progress or to re-
direct services. They are individualized and
inclusive of chrono entry discussions with the
youth.
(a) Assessment:
The assessment is based on information collected
during the admission process with periodic review, 503.3 ⁋ 2
which includes the youth's risk factors, needs and
☒
strengths including, but not limited to, identification of ☐ ☐
substance abuse history, educational, vocational,
counseling, behavioral health, consideration of known
history of trauma, and family strengths and needs.
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(b) Institutional Case Plan:
(1) A case plan shall be developed for each youth
☒
503.3.1
held for at least 30 days or more and created within ☐ ☐
40 days of admission.
(2) The institutional plan shall include, but not be
limited to, written documentation that provides:
☒
☐ ☐
(A) objectives and time frame for the resolution of
problems identified in the assessment;
☒ 503.3.1 (c)
☐ ☐
(B) a plan for meeting the objectives that includes
a description of program resources needed and
☒
503.3.1 (b)
individuals responsible for assuring that the plan ☐ ☐
is implemented;
(3) periodic evaluation of progress towards meeting
the objectives, including periodic review and ☒
☐ ☐ 503.3.1 (c)
discussion of the plan with the youth;
(4) a transition plan, the contents of which shall be
subject to existing resources, shall be developed for 503.3.1
☒
post dispositional youth in accordance with Section ☐ ☐ 516.3; 516.5 (Releases)
1351; and,
(5) in as much as possible and if appropriate, the
plan, including the transition plan, shall be developed
with input from the family, supportive adults, youth, ☒ 503.3.1 (a)
☐ ☐
and Regional Center for the Developmentally
Disabled.
1356 COUNSELING AND CASEWORK SERVICES
503.5
The facility administrator shall develop and implement
703.3 Counseling Services
written policies and procedures ensuring the availability
POC.03.C, 1
of appropriate counseling and casework services for all
youth. Policies and procedures shall ensure:
The VCPAJF agency requires the assigned
CSO to meet with the youth weekly to ensure
☒ he or she is progressing as expected or to
☐ ☐
assist with any difficulty in the program.
We reviewed case Chronos and Critical Case
Team meeting notes which address any
noted positive or negative behaviors
displayed in the program.
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(a) youth will receive assistance with needs or concerns
that may arise;
703.3 (a)(1)
☒
☐ ☐
POC.03.C, 1(a)
(b) youth will receive assistance in requesting contact
with parents, other supportive adults, attorney, clergy,
703.3 (a)(2)
probation officer, or other public official; and,
☒
☐ ☐
POC.03.C, 1 (b)
(c) youth will be provided access to available resources
to meet the youth’s needs.
☒ 703.3 (a)(2)
☐ ☐
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1357 USE OF FORCE
511 Use of Force (UF)
The facility administrator, in cooperation with the
511.3 ⁋ 6
responsible physician, shall develop and implement
511.3.3 Health Care assistance in developing
written policies and procedures for the use of force,
policy
which may include chemical agents. Force shall never
301 Use of Force-Administration Manual
be applied as punishment, discipline, retaliation or
treatment.
There were 138 UF incidents from April 2022
(a) At a minimum, each facility shall develop policies and to June 2023; 95 included physical force and
procedures which: 93 included the use of OC Spray at the
VCPAJF. There were 97 UF incidents in 2022
and 130 UF in 2021. This is down
significantly from the 183 in 2019 and 178 in
2018.
We reviewed 15 UF incident reports and
found the agency documents the efforts to
use the least restrictive option when
available. Staff are required to include the
circumstances leading to the use of force and
☒ justify why force was used. The Supervisor
☐ ☐
on duty is also required to write a Use of
Force Report to include a summary of the
incident, Supervisor actions (including review
of video and interviews with involved staff),
and lastly, the Supervisors Evaluation, which
details the assessment of staff response and
critique of the staff actions.
Each month, the agency conducts a UF
Review with a committee consisting of the
Facility Managers, Supervisors, and staff
involved. All documentation and video
footage are presented so the committee can
determine if the incident was within policy.
The outcome for the Review Committee is: A
– Within Policy; B – Within Policy but training
identified; C – Staff actions referred to
Professional Standards Unit; and D – Other.
Each of the incidents we reviewed were
cleared by Administration as ‘Within Policy’.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 511.3 ⁋ 1
1302 to ensure the safety and security of youth, staff, ☒ 511.3.1 Factors to determine
☐ ☐
others and the facility. Reasonableness of Force.
(2) outline the force options available to staff
including both physical and non-physical options and 511.5
☒
define when those force options are appropriate. ☐ ☐ 511.5.1
FPO.08.F, 1
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(3) describe force options or techniques that are
expressly prohibited by the facility.
511.10 (l)
511.5.1 ⁋ 1 and 3
In policy, the only prohibited use of force is
the Carotid Hold. If time allows, the agency
☒
☐ ☐ operational procedure promotes a use of
force team approach to an incident, including
a supervisor, to determine how and what type
of force is appropriate given the
circumstances. This process allows for a
‘natural’ de-escalation and the use of the
least amount of force necessary.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative 511.3.2 Duty to Intervene
action to immediately stop it. ☒ 511.6
☐ ☐
511.6.1
(5) define a standardized reporting format that
includes time period and procedure for documenting
511.6 Reporting UF
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒
☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma
that may have been experienced by staff and /or the
youth involved.
(6) Include an administrative review and a system for
investigating unreasonable use of force. 511.9 UF Review
☒
☐ ☐ 511.91 UF Review Committee
(7) define the role, notification, and follow-up
procedures required after use of force incidents for 511.6.1 Notifications to Medical, Mental
medical, mental health staff and parents or legal ☒ Health and Parent
☐ ☐
guardians. 517.5
(8) describe the limitations of use of force on
pregnant youth in accordance with Penal Code
☒
512.9
Section 6030(f) and Welfare and Institutions Code ☐ ☐
Section 222.
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(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that:
(1) identify who is approved to carry and/or utilize ☒ 511.4 ⁋ 1 and 2
☐ ☐
chemical agents in the facility and the type, size and
the approved method of deployment for those
chemical agents.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or
☒ 511.4.1
the safety of others and only when de-escalation ☐ ☐
efforts have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents.
This shall include that youth who have been exposed 511.4 ⁋ 3 and 5
☒
to chemical agents shall not be left unattended until ☐ ☐
FPO.08.L, 2
that youth is fully decontaminated or is no longer
suffering the effects of the chemical agent. FPO.08.L, 4
(4) define the role, notification, and follow-up
procedures required after use of force incidents
☒
511.6.1 Notifications to Medical, Mental
involving chemical agents for medical, mental health ☐ ☐
Health and Parent
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for
511.6 (g)
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒
☐ ☐ FPO.08.I, 2
of use, decontamination procedures applied and
identification of any injuries sustained as a result of FPO.08. 4
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training
☒
300.3.1
in use of force and chemical agents when appropriate ☐ ☐
511.4
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
☒ 511.10 (i)
☐ ☐
(2) acceptable chemical agents and the methods of
application.
☒ 511.4 ⁋ 2
☐ ☐
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health.
☒
☐ ☐
511.10 (j)
(4) instruction on the Constitutional Limitations of
Use of Force.
☒ 511.10 (i)
☐ ☐
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(5) physical training force options that may require
the use of perishable skills. 511.3 ⁋ 2
☒
☐ ☐ 511.10
(6) timelines the facility uses to define regular
training. 300 Training
☒
☐ ☐ 511.10 Initial and Annual Training
1358 USE OF PHYSICAL RESTRAINTS
512. Use of Restraints (UR)
The facility administrator, in cooperation with the
301.8 Administration Manual
responsible physician and mental health director, shall
develop and implement written policies and procedures
There has been one use of restraint per this
for the use of restraint devices. Restraint devices
regulation since April 2022. The incident
include any devices which immobilize a youth's
involved a female youth in detention who
extremities and/or prevent the youth from being
exhibited self-harm behaviors. For her own
ambulatory.
☒ protection, the youth was placed in soft
☐ ☐
restraints for approximately 3 hours pending
transport to the hospital. During the time in
restraints, she was under constant
supervision of staff and medical personnel
while in the safety room.
This incident is the first UR since 2019.
Physical restraints may be used only for those youth
who present an immediate danger to themselves or 512.3 (c) and (e)
others, who exhibit behavior which results in the
destruction of property, or reveals the intent to cause
☒
self-inflicted physical harm. Physical restraints should ☐ ☐
be utilized only when it appears less restrictive
alternatives would be ineffective in controlling the
youth’s behavior.
In no case shall restraints be used as punishment or
discipline, or as a substitute for treatment. The use of 512.3 (g) and (l)
restraint devices that attach a youth to a wall, floor or 512.5 (a) 1
other fixture, including a restraint chair, or through 512.9 Pregnant Youth
affixing of hands and feet together behind the back ☒ 512.9.1
☐ ☐
(hogtying) is prohibited. The use of restraints on
pregnant youth is limited in accordance with Penal Code
Section 6030(f) and Welfare and Institutions Code
Section 222.
The provisions of this section do not apply to the use of
handcuffs, shackles or other restraint devices when 512.5 UR for Movement and Transportation
used to restrain youth for movement or transportation
☒
within the facility. Movement within the facility shall be ☐ ☐
governed by Section 1358.5, Use of Restraint Devices
for Movement Within the Facility.
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Youth shall be placed in restraints only with the approval
of the facility manager or designee. The facility manager 512.3 (d)
may delegate authority to place a youth in restraints to
☒
a physician. Reasons for continued retention in ☐ ☐
restraints shall be reviewed and documented at a
minimum of every hour.
A medical opinion on the safety of placement and
retention shall be secured as soon as possible, but no 512.3 (j)(1)
later than two hours from the time of placement. The ☒
☐ ☐
youth shall be medically cleared for continued retention
at least every three hours thereafter.
A mental health consultation shall be secured as soon
as possible, but in no case longer than four hours from 512.3 (j)(2)
☒
the time of placement, to assess the need for mental ☐ ☐
health treatment.
Continuous direct visual supervision shall be conducted
to ensure that the restraints are properly employed, and 512.3 (j)
to ensure the safety and well-being of the youth. 512.7 (e)
Observations of the youth's behavior and any staff ☒
☐ ☐
interventions shall be documented at least every 15
minutes, with actual time of the documentation
recorded.
In addition to the requirements above, policies and
procedures shall address: 512.7 Documentation
☒
☐ ☐
(a) documentation of the circumstances leading to an
application of restraints.
(b) known medical conditions that would contraindicate
certain restraint devices and/or techniques. 512.6 (k)
☒
☐ ☐ 512.10 (h)
(c) acceptable restraint devices.
☒ 512.10 (i)
☐ ☐
(d) signs or symptoms which should result in immediate
medical/mental health referral. ☒ 512.10 (j)
☐ ☐
(e) availability of cardiopulmonary resuscitation
equipment. ☒ 512.10 (k)
☐ ☐
(f) protective housing of restrained youth. While in
restraint devices, all youth shall be housed alone or in a 512.10 (d)
☒
specified housing area for restrained youth which makes ☐ ☐ 512.6 (d)
provision to protect the youth from abuse.
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(g) provision for hydration and sanitation needs. ☒ 512.3 (m)
☐ ☐
512.10 (l)
(h) exercising of extremities. ☒
☐ ☐ 512.6 (k)
1358.5 USE OF RESTRAINT DEVICES FOR
MOVEMENT AND TRANSPORTATION 512.4
WITHIN THE FACILITY. 512.5 UR for Movement and Transportation
The Facility Administrator, in cooperation with the
responsible physician and behavioral/mental health
☒
☐ ☐
director, shall develop and implement written policies
and procedures for the use of restraint devices when the
purpose is for movement or transportation within the
facility that shall include the following:
(a) identification of acceptable restraint devices, staff
approved to utilize restraint devices and the required ☒ 512.1
☐ ☐
training.
(b) the circumstances leading to the application of
restraints must be documented. ☒ 512.5 (a)(1)
☐ ☐
(c) an individual assessment of the need to apply
restraints for movement or transportation that includes 512.5 (b)(1)
consideration of less restrictive alternatives, 512.5 (c)(1)
consideration of a youth’s known medical or mental
health conditions, trauma informed approaches, and a The VCPAJF agency has been tracking the
process for documentation and supervisor review and UR as identified in this regulation since last
approval. ☒ cycle. Since April of 2022, there have been
☐ ☐
17 applications of restraints for movement.
Our review of the reports when restraints
were used provided sufficient justification.
From July 2020 to April 2022, 27 of the 57
reports reviewed included restraints as
defined in this regulation.
(d) consideration of safety and security of the facility,
with a clearly defined expectation that restraint devices 512.3 (g)
☒
shall not be used for the purposes of discipline or ☐ ☐
retaliation.
(e) the use of restraints on pregnant youth is limited in
accordance with Penal Code Section 6030(f) and ☒ 512.9
☐ ☐
Welfare and Institutions Code Section 222.
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1359 SAFETY ROOM PROCEDURES
506 Safety Rooms and Camera Rooms
(a) The facility administrator, and where applicable, in
506.3
cooperation with the responsible physician, shall
develop and implement written policies and procedures
There have been 3 safety room placements
governing the use of safety rooms, as described in Title
since April 2022, all involving self-harming
24, Part 2, Section 1230.1.13. The room shall be used
behavior. Two of the incidents were one
to hold only those youth who present an immediate
female youth in detention, who was actively
danger to themselves or others, who exhibit behavior
trying to harm herself while making suicidal
which results in the destruction of property, or reveals
statements. After the second incident, the
the intent to cause self-inflicted physical harm. A safety
agency was able to transport the youth to the
room shall not be used for punishment or discipline, or
hospital on a 5585 hold. The third incident
as a substitute for treatment. Policies and procedures
involved a different female youth hitting her
shall:
head against her room wall repeatedly. She
was transported to the safety cell for her own
protection pending transport to the hospital
☒
☐ ☐ for evaluation.
The amount of time in the safety cell was
monitored by Medical and Behavior Health
(Crisis Team) and was 2 hours and 47
minutes, 2 hours and 20 minutes, and 1 hour
and 56 minutes.
The agency complied with regulation and
policy for each incident and had multiple staff
and partners in close proximity during each
event.
Prior to the above, the agency has had no
safety cell placements since one in 2019 and
4 in 2018.
(1) include provisions for administration of necessary
nutrition and fluids, access to a toilet, and suitable ☒ 506.4 (e)
☐ ☐
clothing to provide for privacy;
(2) provide for approval of the facility manager, or
designee, before a youth is placed into a safety ☒ 506.4 (a)
☐ ☐
room;
(3) provide for continuous direct visual supervision
and documentation of the youth's behavior and any 506.4 (c)
☒
staff interventions every 15 minutes, with actual time ☐ ☐
recorded;
(4) provide that the youth shall be evaluated by the
facility manager, or designee, every four hours; ☒ 506.4 (g)
☐ ☐
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(5) provide for immediate medical assessment,
where appropriate, or an assessment at the next 506.4 (h)
daily sick call; and,
☒ The policy states the assessment shall take
☐ ☐
place no longer than 12 hours after
placement.
(6) provide a process for documenting the reason for
placement, including attempts to use less restrictive 506.4 (i)
☒
means of control, and decisions to continue and end ☐ ☐
placement.
(b) The placement of a youth in the safety room shall be
☒
accomplished in accordance with the following: ☐ ☐
(1) safety room shall not be used before other less
restrictive options have been attempted and 506.4 (j)
☒
exhausted, unless attempting those options poses a ☐ ☐
threat to the safety or security of any youth or staff.
(2) safety room shall not be used for the purposes of
punishment, coercion, convenience, or retaliation by ☒ 506.4 (l)
☐ ☐
staff.
(3) safety room shall not be used to the extent that it
compromises the mental and physical health of the ☒ 506.4 (l)
☐ ☐
youth.
(c) A youth may be held up to four hours in the safety
room. After the youth has been held in the safety room 506.4 (g)
for a period of four hours, staff shall do one or more of ☒
☐ ☐
the following: Refer to 601.4.5, Room Confinement
☒ 506.4 (g)(1)
(1) return the youth to general population. ☐ ☐
☒ 506.4 (g)(1)
(2) consult with mental health or medical staff, ☐ ☐
(3) develop an individualized plan that includes the
☒
goals and objectives to be met in order to reintegrate ☐ ☐ 506.4 (g)(1)
the youth to general population.
(d) If confinement in the safety room must be extended
beyond four hours, staff shall develop an individualized 506.4 (g)(1)
plan that includes the requirements of Section 1354.5 ☒
☐ ☐
and the goals and objectives to be met in order to
integrate the youth to general population.
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1360 SEARCHES
513 Searches
The facility administrator shall develop and implement
written policies and procedures governing the search of
youth, the facility, and visitors. Policies and procedures
shall provide that: The agency conducts routine unit and room
searches for the ongoing safety of the facility.
☒
☐ ☐
Due to fentanyl and other drugs coming into
the facility, the VCPAJF has purchased two
body scanners and a mail scanner as tools to
prevent this from occurring. It is expected
they will arrive in August. Prospective
policies for their use are being developed.
(a) Searches shall be conducted to ensure the safety
and security of the facility, public, visitors, youth, and ☒ 513.2 ⁋ 1
staff. ☐ ☐
(b) Searches shall be conducted in a manner that
preserves the privacy and dignity of the person being ☒ 513.1 ⁋ 1
searched and shall not be conducted for harassment or ☐ ☐ 513.2 ⁋ 1
as a form of discipline or punishment.
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(c) Strip searches and visual or physical body cavity
searches shall comply with Penal Code Section 4030. 513.4.1 (a)
513.4.2 (a)
The agency has conducted strip searches of
units and youth more in this past year due to
contraband coming into the facility. Visits
have gone to no contact in some cases as
the agency traced the source. Phone call
coding and recordings reviewed also pointed
to a pathway for contraband.
Since April of 2022, there have been 425 strip
searches conducted, 243 due to contraband
in the units and/or positive drug tests of youth
in the facility. Of the 182 additional strip
☒ searches, averaging 13 per month, we found
☐ ☐
documented reasonable suspicion and
authorization by the supervisor in all but 16
incidents. These 16 were approved by a
supervisor but the documentation other than
the coded reason for the search was not
verified. We reviewed the strip searches from
April 2020 to June 2022 (334 – average
15/month), finding this average
consistent/less than current practice.
We provided technical assistance to the
agency to ensure the reasonable suspicion
was not just a conversation but documented
in the electronic search authorization and/or
by incident report.
(d) Physical body cavity searches shall only be
conducted by a medical professional. ☒ 513.4,2 (b)
☐ ☐
(e) Any youth held after a detention hearing shall only
be strip searched with prior approval of a supervisor 513.4.2 (b)
when there is reasonable suspicion based on specific
☒
and articulable facts to believe that youth is concealing ☐ ☐
contraband. The reasonable suspicion shall be
documented.
(f) Searches of transgender and intersex youth shall
comply with Section 1352.5. 501.12 II-A and B
☒ 513.5
☐ ☐
301.5 II Administrative Manual
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(g) Cross-gender pat-down searches and strip searches
are prohibited except in exigent circumstances or when ☒ 513.3 Last ⁋
conducted by a medical professional. Such searches ☐ ☐
must be justified and documented in writing.
1361 GRIEVANCE PROCEDURE
606 Youth Grievances
The facility administrator shall develop and implement
606.3 ⁋ 1
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
The VCPAJF agency reported 72 grievances
condition of confinement, including but not limited to
filed from April 2022 to June 2023, an
health care services, classification decisions, program
average of 5.1 per month. There were 34 in
participation, telephone, mail or visiting procedures,
2022, 35 in 2021, 43 in 2020, reduced from
food, clothing, bedding, mistreatment, harassment or
the 79 in 2019 and 82 in 2018. The process
violations of the nondiscrimination policy. There shall be
and form are compliant with regulation and
no time limit on filing grievances. Policies and
policy, allowing youth to communicate and
procedures shall include provisions whereby the facility
staff to be responsive to the operational
manager ensures:
procedures used.
☒
☐ ☐ We reviewed all the grievances filed from
April 2022 to June of 2023 and found them to
be timely with appropriate sanctions. Staff
comments appeared to be a documented
conversation, leading the youth to
understand the behavior and sanction, or to
find resolution for a condition of confinement
the youth did not agree with.
There were several beyond the regulation 3-
day receipt of the grievance, but each
involved an agency partner of Food Services
grievance. All were resolved within 10 days
of the receipt of the grievance.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ 606.3 Bullet 1
☐ ☐
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ 606.3 Bullet 8
☐ ☐
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ 606.3 Bullet 2
☐ ☐
(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances ☒ 606.4.2 ⁋ 3
that relate to health and safety issues must be ☐ ☐
addressed immediately;
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(1) The youth may elect to be present to explain
his/her version of the grievance to a person not 606.4.5 (a)
☒
directly involved in the circumstances which led to ☐ ☐
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ 606.4.5 (b)
☐ ☐
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ 606.4.3
☐ ☐
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly 606.4.5 (a)
☒
involved in the circumstances which led to the ☐ ☐
grievance;
(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer ☒ 606.4.2 ⁋ 4
time frame. The youth shall be notified of any delay; ☐ ☐
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. 606.5
☒
☐ ☐ 606.5.1
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be 606.4.5 (c)
☒
addressed and documented in accordance with written ☐ ☐
policies and procedures within a specified timeframe.
1362 REPORTING OF INCIDENTS
206 Report Preparation
A written report of all incidents which result in physical
206.4.2
harm, use of force, serious threat of physical harm, or
death of an employee, youth or other person(s) shall be ☒
☐ ☐
maintained. Such written record shall be prepared by
the staff and submitted to the facility manager by the end
of the shift, unless additional time is necessary and
authorized by the facility manager or designee.
1363 USE OF REASONABLE FORCE TO
COLLECT DNA SPECIMENS, SAMPLES, 517 Biological Samples
IMPRESSIONS 517.5 UF to Collect
DHPO 01.P.1.16
(a) Pursuant to Penal Code Section 298.1 authorized
law enforcement, custodial, or corrections personnel
including peace officers, may employ reasonable force
☒
☐ ☐
The VCPAJF policy does not use force to
collect DNA. Staff advise the youth that their
to collect blood specimens, saliva samples, and thumb
failure to cooperate will result in a return to
or palm print impressions from individuals who are
Court.
required to provide such samples, specimens or
impressions pursuant to Penal Code Section 296 and
who refuse following written or oral request.
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(1) For the purpose of this section, the “use of
reasonable force” shall be defined as the force that 511.3.1
an objective, trained and competent correctional
☒
employee, faced with similar facts and ☐ ☐
circumstances, would consider necessary and
reasonable to gain compliance with this section.
(2) The use of reasonable force shall be preceded by
efforts to secure voluntary compliance. Efforts to 517.5.2
secure voluntary compliance shall be documented
☒
and include an advisement of the legal obligation to ☐ ☐
provide the requisite specimen, sample or
impression and the consequences of refusal.
(b) The force shall not be used without the prior written
authorization of the supervising officer on duty. The 517.5.2
authorization shall include information that reflects the ☒
☐ ☐
fact that the offender was asked to provide the requisite
specimen, sample, or impression and refused.
(1) If the use of reasonable force includes a cell
extraction, the extraction shall be videotaped. Video 517.5.1
shall be directed at the cell extraction event. The
videotape shall be retained by the agency for the
☒
length of time required by statute. Notwithstanding ☐ ☐
the use of the video as evidence in a court
proceeding, the tape shall be retained
administratively.
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1370 EDUCATION PROGRAM
1003 Youth Education Services
(a) School Programs
1003.3 ⁋ 3
The County Board of Education shall provide for the 1003.4 (b)(1) Education Program
administration and operation of juvenile court schools in Coordination
conjunction with the Chief Probation Officer, or designee
pursuant to applicable State laws. The school and The Ventura County Office of Education
facility administrators shall develop and implement operates the Providence School onsite at the
written policy and procedures to ensure communication facility. The last evaluation continues to
and coordination between educators and probation reveal a good relationship amongst probation
staff. Culturally responsive and trauma-informed and school staff, with daily briefings and
approaches should be applied when providing thorough monthly meetings with agency
instruction. Education staff should collaborate with the administrators.
facility administrator to use technology to facilitate
learning and ensure safe technology practices. The
facility administrator shall request an annual review of While onsite, we met with the Director of
each required element of the program by the Alternative Education for the Ventura County
Superintendent of Schools, and a report or review Office of Education (VCOE), Stephanie
checklist on compliance, deficiencies, and corrective Rodrigues, Teresa Vega, the site Assistant
action needed to achieve compliance with this section. Principal, and Nicole Garr, Counselor. We
Such a review, when conducted, cannot be delegated to once again discussed the early and easy
the principal or any other staff of any juvenile court graduation requirements and whether the OE
school site. The Superintendent of Schools shall made independent evaluations to address
conduct this review in conjunction with a qualified the need to provide a diploma to a youth
outside agency or individual. Upon receipt of the review, based on their age, credits to date, and
the facility administrator or designee shall review each anticipated length of stay, mostly to ensure
item with the Superintendent of Schools and shall take ☒ that just because a youth is eligible that they
whatever corrective action is necessary to address each ☐ ☐ evaluate the best-case scenario for each
deficiency and to fully protect the educational interests independent youth. Ms. Garr works most with
of all youth in the facility. this population and assured the process is
independent, indicating there could be a
more robust conversation with the parent and
youth when the situation involves a long stay
in custody.
It is significant to note that while onsite, we
were advised 15 youth had graduated so far
this year, 13 with the limited credits pursuant
to AB – 167. This is significant because the
agency and VCOE have limited post-
secondary opportunities for youth beyond
enrollment in an online local college,
AutoTech (not during summer months), and
Paxton Patterson (PP), which is facilitated by
Probation staff. There is a plan for an Ag
Program and Digital Media program to start
this fall.
We discussed the VCOE hard line for not
allowing graduated youth to remain in the
classroom or to provide greater opportunities
for these youth who will remain with the
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agency long-term. VCOE continues to
provide little in terms of opportunities for
graduated youth but allows youth in long-
term custody to graduate early without
consideration of the benefits to remain in the
classroom. The VCPAJF has tentative plans
to fund a teacher to provide services.
(b) Required Elements
1003.2
The facility school program shall comply with the State
1003.3
Education Code and County Board of Education
1003.4 (b)(1)
policies, all applicable federal education statutes and
1003.5
regulations and provide for an annual evaluation of the
educational program offerings. As stated in the 2009
California Standards for the Teaching Profession, ☒
☐ ☐
teachers shall establish and maintain learning
environments that are physically, emotionally, and
intellectually safe. Youth shall be provided a rigorous,
quality educational program that responds to the
different learning styles and abilities of students and
prepares them for high school graduation, career entry,
and post-secondary education.
All youth shall be treated equally, and the education
program shall be free from discriminatory action. Staff 1003.3 (a)
shall refer to transgender, intersex and gender- ☒
☐ ☐
nonconforming youth by their preferred name and
gender.
(1) The course of study shall comply with the State
Education Code and include, but not be limited to, ☒ 1003.5 ⁋ 3
☐ ☐
courses required for high school graduation.
(2) Information and preparation for the High School
Equivalency Test as approved by the California ☒ 1003.5 ⁋ 3
Department of Education shall be made available to ☐ ☐
eligible youth.
(3) Youth shall be informed of post-secondary
education and vocational opportunities. ☒ 1003.4 (o)(1)
☐ ☐
(4) Administration of the High School Equivalency
Tests as approved by the California Department of ☒ 1003.5 ⁋ 3
☐ ☐
Education, shall be made available when possible.
(5) Supplemental instruction shall be afforded to
youth who do not demonstrate sufficient progress ☒ 1003.5 ⁋ 4
☐ ☐
towards grade level standards.
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(6) The minimum school day shall be consistent with
State Education Code Requirements for juvenile 1003.5 ⁋ 2
court schools. The facility administrator, in
conjunction with education staff, must ensure that
operational procedures do not interfere with the time ☒
☐ ☐
afforded for the minimum instructional day.
Absences, time out of class or educational
instruction, both excused and unexcused, shall be
documented.
(7) Education shall be provided to all youth
regardless of classification, housing, security status, 1003.4 (a)
disciplinary or separation status, including room 1003.4 (g)(1)
confinement, except when providing education 1003.8
☒
poses an immediate threat to the safety of self or ☐ ☐
others. Education includes, but is not limited to,
related services as provided in a youth’s Section 504
Plan or Individualized Education Program (IEP).
(c) School Discipline
1003.7 ⁋ 1
(1) Positive behavior management will be
implemented to reduce the need for disciplinary ☒
☐ ☐
action in the school setting and be integrated into the
facility's overall behavioral management plan and
security system.
(2) School staff shall be advised of administrative
decisions made by probation staff that may affect the ☒ 1003.7 ⁋ 2
☐ ☐
educational programming of students.
(3) Except as otherwise provided by the State
Education Code, expulsion/suspension from school 1003.7 ⁋ 3
shall be imposed only when other means of
correction fails to bring about proper conduct.
School staff shall follow the appropriate due process
safeguards as set forth in the State Education Code ☒
☐ ☐
including the rights of students with special needs.
School staff shall document the other means of
correction used prior to imposing expulsion/
suspension if an expulsion/suspension is ultimately
imposed.
(4) The facility administrator, in conjunction with
education staff will develop policies and procedures 1003.4 (g)
☒
that address the rights of any student who has ☐ ☐
continuing difficulty completing a school day.
(d) Provisions for Special Populations
(1) State and federal laws and regulations shall be 1003.3 ⁋ 2
observed for all individuals with disabilities or 1003.4 (a)
suspected disabilities. This includes but is not limited ☒
☐ ☐
to child find, assessment, continuum of alternative
placements, manifestation determination reviews,
and implementation of Section 504 Plans and
Individualized Education Programs.
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(2) Youth identified as English Learners (EL) shall be
afforded an educational program that addresses their 1003.4 (m)
☒
language needs pursuant to all applicable state and ☐ ☐
federal laws and regulations governing programs for
EL students.
(e) Educational Screening and Admission
(1) Youth shall be interviewed after admittance and a 1003.4 (c)(1)
record maintained that documents a youth's ☒ 1003.4 (h)
educational history, including but not limited to: ☐ ☐ 1003.4.1
(A) School progress/school history;
☒ 1003.4.1
☐ ☐
(B) Home Language Survey and the results of the
State Test used for English language proficiency; ☒ 509.9.2
☐ ☐
(C) Needs and services of special populations as
defined by the State Education Code, including but ☒ 701.4 (f)
☐ ☐
not limited to, students with special needs. 1003.4 (e)
(D) Discipline problems.
☒
☐ ☐ 1003.7
(2) Youth will be immediately enrolled in school.
Educational staff shall conduct an assessment to 1003.4 (c)
☒
determine the youth's general academic functioning ☐ ☐ 1003.4.1 ⁋ 1
levels to enable placement in core curriculum
courses.
(3) After admission to the facility, a preliminary
☒
education plan shall be developed for each youth ☐ ☐ 1003.4.1 ⁋ 1
within five school days.
(4) Upon enrollment, education staff shall comply with
the State Education Code and request the youth's 1003.4.1
records from his/her prior school(s), including, but not
limited to, transcripts, Individual Education Program
(IEP), 504 Plan, state language assessment scores, ☒
☐ ☐
immunization records, exit grades, and partial credits.
Upon receipt of the transcripts, the youth's
educational plan shall be reviewed with the youth and
modified as needed. Youth should be informed of the
credits they need to graduate.
(f) Educational Reporting
(1) The complete facility educational record of the 1003.4 (i)
☒
youth shall be forwarded to the next educational ☐ ☐
placement in accordance with the State Education
Code.
(2) The County Superintendent of Schools shall
provide appropriate credit (full or partial) for course ☒ 1003.4 (i)
☐ ☐
work completed while in juvenile court school in
accordance with the State Education Code.
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(g) Transition and Re-Entry Planning
(1) The Superintendent of Schools and the Chief 1003.4 (n)
Probation Officer or designee, shall develop policies
and procedures to meet the transition needs of youth, ☒
☐ ☐
including the development of an education transition
plan, in accordance with the State Education Code
and in alignment with Title 15, Minimum Standards for
Juvenile Facilities, Section 1355.
(h) Post-Secondary Education Opportunities
(1) The school and facility administrator should, 1003.6
whenever possible, collaborate with local post-
secondary education providers to facilitate access to
educational and vocational opportunities for youth that
We noted the VCPAJF Administration made
considers the use of technology to implement these
the decision to defer summer online college
programs.
to facilitate their own college readiness
program. They found youth were unprepared
☒ to understand the responsibilities for
☐ ☐
independent learning and felt a program to
facilitate independent thought, be responsive
to the curriculums, and to be able to seek
assistance from educational staff not in the
classroom were important for the young
population that was not ready for ‘college’
learning.
1371 PROGRAMS, RECREATION, AND
EXERCISE. 1002 Programs, Recreation and Exercise
1002.2
The facility administrator shall develop and implement
written policies and procedures for programs,
☒
☐ ☐
recreation, and exercise for all youth. The intent is to
minimize the amount of time youth are in their rooms or
their bed area.
Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three 1002.3 ⁋ 1
hours a day during the week and five hours a day each
☒
Saturday, Sunday or other non-school days, of which ☐ ☐
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding 1002.3 ⁋ 2
by the administrator/manager or designee that a youth ☒ ☐ ☐ 1002.7 ⁋ 4
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ 1002.3 ⁋ 3
☐ ☐
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There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to 1000.3 (l)
ensure content offered is current, consistent, and
relevant to the population. A review of Programming at the Juvenile
Facility was completed on July 5, 2023, by
☒
☐ ☐ Chief Deputy Tim Dowler. The review
acknowledged program needs for male and
female youth, noting they would be age-
appropriate and targeted based on identified
needs in the Case Plan.
(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to 1002.6
include, but not be limited to, trauma focused, cognitive,
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
Programming includes responses to Victim
social interventions and activities designed to reduce
Awareness, substance abuse, conflict
recidivism. These programs should be based on the
resolution, anger management, parenting
youth’s individual needs as required by Sections 1355
skills, gender-specific programming, mental
and 1356. Such programs may be provided under the ☒
☐ ☐ health services, positive youth development,
direction of the Chief Probation Officer or the County
building effective decision-making skills, and
Office of Education and can be administered by county
other topics that suit the needs of the youth
partners such as mental health agencies, community
population.
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
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(1) Cognitive Behavior Interventions;
1000.2
(2) Management of Stress and Trauma;
1000.3
(3) Anger Management;
Available programs include: Healthy
(4) Conflict Resolution; Lifestyles - Women of Substance Men of
Honor (WOSMOH); Reins of HOPE (equine
(5) Juvenile Justice System;
therapy); Interactive Journaling; Ventura
(6) Trauma-related interventions; County Arts Council (art, guitar, poetry,
drumming, and mural painting); Therapy
(7) Victim Awareness; Dogs; Dating Matters; First 5 Parenting
Program; Brent’s Club; Smart Girls; Boys and
(8) Self-Improvement;
Girls Club Program*; Podcasting; ADPS
(9) Parenting Skills and support; Tablets; STEPS-Y; Word on the Street; City
Impact; Forever Found (CSEC youth);
(10) Tolerance and Diversity; Passport to Manhood; ARISE; Operation
Peace Works; Gender-Specific Services; and
(11) Healing Informed Approaches;
Music N Society.
(12) Interventions by Credible Messengers;
Ventura County Behavior Health provides the
(13) Gender Specific Programming;
following: Dialectical Behavior Therapy
(DBT); Drug and Alcohol Programs
(14) Art, creative writing, or self-expression;
☒
☐ ☐ (individual and group); Moral Recognition
(15) CPR and First Aid training; Therapy (MRT); Seeking Safety; Anger
Management and Conflict Resolution;
(16) Restorative Justice or Civic Engagement;
Individual and Group Therapy; Co-Parent
Counseling; and Sex Offender Treatment.
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population. Educational Programs include: Paxton
Patterson (Construction trades program);
Providence Scholars Program (online
college); College Success; Literacy Tutors;
Money Matters; and AutoTech.
Re-Entry Services include: First Aid/CPR;
Alpha Leadership; Forever Found Case
Management; Second Chance Re-entry
Services; Reducing Risks for Girls; Harm to
Healing Restorative Justice; and Court
Appointed Special Advocates.
*These programs are not occurring currently
due to the facilitators not being available.
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(b) Recreation. All youth shall be provided the
opportunity for at least one hour of daily access to 1002.5
unscheduled activities such as leisure reading, letter
writing, and entertainment. Activities shall be supervised
and include orientation and may include coaching of ☒
☐ ☐ Recreation Programs include Library Carts;
youth.
Organized Games; Special Events; and the
Boys and Girls Club Rec Center
(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity 1002.4
each day.
☒
☐ ☐ Exercise other than that facilitated by staff
include Futsal, Basketball, Boys and Girls
Club Gym, and Special Events.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and 1002.7 ⁋ 3
programs. The administrator/manager shall document ☒
☐ ☐
the reasons why suspension of recreation and programs
occurs.
1372 RELIGIOUS PROGRAM
1007 Religious Programs
The facility administrator shall provide access to
1007.3 ⁋ 2
religious services and/or religious counseling at least
1007.3.1
once each week. Attendance shall be voluntary. A youth
shall be allowed to participate in an activity outside of
their room if he/she elects not to participate in religious ☒
☐ ☐
programs. The agency has religious providers in each
unit one day per week. Youth have the
Religious programs shall provide for: opportunity to meet with them or request a
contact anytime.
(a) opportunity for religious services and practices; ☒ 1007.3.1
☐ ☐
(b) availability of clergy; and, ☒ 1007.12
☐ ☐
(c) availability of religious diets. ☒ 1007.5
☐ ☐
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1373 WORK PROGRAM
1005 Youth Work Program
The facility administrator shall develop policies and
procedures regarding the fair and consistent
assignment of youth to work programs. Work assigned ☒
☐ ☐
to a youth shall be meaningful, constructive and related
to vocational training or increasing a youth's sense of
responsibility. Work programs shall not be imposed as a
disciplinary measure
1374 VISITING
1008 Youth Visitation
The facility administrator shall develop and implement
1008.3.2
written policies and procedures for visiting, that include
provisions for special visits. Youth shall be allowed to
receive visits by parents, guardians or persons standing
in loco parentis, and children of youth. Other family ☒ ☐ ☐ At the time of the inspection, youth are able
members, such as grandparents and siblings, and to have 2 visits per week, for an hour each
supportive adults, may be allowed to visit with the visit, on Wednesdays and Sundays. Special
approval of the facility administrator or designee, and in visits occur on Sunday mornings.
conjunction with the youth’s case plan or in the best
interest of the youth.
All visits shall occur at reasonable times, subject only to
the limitations necessary to maintain order and security. 1008.6 (f)
Visitation shall not be denied solely based on the 1008.6 Last Paragraph
visitor’s criminal history. The staff shall determine in 1008.5 Visitation Schedule
each case, whether the visitor’s criminal history ☒
☐ ☐
represents a risk to the safety of youth or staff in the
facility. Any denial of visitation or limitation on visitations
shall be communicated to the youth, person denied and
facility administrator.
Opportunity for visitation shall be a minimum of two
hours per week. Visits may be supervised, but ☒ 1008.3.2 ⁋ 2
conversations shall not be monitored unless there is a ☐ ☐
security or safety need.
Provisions for special visits, in addition to the two-hour
minimum and/or outside of the regular visiting hours, 1008.8
shall be accommodated as necessary and within the
discretion of the facility administrator or designee.
☒
Family therapy and professional visits shall be ☐ ☐
accommodated outside the provisions of this regulation.
Facilities may provide visitation opportunities outside of
normal visiting hours to accommodate special visits.
The facility may provide access to technology as an
alternative, but not as a replacement, to in-person ☒ 1008.3.2 ⁋ 3
☐ ☐
visiting.
1375 CORRESPONDENCE
1001 Correspondence
The facility administrator shall develop and implement ☒
☐ ☐
written policies and procedures for correspondence
which provide that:
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(a) there is no limitation on the volume of mail that youth
may send or receive; ☒ 1001.3 ⁋ 1
☐ ☐
(b) youth may send two letters per week postage free;
1001.8 (a)
☒
☐ ☐ Youth are able to send seven letters each
week postage-free.
(c) youth may correspond confidentially with state and
federal courts, any member of the State Bar or holder of 1001.4 ⁋ 1
public office, and the Board; however, authorized facility ☒
☐ ☐
staff may open and inspect such mail only to search for
contraband and in the presence of the youth; and,
(d) incoming and outgoing mail, other than that
described in (c), may be read by staff only when there is ☒ 1001.6 ⁋ 2
reasonable cause to believe facility safety and security, ☐ ☐ 1001.6.1
public safety, or youth safety is jeopardized.
1376 TELEPHONE ACCESS
1006.2 Youth Telephone Policy
The administrator of each juvenile facility shall develop
and implement written policies and procedures to
☒
☐ ☐
provide youth with access to telephone
communications.
1377 ACCESS TO LEGAL SERVICES
602 Youth Access to Courts and Counsel
The facility administrator shall develop written
procedures to ensure the right of youth to have access
☒
☐ ☐
to the courts and legal services. Such access shall
include:
(a) access, upon request by the youth, to licensed
attorneys and their authorized representatives; ☒ 602.3 (a)
☐ ☐
(b) provision for confidential consultation with attorneys;
and, ☒ 602.3 (b)
☐ ☐
(c) unlimited postage free, legal correspondence and
cost-free telephone access as appropriate. ☒ 602.3 (c)
☐ ☐
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1390 DISCIPLINE
600 Youth Discipline
The facility administrator shall develop and implement
600.3.1 Rules and Sanctions
written policies and procedures for the discipline of
600.6 Bullet 14
youth that shall promote acceptable behavior; including
1009.3 Behavior Modification Plan
the use of positive behavior interventions and supports. ☒
☐ ☐
Discipline shall be imposed at the least restrictive level
which promotes the desired behavior and shall not
include corporal punishment, group punishment,
physical or psychological degradation. Deprivation of
the following is not permitted:
(a) bed and bedding; ☒ 600.6 Bullet 13 and 14
☐ ☐
(b) daily shower, access to drinking fountain, toilet and
☒ 600.6 Bullet 7
personal hygiene items, and clean clothing; ☐ ☐
(c) full nutrition; ☒ 600.6 Bullet 4
☐ ☐
(d) contact with parent or attorney; ☒ 600.6 Bullet 16 and 19
☐ ☐
(e) exercise; ☒ 600.6 Bullet 11
☐ ☐
(f) medical services and counseling; ☒ 600.6 Bullet 15 and 20
☐ ☐
(g) religious services; ☒ 600.6 Bullet 20
☐ ☐
(h) clean and sanitary living conditions; ☒ 600.6 Bullet 14
☐ ☐
(i) the right to send and receive mail; ☒ 600.6 Bullet 18
☐ ☐
(j) education; and, ☒ 600.6 Bullet 20
☐ ☐
(k) rehabilitative programming. ☒ 600.6 Bullet 20
☐ ☐
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The facility administrator shall establish rules of conduct
and disciplinary penalties to guide the conduct of youth. 600.4 Minor Rules
Such rules and penalties shall include both major 600.5 Major Rules
violations and minor violations, be stated simply and 600.7 Sanctions
☒
affirmatively, and be made available to all youth. ☐ ☐ 1009 Behavior Management Program
Provision shall be made to provide accessible
information to youth with disabilities, limited English
proficiency, or limited literacy.
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1391 DISCIPLINE PROCESS
600.3 Discipline Process
The facility administrator shall develop and implement
written policies and procedures for the administration of
The agency uses two separate forms for
discipline which shall include, but not be limited to:
Disciplinary Due Process. First, the Notice of
Discipline, includes a summary of the
incident and proposed sanction. The second
form is the Hearing Form, currently used for
every due process incident. The form allows
the youth to write their version of the incident
and to list any witnesses. There is also an
area to list the staff who assisted with the
form or a box to check if no one was
requested to help the youth.
Prior to the discipline hearing, the assigned
Hearing Officer reviews video of the incident
and all reports. Once a finding is made, the
youth is notified and is offered an opportunity
to appeal. Appeal forms are available in
every living unit.
We provided technical assistance to include
the opportunity to allow the youth to either
☒
☐ ☐ request a hearing or indicate they do not
want a hearing if they agree to the Notice and
Proposed Sanction. If the minor agrees and
does not want a hearing, then the process is
complete. They would then have the youth
sign the form acknowledging no further
action is requested. If the youth wants the
hearing, then the existing process is fine.
Our guidance is to simplify and shorten the
operational responsibilities of staff.
We reviewed 22 of the 133 Due Process
incidents for 2021, including the Incident
Report and subsequent documentation. The
form prompts staff to follow the process and
the documentation was clear. Of the
incidents reviewed, 9 filed an appeal to the
facility manager.
The process for each incident started the
same day as initiated and was resolved that
day. We found the policy and process
exceeds regulation.
(a) designation of personnel authorized to impose
discipline for violation of rules; ☒ 600.3 (a)
☐ ☐
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(b) prohibiting discipline to be delegated to any youth;
☒ 600.6 Bullet 1
☐ ☐
(c) definition of major and minor rule violations and their
consequences, and due process requirements; 600.4
☒
☐ ☐ 600.5
(d) trauma-informed approaches and positive behavior
interventions; ☒ 600.3.1 ⁋ 2
☐ ☐
(e) minor rule violations may be handled informally by
counseling, advising the youth of expected conduct 600.4 Minor Rules
imposing a minor consequence. Discipline shall be ☒ 600.8 Documentation
☐ ☐
accompanied by written documentation and a policy of
review and appeal to a supervisor; and,
(f) major rule violations and the discipline process shall
be documented and require the following: ☒ 600.5
☐ ☐
(1) written notice of violation prior to a hearing; ☒ 600.5.3
☐ ☐
(2) accommodations provided to youth with
disabilities, limited literacy, and English language ☒ 600.5.7
☐ ☐
learners;
(3) hearing by a person who is not a party to the
☒ 600.5.4 ⁋ 2
incident; ☐ ☐
(4) opportunity for the youth to be heard, present
☒ 600.5.5
evidence and testimony; ☐ ☐
(5) provision for youth to be assisted by staff in the
☒ 600.5.3
hearing process; ☐ ☐
(6) provision for administrative review. ☒ 600.5.10
☐ ☐
(g) violations that result in a removal from camp or
commitment program, but not a return to court, will 600.7.1
☒
follow the due process provisions in subsection (e) ☐ ☐
above.
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1410 MANAGEMENT OF COMMUNICABLE
DISEASES.
VCPA: Policy 705 Communicable Disease
The health administrator/responsible physician, in Policy, Youth
cooperation with the facility administrator and the local Policy 705.3 Procedure
health officer, shall develop written policies and
☒
☐ ☐ Policy 1203 Communicable Disease Policy,
procedures to address the identification, treatment, Members (Staff)
control and follow-up management of communicable
diseases. The policies and procedures shall address,
but not be limited to:
VCPA: Policy 705.3 (c) Procedure
Coronavirus (COVID-19) PRE-BOOKING
(a) Intake health screening procedures; ☒ ☐ ☐ PROCEDURES
Intake and Medical Isolation Procedures
(b) Identification of relevant symptoms; ☒
☐ ☐ Intake and Medical Isolation Procedures
Coronavirus (COVID-19) PRE-BOOKING
(c) Referral for medical evaluation; ☒
☐ ☐ PROCEDURES
VCPA Policy 705.3 (d) Compliance with all
relevant laws and regulations related to
communicable diseases.
VCPA Policy 705.4.3 Medical Consultation,
(d) Treatment responsibilities during detention; ☒
☐ ☐ Evaluation and Treatment
VCPA: Youth Face Mask Protocol and
Expectations
(e) Coordination with public and private community-
☒ VCPA Policy 705.3 (d)(2)
based resources for follow-up treatment; ☐ ☐
VCPA Policy 705.4.2 Supervisor Response
(f) Applicable reporting requirements; and, ☒
☐ ☐ and Reporting Requirements
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VCPA Policy 703 (d)(3) Developing
(g) Strategies for handling disease outbreaks. ☒ strategies for handling communicable
☐ ☐
disease outbreaks.
The policies and procedures shall be updated as
necessary to reflect communicable disease priorities
The agency coordinates policies with local
identified by the local health officer and currently
Public Health and CDC directives in
recommended public health interventions. ☒
☐ ☐ response to the Coronavirus Pandemic.
These policies were updated in 2020.
1433 REQUESTS FOR HEALTH CARE SERVICES
(EXCERPT)
702.3 Youth Access to Health Care
The health administrator, in cooperation with the facility
administrator, shall develop policy and procedures to ☒ ☐ ☐ 702.3 (b) and (c) Unimpeded Access to
establish a daily routine for youth to convey requests for Health Care Services
emergency and non-emergency medical, dental and
behavioral/mental health care services.
1480 STANDARD FACILTY CLOTHING ISSUE
The youth’s personal clothing, undergarments and 802.6 Clothing Issue
footwear may be substituted for the institutional clothing ☒
and footwear specified in this regulation. The facility has ☐ ☐ 363.1 Clothing Exchange
the primary responsibility to provide clothing and
footwear. Clothing provisions shall ensure that:
(a) Clothing is clean, reasonably fitted, durable, easily
laundered, in good repair, and free of holes and tears.
☒ 802.6 Paragraph 1
☐ ☐
(b) The standard issue of climatically suitable clothing
for youth shall consist of but not be limited to:
☒
☐ ☐
(1) Socks and serviceable footwear; ☒ 802.6 Paragraph 2 Bullet 1 and 4
☐ ☐
(2) Outer garments; ☒ 802.6 Paragraph 2 Bullet 2
☐ ☐
(3) New non-disposable underwear which shall
remain with the youth throughout their stay, and;
☒ 802.6 Paragraph 2 Bullet 3 and 5
☐ ☐
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(4) Undergarments, that are freshly laundered and
free of stains, including tee shirts and bras.
☒ 802.6 Paragraph 2 Bullet 3
☐ ☐
(c) Clothing is laundered at the temperature required by
local ordinances for the commercial laundries and dried
☒
802.7
completely in a mechanical dryer or other laundry ☐ ☐
method approved by the local health officer.
(d) Suitable clothing is issued to pregnant youth.
☒ 802.6 Paragraph 2 Bullet 6
☐ ☐
1482 CLOTHING EXCHANGE
The facility administrator shall develop and implement 802.6 Paragraph 1, 4, 5, and 6
written policies and site-specific procedures for the
cleaning and scheduled exchange of clothing. Unless
work, climatic conditions, or illness necessitates more
☒
☐ ☐
frequent exchange, outer garments, except for footwear,
shall be exchanged at least once each week. Tee shirts,
bras, and underwear shall be exchanged daily; youth
shall receive their own underwear back at exchange.
1484 CONTROL OF VERMIN IN YOUTH’S
PERSONAL CLOTHING
Procedure 321
There shall be written policies and site-specific
procedures developed and implemented by the facility FPO.07.B, 1
administrator to control the contamination and/or spread
☒
☐ ☐
of vermin and ecto-parasites in all youth’s personal
clothing. Infested clothing shall be cleaned or stored in
a closed container so as to eradicate or stop the spread
of the vermin.
1485 ISSUE OF PERSONAL CARE ITEMS
There shall be written policies and site-specific 802.8 Personal Hygiene of Youth
procedures developed and implemented by the facility
administrator for the availability of personal hygiene ☒ Procedure 362 Personal Hygiene
☐ ☐
items. Each female youth shall be provided with sanitary
FPO.09.E, 1
napkins, panty liners and tampons as requested. Each
youth to be held over 24 hours shall be provided with the
following personal care items;
(a) Toothbrush; ☒ 802.8 Paragraph 2 Bullet 4
☐ ☐
Procedure 362.1 (f)
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802.8 Paragraph 2 Bullet 3
(b) Toothpaste; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 1
(c) Soap; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 2
(d) Comb; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 5
(e) Shaving implements; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 8
(f) Deodorant; ☒
☐ ☐
Procedure 362.1 (f)
(g) Lotion; ☒ 802.8 Paragraph 2 Bullet 9
☐ ☐
802.8 Paragraph 2 Bullet 10
(h) Shampoo; and, ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 11
(i) Post-shower conditioning hair products. ☒
☐ ☐
Procedure 362.1 (f)
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Youth shall not be required to share any personal care
items listed in items (a) through (d). Liquid soap
provided through a common dispenser is permitted.
Youth shall not share disposable razors. Double edged
802.8 Paragraph 4
safety razors, electric razors, and other shaving
☒
instruments capable of breaking the skin, when shared ☐ ☐ 604.4 Shaving
among youth, shall be disinfected between individual
uses by the method prescribed by the State Board of
Barbering and Cosmetology in Sections 979 and 980,
Chapter 9, Title 16, California Code of Regulations.
1486 PERSONAL HYGIENE
There shall be written policies and site specific Procedure 362.1 (a) and (i)
procedures developed and implemented by the facility
administrator for showering/bathing and brushing of ☒
☐ ☐
teeth. Youth shall be permitted to shower/bathe up on
assignment to a housing unit and on a daily basis
thereafter and given an opportunity to brush their teeth
after each meal.
1487 SHAVING
Youth shall have access to a razor daily, unless their 604.4 Shaving
appearance must be maintained for reasons of
identification in Court. All youth shall have equal ☒
☐ ☐
opportunity to shave face and body hair. The facility
administrator may suspend this requirement in relation
to youth who are considered to be a danger to
themselves or others.
1488 HAIR CARE SERVICES (EXCERPT)
Hair care services shall be available in all juvenile 604.3 Haircuts
facilities. Youth shall receive hair care services monthly. ☒
☐ ☐
Equipment shall be cleaned and disinfected after each
haircut or procedure, by a method approved by the State
Board of Barbering and Cosmetology.
1500 STANDARD BEDDING AND LINEN ISSUE
Clean laundered, suitable bedding and linens, in good 802.5 Bedding Issue
repair, shall be provided for each youth entering a living
☒
☐ ☐
area who is expected to remain overnight, shall include,
but not be limited to:
(a) One mattress or mattress-pillow combination which
meets the requirements of Section 1502 of these
☒ 802.5 (b)
regulations; ☐ ☐
(b) One pillow and a pillow case unless provided for in
(a) above;
☒ 802.5 (e)
☐ ☐
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(c) One mattress cover and a sheet or two sheets; ☒ 802.5 (c)
☐ ☐
(d) One towel; and, ☒ 802.5 (d)
☐ ☐
(e) One blanket or more, up on request ☒ 802.5 (a)
☐ ☐
1501 BEDDING LINEN EXCHANGE
The facility administrator shall develop and implement 802.5 Paragraph 2
site specific written policies and procedures for the
scheduled exchange of laundered bedding and linen ☒
☐ ☐
issued to each youth housed. Washable items such as
sheets, mattress covers, pillow cases and towels shall
be exchanged for clean replacement at least once each
week.
The covering blanket shall be cleaned or laundered
once a month.
☒ 802.5 (a)2
☐ ☐
1510 FACILITY SANITATION, SAFETY AND
MAINTENANCE
800 Housekeeping and Maintenance
The facility administrator shall develop and implement
written policies and site-specific procedures for the Procedure 317
maintenance of an acceptable level of cleanliness,
FPO.06.M, 1 Facility Sanitation, Safety and
repair and safety throughout the facility. The plan shall
Maintenance
provide for a regular schedule of housekeeping tasks, ☒
☐ ☐
equipment, including restraint devices, and physical
plant maintenance and inspections to identify and
correct unsanitary or unsafe conditions or work
practices in a timely manner. The use of chemicals shall
be done in accordance to the product label and Safety
Data Sheet which may include the use of Personal
Protection Equipment (PPE).
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REVIEW OF NON REGULATORY REQUIREMENTS
GRANT FUNDING OR CODE REFERENCE YES NO N/A P/P REFERENCE - COMMENTS
JUVENILE PROBATION AND CAMPS FUNDING (JPCF) (Camps Only)
The programs/services identified on the JPCF Camp
Eligibility Form are being provided at the facility.
☐ ☐ ☒
(Refer to the JPCF Camp Eligibility Form)
208.5 WIC CONTACT BETWEEN PERSONS UNDER THE JUVENILE COURT AGES 19- 20 AND MINORS IN THE
FACILITY
The facility houses Juvenile Court Wards 19 years of
age and older. ☒ ☐ ☐
The facility has been approved to hold persons under
the juvenile court who are ages 19 through 21. ☒ ☐ ☐
The facility continues to comply with the requirements
of 208.5 WIC (programming, capacity and security of
☒ ☐ ☐
the facility) as outlined in the county’s application.
JUVENILE JUSTICE DELINQUENCY PREVENTION ACT MONITORING (JJDPA)
WIC 206 SEPARATE FACILITIES FOR WIC 300
MINORS
☐
☐
Dependent or neglected minors who are defined under Viola ☒
Section 300 of the Welfare and Institutions Code (WIC) tion
are held only in non-secure, separate and segregated
facilities.
DETENTION OF STATUS OFFENDERS (WIC 601)
AND FEDERAL MINORS
☐ ☒ ☐
Status Offenders (WIC 601) are held in the facility.
Status Offenders (WIC 601) are kept separate from
☐
Juvenile Delinquents (WIC 602)? (WIC 207[d]). ☐ ☒
Viola
tion
Federal Minors (ICE Holds or ORR Contract) are held
in the facility. ☐ ☒ ☐
If yes to the above, the Monthly Report on the
Detention of Status Offenders/Federal Minors is
☐ ☐ ☒
submitted to the BSCC.
WIC 208 SEPARATION OF MINORS AND ADULT
INMATES (JJDPA 42 USC 5633, Sec 223,
State Plans (a)[12])
Are adult inmates held in the facility? (When a person ☐ ☒ ☐
in detention is proceeding through the adult court,
AND that person is 18 years of age or older that
person is an adult inmate.)
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If adult inmates are held, they are appropriately
☐ ☒
separated from minors. ☐
Viola
tion
Adult inmates from an adult facility (e.g. inmate
☐
workers or “Scared Straight” programs) are not ☐ ☒
allowed in the facility in a manner that allows contact Viola
with minors. tion
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7728
FACILITY NAME: Ventura County Probation Agency Juvenile Facility (VCPAJF) FACILITY TYPE: Camp
Commitment Services
PERSON(S) INTERVIEWED: Gina Johnson, Chief Probation Officer; Tim Dowler, Chief Deputy Probation Officer; Carrie
Vredenburg, Director – Juvenile Facility Programs; Sandy Carrillo, Director, Juvenile Operations; Rebecca Jimenez, Corrections
Service Officer (CSO) III; Chris Martinez, Supervising Deputy Probation Officer (SDPO); Lola Barnette, SDPO; Allysa Hyne,
SDPO; Justin Burdine, CSO III; Adrian Jimenez, CSO II; Chris Mullins, CSO II; Shirley Scott, Wellpath RN; Teresa Vega, Assistant
Principal Ventura County Office of Education; Stephanie Rodriguez, Director Ventura County Office of Education; Nicole Garr,
Counselor Ventura County Office of Education; Stacy Thompson, Ventura County Food Services Manager; Ana Magbitang,
Manager Ventura County Behavior Health; SYTF Youth - Alex, age 17; Joel, age 18, Brayleen, age 23; Jesus, age 22; Rogelio,
age 19; Detention - Landon, age 18; Frank, age 17; Axel, age 20.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: July 10-13, 2023
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1313 COUNTY INSPECTION AND EVALUATION
OF BUILDING AND GROUNDS 104.3.2 Required Local Inspections,
On an annual basis, or as otherwise required by law,
The following Inspections apply to the entire
each juvenile facility administrator shall obtain a
VCPAJF Physical Plant, including Detention,
documented inspection and evaluation from the ☐
☒ ☐ Commitment, and SYTF.
following:
(a) county building inspector or person designated by the
November 1, 2021
Board of Supervisors to approve building safety;
April 11, 2023
(b) fire authority having jurisdiction, including a fire
clearance as required by Health and Safety Code ☒ ☐ ☐ November 15, 2022
Section 13146.1(a) and (b); April 18, 2023
(c) local health officer, inspection in accordance with
Health and Safety Code Section 101045; 2022:
Environmental Health May 5, 2022
Medical/Mental Health December 3, 2021
Nutritional Health April 15, 2022
☒ ☐ ☐
2023:
Environmental Health June 8, 2023
Medical/Mental Health November 29, 2022
Nutritional Health July 7, 2023
1 This document is intended for use as a tool during the inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally,
many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please
refer to the complete California Code of Regulations, Title 15, Minimum Standards for Local Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and
text of regulations.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(d) county superintendent of schools on the adequacy
of educational services and facilities as required in October 26, 2021
☒ ☐ ☐
Section 1370; December 7, 2022
(e) juvenile court as required by Section 209 of the
Welfare and Institutions Code; and, November 5, 2021
☒ ☐ ☐
March 14, 2023
(f) the Juvenile Justice Commission as required by
Section 229 of the Welfare and Institutions Code or December 7, 2021
☒ ☐ ☐
Probation Commission as required by Section 240 of the December 6, 2022
Welfare and Institutions Code.
1320 APPOINTMENT AND QUALIFICATIONS
100.1
BSCC Note: Compliance with this section is determined
by receipt of the Chief Probation Officer’s certification
The elements of this regulation are addressed
letter confirming that all elements of regulation are met. in a memorandum completed by Chief
Probation Officer Gina Johnson, dated June
20, 2023.
(a) Appointment
☒ ☐ ☐
In each juvenile facility there shall be a superintendent,
director or facility manager in charge of its program and
employees. Such superintendent, director, facility
manager and other employees of the facility shall be
appointed by the facility administrator pursuant to
applicable provisions of law.
(b) Employee Qualifications
Each facility shall: 1200.3 Recruitment
(1) recruit and hire employees who possess
☒ ☐ ☐
knowledge, skills and abilities appropriate to their job
classification and duties in accordance with
applicable civil service or merit system rules;
(2) require a medical evaluation and physical
examination including tuberculosis screening test
1200.4 (i) Medical and Psychological Exam
and evaluation for immunity to contagious illnesses
☒ ☐ ☐
of childhood (i.e., diphtheria, rubeola, rubella, and
mumps);
100.5 Correction Officer Responsibilities
(3) adhere to the minimum standards for the
302.1 Training Policy
selection and training requirements adopted by the
302.4 Minimum Training Requirements
Board pursuant to Section 6035 of the Penal Code; ☒ ☐ ☐
1200.7 Employment Standards
and
1200.7.1 Standards for Correction Officers
(4) conduct a criminal records review, on each new
employee, and psychological examination in
accordance with Section 1031 of the Government ☒ ☐ ☐
1200.4 (g); 1200.71
Code.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(c) Contract personnel, volunteers, and other non-
employees of the facility, who may be present at the
305.2
facility, shall have such clearance and qualifications as
305.3
may be required by law, and their presence at the facility ☒ ☐ ☐
shall be subject to the approval and control of the facility
These sections are related to clearance for
manager.
Volunteers/Interns and Support Personnel.
1321 STAFFING
Each juvenile facility shall: 211 Staffing Plan
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its ☒ ☐ ☐
programming, to provide for safety and security of youth
and staff, and meet established standards and
regulations;
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent 200.3 ⁋ 2 Supervision of Youth
exigent circumstances; 211.3.1 (a)
The facility roster of staff, including mandated
Deputy Probation Officers, and schedules for
all VCPAJF reflect compliance with
regulation. We reviewed staffing for February
and April 2023, as well as schedules leading
up to the on-site inspection, and found youth
are moved to a condensed living unit for the
☒ ☐ ☐ purpose of sleeping to accommodate
coverage.
We have had discussions with the agency
and provided technical assistance to identify
the individual space as one 30-bed unit
rather than two 15-bed individual units. The
space would have significant day space for
programming youth in separate areas to
provide classification-specific programming
or recreation.
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members;
211.3.1 (b)
☒ ☐ ☐
(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has
211.3.1 (c)
completed the Juvenile Corrections Officer Core Course ☒ ☐ ☐
and PC 832 training;
(e) have at least one staff member present on each
living unit whenever there are youth in the living unit;
211.3.1 (e)
☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(f) have sufficient food service personnel relative to the
number and security of living units, including staff 900 Food Services
qualified and available to: plan menus meeting 900.3 Bullet 2
nutritional requirements of youth; provide kitchen
supervision; direct food preparation and servings;
conduct related training programs for culinary staff; and
The agency Food Service Program exceeds
maintain necessary records; or, a facility may serve food
regulation as it relates to meal preparation
that meets nutritional standards prepared by an outside
and delivery. Youth receive 3 hot meals daily
source;
and we note in conversations with youth that
the food is “really good” and “better than at
home.”
☒ ☐ ☐
The Food Services Manager has a
curriculum to administer a hands-on Food
Handlers Program for youth that would
include kitchen responsibilities and skills that
would be lasting into adulthood. We support
this, especially for graduated and long term
stays, as the youth would immediately benefit
upon community re-entry.
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance,
200.5
transportation, control room, facility security and other
support staff for the efficient management of the facility,
and to ensure that youth supervision staff shall not be
☒ ☐ ☐
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to
211.3.1 (f)
temporary variations in staff assignments to meet
special program needs. Staffing shall be in compliance ☒ ☐ ☐
with a minimum youth-staff ratio for the following facility
types:
(1) Juvenile Halls
(A) during the hours that youth are awake, one ☐ ☐ ☒ This facility is not a Juvenile Hall.
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth in detention;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an
arrangement has been made for backup support ☐ ☐ ☒
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- This facility is not a Special Purpose Juvenile
☐ ☐ ☒
awake youth supervision staff member on duty for Hall.
each 10 youth in detention;
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an
arrangement has been made for backup support ☐ ☐ ☒
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(3) Camps
(A) during the hours that youth are awake, one 200.3 ⁋ 2
wide-awake youth supervision staff member on
duty for each 15 youth in the camp population;
The agency has provided sufficient staffing
for the facility only due to mandated overtime
for the youth supervision staff (JCO’s), core
trained Deputy Probation Officers (DPO’s),
and non-core trained DPO’s who work side
by side with core trained staff. VCPAJF is in
their eleventh 40-hour orientation ‘class’ of
the DPO classification to provide for the
necessary coverage. Although the agency
meets required ratio per regulation, it is a
daily task for administrators to provide
coverage for call-outs of scheduled staff.
☒ ☐ ☐
On the day of the inspection, there were 27
youth committed to the Camp Program, 23
male youth and 4 female youth. It was the
intention last cycle to return these youth to
the commitment side of the facility, in Santa
Cruz, however, staffing still prevents this from
occurring. Presently, all youth remain on the
Detention side of the facility.
We provided technical assistance and
referral information to better plan and audit
the call-off coverage, noting this is a
statewide problem for juvenile facilities.
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☒ ☐ ☐ 200.3 ⁋ 2
each 30 youth present in the facility;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in residence, unless 200.3 ⁋ 3
arrangements have been made for backup ☒ ☐ ☐
support services which allow for immediate
response to emergencies;
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☒ ☐ ☐
in the facility; 200.3 ⁋ 3
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be 211.3.1 (g)(1)
given to the size, design, and location of the
camp; types of youth committed to the camp; and
☒ ☐ ☐
the function of the camp in determining the level
of supervision necessary to maintain the safety
and welfare of youth and staff;
(F) personnel with primary responsibility for other
duties such as administration, supervision of 200.5
personnel, academic or trade instruction, clerical,
☒ ☐ ☐
farm, forestry, kitchen or maintenance shall not
be classified as youth supervision staff positions.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1322 YOUTH SUPERVISION STAFF ORIENTATION
AND TRAINING
300.3 Youth Supervision Orientation
(a) Prior to assuming any responsibilities each youth
supervision staff member shall be properly oriented to 300.3 Bullet 6
their duties, including:
(1) youth supervision duties;
The VCPAJF provides new staff with a
comprehensive orientation and training
program, including a Five Phase process,
starting with a Phase 1, an initial Orientation
of 40 hours. Phase 2 includes Initial Policy
Training; Phase 3 includes Supervision of
Youth with Close Training by the assigned
Training Officer (TO); Phase 4 is Sole
Supervision with Monitoring by the TO and
an assigned mentor/trainer; and Phase 5 is
Working Independently with Supervision by
the TO.
☒ ☐ ☐
The training curriculum includes evaluation
of the Probationary staff of job skills and
learning progress, both of which are
documented at each Phase. A staff’s
competency is reviewed by facility
administrators prior to the staff receiving
permanent status with the agency.
Due to staffing shortages, the agency is
providing Phase 1 to the Deputy Probation
Officer staff, cored and non-cored, to provide
additional youth supervision.
Additionally, the agency provides a significant
annual staff training curriculum to ensure
competency is maintained.
(2) scope of decisions they shall make; 300.3 Bullet 13
☒ ☐ ☐
(3) the identity of their supervisor; 300.3 Bullet 8
☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(4) the identity of persons who are responsible to
them;
300.3 Bullet 13
☒ ☐ ☐
(5) persons to contact for decisions that are beyond
their responsibility; and
300.3 Bullet 13
☒ ☐ ☐
(6) ethical responsibilities.
300.3 Bullet 2
☒ ☐ ☐
(b) Prior to assuming any responsibility for the
supervision of youth, each youth supervision staff
302.5 Training
member shall receive a minimum of 40 hours of facility-
specific orientation, including:
The agency’s Five Phased Training Program
☒ ☐ ☐ is a comprehensive effort by tenured facility
staff to ensure new youth supervision staff
are trained in all aspects required to
complete their responsibilities.
(1) individual and group supervision techniques; 300.3.1 Bullet 1
☒ ☐ ☐
(2) regulations and policies relating to discipline and 300.3.1 Bullet 2
rights of youth pursuant to law and the provisions of ☒ ☐ ☐ POC 02.J.1
this chapter;
(3) basic health, sanitation and safety measures; 300.3.1 Bullet 3
☒ ☐ ☐
(4) suicide prevention and response to suicide
300.3.1 Bullet 4
attempts ☒ ☐ ☐
(5) policies regarding use of force, de-escalation
techniques, chemical agents, mechanical and 300.3.1 Bullet 5
☒ ☐ ☐
physical restraints;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(6) review of policies and procedures referencing
300.3.1 Bullet 10
trauma and trauma-informed approaches; ☒ ☐ ☐
(7) procedures to follow in the event of
300.3.1 Bullet 6
emergencies; ☒ ☐ ☐
(8) routine security measures, including facility
300.3.1 Bullet 11
perimeter and grounds; ☒ ☐ ☐
(9) crisis intervention and mental health referrals to
300.3.1 Bullet 7
mental health services; ☒ ☐ ☐
(10) documentation; and 300.3.1 Bullet 8
☒ ☐ ☐
(11) fire/life safety training 300.3.1 Bullet 9
☒ ☐ ☐
(c) Prior to assuming sole supervision of youth, each
youth supervision staff member shall successfully
complete the requirements of the Juvenile Corrections 302.4 ⁋ 1
☒ ☐ ☐
Officer Core Course pursuant to Penal Code Section
6035.
(d) Prior to exercising the powers of a peace officer
youth supervision staff shall successfully complete
training pursuant to Section 830 et seq. of the Penal ☒ ☐ ☐ 302.4 ⁋ 2
Code.
1323 FIRE AND LIFE SAFETY
103.5 Training
Whenever there is a youth in a juvenile facility, there
300.3.1 Bullet 9
shall be at least one wide awake person on duty at all
☒ ☐ ☐
times who meets the training standards established by
the Board for general fire and life safety which relate
specifically to the facility.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1324 POLICY AND PROCEDURES MANUAL
102 Policy and Procedures Manual
All facility administrators shall develop, publish, and
102.5 Distribution of Manual
implement a manual of written policies and procedures
103.2 Post Orders (Procedures)
that address, at a minimum, all regulations that are
applicable to the facility. Such a manual shall be made
The VCPAJF has adopted Lexipol Policy and
available to all employees, reviewed by all employees,
Procedures (Post Orders) which include all
and shall be administratively reviewed at a minimum ☒ ☐ ☐
required elements in regulation while
every two years, and updated, as necessary. Those
allowing flexibility for changes or
records relating to the standards and requirements set
modifications as necessary.
forth in these regulations shall be accessible to the
Board on request.
The manual shall include:
(a) table of organization, including channels of
communications and a description of job classifications; 100 Organization Structure
100.3 (a) Supervising Probation Officer -
Senior Responsibilities
☒ ☐ ☐
100.5 Correction Officer Responsibilities
1102.3 Communications
(b) responsibility of the probation department, purpose
of programs, relationship to the juvenile court, the
101.1 Responsibility and Scope of Juvenile
Juvenile Justice/Delinquency Prevention Commission
Facility
or Probation Committee, probation staff, school ☒ ☐ ☐
personnel and other agencies that are involved in
juvenile facility programs;
(c) responsibilities of all employees;
102.3
☒ ☐ ☐
(d) initial orientation and training program for
employees;
300 Staff Orientation and Training
☒ ☐ ☐
(e) initial orientation, including safety and security issues
and anti-discrimination policies, for support staff, 300 Staff Orientation and Training
contract employees, school, mental/behavioral health 304 Health Care Orientation
and medical staff, program providers and volunteers; ☒ ☐ ☐ 305 Volunteer and Intern Orientation and
Training
(f) maintenance of record-keeping, statistics and
communication system to ensure:
304.5
☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(1) efficient operation of the juvenile facility; 100.1 Purpose and Scope of the Facility
☒ ☐ ☐
(2) legal and proper care of youth; 100.7.2 Agency Responsibility
☒ ☐ ☐
(3) maintenance of individual youth's records; 205.3
☒ ☐ ☐
(4) supply of information to the juvenile court and
205.4
those authorized by the court or by the law; and, ☒ ☐ ☐
(5) release of information regarding youth. 205.4
☒ ☐ ☐
305.4 Volunteers/Interns
(g) ethical responsibilities; 1200.2 Recruitment
☒ ☐ ☐
1200.5 Background Check
1201.5.2 (g) Standards of Conduct
300.3.1 Bullet 10
512.4
706.4
1000.3 Programs and Education
(h) trauma-informed approaches;
☒ ☐ ☐ The VCPAJF policy includes trauma and
trauma-informed approaches in each
element of facility operations, including
training and orientation of staff, admission,
classification, searches, healthcare, hygiene,
education, and programming.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
300.3.1 Bullet 10
500.1 Admission
1000.3 (m)
1002.6
1003.3 Education
(i) culturally responsive approaches;
☒ ☐ ☐
The VCPAJF policy includes cultural
responses in each element of facility
operations, including training and orientation
of staff, admission, classification, hygiene,
education, and programming.
500.5
501.3
513 3; 513.4.3; 513.5; 513.10
605.2
701.6
802.6.1
1000.3 (b)
(j) gender responsive approaches;
☒ ☐ ☐
The VCPAJF policy includes gender
responses in each element of facility
operations including training and orientation
of staff, admission, classification, searches,
healthcare, hygiene, education, and
programming.
(k) a non-discrimination provision that provides that all
youth within the facility shall have fair and equal access 605 Non-Discrimination Provision (NDP)
to all available services, placement, care, treatment, and 605.2
benefits, and provides that no person shall be subject to
discrimination or harassment on the basis of actual or
perceived race, ethnic group identification, ancestry,
☒ ☐ ☐ The VCPAJF has the NDP posted in all living
national origin, immigration status, color, religion,
units and Intake.
gender, sexual orientation, gender identity, gender
expression, mental or physical disability, or HIV status,
including restrictive housing or classification decisions
based solely on any of the above mentioned categories;
(l) storage and maintenance requirements for any
chemical agents related security devices, and weapons 202 Inventory and Supplies
and ammunition, where applicable; ☒ ☐ ☐ 209.3 (i) Weapons Storage
(m) establishment of procedures for collection of Medi-
Cal eligibility information and enrollment of eligible 500.5.4
☒ ☐ ☐
youth; and,
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(n) establishment of a policy that prohibits all forms of
sexual abuse, sexual assault and sexual harassment. 303 Sexual Abuse and Harassment Training
The policy shall include an approach to preventing, 501.6.1 Classification
detecting and responding to such conduct and any 502.4 (n) Orientation
retaliation for reporting such conduct, as well as a ☒ ☐ ☐ 503.3 Assessments
provision for reporting such conduct by youth, staff or a 606.5 Grievances
third party. 701.4 (j) Screenings
1325 FIRE SAFETY PLAN
The facility administrator shall consult with the local fire 401 Fire Safety
department having jurisdiction over the facility, or with
the State Fire Marshal, in developing a plan for fire 401.3 (b)
☒ ☐ ☐
safety which shall include, but not be limited to:
(a) a fire prevention plan to be included as part of the
manual of policy and procedures;
(b) monthly fire and life safety inspections by facility
staff with two-year retention of the inspection record;
401.3 (c)
We reviewed Fire and Life Safety Inspections
for the VCPAJF from April 2022 to June 2023.
The agency has a systematic approach to the
inspection in every space of the facility,
recording any non-working or required
elements of space to confirm it is safe for
youth and staff.
☒ ☐ ☐
The form includes: Fire Extinguishers, Fire
Alarms, First Aid Kits, Exit/Evacuation
Routes, Storage Areas, Electric/Lighting, Lint
Traps/Dryer Exhaust, Flashlights, Door
Locks, Cameras/Monitors, Panic Alarms,
Radios and Cell Phones, and AED’s. Each
area is checked by one of the CSO III’s. If
there is a required fix or referral to
maintenance, it is tracked by administration
to ensure it is addressed and remedied.
(c) fire prevention inspections as required by Health
and Safety Code Section 13146.1(a) and (b);
401.7
☒ ☐ ☐
The last fire inspection for the VCPAJF was
completed on April 18, 2023.
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(d) an evacuation plan;
403 Evacuation Plan
☒ ☐ ☐
(e) documented fire drills not less than quarterly;
401.3 (e)
The agency completes Emergency Fire,
Earthquake, or Emergency Procedures Drills
monthly. We reviewed documentation for all
drills from April 2022 to June 2023. The
facility conducts monthly drills as a training
mechanism while walking through the facility
to ensure staff individually know how to react
☒ ☐ ☐
given an emergency “training” drill.
Documented evacuation drills of youth by
unit occur quarterly, as required by
regulation.
We provided technical assistance to ensure
full evacuations of all youth, at least annually,
as required by VCPAJF Policy 403.4.
(f) a written plan for the emergency housing of youth in
the case of fire; and,
400.12
☒ ☐ ☐
(g) development of a fire suppression pre-plan in
cooperation with the local fire department.
401.3
☒ ☐ ☐
1326 SECURITY REVIEW
Each facility administrator shall develop policies and 209.3
procedures to annually review, evaluate, and document
security of the facility. The review and evaluation shall
include internal and external security, including, but not
Chief Probation Officer Gina Johnson
limited to, key control, equipment, and staff training.
☒ ☐ ☐ completed a memo outlining an
Administrative and Supervisor review of
Security practices conducted on April 19,
2023, and May 30, 2023.
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1327 EMERGENCY PROCEDURES
The facility administrator shall develop facility-specific 400 Facility Emergencies
policies and procedures for emergencies that shall
include, but not be limited to:
Chief Probation Officer Gina Johnson
completed a memo outlining an
Administrative and Supervisor review of
Emergency Procedures conducted on April
19, 2023, and May 30, 2023.
☒ ☐ ☐
It was noted during the meetings several
Emergency Procedures need updating which
is being done now. The agency is compliant
and will forward any new policies or
operational procedures relating to this when
completed.
400.3 (a), (b) and (c)
400.7 Disturbances
(a) escape, disturbances, and the taking of hostages;
☒ ☐ ☐ 400.8 Hostages
400.9 Escape
400.3 (d) and (i)
(b) civil disturbance, active shooter and terrorist
400.7 Disturbances
attack; ☒ ☐ ☐
400.6 Active Shooter and Terrorist Attack
400.3 (e)
(c) fire and natural disasters;
☒ ☐ ☐ 401
400.3 (f)
(d) periodic testing of emergency equipment;
☒ ☐ ☐ 402.5
400.3 (h)
(e) emergency evacuation of the facility; and
☒ ☐ ☐ 403
(f) a program to provide all youth supervision staff
400.13
with an annual review of emergency procedures. ☒ ☐ ☐
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1328 SAFETY CHECKS
The facility administrator shall develop and implement 505.3 (a), (b) and (d)
policy and procedures that provide for direct visual
observation of youth at a minimum of every 15 minutes,
at random or varied intervals during hours when youth
We reviewed safety checks audits for the
are asleep or when youth are in their rooms, confined in
months of December 2022, January and April
holding cells or confined to their bed in a dormitory.
2023 for all occupied facility operational
Supervision is not replaced, but may be supplemented
units. Overall, the electronic checks are
by, an audio/visual electronic surveillance system
random, typically between 11 and 15
designed to detect overt, aggressive or assaultive
minutes, recording the youth room and the
behavior and to summon aid in emergencies. All safety
total number of youths in the unit.
checks shall be documented with the actual time the
check is completed.
☒ ☐ ☐
A CSO III now reviews safety checks for all
units, checking for late or missed checks, as
well as patterned checks. We found few late,
missed, or patterned checks. The staff
responsible and the circumstance is
recorded in the Supervisors Log to allow the
incident to be formally addressed. Our
recommendation is that the audits occur
daily, to ensure all are done per policy, by the
graveyard CSO III.
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1329 SUICIDE PREVENTION PLAN
The facility administrator, in collaboration with the 706.4 Suicide Prevention Plan
healthcare and behavioral/mental health administrators,
shall plan and implement written policies and
procedures which delineate a Suicide Prevention Plan.
Youth are administered the MAYSI-2 upon
The plan shall consider the needs of youth experiencing
admission or whenever a significant event
past or current trauma. Suicide prevention responses
occurs while in custody. The assessment tool
shall be respectful and in the least invasive manner
identifies cautions or warnings for behavior
consistent with the level of suicide risk. The plan shall
involving suicidal ideation or tendencies. A
include the following elements:
Classification Questionnaire during booking
to determine appropriate housing and
supervision status also is responsive to this
regulation.
The agency has had three suicide incidents
that resulted in a safety room placement, one
involving a female youth from the
Commitment Program, since April 2022. The
☒ ☐ ☐ female youth was transported to the
Emergency Room. There have been other
incidents of youth with a caution or warning
from the MAYSI assessment, 13 total, that
have been referred to Behavior Health.
Youth are placed on special watch in these
situations, pending being seen and/or
evaluated by Behavior Health.
We note Behavior Health has taken a much
more involved and consistent approach to all
intake, assessment, and crisis incidents,
observed by documented responses to
incidents. The clinicians are proactive and
engaged with the processes and staff
engagement for successful treatment
approaches to youth in crisis.
(a) Suicide prevention training as required in Section
1322, Youth Supervision Staff Orientation, and Training 300.3.1 Bullet 4
and the Juvenile Corrections Officer Core Course. ☒ ☐ ☐ 304.5 (e)
(b) Screening, Identification Assessment and
Precautionary Protocols 501.3 Bullet 8
(1) All youth shall be screened for risk of suicide at ☒ ☐ ☐ 701.4 (c)
intake and as needed during detention.
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(2) All youth supervision staff who perform intake
processes shall be trained in screening youth for risk
☒ ☐ ☐ 501.11 Staff Training in Classification
of suicide.
(3) All youth who have been identified during the
intake screening process to be at risk of suicide shall
701.4 (c)(2)
be referred to behavioral/mental health staff for a ☒ ☐ ☐
suicide risk assessment.
(4) Precautionary protocols shall be developed to
ensure the youth’s safety pending the
☒ ☐ ☐ 706.5
behavioral/mental health assessment.
(c) Referral process to behavioral/mental health staff for
assessment and/or services. 703.4 ⁋ 2
☒ ☐ ☐ 706.3
(d) Procedures for monitoring of youth identified at risk
for suicide. 706.3
☒ ☐ ☐ 706.5
(e) Safety Interventions
(1) Procedures to address intervention protocols for
☒ ☐ ☐
youth identified at risk for suicide which may include,
but are not limited to:
(A) Housing consideration
501.3
☒ ☐ ☐
706.5 ⁋
1
(B) Treatment strategies including trauma-
informed approaches
706.4
☒ ☐ ☐
(2) Procedures to instruct youth supervision staff
how to respond to youth who exhibit suicidal
FPO.07.F, 6 Caution Status
behaviors.
☒ ☐ ☐
FPO.07.F, 2
(f) Communication
(1) The intake process shall include communication
701.4, C-1
with the arresting officer and family guardians
☒ ☐ ☐
regarding the youth’s past or present suicidal
ideations, behaviors or attempts.
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(2) Procedures for clear and current information
sharing about youth at risk for suicide with youth
supervision, healthcare, and behavioral/mental 706.3 ⁋ 1
health staff.
706.8 ⁋ 1 and 2
☒ ☐ ☐
FPO.07.F, 2 (a)
(g) Debriefing of Critical Incidents Related to Suicides or
Attempts
(1) Process for administrative review of the 706.9 ⁋ 1 Debriefing
☒ ☐ ☐
circumstances and responses proceeding, during
and after the critical incident.
(2) Process for a debriefing event with affected
706.9 ⁋ 2
staff. ☒ ☐ ☐
(3) Process for a debriefing event with affected
youth.
706.9 ⁋ 2
☒ ☐ ☐
(h) Documentation
(1) Documentation processes shall be developed to 706.6 Observation Logs
ensure compliance with this regulation ☒ ☐ ☐ 706.7 Documentation
Youth identified at risk for suicide shall not be denied the
opportunity to participate in facility programs, services 706.4 ⁋ 2
and activities which are available to other non-suicidal
youth, unless deemed necessary for the safety of the
youth or security of the facility. Any deprivation of ☒ ☐ ☐
programs, services or activities for youth at risk of
suicide shall be documented and approved by the
facility manager.
1340 REPORTING OF LEGAL ACTIONS
101.5
Each facility shall submit to the Board a letter of
notification on each legal action, pertaining to conditions
☒ ☐ ☐ There are no legal issues pending at the
of confinement, filed against persons or legal entities
VCPAJF.
responsible for juvenile facility operation.
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1341 DEATH AND SERIOUS ILLNESS OR INJURY
OF A YOUTH WHILE DETAINED 518.3 In Custody Death
518.3 ⁋ 3 In Custody Death Notifications
(1) Death of a Youth.
(a) The facility administrator, in cooperation with
the health administrator and the behavioral/mental
health director, shall develop written policies and ☒ ☐ ☐
procedures in the event of the death of a youth while
detained, which include notifications to necessary
parties, which may include the Juvenile Court, the
parent, guardian or person standing in loco parentis
and the youth’s attorney of record.
(b) The health administrator, in cooperation with the
facility administrator, shall develop written policies
and procedures to assure there is a medical and 518.4 ⁋ 2
operational review of every in-custody death of a
youth. The review team shall include the facility
☒ ☐ ☐
administrator and/or facility manager, the health
administrator, the responsible physician and other
health care and supervision staff who are relevant to
the incident.
(c) The administrator of the facility shall provide to
the Board a copy of the report submitted to the
Attorney General under Government Code Section 518.3 ⁋ 5
☒ ☐ ☐
12525. A copy of the report shall be submitted to the
Board within 10 calendar days after the death.
(d) Upon receipt of a report of the death of a youth
from the administrator, the Board may within 30
The facility administrators are aware of this
calendar days inspect and evaluate the juvenile
regulation.
facility, jail, lockup or court holding facility pursuant to
☒ ☐ ☐
the provisions of this subchapter. Any inquiry made
by the Board shall be limited to the standards and
requirements set forth in these regulations.
(2) Serious Illness or Injury of Youth.
(a) The facility administrator, in cooperation with 700.3.1 (b)5
the health administrator, shall develop written
700.3.1 (b)14
policies and procedures for the notification to
☒ ☐ ☐
necessary parties, which may include the Juvenile
700.3.1 (b)18 Responsibilities of the Health
Court, the parent, guardian or person standing in
Care Administrator (Illness)
loco parentis and the youth’s attorney of record in the
case of a serious illness or injury of a youth. 801.7 Youth Safety (Injury)
1342 POPULATION ACCOUNTING
Each juvenile facility shall submit required population and 1101.6.1
profile survey reports to the Board within 10 working days ☒ ☐ ☐
after the end of each reporting period, in a format to be
provided by the Board.
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1343 JUVENILE FACILITY CAPACITY (EXCERPT)
When the number of youth detained in a living unit of a 1101.3
juvenile facility exceeds its rated capacity for more than
☒ ☐ ☐
fifteen (15) calendar days in a month, the facility
administrator shall provide a crowding report to the
Board in a format provided by the Board.
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1350 ADMITTANCE PROCEDURES
The facility administrator shall develop and implement 500.1 Admission
written policies and procedures for admittance of youth
that emphasize respectful and humane engagement
with youth, and reflect that the admission process may
The VCPAJF has a comprehensive
be traumatic to youth who may have already
admission process and includes many
experienced trauma. Policies shall be trauma-informed,
advisements and assessments to assist in
culturally relevant, and responsive to the language and
determining appropriate classification.
literacy needs of youth. In addition to the requirements
These tools articulate detention criteria,
of Sections 1324 and 1430 of these regulations:
housing location, security status, suicidal
tendencies, and the propensity for violence
or victimization. The intake and booking
process provides information to acclimate
the youth to detention as well as orient the
youth to expectations, rights, and rules.
Staff complete a Juvenile Risk Assessment
Tool to determine if detention is appropriate,
with override and mitigation factors. If
detained, the MAYSI-2 Questionnaire and
Classification Assessment Questionnaire are
administered to assist in placement and any
security status needs. Youth then
acknowledge the Prison Rape Elimination
☒ ☐ ☐
Act (PREA) policy as it relates to Sexual
Abuse, Harassment, and Assault. The Zero
Tolerance for Gang or Violence is also part of
the admission documents the youth signs to
acknowledge. Added this cycle is the Youth
Bill of Rights and Ombudsman information
provided through the Office of Youth and
Community Restoration.
This process is abbreviated for commitment
youth, including the re-assessment for
housing in the short- or long-term program.
We reviewed numerous intake and remand
Admission paperwork and documentation
outlining the procedures in policy and
regulation. We found the process is lengthy
and exceeds regulatory requirements to
make the best admission decisions. When
committed, youth receive a re-assessment to
make appropriate housing decisions.
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(a) the admittance process shall include:
(1) Access to two free phone calls within one hour of
500.8
admittance in accordance with the provisions of ☒ ☐ ☐
Welfare and Institution Code Section 627;
(2) Offer of a shower; 500.9
☒ ☐ ☐
(3) Documented secure storage of personal
500.7.2
belongings; ☒ ☐ ☐
(4) Offer of food upon arrival; 500.5.5
☒ ☐ ☐
(5) Screening for physical and behavioral health
304.6 Initial Youth Screening
and safety issues, intellectual or developmental
☒ ☐ ☐ 501.3 Bullet 10
disabilities;
(6) Screening for physical and developmental
disabilities in accordance with Sections 1329, 1413, 501.3 Bullet 10
☒ ☐ ☐
and 1430 of these regulations;
(7) Contact with Regional Center for the
Developmentally Disabled for youth that are
702.7 Last Paragraph
suspected of or identified as having a
☒ ☐ ☐
developmental disability, pursuant to Section 1413;
and,
501.12
(8) Procedures consistent with Section 1352.5.
☒ ☐ ☐
802.6.1
(b) juvenile hall administrators shall establish written
criteria for detention that considers the least restrictive
☒ ☐ ☐ 500.3 (h)
environment.
(c) juvenile camps and post-dispositional programs in
juvenile halls shall develop policies and procedures that
500.5.3
advise the youth of the estimated length of stay, inform
them of program guidelines and provide written ☒ ☐ ☐
screening criteria for inclusion and exclusion from the
program.
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(d) juvenile halls shall develop policies and procedures
that advise any committed youth of the estimated length
☒ ☐ ☐ 500.5.3
of his/her stay.
1350.5 SCREENING FOR THE RISK OF SEXUAL
ABUSE
501.3
The facility administrator shall develop and implement 701.4 (j) (1)
written policies and procedures to reduce the risk of
sexual abuse by or upon youth. The policy shall require The MAYSI-2 and Classification
☒ ☐ ☐
facility staff to assess each youth within 72 hours of Questionnaire are responsive to this
admission based on the following information: regulation. Youth also watch a PREA video
and read agency policies on how to report
sexual abuse, assault, or discrimination.
(a) Prior sexual victimization or abusiveness; 501.3 Bullet 19 and 21
☒ ☐ ☐
(b) Gender nonconforming appearance or manner; or
identification as lesbian, gay or bisexual, transgender,
501.3 Bullet 20 and 24
queer or intersex, and whether the youth may, therefore, ☒ ☐ ☐
be vulnerable to sexual abuse;
(c) Current charges and offense history; 501.3 Bullet 4-6
☒ ☐ ☐
(d) Age; 501.3 Bullet 1
☒ ☐ ☐
(e) Level of emotional and cognitive development; 501.3 Bullet 7
☒ ☐ ☐
(f) Physical size and stature; 501.3 Bullet 3
☒ ☐ ☐
(g) Mental illness or mental disabilities; 501.3 Bullet 10 and 13
☒ ☐ ☐
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(h) Intellectual or developmental disabilities; 501.3 Bullet 14
☒ ☐ ☐
(i) Physical disabilities; 501.3 Bullet 12
☒ ☐ ☐
(j) The youth’s perception of vulnerability; and, 501.3 Bullet 22
☒ ☐ ☐
(k) Any other specific information about the individual
youth that may indicate heightened needs for
501.3 Bullets 1-24
supervision, additional safety precautions, or separation ☒ ☐ ☐
from certain other youth.
Staff shall ascertain this information through
conversations with the youth during the admittance
501.4
process, medical and behavioral health screenings;
during classification assessments; and by reviewing ☒ ☐ ☐
court records, case files, facility behavioral records, and
other relevant documentation from the youth’s files.
The facility administrator shall implement appropriate
controls on the dissemination of information within the
501.3 Last Paragraph
facility relative to responses received pursuant to this
assessment in order to ensure that sensitive information ☒ ☐ ☐
is not exploited to the youth’s detriment by staff or other
youth.
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1351 RELEASE PROCEDURES
The facility administrator shall develop and implement 516 Releases
written policies and procedures for release of youth from
custody which provide for:
The process for release from all VCPAJF
programs includes transition planning and
linkage to appropriate community services.
We were provided and reviewed the Ventura
County Community Resource List which
outlines available services in different
geographical areas of the county.
The agency identifies youth needing special
release services in the Multi-Disciplinary
Team (MDT), Critical Care Team (CCT), and
☒ ☐ ☐
Treatment Team (TTM) meetings which
occur weekly. Participation includes
representatives from Behavior Health,
Medical, and the VCOE school personnel, as
well as CSO or DPO probation staff.
We reviewed the Release Form, which
includes the youth’s information at booking,
disposition, release authorization, and
signature and identification of the person the
youth is released to. Also included is
acknowledgment of property released to the
youth.
(a) verification of identity/release papers; ☒ 516.3 (a)
☐ ☐
516.3 (d)
(b) return of personal clothing and valuables;
☒ ☐ ☐
(c) notification to the youth's parents or guardian; 516.3 (l)
☒ ☐ ☐
(d) notification to the facility health care provider in
accordance with Sections 1408 and 1437 of these
☒ ☐ ☐ 516.3 (c) and (m)
regulations, for coordination with outside agencies; and,
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(e) notification of school staff; 516.3 (n)
☒ ☐ ☐
(f) notification of facility mental health personnel. 516.3 (m)
☒ ☐ ☐
The facility administrator shall develop and implement
policies and procedures for post-disposition youth to
516.3 (g) and (n)
coordinate the provision of transitional and reentry
services including, but not limited to, medical and
behavioral health, education, probation supervision and
community-based services. The MDT and TTM process articulates the
☒ ☐ ☐ specific services a youth needs post-
commitment, based on the programs
received while in the program, and transition
services available.
The facility administrator shall develop and implement
written policies and procedures for the furlough of youth
526.4
from custody.
Furloughs have not occurred since Covid,
☒ ☐ ☐ however, the agency is working on a process
for them to start back up with specific field
probation staff responsibilities applied to re-
entry services and supervision.
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1352 CLASSIFICATION
The facility administrator shall develop and implement 501 Classification
written policies and procedures on classification of youth
for the purpose of determining housing placement in the
facility.
The Classification Questionnaire used at
Such procedures shall: booking assists staff in determining the most
appropriate placement of youth at admission
and to address observed security or safety
needs of youth.
We reviewed admission and commitment
documentation including this form and found
it to be consistent with regulation
requirements and policy. Additionally, youth
are re-classified based on circumstances as
they occur while in the facility via the Critical
Case Team meetings. This is memorialized in
the youth’s electronic file, the Ventura County
Integrated Justice Information System.
☒ ☐ ☐
It is significant to note the agency works with
medical and behavioral health staff to assist
in special classification needs, as well as
reviewing the youth’s behavior which may
prompt a new classification.
We provided technical assistance promoting
an inclusive classification system and to not
rely on youth age as the primary tool. With
the recent clarification of sight and sound
separation of youth via AB 134, the agency is
going to re-review all classification systems
and move youth to the appropriate
classification considering all facets in
regulation.
(a) provide for the safety of the youth, other youth,
facility staff, and the public by placing youth in the
501.7
appropriate, least restrictive housing and program
settings. Housing assignments shall consider the need ☒ ☐ ☐
for single, double or dormitory assignment or location
within the dormitory;
(b) consider facility populations and physical design of
the facility;
501.8
☒ ☐ ☐
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(c) provide that a youth shall be classified upon
admittance to the facility; classification factors shall
501.3
include, but not be limited to: age, maturity,
sophistication, emotional stability, program needs, legal
☒ ☐ ☐
status, public safety considerations, medical/mental
health considerations, gender and gender identity of the
youth;
(d) provide for periodic classification reviews, including
provisions that consider the level of supervision and the
501.6.1 Periodic Reviews
youth's behavior while in custody; and,
501.6.2 Staff Initiated Reviews
Classification status is reviewed by the CSO
☒ ☐ ☐ III, SDPO, and/or the Watch Commander as
necessary to ensure youth are reintegrated
in the least restrictive classification as
necessary based on their security, medical,
or mental health status.
(e) provide that facility staff shall not separate youth from
the general population or assign youth to a single
occupancy room based solely on the youth's actual or 501.10.1 ⁋ 2 Non-Discrimination Provision
perceived race, ethnic group identification, ancestry,
605.2 ⁋ 1 Non-Discrimination Provision
national origin, color, religion, gender, sexual
orientation, gender identity, gender expression, mental
☒ ☐ ☐
or physical disability, or HIV status. This section does
not prohibit staff from placing youth in a single
occupancy room at the youth's specific request or in
accordance with Title 15 regulations regarding
separation.
(f) facility staff shall not consider lesbian, gay, bisexual,
transgender, questioning or intersex identification or
status as an indicator of likelihood of being sexually ☒ ☐ ☐ 501.10 ⁋ 3
abusive.
1352.5 TRANSGENDER AND INTERSEX YOUTH.
The facility administrator shall develop written policies 501.12 Transgender and Intersex Youth
and procedures ensuring respectful and equitable
☒ ☐ ☐
treatment of transgender and intersex youth. The 501.6.1 ⁋ 2
policies shall provide that:
(a) Facility staff shall respect every youth’s gender
identity and shall refer to the youth by the youth’s
501.12 I-A
preferred name and gender pronoun, regardless of the
youth’s legal name. Facilities may prohibit the use of
☒ ☐ ☐
gang or slang names or names that otherwise
compromise facility operations as determined by the
facility manager or designee, and shall document any
decision made on this basis.
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(b) Facility staff shall permit youth to dress and present
themselves in a manner consistent with their gender
501.12 I-B
identity and shall provide youth with the institution’s ☒ ☐ ☐
clothing and undergarments consistent with their gender
802.6.1 Clothing Issue
identity.
(c) Facility staff shall house youth in the unit or room that
best meets their individual needs and promotes their
500.6.2
safety and well-being. Staff may not automatically house
youth according to their external anatomy and shall
501.3 Bullet 9, 19-22
document the reasons for any decision to house youth ☒ ☐ ☐
in a unit that does not match their gender identity. In 501.12 I-C
making a housing decision, staff shall consider the
youth’s preferences, as well as any recommendations
from the youth’s health or behavioral health provider.
(d) Facility administrators shall ensure that transgender
and intersex youth have access to medical and
501.12 I-D
behavioral health providers qualified to provide care and ☒ ☐ ☐
treatment to transgender and intersex youth.
702.7 (f)
(e) Consistent with the facility’s reasonable and
necessary security considerations and physical plant,
501.12 I-E
facility staff shall make every effort to ensure the safety
☒ ☐ ☐
and privacy of transgender and intersex youth when the
802.11 Showers
youth are using the bathroom or shower, or dressing or
undressing.
Facility staff shall not conduct physical searches of any
youth for the purpose of determining the youth’s
501.12 II-A and B
anatomical sex. Whenever feasible, the facility shall
respect the youth’s preference regarding the gender of ☒ ☐ ☐
513.5
the staff member who conducts any search of the youth.
POC.04.F.3
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1353 ORIENTATION
The facility administrator shall develop and implement 502 Youth Orientation
written policies and procedures to orient a youth prior to 502.2
placement in a living area. Both written and verbal
information shall be provided and supplemented with The intake and booking process for all
video orientation if feasible. Provision shall be made to VCPAJF includes a review of facility
provide accessible orientation information to all detained operations, youth rights, and the rules that
youth including those with disabilities, limited literacy, or guide youth through the program. The
English language learners. Orientation shall include Orientation for each facility type includes all
information that addresses: aspects of programming and activities while
detained. Once committed, youth go through
a review of expectations and program
components experienced for long-term
stays.
Facility expectations and opportunities are
☒ ☐ ☐
explained in both verbal and written formats
to allow a youth to understand the material
while in-custody. The individual program is
outlined in a handbook to promote progress
through positive behavior to earn incentives.
We provided technical assistance to
consolidate the booking forms requiring
youth acknowledgment relating to the
Ombudsman and Youth Bill of Rights for a
more streamlined approach and training
opportunity for youth to better understand the
program expectations. The new Youth
Handbook is descriptive as it relates to all
Orientation components.
(a) facility rules including contraband and searches and
disciplinary procedures;
502.4 (a)
☒ ☐ ☐
(b) facility’s system of positive behavior interventions
and supports, including behavior expectations, 502.4 (b)
incentives that youth will receive for complying with 1009.3 (a) BMP
☒ ☐ ☐
facility rules, and consequences that may result when
youth violate the rules of the facility;
(c) age appropriate information that explains the
facility’s policy prohibiting sexual abuse and sexual 502.4 (n)
harassment and how to report incidents or suspicions of ☒ ☐ ☐
sexual abuse or sexual harassment;
(d) identification of key staff and their roles;
502.4 (v)
☒ ☐ ☐ 1208.7 (a)
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(e) the existence of the grievance procedure, the steps
that must be taken to use it, the youth’s right to be free 502.4 (e)
of retaliation for reporting a grievance, and the name of ☒ ☐ ☐
the person or position designated to resolve the issue;
(f) access to legal services and information on the
502.4 (i)
court process; ☒ ☐ ☐
(g) access to routine and emergency health and mental
502.4 (f)
health care; ☒ ☐ ☐
(h) access to education, religious services, and
502.4 (g)
recreational activities; ☒ ☐ ☐
(i) housing assignments; 502.4 (h)
☒ ☐ ☐
(j) opportunity for personal hygiene and daily showers
including the availability of personal care items 502.4 (d)
☒ ☐ ☐
(k) rules and access to correspondence, visits and
telephone use; 502.4 (c)
☒ ☐ ☐
(l) availability of reading materials, programming, and
other activities; 502.4 (k)
☒ ☐ ☐
(m) facility policies on the use of force, use of restraints,
chemical agents and room confinement; 502.4 (l), (m) and (w)
☒ ☐ ☐
(n) immigration legal services; 502.4 (p)
☒ ☐ ☐
(o) emergencies including evacuation procedures; 502.4 (r)
☒ ☐ ☐
(p) non-discrimination policy and the right to be free from
physical, verbal or sexual abuse and harassment by 303.1 (g)
other youth and staff; 502.4 (n) and (u)
☒ ☐ ☐
603.1
(q) availability of services and programs in a language
other than English if appropriate;
502.4 Last 2 Paragraphs
☒ ☐ ☐
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(r) the process for requesting different housing,
education, programming and work assignments;
502.4 (x)
☒ ☐ ☐
(s) a process for which parents/guardians receive
information regarding the youth’s stay in the facility that
502.4 (y)
at a minimum includes answers to frequently asked
☒ ☐ ☐
questions and provides contact information for the
facility, medical, school and mental health; and,
(t) a process by which youth may request access to Title
15 Minimum Standards for Juvenile Facilities.
502.4 (z)
☒ ☐ ☐
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1354 SEPARATION
The facility administrator shall develop and implement 519 Youth Separation
written policies and procedures that address:
519 Second to last ⁋
500.6.2
The VCPAJF agency has a well-documented
practice of recording a youth’s request to
decline participation in unit programs and
activities. There has been some confusion
amongst staff for what is referred to as
‘decliners’ versus those that self-separate for
protective custody reasons.
We reviewed self-separation half sheets,
revealing the youth’s request for non-
participation in an activity or program,
including their signature detailing the reason.
These are short-term separations and are
☒ ☐ ☐ well documented.
We also reviewed four incidents of long-term
self-separations that turned into a re-
classification. The incident report or youth’s
signed request to self-separate and notes
from Critical Case Meetings articulated
efforts by staff and/or Behavior Health to
reintegrate the youth. The case logs also
detail unit staff efforts to get a youth back into
programming. These long-term ‘separations’
are a classification the agency is working on
to facilitate needs and activities in an
environment where the youth feels safe to
engage in unit activities.
We provided technical assistance to
encourage a ‘re-branding’ for these youth
that is positive-focused.
(a) separation of youth for reasons that include, but are
not be limited to, medical and mental health conditions, 519 Medical Separation
assaultive behavior, disciplinary consequences and 519.3 Self Separation
protective custody. 501.7
☒ ☐ ☐
600.3.1
601.4
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(b) consideration of positive youth development and
trauma-informed care.
519 ⁋ 3
☒ ☐ ☐
501.7.1 ⁋ 1
(c) separated youth shall not be denied normal
privileges available at the facility, except when
necessary to accomplish the objective of separation. 519 ⁋ 4
☒ ☐ ☐
501.7.1 ⁋ 2
(d) when the objective of the separation is discipline,
Title 15 Section 1390 shall apply.
519 ⁋ 5
☒ ☐ ☐
501.7.1 ⁋ 1
(e) when separation results in room confinement, the
separation shall occur in accordance with Welfare and
Institutions Code Section 208.3 and Section 1354.5 of ☒ ☐ ☐ 519 ⁋ 1
these regulations.
601 Room Confinement
(f) policies and procedures shall ensure a daily review
of separated youth to determine if separation remains
necessary. 519 Last ⁋
☒ ☐ ☐
501.7.1 ⁋ 4
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1354.5 ROOM CONFINEMENT
(a) The facility administrator shall develop and 601 Room Confinement (RC)
implement written policies and procedures addressing
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
The VCPAJF agency reported 119 incidents
208.3. The placement of a youth in room confinement
of Room Confinement from April 2022 to
shall be accomplished in accordance with the following
June 2023. This is slightly more than the 50
guidelines:
in 2021, but less than the previous ‘time outs’
recorded in 2018-2019 before the regulation
and legislation were implemented.
After a safety and security-related incident,
staff initiated an RC Log which prompts them
to initiate specific documentation practices
and alerts to senior staff. Agency policy and
procedures include the staff recording
behavior and attempts to remove the youth
from RC status as soon as the threat is
minimized. When this happens, youth must
agree to respond with appropriate behaviors
in a contract format to document the
expectations when removed. In most cases,
the youth return to regular unit activities.
☒ ☐ ☐
We reviewed 7 RC incidents and 10 UF
incidents resulting in RC, including 4 youth in
the commitment program, and found the
agency utilizes RC for applicable behavior-
related incidents that pose a safety and
security risk to other youth, staff, or the facility
operations.
Staff and supervisors provided appropriate
responses to reintegrate youth to
programming, including behavior health input
and involvement. Safety check logs and
behavior health intervention documentation
was included in the reviewed incidents.
The agency has adopted an early morning
review of youth on RC going into the
following day in an effort to return the youth
to normal activities as the youth starts their
day.
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(1) Room confinement shall not be used before
other, less restrictive, options have been attempted
601.4 (a)
and exhausted, unless attempting those options
☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or
☒ ☐ ☐ 601.4 (b)
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health
☒ ☐ ☐ 601.4 (c)
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room
601.4.5 (a)
confinement for a period of four hours, staff shall do one ☒ ☐ ☐
or more of the following:
(1) Return the youth to general population. 601.4.5 (a) (1)
☒ ☐ ☐
(2) Consult with mental health or medical staff. 601.4.5 (a) (2)
☒ ☐ ☐
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate
☒ ☐ ☐ 601.4.5 (a) (3)
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following:
601.4.5 (b)
☒ ☐ ☐
(A) Document the reasons for room confinement
and the basis for the extension, the date and time
601.4.5 (b)(1)
the youth was first placed in room confinement,
☒ ☐ ☐
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to
☒ ☐ ☐ 601.4.5 (b)(2)
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee
☒ ☐ ☐ 601.4.5 (b)(3)
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth
601.1.1
in juvenile facilities and does not apply to normal ☒ ☐ ☐
sleeping hours.
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(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional
☒ ☐ ☐ 102.2.1
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires 400 Facility Emergencies
a significant departure from normal institutional 400.3.1 Emergency Suspension of
operations, including a natural disaster or facility- Standards
wide threat that poses an imminent and substantial ☒ ☐ ☐
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and
501.7.2
protect against the spread of a communicable
disease for the shortest amount of time required to
519 Medical Separation
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an
☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1355 INSTITUTIONAL ASSESSMENT AND PLAN
The facility administrator shall develop and implement 503 Case Management
written policies and procedures for assessment and
case planning.
The VCPAJF agency has an operational
process to complete and update Institutional
Assessments and Plans originally done by
the field DPO with ongoing updates by the
assigned CSO. Documents included the
original case plan with identified risks and
needs and ongoing plans targeting service
delivery for the youth. Educational progress
from Providence School, case notes and
number of hours with Behavior Health
Services, and youth chrono notes from
facility staff all contribute to the overall plan
while the youth is detained.
The plans are completed by staff and
reviewed by supervisors. The plan
☒ ☐ ☐ documents education, substance abuse,
aggression, anti-social environments, family,
impulsivity, remorse, and violence,
articulating a plan and discussion points for
each. The plan includes targeted program
progress by documenting if the objective or
goal was “met”, is “ongoing”, or “completed.”
We reviewed 10 ongoing IAP’s and 8
Transitional MDTs for 18 youth and found
each had an individualized plan, including the
most significant areas to address with
targeted services. The plans are reviewed
every 30 days to show progress or to re-
direct services. They are individualized and
inclusive of chrono entry discussions with the
youth. We have shared the agency plans with
other counties to demonstrate how
comprehensive and complete they are.
(a) Assessment:
The assessment is based on information collected
during the admission process with periodic review, 503.3 ⁋ 2
which includes the youth's risk factors, needs and
strengths including, but not limited to, identification of ☒ ☐ ☐
substance abuse history, educational, vocational,
counseling, behavioral health, consideration of known
history of trauma, and family strengths and needs.
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(b) Institutional Case Plan:
(1) A case plan shall be developed for each youth
503.3.1
held for at least 30 days or more and created within ☒ ☐ ☐
40 days of admission.
(2) The institutional plan shall include, but not be
limited to, written documentation that provides: ☒ ☐ ☐
(A) objectives and time frame for the resolution of
problems identified in the assessment;
503.3.1 (c)
☒ ☐ ☐
(B) a plan for meeting the objectives that includes
a description of program resources needed and
503.3.1 (b)
individuals responsible for assuring that the plan ☒ ☐ ☐
is implemented;
(3) periodic evaluation of progress towards meeting
the objectives, including periodic review and
☒ ☐ ☐ 503.3.1 (c)
discussion of the plan with the youth;
(4) a transition plan, the contents of which shall be
subject to existing resources, shall be developed for 503.3.1
post dispositional youth in accordance with Section ☒ ☐ ☐ 516.3; 516.5 (Releases)
1351; and,
(5) in as much as possible and if appropriate, the
plan, including the transition plan, shall be developed
503.3.1 (a)
with input from the family, supportive adults, youth,
☒ ☐ ☐
and Regional Center for the Developmentally
Disabled.
1356 COUNSELING AND CASEWORK SERVICES
503.5
The facility administrator shall develop and implement
703.3 Counseling Services
written policies and procedures ensuring the availability
POC.03.C, 1
of appropriate counseling and casework services for all
youth. Policies and procedures shall ensure:
The VCPAJF agency requires the assigned
CSO to meet with the youth weekly to ensure
he or she are progressing as expected or to
☒ ☐ ☐
assist with any difficulty in the program.
We reviewed case Chrono’s and Critical
Case Team meeting notes which address
any noted positive or negative behaviors
displayed in the program.
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(a) youth will receive assistance with needs or concerns
that may arise;
703.3 (a)(1)
☒ ☐ ☐
POC.03.C, 1(a)
(b) youth will receive assistance in requesting contact
with parents, other supportive adults, attorney, clergy,
703.3 (a)(2)
probation officer, or other public official; and,
☒ ☐ ☐
POC.03.C, 1 (b)
(c) youth will be provided access to available resources
to meet the youth’s needs.
703.3 (a)(2)
☒ ☐ ☐
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1357 USE OF FORCE
511 Use of Force (UF)
The facility administrator, in cooperation with the
511.3 ⁋ 6
responsible physician, shall develop and implement
511.3.3 Health Care assistance in developing
written policies and procedures for the use of force,
policy
which may include chemical agents. Force shall never
301 Use of Force-Administration Manual
be applied as punishment, discipline, retaliation or
treatment.
There were 138 UF incidents from April 2022
(a) At a minimum, each facility shall develop policies and to June 2023; 95 included physical force and
procedures which: 93 included the use of OC Spray at the
VCPAJF. There were 97 UF incidents in 2022
and 130 UF in 2021. This is down
significantly from the 183 in 2019 and 178 in
2018.
We reviewed 15 UF incident reports and
found the agency documents the efforts to
use the least restrictive option when
available. Staff are required to include the
circumstances leading to the use of force and
justify why force was used. The Supervisor
☒ ☐ ☐
on duty is also required to write a Use of
Force Report to include a summary of the
incident, Supervisor actions (including review
of video and interviews with involved staff),
and, lastly, the Supervisors Evaluation, which
details the assessment of staff response and
critique of the staff actions.
Each month, the agency conducts a UF
Review with a committee consisting of the
Facility Managers, Supervisors, and staff
involved. All documentation and video
footage are presented so the committee can
determine if the incident was within policy.
The outcome for the Review Committee is: A
– Within Policy; B – Within Policy but training
identified; C – Staff actions referred to
Professional Standards Unit; and D – Other.
Each of the incidents we reviewed were
cleared by Administration as ‘Within Policy’.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 511.3 ⁋ 1
1302 to ensure the safety and security of youth, staff, 511.3.1 Factors to determine
☒ ☐ ☐
others and the facility. Reasonableness of Force.
(2) outline the force options available to staff
including both physical and non-physical options and 511.5
define when those force options are appropriate. ☒ ☐ ☐ 511.5.1
FPO.08.F, 1
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(3) describe force options or techniques that are
expressly prohibited by the facility.
511.10 (l)
511.5.1 ⁋ 1 and 3
In policy, the only prohibited use of force is
the Carotid Hold. If time allows, the agency
☒ ☐ ☐ operational procedure promotes a use of
force team approach to an incident, including
a supervisor, to determine how and what type
of force is appropriate given the
circumstances. This process allows for a
‘natural’ de-escalation and the use of the
least amount of force necessary.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative 511.3.2 Duty to Intervene
action to immediately stop it. 511.6
☒ ☐ ☐
511.6.1
(5) define a standardized reporting format that
includes time period and procedure for documenting
511.6 Reporting UF
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff,
☒ ☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma
that may have been experienced by staff and /or the
youth involved.
(6) Include an administrative review and a system for
investigating unreasonable use of force. 511.9 UF Review
☒ ☐ ☐ 511.91 UF Review Committee
(7) define the role, notification, and follow-up
procedures required after use of force incidents for 511.6.1 Notifications to Medical, Mental
medical, mental health staff and parents or legal Health and Parent
☒ ☐ ☐
guardians. 517.5
(8) describe the limitations of use of force on
pregnant youth in accordance with Penal Code
512.9
Section 6030(f) and Welfare and Institutions Code ☒ ☐ ☐
Section 222.
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(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that:
(1) identify who is approved to carry and/or utilize 511.4 ⁋ 1 and 2
☒ ☐ ☐
chemical agents in the facility and the type, size and
the approved method of deployment for those
chemical agents.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or
511.4.1
the safety of others and only when de-escalation ☒ ☐ ☐
efforts have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents.
This shall include that youth who have been exposed 511.4 ⁋ 3 and 5
to chemical agents shall not be left unattended until ☒ ☐ ☐
FPO.08.L, 2
that youth is fully decontaminated or is no longer
suffering the effects of the chemical agent. FPO.08.L, 4
(4) define the role, notification, and follow-up
procedures required after use of force incidents
511.6.1 Notifications to Medical, Mental
involving chemical agents for medical, mental health ☒ ☐ ☐
Health and Parent
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for
511.6 (g)
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location
☒ ☐ ☐ FPO.08.I, 2
of use, decontamination procedures applied and
identification of any injuries sustained as a result of FPO.08. 4
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training
300.3.1
in use of force and chemical agents when appropriate ☒ ☐ ☐
511.4
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
511.10 (i)
☒ ☐ ☐
(2) acceptable chemical agents and the methods of
application.
511.4 ⁋ 2
☒ ☐ ☐
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health. ☒ ☐ ☐
511.10 (j)
(4) instruction on the Constitutional Limitations of
Use of Force.
511.10 (i)
☒ ☐ ☐
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(5) physical training force options that may require
the use of perishable skills. 511.3 ⁋ 2
☒ ☐ ☐ 511.10
(6) timelines the facility uses to define regular
training. 300 Training
☒ ☐ ☐ 511.10 Initial and Annual Training
1358 USE OF PHYSICAL RESTRAINTS
512. Use of Restraints UR
The facility administrator, in cooperation with the
301.8 Administration Manual
responsible physician and mental health director, shall
develop and implement written policies and procedures
There has been one use of restraint per this
for the use of restraint devices. Restraint devices
☒ ☐ ☐ regulation since April 2022, not involving a
include any devices which immobilize a youth's
Commitment youth.
extremities and/or prevent the youth from being
ambulatory.
This incident is the first UR since 2019.
Physical restraints may be used only for those youth
who present an immediate danger to themselves or 512.3 (c) and (e)
others, who exhibit behavior which results in the
destruction of property, or reveals the intent to cause
self-inflicted physical harm. Physical restraints should ☒ ☐ ☐
be utilized only when it appears less restrictive
alternatives would be ineffective in controlling the
youth’s behavior.
In no case shall restraints be used as punishment or
discipline, or as a substitute for treatment. The use of 512.3 (g) and (l)
restraint devices that attach a youth to a wall, floor or 512.5 (a) 1
other fixture, including a restraint chair, or through 512.9 Pregnant Youth
affixing of hands and feet together behind the back 512.9.1
☒ ☐ ☐
(hogtying) is prohibited. The use of restraints on
pregnant youth is limited in accordance with Penal Code
Section 6030(f) and Welfare and Institutions Code
Section 222.
The provisions of this section do not apply to the use of
handcuffs, shackles or other restraint devices when 512.5 UR for Movement and Transportation
used to restrain youth for movement or transportation
within the facility. Movement within the facility shall be ☒ ☐ ☐
governed by Section 1358.5, Use of Restraint Devices
for Movement Within the Facility.
Youth shall be placed in restraints only with the approval
of the facility manager or designee. The facility manager 512.3 (d)
may delegate authority to place a youth in restraints to
a physician. Reasons for continued retention in ☒ ☐ ☐
restraints shall be reviewed and documented at a
minimum of every hour.
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A medical opinion on the safety of placement and
retention shall be secured as soon as possible, but no 512.3 (j)(1)
later than two hours from the time of placement. The
☒ ☐ ☐
youth shall be medically cleared for continued retention
at least every three hours thereafter.
A mental health consultation shall be secured as soon
as possible, but in no case longer than four hours from 512.3 (j)(2)
the time of placement, to assess the need for mental ☒ ☐ ☐
health treatment.
Continuous direct visual supervision shall be conducted
to ensure that the restraints are properly employed, and 512.3 (j)
to ensure the safety and well-being of the youth. 512.7 (e)
Observations of the youth's behavior and any staff
☒ ☐ ☐
interventions shall be documented at least every 15
minutes, with actual time of the documentation
recorded.
In addition to the requirements above, policies and
procedures shall address: 512.7 Documentation
☒ ☐ ☐
(a) documentation of the circumstances leading to an
application of restraints.
(b) known medical conditions that would contraindicate
certain restraint devices and/or techniques. 512.6 (k)
☒ ☐ ☐ 512.10 (h)
(c) acceptable restraint devices.
512.10 (i)
☒ ☐ ☐
(d) signs or symptoms which should result in immediate
medical/mental health referral. 512.10 (j)
☒ ☐ ☐
(e) availability of cardiopulmonary resuscitation
equipment. 512.10 (k)
☒ ☐ ☐
(f) protective housing of restrained youth. While in
restraint devices, all youth shall be housed alone or in a 512.10 (d)
specified housing area for restrained youth which makes ☒ ☐ ☐ 512.6 (d)
provision to protect the youth from abuse.
(g) provision for hydration and sanitation needs. 512.3 (m)
☒ ☐ ☐
512.10 (l)
(h) exercising of extremities.
☒ ☐ ☐ 512.6 (k)
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1358.5 USE OF RESTRAINT DEVICES FOR
MOVEMENT AND TRANSPORTATION 512.4
WITHIN THE FACILITY. 512.5 UR for Movement and Transportation
The Facility Administrator, in cooperation with the
responsible physician and behavioral/mental health ☒ ☐ ☐
director, shall develop and implement written policies
and procedures for the use of restraint devices when the
purpose is for movement or transportation within the
facility that shall include the following:
(a) identification of acceptable restraint devices, staff
approved to utilize restraint devices and the required 512.1
☒ ☐ ☐
training.
(b) the circumstances leading to the application of
restraints must be documented. 512.5 (a)(1)
☒ ☐ ☐
(c) an individual assessment of the need to apply
restraints for movement or transportation that includes 512.5 (b)(1)
consideration of less restrictive alternatives, 512.5 (c)(1)
consideration of a youth’s known medical or mental
health conditions, trauma informed approaches, and a The VCPAJF agency has been tracking the
process for documentation and supervisor review and UR as identified in this regulation since last
approval. cycle. Since April of 2022, there have been
☒ ☐ ☐
17 applications of restraints for movement.
Our review of the reports when restraints
were used provided sufficient justification.
From July 2020 to April 2022, 27 of the 57
reports reviewed included restraints as
defined in this regulation.
(d) consideration of safety and security of the facility,
with a clearly defined expectation that restraint devices 512.3 (g)
shall not be used for the purposes of discipline or ☒ ☐ ☐
retaliation.
(e) the use of restraints on pregnant youth is limited in
accordance with Penal Code Section 6030(f) and 512.9
☒ ☐ ☐
Welfare and Institutions Code Section 222.
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1359 SAFETY ROOM PROCEDURES
506 Safety Rooms and Camera Rooms
(a) The facility administrator, and where applicable, in
506.3
cooperation with the responsible physician, shall
develop and implement written policies and procedures
There have been 3 safety room placements
governing the use of safety rooms, as described in Title
since April 2022, one involving a female
24, Part 2, Section 1230.1.13. The room shall be used
youth in commitment, who was actively trying
to hold only those youth who present an immediate
to harm herself while making suicidal
danger to themselves or others, who exhibit behavior
statements. The agency was able to
which results in the destruction of property, or reveals
transport the youth to the hospital on a 5585
the intent to cause self-inflicted physical harm. A safety
hold. She was transported to the safety cell
room shall not be used for punishment or discipline, or
without restraints for her own protection,
as a substitute for treatment. Policies and procedures
pending transport to the hospital for
shall:
evaluation.
☒ ☐ ☐
The amount of time in the safety cell was
monitored by Medical and Behavior Health
(Crisis Team) and was 1 hour and 56
minutes.
The agency complied with regulation and
policy for each incident and had multiple staff
and partners in close proximity during each
event.
Prior to the above, the agency has had no
safety cell placements since one in 2019 and
4 in 2018.
(1) include provisions for administration of necessary
nutrition and fluids, access to a toilet, and suitable 506.4 (e)
☒ ☐ ☐
clothing to provide for privacy;
(2) provide for approval of the facility manager, or
designee, before a youth is placed into a safety 506.4 (a)
☒ ☐ ☐
room;
(3) provide for continuous direct visual supervision
and documentation of the youth's behavior and any 506.4 (c)
staff interventions every 15 minutes, with actual time ☒ ☐ ☐
recorded;
(4) provide that the youth shall be evaluated by the
facility manager, or designee, every four hours; 506.4 (g)
☒ ☐ ☐
(5) provide for immediate medical assessment,
where appropriate, or an assessment at the next 506.4 (h)
daily sick call; and,
The policy states the assessment shall take
☒ ☐ ☐
place no longer than 12 hours after
placement.
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(6) provide a process for documenting the reason for
placement, including attempts to use less restrictive 506.4 (i)
means of control, and decisions to continue and end ☒ ☐ ☐
placement.
(b) The placement of a youth in the safety room shall be
accomplished in accordance with the following: ☒ ☐ ☐
(1) safety room shall not be used before other less
restrictive options have been attempted and 506.4 (j)
exhausted, unless attempting those options poses a ☒ ☐ ☐
threat to the safety or security of any youth or staff.
(2) safety room shall not be used for the purposes of
punishment, coercion, convenience, or retaliation by 506.4 (l)
☒ ☐ ☐
staff.
(3) safety room shall not be used to the extent that it
compromises the mental and physical health of the 506.4 (l)
☒ ☐ ☐
youth.
(c) A youth may be held up to four hours in the safety
room. After the youth has been held in the safety room 506.4 (g)
for a period of four hours, staff shall do one or more of
☒ ☐ ☐
the following: Refer to 601.4.5, Room Confinement
506.4 (g)(1)
(1) return the youth to general population. ☒ ☐ ☐
506.4 (g)(1)
(2) consult with mental health or medical staff, ☒ ☐ ☐
(3) develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate ☒ ☐ ☐ 506.4 (g)(1)
the youth to general population.
(d) If confinement in the safety room must be extended
beyond four hours, staff shall develop an individualized 506.4 (g)(1)
plan that includes the requirements of Section 1354.5
☒ ☐ ☐
and the goals and objectives to be met in order to
integrate the youth to general population.
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1360 SEARCHES
513 Searches
The facility administrator shall develop and implement
written policies and procedures governing the search of
youth, the facility, and visitors. Policies and procedures
shall provide that: The agency conducts routine unit and room
searches for the ongoing safety of the facility.
☒ ☐ ☐
Due to fentanyl and other drugs coming into
the facility, the VCPAJF has purchased two
body scanners and a mail scanner as tools to
prevent this from occurring. It is expected
they will arrive in August. Prospective
policies for their use are being developed.
(a) Searches shall be conducted to ensure the safety
and security of the facility, public, visitors, youth, and 513.2 ⁋ 1
staff. ☒ ☐ ☐
(b) Searches shall be conducted in a manner that
preserves the privacy and dignity of the person being 513.1 ⁋ 1
searched and shall not be conducted for harassment or ☒ ☐ ☐ 513.2 ⁋ 1
as a form of discipline or punishment.
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(c) Strip searches and visual or physical body cavity
searches shall comply with Penal Code Section 4030. 513.4.1 (a)
513.4.2 (a)
The agency has conducted strip searches of
units and youth more in this past year due to
contraband coming into the facility. Visits
have gone to no contact in some cases as
the agency traced the source. Phone call
coding and recordings reviewed also pointed
to a pathway for contraband.
Since April of 2022, there have been 425 strip
searches conducted, 243 due to contraband
in the units and/or positive drug test of youth
in the facility. Of the 182 additional strip
searches, averaging 13 per month, we found
☒ ☐ ☐
documented reasonable suspicion and
authorization by the supervisor in all but 16
incidents. These 16 were approved by a
supervisor but the documentation, other than
the coded reason for the search, was not
verified. We reviewed the strip searches from
April 2020 to June 2022 (334 – average
15/month), finding this average
consistent/less than current practice.
We provided technical assistance to the
agency to ensure the reasonable suspicion
was not just a conversation but documented
in the electronic search authorization and/or
by incident report.
(d) Physical body cavity searches shall only be
conducted by a medical professional. 513.4,2 (b)
☒ ☐ ☐
(e) Any youth held after a detention hearing shall only
be strip searched with prior approval of a supervisor 513.4.2 (b)
when there is reasonable suspicion based on specific
and articulable facts to believe that youth is concealing ☒ ☐ ☐
contraband. The reasonable suspicion shall be
documented.
(f) Searches of transgender and intersex youth shall
comply with Section 1352.5. 501.12 II-A and B
513.5
☒ ☐ ☐
301.5 II Administrative Manual
(g) Cross-gender pat-down searches and strip searches
are prohibited except in exigent circumstances or when 513.3 Last ⁋
conducted by a medical professional. Such searches ☒ ☐ ☐
must be justified and documented in writing.
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1361 GRIEVANCE PROCEDURE
606 Youth Grievances
The facility administrator shall develop and implement
606.3 ⁋ 1
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
The VCPAJF agency reported 72 grievances
condition of confinement, including but not limited to
filed from April 2022 to June 2023, an
health care services, classification decisions, program
average of 5.1 per month. There were 34 in
participation, telephone, mail or visiting procedures,
2022, 35 in 2021, and 43 in 2020, reduced
food, clothing, bedding, mistreatment, harassment or
from the 79 in 2019 and 82 in 2018. The
violations of the nondiscrimination policy. There shall be
process and form are compliant with
no time limit on filing grievances. Policies and
regulation and policy, allowing youth to
procedures shall include provisions whereby the facility
communicate and staff to be responsive to
manager ensures:
the operational procedures used.
☒ ☐ ☐ We reviewed all the grievances filed from
April 2022 to June 2023 and found them to
be timely with appropriate sanctions. Staff
comments appeared to be a documented
conversation, leading the youth to
understand the behavior and sanction, or to
find resolution for a condition of confinement
the youth did not agree with.
There were several beyond the regulation 3-
day receipt of the grievance, but each
involved an agency partner grievance. All
were resolved within 10 days of the receipt of
the grievance.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to 606.3 Bullet 1
☒ ☐ ☐
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth 606.3 Bullet 8
☒ ☐ ☐
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; 606.3 Bullet 2
☒ ☐ ☐
(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances 606.4.2 ⁋ 3
that relate to health and safety issues must be ☒ ☐ ☐
addressed immediately;
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not 606.4.5 (a)
directly involved in the circumstances which led to ☒ ☐ ☐
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. 606.4.5 (b)
☒ ☐ ☐
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(e) provision for a written response to the grievance
which includes the reasons for the decisions; 606.4.3
☒ ☐ ☐
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly 606.4.5 (a)
involved in the circumstances which led to the ☒ ☐ ☐
grievance;
(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer 606.4.2 ⁋ 4
time frame. The youth shall be notified of any delay; ☒ ☐ ☐
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. 606.5
☒ ☐ ☐ 606.5.1
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be 606.4.5 (c)
addressed and documented in accordance with written ☒ ☐ ☐
policies and procedures within a specified timeframe.
1362 REPORTING OF INCIDENTS
206 Report Preparation
A written report of all incidents which result in physical
206.4.2
harm, use of force, serious threat of physical harm, or
death of an employee, youth or other person(s) shall be
☒ ☐ ☐
maintained. Such written record shall be prepared by
the staff and submitted to the facility manager by the end
of the shift, unless additional time is necessary and
authorized by the facility manager or designee.
1363 USE OF REASONABLE FORCE TO
COLLECT DNA SPECIMENS, SAMPLES, 517 Biological Samples
IMPRESSIONS 517.5 UF to Collect
DHPO 01.P.1.16
(a) Pursuant to Penal Code Section 298.1 authorized
law enforcement, custodial, or corrections personnel
The VCPAJF policy does not use force to
including peace officers, may employ reasonable force ☒ ☐ ☐
collect DNA. Staff advise the youth that their
to collect blood specimens, saliva samples, and thumb
failure to cooperate will result in a return to
or palm print impressions from individuals who are
Court.
required to provide such samples, specimens or
impressions pursuant to Penal Code Section 296 and
who refuse following written or oral request.
(1) For the purpose of this section, the “use of
reasonable force” shall be defined as the force that 511.3.1
an objective, trained and competent correctional
employee, faced with similar facts and ☒ ☐ ☐
circumstances, would consider necessary and
reasonable to gain compliance with this section.
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(2) The use of reasonable force shall be preceded by
efforts to secure voluntary compliance. Efforts to 517.5.2
secure voluntary compliance shall be documented
and include an advisement of the legal obligation to ☒ ☐ ☐
provide the requisite specimen, sample or
impression and the consequences of refusal.
(b) The force shall not be used without the prior written
authorization of the supervising officer on duty. The 517.5.2
authorization shall include information that reflects the
☒ ☐ ☐
fact that the offender was asked to provide the requisite
specimen, sample, or impression and refused.
(1) If the use of reasonable force includes a cell
extraction, the extraction shall be videotaped. Video 517.5.1
shall be directed at the cell extraction event. The
videotape shall be retained by the agency for the
length of time required by statute. Notwithstanding ☒ ☐ ☐
the use of the video as evidence in a court
proceeding, the tape shall be retained
administratively.
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1370 EDUCATION PROGRAM
1003 Youth Education Services
(a) School Programs
1003.3 ⁋ 3
The County Board of Education shall provide for the 1003.4 (b)(1) Education Program
administration and operation of juvenile court schools in Coordination
conjunction with the Chief Probation Officer, or designee
pursuant to applicable State laws. The school and The Ventura County Office of Education
facility administrators shall develop and implement operates the Providence School onsite at the
written policy and procedures to ensure communication facility. The last evaluation continues to
and coordination between educators and probation reveal a good relationship amongst probation
staff. Culturally responsive and trauma-informed and school staff, with daily briefings and
approaches should be applied when providing thorough monthly meetings with agency
instruction. Education staff should collaborate with the administrators.
facility administrator to use technology to facilitate
learning and ensure safe technology practices. The
facility administrator shall request an annual review of While onsite, we met with the Director of
each required element of the program by the Alternative Education for the Ventura County
Superintendent of Schools, and a report or review Office of Education (VCOE), Stephanie
checklist on compliance, deficiencies, and corrective Rodrigues, Teresa Vega, the site Principal,
action needed to achieve compliance with this section. and Nicole Garr, the School Counselor. We
Such a review, when conducted, cannot be delegated to once again discussed the early and easy
the principal or any other staff of any juvenile court graduation requirements and whether the
school site. The Superintendent of Schools shall VCOE made independent evaluations to
conduct this review in conjunction with a qualified address the need to provide a diploma to a
outside agency or individual. Upon receipt of the review, youth based on their age, credits to date, and
the facility administrator or designee shall review each anticipated length of stay, mostly to ensure
item with the Superintendent of Schools and shall take that just because a youth is eligible that they
whatever corrective action is necessary to address each ☒ ☐ ☐ evaluate the best-case scenario for each
deficiency and to fully protect the educational interests youth independently. Ms. Garr works most
of all youth in the facility. with this population and assured the process
is independent, indicating there could be a
more robust conversation with the parent and
youth when the situation involves a long stay
in custody.
It is significant to note that while onsite, we
were advised 15 youth had graduated so far
this year, 13 with the limited credits pursuant
to AB 167. This is significant because the
agency and VCOE have limited post-
secondary opportunities for youth beyond
enrollment in an online local college,
AutoTech (not during summer months), and
Paxton Patterson (PP), which is facilitated by
Probation staff. There is a plan for an Ag
Program and Digital Media program to start
this fall.
We discussed the VCOE hard line for not
allowing graduated youth in the classroom or
to provide greater opportunities for these
youth who will remain with the agency long-
term. VCOE continues to provide little in
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terms of opportunities for graduated youth
but allows youth in long-term custody to
graduate early without consideration of the
benefits to remain in the classroom. The
VCPAJF is considering funding a teacher to
provide services.
(b) Required Elements
1003.2
The facility school program shall comply with the State
1003.3
Education Code and County Board of Education
1003.4 (b)(1)
policies, all applicable federal education statutes and
1003.5
regulations and provide for an annual evaluation of the
educational program offerings. As stated in the 2009
California Standards for the Teaching Profession,
☒ ☐ ☐
teachers shall establish and maintain learning
environments that are physically, emotionally, and
intellectually safe. Youth shall be provided a rigorous,
quality educational program that responds to the
different learning styles and abilities of students and
prepares them for high school graduation, career entry,
and post-secondary education.
All youth shall be treated equally, and the education
program shall be free from discriminatory action. Staff 1003.3 (a)
shall refer to transgender, intersex and gender-
☒ ☐ ☐
nonconforming youth by their preferred name and
gender.
(1) The course of study shall comply with the State
Education Code and include, but not be limited to, 1003.5 ⁋ 3
☒ ☐ ☐
courses required for high school graduation.
(2) Information and preparation for the High School
Equivalency Test as approved by the California 1003.5 ⁋ 3
Department of Education shall be made available to ☒ ☐ ☐
eligible youth.
(3) Youth shall be informed of post-secondary
education and vocational opportunities. 1003.4 (o)(1)
☒ ☐ ☐
(4) Administration of the High School Equivalency
Tests as approved by the California Department of 1003.5 ⁋ 3
☒ ☐ ☐
Education, shall be made available when possible.
(5) Supplemental instruction shall be afforded to
youth who do not demonstrate sufficient progress 1003.5 ⁋ 4
☒ ☐ ☐
towards grade level standards.
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(6) The minimum school day shall be consistent with
State Education Code Requirements for juvenile 1003.5 ⁋ 2
court schools. The facility administrator, in
conjunction with education staff, must ensure that
operational procedures do not interfere with the time
☒ ☐ ☐
afforded for the minimum instructional day.
Absences, time out of class or educational
instruction, both excused and unexcused, shall be
documented.
(7) Education shall be provided to all youth
regardless of classification, housing, security status, 1003.4 (a)
disciplinary or separation status, including room 1003.4 (g)(1)
confinement, except when providing education 1003.8
poses an immediate threat to the safety of self or ☒ ☐ ☐
others. Education includes, but is not limited to,
related services as provided in a youth’s Section 504
Plan or Individualized Education Program (IEP).
(c) School Discipline
1003.7 ⁋ 1
(1) Positive behavior management will be
implemented to reduce the need for disciplinary
☒ ☐ ☐
action in the school setting and be integrated into the
facility's overall behavioral management plan and
security system.
(2) School staff shall be advised of administrative
decisions made by probation staff that may affect the 1003.7 ⁋ 2
☒ ☐ ☐
educational programming of students.
(3) Except as otherwise provided by the State
Education Code, expulsion/suspension from school 1003.7 ⁋ 3
shall be imposed only when other means of
correction fails to bring about proper conduct.
School staff shall follow the appropriate due process
safeguards as set forth in the State Education Code
☒ ☐ ☐
including the rights of students with special needs.
School staff shall document the other means of
correction used prior to imposing expulsion/
suspension if an expulsion/suspension is ultimately
imposed.
(4) The facility administrator, in conjunction with
education staff will develop policies and procedures 1003.4 (g)
that address the rights of any student who has ☒ ☐ ☐
continuing difficulty completing a school day.
(d) Provisions for Special Populations
(1) State and federal laws and regulations shall be 1003.3 ⁋ 2
observed for all individuals with disabilities or 1003.4 (a)
suspected disabilities. This includes but is not limited
☒ ☐ ☐
to child find, assessment, continuum of alternative
placements, manifestation determination reviews,
and implementation of Section 504 Plans and
Individualized Education Programs.
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(2) Youth identified as English Learners (EL) shall be
afforded an educational program that addresses their 1003.4 (m)
language needs pursuant to all applicable state and ☒ ☐ ☐
federal laws and regulations governing programs for
EL students.
(e) Educational Screening and Admission
(1) Youth shall be interviewed after admittance and a 1003.4 (c)(1)
record maintained that documents a youth's 1003.4 (h)
educational history, including but not limited to: ☒ ☐ ☐ 1003.4.1
(A) School progress/school history;
1003.4.1
☒ ☐ ☐
(B) Home Language Survey and the results of the
State Test used for English language proficiency; 509.9.2
☒ ☐ ☐
(C) Needs and services of special populations as
defined by the State Education Code, including but 701.4 (f)
☒ ☐ ☐
not limited to, students with special needs. 1003.4 (e)
(D) Discipline problems.
☒ ☐ ☐ 1003.7
(2) Youth will be immediately enrolled in school.
Educational staff shall conduct an assessment to 1003.4 (c)
determine the youth's general academic functioning ☒ ☐ ☐ 1003.4.1 ⁋ 1
levels to enable placement in core curriculum
courses.
(3) After admission to the facility, a preliminary
education plan shall be developed for each youth ☒ ☐ ☐ 1003.4.1 ⁋ 1
within five school days.
(4) Upon enrollment, education staff shall comply with
the State Education Code and request the youth's 1003.4.1
records from his/her prior school(s), including, but not
limited to, transcripts, Individual Education Program
(IEP), 504 Plan, state language assessment scores,
☒ ☐ ☐
immunization records, exit grades, and partial credits.
Upon receipt of the transcripts, the youth's
educational plan shall be reviewed with the youth and
modified as needed. Youth should be informed of the
credits they need to graduate.
(f) Educational Reporting
(1) The complete facility educational record of the 1003.4 (i)
youth shall be forwarded to the next educational ☒ ☐ ☐
placement in accordance with the State Education
Code.
(2) The County Superintendent of Schools shall
provide appropriate credit (full or partial) for course 1003.4 (i)
☒ ☐ ☐
work completed while in juvenile court school in
accordance with the State Education Code.
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(g) Transition and Re-Entry Planning
(1) The Superintendent of Schools and the Chief 1003.4 (n)
Probation Officer or designee, shall develop policies
and procedures to meet the transition needs of youth,
☒ ☐ ☐
including the development of an education transition
plan, in accordance with the State Education Code
and in alignment with Title 15, Minimum Standards for
Juvenile Facilities, Section 1355.
(h) Post-Secondary Education Opportunities
(1) The school and facility administrator should, 1003.6
whenever possible, collaborate with local post-
secondary education providers to facilitate access to
educational and vocational opportunities for youth that
We noted the VCPAJF Administration made
considers the use of technology to implement these
the decision to defer summer online college
programs.
to facilitate their own college readiness
program. They found youth were unprepared
to understand the responsibilities for
☒ ☐ ☐
independent learning and felt a program to
facilitate independent thought, how be
responsive to the curriculums, and to be able
to seek assistance from educational staff not
in the classroom were important for the
young population that was not ready for
‘college’ learning.
1371 PROGRAMS, RECREATION, AND
EXERCISE. 1002 Programs, Recreation and Exercise
1002.2
The facility administrator shall develop and implement
written policies and procedures for programs, ☒ ☐ ☐
recreation, and exercise for all youth. The intent is to
minimize the amount of time youth are in their rooms or
their bed area.
Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three 1002.3 ⁋ 1
hours a day during the week and five hours a day each
Saturday, Sunday or other non-school days, of which ☒ ☐ ☐
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding 1002.3 ⁋ 2
by the administrator/manager or designee that a youth ☒ ☐ ☐ 1002.7 ⁋ 4
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. 1002.3 ⁋ 3
☒ ☐ ☐
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There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to 1000.3 (l)
ensure content offered is current, consistent, and
relevant to the population. A review of Programming at the Juvenile
Facility was completed on July 5, 2023, by
☒ ☐ ☐ Chief Deputy Tim Dowler. The review
acknowledged program needs for male and
female youth, noting they would be age-
appropriate and targeted based on identified
needs in the Case Plan.
(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to 1002.6
include, but not be limited to, trauma focused, cognitive,
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
Programming includes responses to Victim
social interventions and activities designed to reduce
Awareness, substance abuse, conflict
recidivism. These programs should be based on the
resolution, anger management, parenting
youth’s individual needs as required by Sections 1355
skills, gender-specific programming, mental
and 1356. Such programs may be provided under the
☒ ☐ ☐ health services, positive youth development,
direction of the Chief Probation Officer or the County
building effective decision-making skills, and
Office of Education and can be administered by county
other topics that suit the needs of the youth
partners such as mental health agencies, community
population.
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
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(1) Cognitive Behavior Interventions;
1000.2
(2) Management of Stress and Trauma;
1000.3
(3) Anger Management;
Available programs include: Healthy
(4) Conflict Resolution; Lifestyles - Women of Substance Men of
Honor (WOSMOH); Reins of HOPE (equine
(5) Juvenile Justice System;
therapy); Interactive Journaling; Ventura
(6) Trauma-related interventions; County Arts Council (art, guitar, poetry,
drumming, and mural painting); Therapy
(7) Victim Awareness; Dogs; Dating Matters; First 5 Parenting
Program; Brent’s Club; Smart Girls; Boys and
(8) Self-Improvement;
Girls Club Program*; Podcasting; ADPS
(9) Parenting Skills and support; Tablets; STEPS-Y; Word on the Street; City
Impact; Forever Found (CSEC youth);
(10) Tolerance and Diversity; Passport to Manhood; ARISE; Operation
Peace Works; Gender Specific Services;
(11) Healing Informed Approaches;
and Music N Society.
(12) Interventions by Credible Messengers;
Ventura County Behavior Health provides the
(13) Gender Specific Programming;
following: Dialectical Behavior Therapy
(DBT); Drug and Alcohol Programs
(14) Art, creative writing, or self-expression;
☒ ☐ ☐ (individual and group); Moral Recognition
(15) CPR and First Aid training; Therapy (MRT); Seeking Safety; Anger
Management and Conflict Resolution;
(16) Restorative Justice or Civic Engagement;
Individual and Group Therapy; Co-Parent
Counseling; and Sex Offender Treatment.
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population. Educational Programs include: Paxton
Patterson (Construction trades program);
Providence Scholars Program (online
college); College Success; Literacy Tutors;
Money Matters; and AutoTech.
Re-Entry Services include: First Aid/CPR;
Alpha Leadership; Forever Found Case
Management; Second Chance Re-entry
Services; Reducing Risks for Girls; Harm to
Healing Restorative Justice; and, Court
Appointed Special Advocates.
*These programs are not occurring currently
due to the facilitators not being available.
(b) Recreation. All youth shall be provided the
opportunity for at least one hour of daily access to 1002.5
unscheduled activities such as leisure reading, letter
writing, and entertainment. Activities shall be supervised
☒ ☐ ☐
and include orientation and may include coaching of
Recreation Programs include Library Carts;
youth.
Organized Games; Special Events; and the
Boys and Girls Club Rec Center
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(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity 1002.4
each day.
☒ ☐ ☐ Exercise other than that facilitated by staff
include Futsal, Basketball, Boys and Girls
Club Gym, and Special Events.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and 1002.7 ⁋ 3
programs. The administrator/manager shall document
☒ ☐ ☐
the reasons why suspension of recreation and programs
occurs.
1372 RELIGIOUS PROGRAM
1007 Religious Programs
The facility administrator shall provide access to
1007.3 ⁋ 2
religious services and/or religious counseling at least
1007.3.1
once each week. Attendance shall be voluntary. A youth
shall be allowed to participate in an activity outside of
their room if he/she elects not to participate in religious
☒ ☐ ☐
programs. The agency has religious providers in each
unit one day per week. Youth have the
Religious programs shall provide for: opportunity to meet with them or request a
contact anytime.
(a) opportunity for religious services and practices; 1007.3.1
☒ ☐ ☐
(b) availability of clergy; and, 1007.12
☒ ☐ ☐
(c) availability of religious diets. 1007.5
☒ ☐ ☐
1373 WORK PROGRAM
1005 Youth Work Program
The facility administrator shall develop policies and
procedures regarding the fair and consistent
assignment of youth to work programs. Work assigned
☒ ☐ ☐
to a youth shall be meaningful, constructive and related
to vocational training or increasing a youth's sense of
responsibility. Work programs shall not be imposed as a
disciplinary measure
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1374 VISITING
1008 Youth Visitation
The facility administrator shall develop and implement
1008.3.2
written policies and procedures for visiting, that include
provisions for special visits. Youth shall be allowed to
receive visits by parents, guardians or persons standing
in loco parentis, and children of youth. Other family ☒ ☐ ☐ At the time of the inspection, youth are able
members, such as grandparents and siblings, and to have 2 visits per week, for an hour each
supportive adults, may be allowed to visit with the visit, on Wednesdays and Sundays. Special
approval of the facility administrator or designee, and in visits occur on Sunday mornings.
conjunction with the youth’s case plan or in the best
interest of the youth.
All visits shall occur at reasonable times, subject only to
the limitations necessary to maintain order and security. 1008.6 (f)
Visitation shall not be denied solely based on the 1008.6 Last Paragraph
visitor’s criminal history. The staff shall determine in 1008.5 Visitation Schedule
each case, whether the visitor’s criminal history
☒ ☐ ☐
represents a risk to the safety of youth or staff in the
facility. Any denial of visitation or limitation on visitations
shall be communicated to the youth, person denied and
facility administrator.
Opportunity for visitation shall be a minimum of two
hours per week. Visits may be supervised, but 1008.3.2 ⁋ 2
conversations shall not be monitored unless there is a ☒ ☐ ☐
security or safety need.
Provisions for special visits, in addition to the two-hour
minimum and/or outside of the regular visiting hours, 1008.8
shall be accommodated as necessary and within the
discretion of the facility administrator or designee.
Family therapy and professional visits shall be ☒ ☐ ☐
accommodated outside the provisions of this regulation.
Facilities may provide visitation opportunities outside of
normal visiting hours to accommodate special visits.
The facility may provide access to technology as an
alternative, but not as a replacement, to in-person 1008.3.2 ⁋ 3
☒ ☐ ☐
visiting.
1375 CORRESPONDENCE
1001 Correspondence
The facility administrator shall develop and implement
☒ ☐ ☐
written policies and procedures for correspondence
which provide that:
(a) there is no limitation on the volume of mail that youth
may send or receive; 1001.3 ⁋ 1
☒ ☐ ☐
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(b) youth may send two letters per week postage free;
1001.8 (a)
☒ ☐ ☐ Youth are able to send seven letters each
week, postage-free.
(c) youth may correspond confidentially with state and
federal courts, any member of the State Bar or holder of 1001.4 ⁋ 1
public office, and the Board; however, authorized facility
☒ ☐ ☐
staff may open and inspect such mail only to search for
contraband and in the presence of the youth; and,
(d) incoming and outgoing mail, other than that
described in (c), may be read by staff only when there is 1001.6 ⁋ 2
reasonable cause to believe facility safety and security, ☒ ☐ ☐ 1001.6.1
public safety, or youth safety is jeopardized.
1376 TELEPHONE ACCESS
1006.2 Youth Telephone Policy
The administrator of each juvenile facility shall develop
and implement written policies and procedures to ☒ ☐ ☐
provide youth with access to telephone
communications.
1377 ACCESS TO LEGAL SERVICES
602 Youth Access to Courts and Counsel
The facility administrator shall develop written
procedures to ensure the right of youth to have access ☒ ☐ ☐
to the courts and legal services. Such access shall
include:
(a) access, upon request by the youth, to licensed
attorneys and their authorized representatives; 602.3 (a)
☒ ☐ ☐
(b) provision for confidential consultation with attorneys;
and, 602.3 (b)
☒ ☐ ☐
(c) unlimited postage free, legal correspondence and
cost-free telephone access as appropriate. 602.3 (c)
☒ ☐ ☐
1390 DISCIPLINE
600 Youth Discipline
The facility administrator shall develop and implement
600.3.1 Rules and Sanctions
written policies and procedures for the discipline of
600.6 Bullet 14
youth that shall promote acceptable behavior; including
1009.3 Behavior Modification Plan
the use of positive behavior interventions and supports.
☒ ☐ ☐
Discipline shall be imposed at the least restrictive level
which promotes the desired behavior and shall not
include corporal punishment, group punishment,
physical or psychological degradation. Deprivation of
the following is not permitted:
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(a) bed and bedding; 600.6 Bullet 13 and 14
☒ ☐ ☐
(b) daily shower, access to drinking fountain, toilet and
600.6 Bullet 7
personal hygiene items, and clean clothing; ☒ ☐ ☐
(c) full nutrition; 600.6 Bullet 4
☒ ☐ ☐
(d) contact with parent or attorney; 600.6 Bullet 16 and 19
☒ ☐ ☐
(e) exercise; 600.6 Bullet 11
☒ ☐ ☐
(f) medical services and counseling; 600.6 Bullet 15 and 20
☒ ☐ ☐
(g) religious services; 600.6 Bullet 20
☒ ☐ ☐
(h) clean and sanitary living conditions; 600.6 Bullet 14
☒ ☐ ☐
600.6 Bullet 18
(i) the right to send and receive mail;
☒ ☐ ☐
(j) education; and, 600.6 Bullet 20
☒ ☐ ☐
(k) rehabilitative programming. 600.6 Bullet 20
☒ ☐ ☐
The facility administrator shall establish rules of conduct
and disciplinary penalties to guide the conduct of youth. 600.4 Minor Rules
Such rules and penalties shall include both major 600.5 Major Rules
violations and minor violations, be stated simply and 600.7 Sanctions
affirmatively, and be made available to all youth. ☒ ☐ ☐ 1009 Behavior Management Program
Provision shall be made to provide accessible
information to youth with disabilities, limited English
proficiency, or limited literacy.
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1391 DISCIPLINE PROCESS
600.3 Discipline Process
The facility administrator shall develop and implement
written policies and procedures for the administration of
The agency uses two separate forms for
discipline which shall include, but not be limited to:
Disciplinary Due Process. First, the Notice of
Discipline includes a summary of the incident
and proposed sanction. The second form is
the Hearing Form, currently used for every
due process incident. The form allows the
youth to write their version of the incident and
to list any witnesses. There is also an area to
list the staff who assisted with the form or a
box to check if no one was requested to help
the youth.
Prior to the discipline hearing, the assigned
Hearing Officer reviews video of the incident
and all reports. Once a finding is made, the
youth is notified and is offered an opportunity
to appeal. Appeal forms are available in
every living unit.
We provided technical assistance to include
the opportunity to allow the youth to either
request a hearing or indicate they do not
want a hearing if they agree to the Notice and
☒ ☐ ☐ Proposed Sanction. If the minor agrees and
does not want a hearing, then the process is
complete. They would then have the youth
sign the form acknowledging no further
action is requested. If the youth wants the
hearing, then the existing process is fine.
Our guidance is to simplify and shorten the
operational responsibilities of staff.
We reviewed 31 of the 528 Due Process
incidents from April 2022 to June 2023,
including the Incident Report and
subsequent documentation. The form
prompts staff to follow the process and the
documentation was clear. Of the incidents
reviewed, only 7 filed an appeal to the facility
manager. In total, 214 Appeals were filed of
the total major rule violations. We found the
numbers surged based mostly on the issues
of contraband in the facility.
The process for each incident started the
same day as initiated and was resolved that
day. We found the policy and process
exceeds regulation.
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(a) designation of personnel authorized to impose
discipline for violation of rules; 600.3 (a)
☒ ☐ ☐
(b) prohibiting discipline to be delegated to any youth;
600.6 Bullet 1
☒ ☐ ☐
(c) definition of major and minor rule violations and their
consequences, and due process requirements; 600.4
☒ ☐ ☐ 600.5
(d) trauma-informed approaches and positive behavior
interventions; 600.3.1 ⁋ 2
☒ ☐ ☐
(e) minor rule violations may be handled informally by
counseling, advising the youth of expected conduct 600.4 Minor Rules
imposing a minor consequence. Discipline shall be 600.8 Documentation
☒ ☐ ☐
accompanied by written documentation and a policy of
review and appeal to a supervisor; and,
(f) major rule violations and the discipline process shall
be documented and require the following: 600.5
☒ ☐ ☐
(1) written notice of violation prior to a hearing; 600.5.3
☒ ☐ ☐
(2) accommodations provided to youth with
disabilities, limited literacy, and English language 600.5.7
☒ ☐ ☐
learners;
(3) hearing by a person who is not a party to the
600.5.4 ⁋ 2
incident; ☒ ☐ ☐
(4) opportunity for the youth to be heard, present
600.5.5
evidence and testimony; ☒ ☐ ☐
(5) provision for youth to be assisted by staff in the
600.5.3
hearing process; ☒ ☐ ☐
(6) provision for administrative review. 600.5.10
☒ ☐ ☐
(g) violations that result in a removal from camp or
commitment program, but not a return to court, will 600.7.1
follow the due process provisions in subsection (e) ☒ ☐ ☐
above.
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1410 MANAGEMENT OF COMMUNICABLE
DISEASES.
VCPA: Policy 705 Communicable Disease
The health administrator/responsible physician, in Policy, Youth
cooperation with the facility administrator and the local
health officer, shall develop written policies and ☒ ☐ ☐ Policy 705.3 Procedure
procedures to address the identification, treatment,
Policy 1203 Communicable Disease Policy,
control and follow-up management of communicable
Members (Staff)
diseases. The policies and procedures shall address,
but not be limited to:
VCPA: Policy 705.3 (c) Procedure
Coronavirus (COVID-19) PRE-BOOKING
(a) Intake health screening procedures; ☒ ☐ ☐ PROCEDURES
Intake and Medical Isolation Procedures
(b) Identification of relevant symptoms;
☒ ☐ ☐ Intake and Medical Isolation Procedures
Coronavirus (COVID-19) PRE-BOOKING
(c) Referral for medical evaluation;
☒ ☐ ☐ PROCEDURES
VCPA Policy 705.3 (d) Compliance with all
relevant laws and regulations related to
communicable diseases.
VCPA Policy 705.4.3 Medical Consultation,
(d) Treatment responsibilities during detention;
☒ ☐ ☐ Evaluation and Treatment
VCPA: Youth Face Mask Protocol and
Expectations
(e) Coordination with public and private community-
VCPA Policy 705.3 (d)(2)
based resources for follow-up treatment; ☒ ☐ ☐
(f) Applicable reporting requirements; and,
☒ ☐ ☐ VCPA Policy 705.4.2 Supervisor Response
and Reporting Requirements
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VCPA Policy 703 (d)(3) Developing
(g) Strategies for handling disease outbreaks. strategies for handling communicable
☒ ☐ ☐
disease outbreaks.
The policies and procedures shall be updated as
necessary to reflect communicable disease priorities
The agency coordinates policies with local
identified by the local health officer and currently
Public Health and CDC directives in
recommended public health interventions.
☒ ☐ ☐ response to the Coronavirus Pandemic.
These policies were updated in 2020.
1433 REQUESTS FOR HEALTH CARE SERVICES
(EXCERPT)
702.3 Youth Access to Health Care
The health administrator, in cooperation with the facility
administrator, shall develop policy and procedures to ☒ ☐ ☐ 702.3 (b) and (c) Unimpeded Access to
establish a daily routine for youth to convey requests for Health Care Services
emergency and non-emergency medical, dental and
behavioral/mental health care services.
1480 STANDARD FACILTY CLOTHING ISSUE
The youth’s personal clothing, undergarments and 802.6 Clothing Issue
footwear may be substituted for the institutional clothing
and footwear specified in this regulation. The facility has ☒ ☐ ☐ 363.1 Clothing Exchange
the primary responsibility to provide clothing and
footwear. Clothing provisions shall ensure that:
(a) Clothing is clean, reasonably fitted, durable, easily
laundered, in good repair, and free of holes and tears.
802.6 Paragraph 1
☒ ☐ ☐
(b) The standard issue of climatically suitable clothing
for youth shall consist of but not be limited to: ☒ ☐ ☐
(1) Socks and serviceable footwear; 802.6 Paragraph 2 Bullet 1 and 4
☒ ☐ ☐
(2) Outer garments; 802.6 Paragraph 2 Bullet 2
☒ ☐ ☐
(3) New non-disposable underwear which shall
remain with the youth throughout their stay, and;
802.6 Paragraph 2 Bullet 3 and 5
☒ ☐ ☐
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(4) Undergarments, that are freshly laundered and
free of stains, including tee shirts and bras.
802.6 Paragraph 2 Bullet 3
☒ ☐ ☐
(c) Clothing is laundered at the temperature required by
local ordinances for the commercial laundries and dried
802.7
completely in a mechanical dryer or other laundry ☒ ☐ ☐
method approved by the local health officer.
(d) Suitable clothing is issued to pregnant youth.
802.6 Paragraph 2 Bullet 6
☒ ☐ ☐
1482 CLOTHING EXCHANGE
The facility administrator shall develop and implement 802.6 Paragraph 1, 4, 5, and 6
written policies and site-specific procedures for the
cleaning and scheduled exchange of clothing. Unless
work, climatic conditions, or illness necessitates more ☒ ☐ ☐
frequent exchange, outer garments, except for footwear,
shall be exchanged at least once each week. Tee shirts,
bras, and underwear shall be exchanged daily; youth
shall receive their own underwear back at exchange.
1484 CONTROL OF VERMIN IN YOUTH’S
PERSONAL CLOTHING
Procedure 321
There shall be written policies and site-specific
procedures developed and implemented by the facility FPO.07.B, 1
administrator to control the contamination and/or spread ☒ ☐ ☐
of vermin and ecto-parasites in all youth’s personal
clothing. Infested clothing shall be cleaned or stored in
a closed container so as to eradicate or stop the spread
of the vermin.
1485 ISSUE OF PERSONAL CARE ITEMS
There shall be written policies and site-specific 802.8 Personal Hygiene of Youth
procedures developed and implemented by the facility
administrator for the availability of personal hygiene Procedure 362 Personal Hygiene
☒ ☐ ☐
items. Each female youth shall be provided with sanitary
FPO.09.E, 1
napkins, panty liners and tampons as requested. Each
youth to be held over 24 hours shall be provided with the
following personal care items;
(a) Toothbrush; 802.8 Paragraph 2 Bullet 4
☒ ☐ ☐
Procedure 362.1 (f)
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802.8 Paragraph 2 Bullet 3
(b) Toothpaste;
☒ ☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 1
(c) Soap;
☒ ☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 2
(d) Comb;
☒ ☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 5
(e) Shaving implements;
☒ ☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 8
(f) Deodorant;
☒ ☐ ☐
Procedure 362.1 (f)
(g) Lotion; 802.8 Paragraph 2 Bullet 9
☒ ☐ ☐
802.8 Paragraph 2 Bullet 10
(h) Shampoo; and,
☒ ☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 11
(i) Post-shower conditioning hair products.
☒ ☐ ☐
Procedure 362.1 (f)
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Youth shall not be required to share any personal care
items listed in items (a) through (d). Liquid soap
provided through a common dispenser is permitted.
Youth shall not share disposable razors. Double edged
802.8 Paragraph 4
safety razors, electric razors, and other shaving
instruments capable of breaking the skin, when shared ☒ ☐ ☐ 604.4 Shaving
among youth, shall be disinfected between individual
uses by the method prescribed by the State Board of
Barbering and Cosmetology in Sections 979 and 980,
Chapter 9, Title 16, California Code of Regulations.
1486 PERSONAL HYGIENE
There shall be written policies and site specific Procedure 362.1 (a) and (i)
procedures developed and implemented by the facility
administrator for showering/bathing and brushing of
☒ ☐ ☐
teeth. Youth shall be permitted to shower/bathe up on
assignment to a housing unit and on a daily basis
thereafter and given an opportunity to brush their teeth
after each meal.
1487 SHAVING
Youth shall have access to a razor daily, unless their 604.4 Shaving
appearance must be maintained for reasons of
identification in Court. All youth shall have equal
☒ ☐ ☐
opportunity to shave face and body hair. The facility
administrator may suspend this requirement in relation
to youth who are considered to be a danger to
themselves or others.
1488 HAIR CARE SERVICES (EXCERPT)
Hair care services shall be available in all juvenile 604.3 Haircuts
facilities. Youth shall receive hair care services monthly.
☒ ☐ ☐
Equipment shall be cleaned and disinfected after each
haircut or procedure, by a method approved by the State
Board of Barbering and Cosmetology.
1500 STANDARD BEDDING AND LINEN ISSUE
Clean laundered, suitable bedding and linens, in good 802.5 Bedding Issue
repair, shall be provided for each youth entering a living ☒ ☐ ☐
area who is expected to remain overnight, shall include,
but not be limited to:
(a) One mattress or mattress-pillow combination which
meets the requirements of Section 1502 of these
802.5 (b)
regulations; ☒ ☐ ☐
(b) One pillow and a pillow case unless provided for in
(a) above;
802.5 (e)
☒ ☐ ☐
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(c) One mattress cover and a sheet or two sheets; 802.5 (c)
☒ ☐ ☐
(d) One towel; and, 802.5 (d)
☒ ☐ ☐
(e) One blanket or more, up on request 802.5 (a)
☒ ☐ ☐
1501 BEDDING LINEN EXCHANGE
The facility administrator shall develop and implement 802.5 Paragraph 2
site specific written policies and procedures for the
scheduled exchange of laundered bedding and linen
☒ ☐ ☐
issued to each youth housed. Washable items such as
sheets, mattress covers, pillow cases and towels shall
be exchanged for clean replacement at least once each
week.
The covering blanket shall be cleaned or laundered
once a month.
802.5 (a)2
☒ ☐ ☐
1510 FACILITY SANITATION, SAFETY AND
MAINTENANCE
800 Housekeeping and Maintenance
The facility administrator shall develop and implement
written policies and site-specific procedures for the Procedure 317
maintenance of an acceptable level of cleanliness,
FPO.06.M, 1 Facility Sanitation, Safety and
repair and safety throughout the facility. The plan shall
Maintenance
provide for a regular schedule of housekeeping tasks,
☒ ☐ ☐
equipment, including restraint devices, and physical
plant maintenance and inspections to identify and
correct unsanitary or unsafe conditions or work
practices in a timely manner. The use of chemicals shall
be done in accordance to the product label and Safety
Data Sheet which may include the use of Personal
Protection Equipment (PPE).
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REVIEW OF NON REGULATORY REQUIREMENTS
GRANT FUNDING OR CODE REFERENCE YES NO N/A P/P REFERENCE - COMMENTS
JUVENILE PROBATION AND CAMPS FUNDING (JPCF) (Camps Only)
The programs/services identified on the JPCF Camp
Eligibility Form are being provided at the facility.
☒ ☐ ☐
(Refer to the JPCF Camp Eligibility Form)
208.5 WIC CONTACT BETWEEN PERSONS UNDER THE JUVENILE COURT AGES 19- 20 AND MINORS IN THE
FACILITY
The facility houses Juvenile Court Wards 19 years of
age and older. ☒ ☐ ☐
The facility has been approved to hold persons under
the juvenile court who are ages 19 through 21. ☒ ☐ ☐
The facility continues to comply with the requirements
of 208.5 WIC (programming, capacity and security of
☒ ☐ ☐
the facility) as outlined in the county’s application.
JUVENILE JUSTICE DELINQUENCY PREVENTION ACT MONITORING (JJDPA)
WIC 206 SEPARATE FACILITIES FOR WIC 300
MINORS
☐
☐
Dependent or neglected minors who are defined under Viola ☒
Section 300 of the Welfare and Institutions Code (WIC) tion
are held only in non-secure, separate and segregated
facilities.
DETENTION OF STATUS OFFENDERS (WIC 601)
AND FEDERAL MINORS
☐ ☒ ☐
Status Offenders (WIC 601) are held in the facility.
Status Offenders (WIC 601) are kept separate from
☐
Juvenile Delinquents (WIC 602)? (WIC 207[d]). ☐ ☒
Viola
tion
Federal Minors (ICE Holds or ORR Contract) are held
in the facility. ☐ ☒ ☐
If yes to the above, the Monthly Report on the
Detention of Status Offenders/Federal Minors is
☐ ☐ ☒
submitted to the BSCC.
WIC 208 SEPARATION OF MINORS AND ADULT
INMATES (JJDPA 42 USC 5633, Sec 223,
State Plans (a)[12])
Are adult inmates held in the facility? (When a person ☐ ☒ ☐
in detention is proceeding through the adult court,
AND that person is 18 years of age or older that
person is an adult inmate.)
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If adult inmates are held, they are appropriately
☐ ☒
separated from minors. ☐
Viola
tion
Adult inmates from an adult facility (e.g. inmate
☐
workers or “Scared Straight” programs) are not ☐ ☒
allowed in the facility in a manner that allows contact Viola
with minors. tion
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7740
FACILITY NAME: Ventura County Probation Agency Juvenile Facility (VCPAJF) FACILITY TYPE: SYTF
Secure Youth Treatment Facility – Detention Services
PERSON(S) INTERVIEWED: Gina Johnson, Chief Probation Officer; Tim Dowler, Chief Deputy Probation Officer; Carrie
Vredenburg, Director – Juvenile Facility Programs; Sandy Carrillo, Director, Juvenile Operations; Rebecca Jimenez, Corrections
Service Officer (CSO) III; Chris Martinez, Supervising Deputy Probation Officer (SDPO); Lola Barnette, SDPO; Allysa Hyne,
SDPO; Justin Burdine, CSO III; Adrian Jimenez, CSO II; Chris Mullins, CSO II; Shirley Scott, Wellpath RN; Teresa Vega, Assistant
Principal Ventura County Office of Education; Stephanie Rodriguez, Director Ventura County Office of Education; Nicole Garr,
Counselor Ventura County Office of Education; Stacy Thompson, Ventura County Food Services Manager; Ana Magbitang,
Manager Ventura County Behavior Health; SYTF Youth - Alex, age 17; Joel, age 18, Brayleen, age 23; Jesus, age 22; Rogelio,
age 19; Detention - Landon, age 18; Frank, age 17; Axel, age 20.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: July 10-13, 2023
** The agency has had no youth participate in the Detention Services segment of SYTF as it is a Post-Disposition Program.
All youth currently in the SYTF Commitment fall under the same parameters of Commitment Programming and Services
with the exception of ratios of youth to staff, which conform to JH ratios of 1:10.
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1313 COUNTY INSPECTION AND EVALUATION
OF BUILDING AND GROUNDS 104.3.2 Required Local Inspections,
On an annual basis, or as otherwise required by law,
The following Inspections apply to the entire
each juvenile facility administrator shall obtain a
☐ VCPAJF Physical Plant, including Detention,
documented inspection and evaluation from the
☒ ☐ Commitment, and SYTF.
following:
(a) county building inspector or person designated by the
November 1, 2021
Board of Supervisors to approve building safety;
April 11, 2023
(b) fire authority having jurisdiction, including a fire
clearance as required by Health and Safety Code November 15, 2022
☒ ☐ ☐
Section 13146.1(a) and (b); April 18, 2023
1 This document is intended for use as a tool during the inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally,
many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please
refer to the complete California Code of Regulations, Title 15, Minimum Standards for Local Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and
text of regulations.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(c) local health officer, inspection in accordance with
Health and Safety Code Section 101045; 2022:
Environmental Health May 5, 2022
Medical/Mental Health December 3, 2021
Nutritional Health April 15, 2022
☒ ☐ ☐
2023:
Environmental Health June 8, 2023
Medical/Mental Health November 29, 2022
Nutritional Health July 7, 2023
(d) county superintendent of schools on the adequacy
of educational services and facilities as required in October 26, 2021
☒ ☐ ☐
Section 1370; December 7, 2022
(e) juvenile court as required by Section 209 of the
Welfare and Institutions Code; and, November 5, 2021
☒ ☐ ☐
March 14, 2023
(f) the Juvenile Justice Commission as required by
Section 229 of the Welfare and Institutions Code or December 7, 2021
☒ ☐ ☐
Probation Commission as required by Section 240 of the December 6, 2022
Welfare and Institutions Code.
1320 APPOINTMENT AND QUALIFICATIONS
100.1
BSCC Note: Compliance with this section is determined
by receipt of the Chief Probation Officer’s certification
The elements of this regulation are addressed
letter confirming that all elements of regulation are met. in a memorandum completed by Interim Chief
Probation Officer Gina Johnson, dated June
20, 2023.
(a) Appointment
☒ ☐ ☐
In each juvenile facility there shall be a superintendent,
director or facility manager in charge of its program and
employees. Such superintendent, director, facility
manager and other employees of the facility shall be
appointed by the facility administrator pursuant to
applicable provisions of law.
(b) Employee Qualifications
Each facility shall: 1200.3 Recruitment
(1) recruit and hire employees who possess
☒ ☐ ☐
knowledge, skills and abilities appropriate to their job
classification and duties in accordance with
applicable civil service or merit system rules;
(2) require a medical evaluation and physical
examination including tuberculosis screening test
1200.4 (i) Medical and Psychological Exam
and evaluation for immunity to contagious illnesses
☒ ☐ ☐
of childhood (i.e., diphtheria, rubeola, rubella, and
mumps);
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
100.5 Correction Officer Responsibilities
(3) adhere to the minimum standards for the
302.1 Training Policy
selection and training requirements adopted by the
302.4 Minimum Training Requirements
Board pursuant to Section 6035 of the Penal Code; ☒ ☐ ☐
1200.7 Employment Standards
and
1200.7.1 Standards for Correction Officers
(4) conduct a criminal records review, on each new
employee, and psychological examination in
accordance with Section 1031 of the Government ☒ ☐ ☐
1200.4 (g); 1200.71
Code.
(c) Contract personnel, volunteers, and other non-
employees of the facility, who may be present at the
305.2
facility, shall have such clearance and qualifications as
may be required by law, and their presence at the facility
☒
☐ ☐
305.3
shall be subject to the approval and control of the facility
These sections are related to clearance for
manager.
Volunteers/Interns and Support Personnel.
1321 STAFFING
Each juvenile facility shall: 211 Staffing Plan
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its ☒ ☐ ☐
programming, to provide for safety and security of youth
and staff, and meet established standards and
regulations;
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent 200.3 ⁋ 2 Supervision of Youth
exigent circumstances; 211.3.1 (a)
The facility roster of staff, including mandated
Deputy Probation Officers, and schedules for
all VCPAJF reflect compliance with
regulation. We reviewed staffing for February
and April 2023, as well as schedules leading
up to the onsite inspection, and found youth
are moved to a condensed living unit for the
☒ ☐ ☐ purpose of sleeping to accommodate
coverage.
We have had discussions with the agency
and provided technical assistance to identify
the individual space as one 30-bed unit
rather than two 15-bed individual units. The
space would have significant day space for
programming youth in separate areas to
provide classification-specific programming
or recreation.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members;
211.3.1 (b)
☒ ☐ ☐
(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has
211.3.1 (c)
completed the Juvenile Corrections Officer Core Course ☒ ☐ ☐
and PC 832 training;
(e) have at least one staff member present on each
living unit whenever there are youth in the living unit;
211.3.1 (e)
☒ ☐ ☐
(f) have sufficient food service personnel relative to the
number and security of living units, including staff 900 Food Services
qualified and available to: plan menus meeting 900.3 Bullet 2
nutritional requirements of youth; provide kitchen
supervision; direct food preparation and servings;
☒ ☐ ☐
conduct related training programs for culinary staff; and
maintain necessary records; or, a facility may serve food
that meets nutritional standards prepared by an outside
source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance,
200.5
transportation, control room, facility security and other
support staff for the efficient management of the facility,
and to ensure that youth supervision staff shall not be
☒ ☐ ☐
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to
211.3.1 (f)
temporary variations in staff assignments to meet
special program needs. Staffing shall be in compliance ☒ ☐ ☐
with a minimum youth-staff ratio for the following facility
types:
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(1) Juvenile Halls
(A) during the hours that youth are awake, one 200.3 ⁋ 2
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
The agency has provided sufficient staffing
for the facility only due to mandated overtime
for the youth supervision staff (JCO’s), core
trained Deputy Probation Officers (DPO’s),
and non-core trained DPO’s who work side
by side with core trained staff. VCPAJF is in
their eleventh 40-hour orientation ‘class’ of
the DPO classification to provide for the
☒ ☐ ☐ necessary coverage. Although the agency
meets required Detention ratio identified as
1:10 per policy, it is a daily task for
administrators to provide coverage for call-
outs of scheduled staff.
We provided technical assistance and
referral information to better plan and audit
the call-off coverage, noting this is a
statewide problem for juvenile facilities.
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☒ ☐ ☐ 200.3 ⁋ 2
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an 200.3 ⁋ 3
arrangement has been made for backup support ☒ ☐ ☐
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☒ ☐ ☐
in the facility. 200.3 ⁋ 3
(E) personnel with primary responsibility for other
duties such as administration, supervision of 200.3.1
personnel, academic or trade instruction, clerical, 200.5
☒ ☐ ☐
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- This facility is not a Special Purpose Juvenile
☐ ☐ ☒
awake youth supervision staff member on duty for Hall.
each 10 youth in detention;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an
arrangement has been made for backup support ☐ ☐ ☒
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one The SYTF Population is not identified as a
☐ ☐ ☒
wide-awake youth supervision staff member on Camp.
duty for each 15 youth in the camp population;
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth present in the facility;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in residence, unless
arrangements have been made for backup ☐ ☐ ☒
support services which allow for immediate
response to emergencies;
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be
given to the size, design, and location of the
camp; types of youth committed to the camp; and
☐ ☐ ☒
the function of the camp in determining the level
of supervision necessary to maintain the safety
and welfare of youth and staff;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(F) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
farm, forestry, kitchen or maintenance shall not
be classified as youth supervision staff positions.
1322 YOUTH SUPERVISION STAFF ORIENTATION
AND TRAINING
300.3 Youth Supervision Orientation
(a) Prior to assuming any responsibilities each youth
supervision staff member shall be properly oriented to 300.3 Bullet 6
their duties, including:
(1) youth supervision duties;
The VCPAJF provides new staff with a
comprehensive orientation and training
program, including a Five Phase process,
starting with a Phase 1, an initial Orientation
of 40 hours. Phase 2 includes Initial Policy
Training; Phase 3 includes Supervision of
Youth with Close Training by the assigned
Training Officer (TO); Phase 4 is Sole
Supervision with Monitoring by the TO and
an assigned mentor/trainer; and, Phase 5 is
Working Independently with Supervision by
the TO.
☒ ☐ ☐
The training curriculum includes evaluation
of the Probationary staff of job skills and
learning progress, both of which are
documented at each Phase. A staff’s
competency is reviewed by facility
administrators prior to the staff receiving
permanent status with the agency.
Due to staffing shortages, the agency is
providing Phase 1 to the Deputy Probation
Officer staff, cored and non-cored, to provide
additional youth supervision.
Additionally, the agency provides a significant
annual staff training curriculum to ensure
competency continues.
(2) scope of decisions they shall make; 300.3 Bullet 13
☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(3) the identity of their supervisor; 300.3 Bullet 8
☒ ☐ ☐
(4) the identity of persons who are responsible to
them;
300.3 Bullet 13
☒ ☐ ☐
(5) persons to contact for decisions that are beyond
their responsibility; and
300.3 Bullet 13
☒ ☐ ☐
(6) ethical responsibilities.
300.3 Bullet 2
☒ ☐ ☐
(b) Prior to assuming any responsibility for the
supervision of youth, each youth supervision staff
302.5 Training
member shall receive a minimum of 40 hours of facility-
specific orientation, including:
The agency’s Five Phased Training Program
☒ ☐ ☐ is a comprehensive effort by tenured facility
staff to ensure new youth supervision staff
are trained in all aspects required to
complete their responsibilities.
(1) individual and group supervision techniques; 300.3.1 Bullet 1
☒ ☐ ☐
(2) regulations and policies relating to discipline and 300.3.1 Bullet 2
rights of youth pursuant to law and the provisions of ☒ ☐ ☐ POC 02.J.1
this chapter;
(3) basic health, sanitation and safety measures; 300.3.1 Bullet 3
☒ ☐ ☐
(4) suicide prevention and response to suicide
300.3.1 Bullet 4
attempts ☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(5) policies regarding use of force, de-escalation
techniques, chemical agents, mechanical and 300.3.1 Bullet 5
☒ ☐ ☐
physical restraints;
(6) review of policies and procedures referencing
300.3.1 Bullet 10
trauma and trauma-informed approaches; ☒ ☐ ☐
(7) procedures to follow in the event of
300.3.1 Bullet 6
emergencies; ☒ ☐ ☐
(8) routine security measures, including facility
300.3.1 Bullet 11
perimeter and grounds; ☒ ☐ ☐
(9) crisis intervention and mental health referrals to
300.3.1 Bullet 7
mental health services; ☒ ☐ ☐
(10) documentation; and 300.3.1 Bullet 8
☒ ☐ ☐
(11) fire/life safety training 300.3.1 Bullet 9
☒ ☐ ☐
(c) Prior to assuming sole supervision of youth, each
youth supervision staff member shall successfully
complete the requirements of the Juvenile Corrections 302.4 ⁋ 1
☒ ☐ ☐
Officer Core Course pursuant to Penal Code Section
6035.
(d) Prior to exercising the powers of a peace officer
youth supervision staff shall successfully complete
training pursuant to Section 830 et seq. of the Penal ☒ ☐ ☐ 302.4 ⁋ 2
Code.
1323 FIRE AND LIFE SAFETY
103.5 Training
Whenever there is a youth in a juvenile facility, there
300.3.1 Bullet 9
shall be at least one wide awake person on duty at all
☒ ☐ ☐
times who meets the training standards established by
the Board for general fire and life safety which relate
specifically to the facility.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1324 POLICY AND PROCEDURES MANUAL
102 Policy and Procedures Manual
All facility administrators shall develop, publish, and
102.5 Distribution of Manual
implement a manual of written policies and procedures
103.2 Post Orders (Procedures)
that address, at a minimum, all regulations that are
applicable to the facility. Such a manual shall be made
The VCPAJF has adopted Lexipol Policy and
available to all employees, reviewed by all employees,
Procedures (Post Orders) which include all
and shall be administratively reviewed at a minimum
required elements in regulation while
every two years, and updated, as necessary. Those
☒ ☐ ☐
allowing flexibility for changes or
records relating to the standards and requirements set
modifications as necessary.
forth in these regulations shall be accessible to the
Board on request.
There are currently no regulations specific to
The manual shall include: SYTF.
(a) table of organization, including channels of
communications and a description of job classifications; 100 Organization Structure
100.3 (a) Supervising Probation Officer -
Senior Responsibilities
☒ ☐ ☐
100.5 Correction Officer Responsibilities
1102.3 Communications
(b) responsibility of the probation department, purpose
of programs, relationship to the juvenile court, the
101.1 Responsibility and Scope of Juvenile
Juvenile Justice/Delinquency Prevention Commission
Facility
or Probation Committee, probation staff, school ☒ ☐ ☐
personnel and other agencies that are involved in
juvenile facility programs;
(c) responsibilities of all employees;
102.3
☒ ☐ ☐
(d) initial orientation and training program for
employees;
300 Staff Orientation and Training
☒ ☐ ☐
(e) initial orientation, including safety and security issues
and anti-discrimination policies, for support staff, 300 Staff Orientation and Training
contract employees, school, mental/behavioral health 304 Health Care Orientation
and medical staff, program providers and volunteers; ☒ ☐ ☐ 305 Volunteer and Intern Orientation and
Training
(f) maintenance of record-keeping, statistics and
communication system to ensure:
304.5
☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(1) efficient operation of the juvenile facility; 100.1 Purpose and Scope of the Facility
☒ ☐ ☐
(2) legal and proper care of youth; 100.7.2 Agency Responsibility
☒ ☐ ☐
(3) maintenance of individual youth's records; 205.3
☒ ☐ ☐
(4) supply of information to the juvenile court and
205.4
those authorized by the court or by the law; and, ☒ ☐ ☐
(5) release of information regarding youth. 205.4
☒ ☐ ☐
305.4 Volunteers/Interns
(g) ethical responsibilities; 1200.2 Recruitment
☒ ☐ ☐
1200.5 Background Check
1201.5.2 (g) Standards of Conduct
300.3.1 Bullet 10
512.4
706.4
1000.3 Programs and Education
(h) trauma-informed approaches;
☒ ☐ ☐ The VCPAJF policy includes trauma and
trauma-informed approaches in each
element of facility operations, including
training and orientation of staff, admission,
classification, searches, healthcare, hygiene,
education, and programming.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
300.3.1 Bullet 10
500.1 Admission
1000.3 (m)
1002.6
1003.3 Education
(i) culturally responsive approaches;
☒ ☐ ☐
The VCPAJF policy includes cultural
responses in each element of facility
operations, including training and orientation
of staff, admission, classification, hygiene,
education, and programming.
500.5
501.3
513 3; 513.4.3; 513.5; 513.10
605.2
701.6
802.6.1
1000.3 (b)
(j) gender responsive approaches;
☒ ☐ ☐
The VCPAJF policy includes gender
responses in each element of facility
operations including training and orientation
of staff, admission, classification, searches,
healthcare, hygiene, education, and
programming.
(k) a non-discrimination provision that provides that all
youth within the facility shall have fair and equal access 605 Non-Discrimination Provision (NDP)
to all available services, placement, care, treatment, and 605.2
benefits, and provides that no person shall be subject to
discrimination or harassment on the basis of actual or
perceived race, ethnic group identification, ancestry,
☒ ☐ ☐ The VCPAJF has the NDP posted in all living
national origin, immigration status, color, religion,
units and Intake.
gender, sexual orientation, gender identity, gender
expression, mental or physical disability, or HIV status,
including restrictive housing or classification decisions
based solely on any of the above mentioned categories;
(l) storage and maintenance requirements for any
chemical agents related security devices, and weapons 202 Inventory and Supplies
and ammunition, where applicable; ☒ ☐ ☐ 209.3 (i) Weapons Storage
(m) establishment of procedures for collection of Medi-
Cal eligibility information and enrollment of eligible 500.5.4
☒ ☐ ☐
youth; and,
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(n) establishment of a policy that prohibits all forms of
sexual abuse, sexual assault and sexual harassment. 303 Sexual Abuse and Harassment Training
The policy shall include an approach to preventing, 501.6.1 Classification
detecting and responding to such conduct and any 502.4 (n) Orientation
retaliation for reporting such conduct, as well as a ☒ ☐ ☐ 503.3 Assessments
provision for reporting such conduct by youth, staff or a 606.5 Grievances
third party. 701.4 (j) Screenings
1325 FIRE SAFETY PLAN
The facility administrator shall consult with the local fire 401 Fire Safety
department having jurisdiction over the facility, or with
the State Fire Marshal, in developing a plan for fire 401.3 (b)
☒ ☐ ☐
safety which shall include, but not be limited to:
(a) a fire prevention plan to be included as part of the
manual of policy and procedures;
(b) monthly fire and life safety inspections by facility
staff with two-year retention of the inspection record;
401.3 (c)
We reviewed Fire and Life Safety Inspections
for the VCPAJF from April 2022 to June 2023.
The agency has a systematic approach to the
inspection in every space of the facility,
recording any non-working or required
elements of space to confirm it is safe for
youth and staff.
☒ ☐ ☐
The form includes: Fire Extinguishers, Fire
Alarms, First Aid Kits, Exit/Evacuation
Routes, Storage Areas, Electric/Lighting, Lint
Traps/Dryer Exhaust, Flashlights, Door
Locks, Cameras/Monitors, Panic Alarms,
Radios and Cell Phones, and AED’s. Each
area is checked by one of the CSO III’s. If
there is a required fix or referral to
maintenance, it is tracked by administration
to ensure it is addressed and remedied.
(c) fire prevention inspections as required by Health
and Safety Code Section 13146.1(a) and (b);
401.7
☒ ☐ ☐
The last fire inspection for the VCPAJF was
completed on April 18, 2023.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(d) an evacuation plan;
403 Evacuation Plan
☒ ☐ ☐
(e) documented fire drills not less than quarterly;
401.3 (e)
The agency completes Emergency
Fire/Earthquake or Emergency procedures
Drills monthly. We reviewed documentation
for all drills from April 2022 to June 2023. The
facility conducts monthly drills as a training
mechanism while walking through the facility
to ensure staff individually know how to react
☒ ☐ ☐
given an emergency “training” drill.
Documented evacuation drills of youth by
unit occur quarterly, as required by
regulation.
We provided technical assistance to ensure
full evacuations of all youth, at least annually,
as required by VCPAJF Policy 403.4.
(f) a written plan for the emergency housing of youth in
the case of fire; and,
400.12
☒ ☐ ☐
(g) development of a fire suppression pre-plan in
cooperation with the local fire department.
401.3
☒ ☐ ☐
1326 SECURITY REVIEW
Each facility administrator shall develop policies and 209.3
procedures to annually review, evaluate, and document
security of the facility. The review and evaluation shall
include internal and external security, including, but not
Chief Probation Officer Gina Johnson
limited to, key control, equipment, and staff training.
☒ ☐ ☐ completed a memo outlining an
Administrative and Supervisor review of
Security practices conducted on April 19,
2023, and May 30, 2023.
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1327 EMERGENCY PROCEDURES
The facility administrator shall develop facility-specific 400 Facility Emergencies
policies and procedures for emergencies that shall
include, but not be limited to:
Chief Probation Officer Gina Johnson
completed a memo outlining an
Administrative and Supervisor review of
Emergency Procedures conducted on April
19, 2023, and May 30, 2023.
☒ ☐ ☐
It was noted during the meetings several
Emergency Procedures need updating which
is being done now. The agency is compliant
and will forward any new policies or
operational procedures relating to this when
completed.
400.3 (a), (b) and (c)
400.7 Disturbances
(a) escape, disturbances, and the taking of hostages;
☒ ☐ ☐ 400.8 Hostages
400.9 Escape
400.3 (d) and (i)
(b) civil disturbance, active shooter and terrorist
400.7 Disturbances
attack; ☒ ☐ ☐
400.6 Active Shooter and Terrorist Attack
400.3 (e)
(c) fire and natural disasters;
☒ ☐ ☐ 401
400.3 (f)
(d) periodic testing of emergency equipment;
☒ ☐ ☐ 402.5
400.3 (h)
(e) emergency evacuation of the facility; and
☒ ☐ ☐ 403
(f) a program to provide all youth supervision staff
400.13
with an annual review of emergency procedures. ☒ ☐ ☐
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1328 SAFETY CHECKS
The facility administrator shall develop and implement 505.3 (a), (b) and (d)
policy and procedures that provide for direct visual
observation of youth at a minimum of every 15 minutes,
at random or varied intervals during hours when youth
We reviewed safety checks audits for the
are asleep or when youth are in their rooms, confined in
months of December 2022, January and April
holding cells or confined to their bed in a dormitory.
2023 for all occupied facility operational
Supervision is not replaced, but may be supplemented
units. Overall, the electronic checks are
by, an audio/visual electronic surveillance system
random, typically between 11 and 15
designed to detect overt, aggressive or assaultive
minutes, recording the youth room and the
behavior and to summon aid in emergencies. All safety
total number of youths in the unit.
checks shall be documented with the actual time the
check is completed.
☒ ☐ ☐
A CSO III now reviews safety checks for all
units, checking for late or missed checks, as
well as patterned checks. We found very few
late, missed, or patterned checks. The staff
responsible and the circumstance is
recorded in the Supervisors Log to allow the
incident to be formally addressed. Our
recommendation is that the audits occur
daily, to ensure all are done per policy, by the
graveyard CSO III.
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1329 SUICIDE PREVENTION PLAN
The facility administrator, in collaboration with the 706.4 Suicide Prevention Plan
healthcare and behavioral/mental health administrators,
shall plan and implement written policies and
procedures which delineate a Suicide Prevention Plan.
Youth are administered the MAYSI-2 upon
The plan shall consider the needs of youth experiencing
admission or whenever a significant event
past or current trauma. Suicide prevention responses
occurs while in custody. The assessment tool
shall be respectful and in the least invasive manner
identifies cautions or warnings for behavior
consistent with the level of suicide risk. The plan shall
involving suicidal ideation or tendencies. A
include the following elements:
Classification Questionnaire during booking
to determine appropriate housing and
supervision status also is responsive to this
regulation.
The agency has had three suicide incidents
that resulting in a safety room placement,
none involving SYTF youth. There have been
☒ ☐ ☐
13 incidents of youth with a caution or
warning from the MAYSI assessment that
have been referred to Behavior Health.
Youth are placed on special watch in these
situations pending being seen and/or
evaluated by Behavior Health.
We note Behavior Health has taken a much
more involved and consistent approach to all
intake, assessment, and crisis incidents,
observed by documented responses to
incidents. The clinicians are proactive and
engaged with the processes and staff
engagement for successful treatment
approaches to youth in crisis.
(a) Suicide prevention training as required in Section
1322, Youth Supervision Staff Orientation, and Training 300.3.1 Bullet 4
and the Juvenile Corrections Officer Core Course. ☒ ☐ ☐ 304.5 (e)
(b) Screening, Identification Assessment and
Precautionary Protocols 501.3 Bullet 8
(1) All youth shall be screened for risk of suicide at ☒ ☐ ☐ 701.4 (c)
intake and as needed during detention.
(2) All youth supervision staff who perform intake
processes shall be trained in screening youth for risk
☒ ☐ ☐ 501.11 Staff Training in Classification
of suicide.
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(3) All youth who have been identified during the
intake screening process to be at risk of suicide shall
701.4 (c)(2)
be referred to behavioral/mental health staff for a ☒ ☐ ☐
suicide risk assessment.
(4) Precautionary protocols shall be developed to
ensure the youth’s safety pending the
☒ ☐ ☐ 706.5
behavioral/mental health assessment.
(c) Referral process to behavioral/mental health staff for
assessment and/or services. 703.4 ⁋ 2
☒ ☐ ☐ 706.3
(d) Procedures for monitoring of youth identified at risk
for suicide. 706.3
☒ ☐ ☐ 706.5
(e) Safety Interventions
(1) Procedures to address intervention protocols for
☒ ☐ ☐
youth identified at risk for suicide which may include,
but are not limited to:
(A) Housing consideration
501.3
☒ ☐ ☐
706.5 ⁋
1
(B) Treatment strategies including trauma-
informed approaches
706.4
☒ ☐ ☐
(2) Procedures to instruct youth supervision staff
how to respond to youth who exhibit suicidal
FPO.07.F, 6 Caution Status
behaviors.
☒ ☐ ☐
FPO.07.F, 2
(f) Communication
(1) The intake process shall include communication
701.4, C-1
with the arresting officer and family guardians
☒ ☐ ☐
regarding the youth’s past or present suicidal
ideations, behaviors or attempts.
(2) Procedures for clear and current information
sharing about youth at risk for suicide with youth
supervision, healthcare, and behavioral/mental 706.3 ⁋ 1
health staff.
706.8 ⁋ 1 and 2
☒ ☐ ☐
FPO.07.F, 2 (a)
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(g) Debriefing of Critical Incidents Related to Suicides or
Attempts
(1) Process for administrative review of the 706.9 ⁋ 1 Debriefing
☒ ☐ ☐
circumstances and responses proceeding, during
and after the critical incident.
(2) Process for a debriefing event with affected
706.9 ⁋ 2
staff. ☒ ☐ ☐
(3) Process for a debriefing event with affected
youth.
706.9 ⁋ 2
☒ ☐ ☐
(h) Documentation
(1) Documentation processes shall be developed to 706.6 Observation Logs
ensure compliance with this regulation ☒ ☐ ☐ 706.7 Documentation
Youth identified at risk for suicide shall not be denied the
opportunity to participate in facility programs, services 706.4 ⁋ 2
and activities which are available to other non-suicidal
youth, unless deemed necessary for the safety of the
youth or security of the facility. Any deprivation of ☒ ☐ ☐
programs, services or activities for youth at risk of
suicide shall be documented and approved by the
facility manager.
1340 REPORTING OF LEGAL ACTIONS
101.5
Each facility shall submit to the Board a letter of
notification on each legal action, pertaining to conditions
☒ ☐ ☐ There are no legal issues pending at the
of confinement, filed against persons or legal entities
VCPAJF.
responsible for juvenile facility operation.
1341 DEATH AND SERIOUS ILLNESS OR INJURY
OF A YOUTH WHILE DETAINED 518.3 In Custody Death
518.3 ⁋ 3 In Custody Death Notifications
(1) Death of a Youth.
(a) The facility administrator, in cooperation with
the health administrator and the behavioral/mental
health director, shall develop written policies and ☒ ☐ ☐
procedures in the event of the death of a youth while
detained, which include notifications to necessary
parties, which may include the Juvenile Court, the
parent, guardian or person standing in loco parentis
and the youth’s attorney of record.
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(b) The health administrator, in cooperation with the
facility administrator, shall develop written policies
and procedures to assure there is a medical and 518.4 ⁋ 2
operational review of every in-custody death of a
youth. The review team shall include the facility
☒ ☐ ☐
administrator and/or facility manager, the health
administrator, the responsible physician and other
health care and supervision staff who are relevant to
the incident.
(c) The administrator of the facility shall provide to
the Board a copy of the report submitted to the
Attorney General under Government Code Section 518.3 ⁋ 5
☒ ☐ ☐
12525. A copy of the report shall be submitted to the
Board within 10 calendar days after the death.
(d) Upon receipt of a report of the death of a youth
from the administrator, the Board may within 30
The facility administrators are aware of this
calendar days inspect and evaluate the juvenile
regulation.
facility, jail, lockup or court holding facility pursuant to
☒ ☐ ☐
the provisions of this subchapter. Any inquiry made
by the Board shall be limited to the standards and
requirements set forth in these regulations.
(2) Serious Illness or Injury of Youth.
(a) The facility administrator, in cooperation with 700.3.1 (b)5
the health administrator, shall develop written
700.3.1 (b)14
policies and procedures for the notification to
☒ ☐ ☐
necessary parties, which may include the Juvenile
700.3.1 (b)18 Responsibilities of the Health
Court, the parent, guardian or person standing in
Care Administrator (Illness)
loco parentis and the youth’s attorney of record in the
case of a serious illness or injury of a youth. 801.7 Youth Safety (Injury)
1342 POPULATION ACCOUNTING
Each juvenile facility shall submit required population and ☒ 1101.6.1
profile survey reports to the Board within 10 working days ☐ ☐
after the end of each reporting period, in a format to be
provided by the Board.
1343 JUVENILE FACILITY CAPACITY (EXCERPT)
When the number of youth detained in a living unit of a 1101.3
juvenile facility exceeds its rated capacity for more than ☒ ☐
☐
fifteen (15) calendar days in a month, the facility
administrator shall provide a crowding report to the
Board in a format provided by the Board.
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1350 ADMITTANCE PROCEDURES
The facility administrator shall develop and implement 500.1 Admission
written policies and procedures for admittance of youth
that emphasize respectful and humane engagement
with youth, and reflect that the admission process may
The VCPAJF has a comprehensive
be traumatic to youth who may have already
admission process and includes many
experienced trauma. Policies shall be trauma-informed,
advisals and assessments to assist in
culturally relevant, and responsive to the language and
determining appropriate classification.
literacy needs of youth. In addition to the requirements
These tools articulate detention criteria,
of Sections 1324 and 1430 of these regulations:
housing location, security status, suicidal
tendencies, and the propensity for violence
or victimization. The intake and booking
process provides information to acclimate
the youth to detention as well as orient the
youth to expectations, rights, and rules. The
assessments continue to the youth file when
committed to SYTF.
Staff complete a Juvenile Risk Assessment
Tool to determine if detention is appropriate,
with override and mitigation factors. If
☒ ☐ ☐ detained, the MAYSI-2 Questionnaire and
Classification Assessment Questionnaire are
administered to assist in placement and any
security status needs. Youth then
acknowledge the Prison Rape Elimination
Act (PREA) policy as it relates to Sexual
Abuse, Harassment, and Assault. The Zero
Tolerance for Gang or Violence is also part of
the admission documents the youth signs to
acknowledge. Added this cycle is the Youth
Bill of Rights and Ombudsman information
provided through the Office of Youth and
Community Restoration.
We reviewed numerous intake and remand
Admission paperwork and documentation
outlining the procedures in policy and
regulation. We found the process is lengthy
and exceeds regulatory requirements to
make the best admission decisions.
(a) the admittance process shall include:
(1) Access to two free phone calls within one hour of
500.8
admittance in accordance with the provisions of ☒ ☐ ☐
Welfare and Institution Code Section 627;
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(2) Offer of a shower; 500.9
☒ ☐ ☐
(3) Documented secure storage of personal
500.7.2
belongings; ☒ ☐ ☐
(4) Offer of food upon arrival; 500.5.5
☒ ☐ ☐
(5) Screening for physical and behavioral health
304.6 Initial Youth Screening
and safety issues, intellectual or developmental
☒ ☐ ☐ 501.3 Bullet 10
disabilities;
(6) Screening for physical and developmental
disabilities in accordance with Sections 1329, 1413, 501.3 Bullet 10
☒ ☐ ☐
and 1430 of these regulations;
(7) Contact with Regional Center for the
Developmentally Disabled for youth that are
702.7 Last Paragraph
suspected of or identified as having a
☒ ☐ ☐
developmental disability, pursuant to Section 1413;
and,
501.12
(8) Procedures consistent with Section 1352.5.
☒ ☐ ☐
802.6.1
(b) juvenile hall administrators shall establish written
criteria for detention that considers the least restrictive
☒ ☐ ☐ 500.3 (h)
environment.
(c) juvenile camps and post-dispositional programs in
juvenile halls shall develop policies and procedures that
500.5.3
advise the youth of the estimated length of stay, inform
them of program guidelines and provide written ☒ ☐ ☐
screening criteria for inclusion and exclusion from the
program.
(d) juvenile halls shall develop policies and procedures
that advise any committed youth of the estimated length
☒ ☐ ☐ 500.5.3
of his/her stay.
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1350.5 SCREENING FOR THE RISK OF SEXUAL
ABUSE
501.3
The facility administrator shall develop and implement 701.4 (j) (1)
written policies and procedures to reduce the risk of
sexual abuse by or upon youth. The policy shall require The MAYSI-2 and Classification
☒ ☐ ☐
facility staff to assess each youth within 72 hours of Questionnaire are responsive to this
admission based on the following information: regulation. Youth also watch a PREA video
and read agency policies on how to report
sexual abuse, assault, or discrimination.
(a) Prior sexual victimization or abusiveness; 501.3 Bullet 19 and 21
☒ ☐ ☐
(b) Gender nonconforming appearance or manner; or
identification as lesbian, gay or bisexual, transgender,
501.3 Bullet 20 and 24
queer or intersex, and whether the youth may, therefore, ☒ ☐ ☐
be vulnerable to sexual abuse;
(c) Current charges and offense history; 501.3 Bullet 4-6
☒ ☐ ☐
(d) Age; 501.3 Bullet 1
☒ ☐ ☐
(e) Level of emotional and cognitive development; 501.3 Bullet 7
☒ ☐ ☐
(f) Physical size and stature; 501.3 Bullet 3
☒ ☐ ☐
(g) Mental illness or mental disabilities; 501.3 Bullet 10 and 13
☒ ☐ ☐
(h) Intellectual or developmental disabilities; 501.3 Bullet 14
☒ ☐ ☐
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(i) Physical disabilities; 501.3 Bullet 12
☒ ☐ ☐
(j) The youth’s perception of vulnerability; and, 501.3 Bullet 22
☒ ☐ ☐
(k) Any other specific information about the individual
youth that may indicate heightened needs for
501.3 Bullets 1-24
supervision, additional safety precautions, or separation ☒ ☐ ☐
from certain other youth.
Staff shall ascertain this information through
conversations with the youth during the admittance
501.4
process, medical and behavioral health screenings;
during classification assessments; and by reviewing ☒ ☐ ☐
court records, case files, facility behavioral records, and
other relevant documentation from the youth’s files.
The facility administrator shall implement appropriate
controls on the dissemination of information within the
501.3 Last Paragraph
facility relative to responses received pursuant to this
assessment in order to ensure that sensitive information ☒ ☐ ☐
is not exploited to the youth’s detriment by staff or other
youth.
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1351 RELEASE PROCEDURES
The facility administrator shall develop and implement 516 Releases
written policies and procedures for release of youth from
custody which provide for:
The process for release from all VCPAJF
programs includes transition planning and
linkage to appropriate community services.
We were provided and reviewed the Ventura
County Community Resource List which
outlines available services in different
geographical areas of the county.
The agency identifies youth needing special
release services in the Multi-Disciplinary
Team (MDT), Critical Care Team (CCT), and
Treatment Team (TTM) meetings which
occur weekly. Participation includes
representatives from Behavior Health,
☒ ☐ ☐
Medical, and the VCOE school personnel, as
well as CSO or DPO probation staff.
We reviewed the Release Form, which
includes the youth’s information at booking,
disposition, release authorization, and
signature and identification of the person the
youth is released to. Also included is
acknowledgment of property released to the
youth.
Four youth have been released from SYTF,
one to the family on community supervision
and 3 to the California Conservation Corp as
a step-down.
(a) verification of identity/release papers; 516.3 (a)
☒ ☐ ☐
516.3 (d)
(b) return of personal clothing and valuables;
☒ ☐ ☐
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(c) notification to the youth's parents or guardian; 516.3 (l)
☒ ☐ ☐
(d) notification to the facility health care provider in
accordance with Sections 1408 and 1437 of these
☒ ☐ ☐ 516.3 (c) and (m)
regulations, for coordination with outside agencies; and,
(e) notification of school staff; 516.3 (n)
☒ ☐ ☐
(f) notification of facility mental health personnel. 516.3 (m)
☒ ☐ ☐
The facility administrator shall develop and implement
policies and procedures for post-disposition youth to
516.3 (g) and (n)
coordinate the provision of transitional and reentry
services including, but not limited to, medical and ☒ ☐ ☐
behavioral health, education, probation supervision and
community-based services.
The facility administrator shall develop and implement
written policies and procedures for the furlough of youth
☒ ☐ ☐ 526.4
from custody.
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1352 CLASSIFICATION
The facility administrator shall develop and implement 501 Classification
written policies and procedures on classification of youth
for the purpose of determining housing placement in the
facility.
The Classification Questionnaire used at
Such procedures shall: booking assists staff in determining the most
appropriate placement of youth at admission
and to address observed security or safety
needs of youth.
We reviewed admission documentation
including this form and found it to be
consistent with regulation requirements and
policy. Additionally, youth are re-classified
based on circumstances as they occur while
in the facility via the Critical Case Team
meetings. This is memorialized in the youth’s
☒ ☐ ☐ electronic file, the Ventura County Integrated
Justice Information System. SYTF youth are
in their own unit and classified as ‘younger’
or ‘older’ youth. Since there are only 11
committed and legislation has provided a
clear direction for sight and sound
separation, the agency is moving forward to
consider housing all youth in one unit and
allow a second unit as they advance in the
program.
It is significant to note the agency works with
medical and behavior health staff to assist in
special classification needs, as well as
reviewing the youth’s behavior which may
prompt a new classification.
(a) provide for the safety of the youth, other youth,
facility staff, and the public by placing youth in the
501.7
appropriate, least restrictive housing and program
settings. Housing assignments shall consider the need ☒ ☐ ☐
for single, double or dormitory assignment or location
within the dormitory;
(b) consider facility populations and physical design of
the facility;
501.8
☒ ☐ ☐
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(c) provide that a youth shall be classified upon
admittance to the facility; classification factors shall
501.3
include, but not be limited to: age, maturity,
sophistication, emotional stability, program needs, legal
☒ ☐ ☐
status, public safety considerations, medical/mental
health considerations, gender and gender identity of the
youth;
(d) provide for periodic classification reviews, including
provisions that consider the level of supervision and the
501.6.1 Periodic Reviews
youth's behavior while in custody; and,
501.6.2 Staff Initiated Reviews
Classification status is reviewed by the CSO
☒ ☐ ☐ III, SDPO, and/or the Watch Commander as
necessary to ensure youth are reintegrated
in the least restrictive classification as
necessary based on their security, medical,
or mental health status.
(e) provide that facility staff shall not separate youth from
the general population or assign youth to a single
occupancy room based solely on the youth's actual or 501.10.1 ⁋ 2 Non-Discrimination Provision
perceived race, ethnic group identification, ancestry,
605.2 ⁋ 1 Non-Discrimination Provision
national origin, color, religion, gender, sexual
orientation, gender identity, gender expression, mental
☒ ☐ ☐
or physical disability, or HIV status. This section does
not prohibit staff from placing youth in a single
occupancy room at the youth's specific request or in
accordance with Title 15 regulations regarding
separation.
(f) facility staff shall not consider lesbian, gay, bisexual,
transgender, questioning or intersex identification or
status as an indicator of likelihood of being sexually ☒ ☐ ☐ 501.10 ⁋ 3
abusive.
1352.5 TRANSGENDER AND INTERSEX YOUTH.
The facility administrator shall develop written policies 501.12 Transgender and Intersex Youth
and procedures ensuring respectful and equitable
☒ ☐ ☐
treatment of transgender and intersex youth. The 501.6.1 ⁋ 2
policies shall provide that:
(a) Facility staff shall respect every youth’s gender
identity and shall refer to the youth by the youth’s
501.12 I-A
preferred name and gender pronoun, regardless of the
youth’s legal name. Facilities may prohibit the use of
☒ ☐ ☐
gang or slang names or names that otherwise
compromise facility operations as determined by the
facility manager or designee, and shall document any
decision made on this basis.
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(b) Facility staff shall permit youth to dress and present
themselves in a manner consistent with their gender
501.12 I-B
identity and shall provide youth with the institution’s ☒ ☐ ☐
clothing and undergarments consistent with their gender
802.6.1 Clothing Issue
identity.
(c) Facility staff shall house youth in the unit or room that
best meets their individual needs and promotes their
500.6.2
safety and well-being. Staff may not automatically house
youth according to their external anatomy and shall
501.3 Bullet 9, 19-22
document the reasons for any decision to house youth ☒ ☐ ☐
in a unit that does not match their gender identity. In 501.12 I-C
making a housing decision, staff shall consider the
youth’s preferences, as well as any recommendations
from the youth’s health or behavioral health provider.
(d) Facility administrators shall ensure that transgender
and intersex youth have access to medical and
501.12 I-D
behavioral health providers qualified to provide care and ☒ ☐ ☐
treatment to transgender and intersex youth.
702.7 (f)
(e) Consistent with the facility’s reasonable and
necessary security considerations and physical plant,
501.12 I-E
facility staff shall make every effort to ensure the safety
☒ ☐ ☐
and privacy of transgender and intersex youth when the
802.11 Showers
youth are using the bathroom or shower, or dressing or
undressing.
Facility staff shall not conduct physical searches of any
youth for the purpose of determining the youth’s
501.12 II-A and B
anatomical sex. Whenever feasible, the facility shall
respect the youth’s preference regarding the gender of ☒ ☐ ☐
513.5
the staff member who conducts any search of the youth.
POC.04.F.3
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1353 ORIENTATION
The facility administrator shall develop and implement 502 Youth Orientation
written policies and procedures to orient a youth prior to 502.2
placement in a living area. Both written and verbal
information shall be provided and supplemented with The intake and booking process for all
video orientation if feasible. Provision shall be made to VCPAJF includes a review of facility
provide accessible orientation information to all detained operations, youth rights, and the rules that
youth including those with disabilities, limited literacy, or guide youth through the program. The
English language learners. Orientation shall include Orientation for each facility type includes all
information that addresses: aspects of programming and activities while
detained.
Facility expectations and opportunities are
explained in both verbal and written formats
☒ ☐ ☐ to allow a youth to understand the material
while in-custody. The individual program is
outlined in a handbook to promote progress
through positive behavior to earn incentives.
We provided technical assistance to
consolidate the booking forms requiring
youth acknowledgment relating to the
Ombudsman and Youth Bill of Rights for a
more streamlined approach and training
opportunity for youth to better understand the
program expectations. The new Youth
Handbook is descriptive as it relates to all
Orientation components.
(a) facility rules including contraband and searches and
disciplinary procedures;
502.4 (a)
☒ ☐ ☐
(b) facility’s system of positive behavior interventions
and supports, including behavior expectations, 502.4 (b)
incentives that youth will receive for complying with 1009.3 (a) BMP
☒ ☐ ☐
facility rules, and consequences that may result when
youth violate the rules of the facility;
(c) age appropriate information that explains the
facility’s policy prohibiting sexual abuse and sexual 502.4 (n)
harassment and how to report incidents or suspicions of ☒ ☐ ☐
sexual abuse or sexual harassment;
(d) identification of key staff and their roles;
502.4 (v)
☒ ☐ ☐ 1208.7 (a)
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(e) the existence of the grievance procedure, the steps
that must be taken to use it, the youth’s right to be free 502.4 (e)
of retaliation for reporting a grievance, and the name of ☒ ☐ ☐
the person or position designated to resolve the issue;
(f) access to legal services and information on the
502.4 (i)
court process; ☒ ☐ ☐
(g) access to routine and emergency health and mental
502.4 (f)
health care; ☒ ☐ ☐
(h) access to education, religious services, and
502.4 (g)
recreational activities; ☒ ☐ ☐
(i) housing assignments; 502.4 (h)
☒ ☐ ☐
(j) opportunity for personal hygiene and daily showers
including the availability of personal care items 502.4 (d)
☒ ☐ ☐
(k) rules and access to correspondence, visits and
telephone use; 502.4 (c)
☒ ☐ ☐
(l) availability of reading materials, programming, and
other activities; 502.4 (k)
☒ ☐ ☐
(m) facility policies on the use of force, use of restraints,
chemical agents and room confinement; 502.4 (l), (m) and (w)
☒ ☐ ☐
(n) immigration legal services; 502.4 (p)
☒ ☐ ☐
(o) emergencies including evacuation procedures; 502.4 (r)
☒ ☐ ☐
(p) non-discrimination policy and the right to be free from
physical, verbal or sexual abuse and harassment by 303.1 (g)
other youth and staff; 502.4 (n) and (u)
☒ ☐ ☐
603.1
(q) availability of services and programs in a language
other than English if appropriate;
502.4 Last 2 Paragraphs
☒ ☐ ☐
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(r) the process for requesting different housing,
education, programming and work assignments;
502.4 (x)
☒ ☐ ☐
(s) a process for which parents/guardians receive
information regarding the youth’s stay in the facility that
502.4 (y)
at a minimum includes answers to frequently asked
☒ ☐ ☐
questions and provides contact information for the
facility, medical, school and mental health; and,
(t) a process by which youth may request access to Title
15 Minimum Standards for Juvenile Facilities.
502.4 (z)
☒ ☐ ☐
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1354 SEPARATION
The facility administrator shall develop and implement 519 Youth Separation
written policies and procedures that address:
519 Second to last ⁋
500.6.2
The VCPAJF agency has a well-documented
practice of recording a youth’s request to
decline participation in unit programs and
activities. There has been some confusion
amongst staff for what is referred to as
‘decliners’ versus those that self-separate for
protective custody reasons.
We reviewed self-separation half sheets,
revealing the youth’s request for non-
participation in an activity or program
including their signature detailing the reason.
☒ ☐ ☐ These are short-term separations and are
well documented.
We also reviewed four incidents of long-term
self-separations that turned into a re-
classification. The incident report or youth’s
signed request to self-separate and notes
from Critical Case Meetings articulated
efforts by staff and/or Behavior Health to
reintegrate the youth. The case logs also
detail unit staff efforts to get a youth back into
programming. These long-term ‘separations’
are a classification the agency is working on
to facilitate needs and activities in an
environment where the youth feels safe to
engage in unit activities. We provided
technical assistance to encourage a ‘re-
branding’ for these youth that is positive-
focused.
(a) separation of youth for reasons that include, but are
not be limited to, medical and mental health conditions, 519 Medical Separation
assaultive behavior, disciplinary consequences and 519.3 Self Separation
protective custody. 501.7
☒ ☐ ☐
600.3.1
601.4
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(b) consideration of positive youth development and
trauma-informed care.
519 ⁋ 3
☒ ☐ ☐
501.7.1 ⁋ 1
(c) separated youth shall not be denied normal
privileges available at the facility, except when
necessary to accomplish the objective of separation. 519 ⁋ 4
☒ ☐ ☐
501.7.1 ⁋ 2
(d) when the objective of the separation is discipline,
Title 15 Section 1390 shall apply.
519 ⁋ 5
☒ ☐ ☐
501.7.1 ⁋ 1
(e) when separation results in room confinement, the
separation shall occur in accordance with Welfare and
Institutions Code Section 208.3 and Section 1354.5 of ☒ ☐ ☐ 519 ⁋ 1
these regulations.
601 Room Confinement
(f) policies and procedures shall ensure a daily review
of separated youth to determine if separation remains
necessary. 519 Last ⁋
☒ ☐ ☐
501.7.1 ⁋ 4
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1354.5 ROOM CONFINEMENT
(a) The facility administrator shall develop and 601 Room Confinement (RC)
implement written policies and procedures addressing
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
The VCPAJF agency reported 119 incidents
208.3. The placement of a youth in room confinement
of Room Confinement from April 2022 to
shall be accomplished in accordance with the following
June 2023. This is slightly more than the 50
guidelines:
in 2021, but less than the previous ‘time outs’
recorded in 2018-2019 before the regulation
and legislation were implemented.
After a safety and security-related incident,
staff initiated an RC Log which prompts them
to initiate specific documentation practices
and alerts to senior staff. Agency policy and
procedures include the staff recording
behavior and attempts to remove the youth
from RC status as soon as the threat is
minimized. When this happens, youth must
agree to respond with appropriate behaviors
in a contract format to document the
expectations when removed. In most cases,
the youth return to regular unit activities.
☒ ☐ ☐
We reviewed 7 RC incidents and 10 UF
incidents resulting in RC, including 4 SYTF
youth, and found the agency utilizes RC for
applicable behavior-related incidents that
pose a safety and security risk to other youth,
staff or the facility operations.
Staff and supervisors provided appropriate
responses to reintegrate youth to
programming, including behavior health input
and involvement. Safety check logs and
behavior health intervention documentation
was included in the reviewed incidents.
The agency has adopted an early morning
review of youth on RC going into the
following day in an effort to return the youth
to normal activities as the youth starts their
day.
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(1) Room confinement shall not be used before
other, less restrictive, options have been attempted
601.4 (a)
and exhausted, unless attempting those options
☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or
☒ ☐ ☐ 601.4 (b)
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health
☒ ☐ ☐ 601.4 (c)
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room
601.4.5 (a)
confinement for a period of four hours, staff shall do one ☒ ☐ ☐
or more of the following:
(1) Return the youth to general population. 601.4.5 (a) (1)
☒ ☐ ☐
(2) Consult with mental health or medical staff. 601.4.5 (a) (2)
☒ ☐ ☐
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate
☒ ☐ ☐ 601.4.5 (a) (3)
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following:
601.4.5 (b)
☒ ☐ ☐
(A) Document the reasons for room confinement
and the basis for the extension, the date and time
601.4.5 (b)(1)
the youth was first placed in room confinement,
☒ ☐ ☐
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to
☒ ☐ ☐ 601.4.5 (b)(2)
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee
☒ ☐ ☐ 601.4.5 (b)(3)
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth
601.1.1
in juvenile facilities and does not apply to normal ☒ ☐ ☐
sleeping hours.
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(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional
☒ ☐ ☐ 102.2.1
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires 400 Facility Emergencies
a significant departure from normal institutional 400.3.1 Emergency Suspension of
operations, including a natural disaster or facility- Standards
wide threat that poses an imminent and substantial ☒ ☐ ☐
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and
501.7.2
protect against the spread of a communicable
disease for the shortest amount of time required to
519 Medical Separation
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an
☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1355 INSTITUTIONAL ASSESSMENT AND PLAN
The facility administrator shall develop and implement 503 Case Management
written policies and procedures for assessment and
case planning.
The VCPAJF agency has an operational
process to complete and update Institutional
Assessments and Plans originally done by
the field DPO with ongoing updates by the
assigned CSO. Documents included the
original case plan with identified risks and
needs and ongoing plans targeting service
delivery for the youth. Educational progress
from Providence School, case notes and
number of hours with Behavior Health
Services, and youth chrono notes from
facility staff all contribute to the overall plan
while the youth is detained.
The plans are completed by staff and
reviewed by supervisors. The plan
documents education, substance abuse,
aggression, anti-social environments, family,
impulsivity, remorse, and violence,
articulating a plan and discussion points for
☒ each.
☐ ☐
We reviewed 3 six-month review reports to
the Court specific to SYTF youth. The
individualized plans were detailed and
comprehensive of all the youth that had been
involved during the period covered.
Numerous agency partners provide input
specific to their programs, allowing for a well-
rounded description of services and
successes.
SYTF also have initial, ongoing, and
Transitional Plans during their stay. We
reviewed 10 ongoing IAP’s and 8 Transitional
MDTs for 18 youth and found each had an
individualized plan, including the most
significant areas to address with targeted
services. The plans are reviewed every 30
days to show progress or to re-direct
services. They are individualized and
inclusive of chrono entry discussions with the
youth.
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(a) Assessment:
The assessment is based on information collected
during the admission process with periodic review, 503.3 ⁋ 2
which includes the youth's risk factors, needs and
☒
strengths including, but not limited to, identification of ☐ ☐
substance abuse history, educational, vocational,
counseling, behavioral health, consideration of known
history of trauma, and family strengths and needs.
(b) Institutional Case Plan:
(1) A case plan shall be developed for each youth
☒
503.3.1
held for at least 30 days or more and created within ☐ ☐
40 days of admission.
(2) The institutional plan shall include, but not be
limited to, written documentation that provides:
☒
☐ ☐
(A) objectives and time frame for the resolution of
problems identified in the assessment;
☒ 503.3.1 (c)
☐ ☐
(B) a plan for meeting the objectives that includes
a description of program resources needed and
☒
503.3.1 (b)
individuals responsible for assuring that the plan ☐ ☐
is implemented;
(3) periodic evaluation of progress towards meeting
the objectives, including periodic review and ☒
☐ ☐ 503.3.1 (c)
discussion of the plan with the youth;
(4) a transition plan, the contents of which shall be
subject to existing resources, shall be developed for 503.3.1
☒
post dispositional youth in accordance with Section ☐ ☐ 516.3; 516.5 (Releases)
1351; and,
(5) in as much as possible and if appropriate, the
plan, including the transition plan, shall be developed
with input from the family, supportive adults, youth, ☒ 503.3.1 (a)
☐ ☐
and Regional Center for the Developmentally
Disabled.
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1356 COUNSELING AND CASEWORK SERVICES
503.5
The facility administrator shall develop and implement
703.3 Counseling Services
written policies and procedures ensuring the availability
POC.03.C, 1
of appropriate counseling and casework services for all
youth. Policies and procedures shall ensure:
The VCPAJF agency requires the assigned
CSO to meet with the youth weekly to ensure
☒ he or she is progressing as expected or to
☐ ☐
assist with any difficulty in the program.
We reviewed case Chrono’s and Critical
Case Team meeting notes which address
any noted positive or negative behaviors
displayed in the program.
(a) youth will receive assistance with needs or concerns
that may arise;
703.3 (a)(1)
☒
☐ ☐
POC.03.C, 1(a)
(b) youth will receive assistance in requesting contact
with parents, other supportive adults, attorney, clergy,
703.3 (a)(2)
probation officer, or other public official; and,
☒
☐ ☐
POC.03.C, 1 (b)
(c) youth will be provided access to available resources
to meet the youth’s needs.
☒ 703.3 (a)(2)
☐ ☐
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1357 USE OF FORCE
511 Use of Force (UF)
The facility administrator, in cooperation with the
511.3 ⁋ 6
responsible physician, shall develop and implement
511.3.3 Health Care assistance in developing
written policies and procedures for the use of force,
policy
which may include chemical agents. Force shall never
301 Use of Force-Administration Manual
be applied as punishment, discipline, retaliation or
treatment.
There were 138 UF incidents from April 2022
(a) At a minimum, each facility shall develop policies and to June 2023, 95 included physical force and
procedures which: 93 included the use of OC Spray at the
VCPAJF. There were 97 UF incidents in 2022
and 130 UF in 2021. This is down
significantly from the 183 in 2019 and 178 in
2018.
We reviewed 15 UF incident reports and
found the agency documents the efforts to
use the least restrictive option when
available. Staff are required to include the
circumstances leading to the use of force and
☒ justify why force was used. The Supervisor
☐ ☐
on duty is also required to write a Use of
Force Report to include a summary of the
incident, Supervisor actions (including review
of video and interviews with involved staff),
and, lastly, the Supervisors Evaluation, which
details the assessment of staff response and
critique of the staff actions.
Each month the agency conducts a UF
Review with a committee consisting of the
Facility Managers, Supervisors, and staff
involved. All documentation and video
footage are presented so the committee can
determine if the incident was within policy.
The outcome for the Review Committee is: A
– Within Policy; B – Within Policy but training
identified; C – Staff actions referred to
Professional Standards Unit; and D – Other.
Each of the incidents we reviewed were
cleared by Administration as ‘Within Policy’.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 511.3 ⁋ 1
1302 to ensure the safety and security of youth, staff, ☒ 511.3.1 Factors to determine
☐ ☐
others and the facility. Reasonableness of Force.
(2) outline the force options available to staff
including both physical and non-physical options and 511.5
☒
define when those force options are appropriate. ☐ ☐ 511.5.1
FPO.08.F, 1
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(3) describe force options or techniques that are
expressly prohibited by the facility.
511.10 (l)
511.5.1 ⁋ 1 and 3
In policy, the only prohibited use of force is
the Carotid Hold. If time allows, the agency
☒
☐ ☐ operational procedure promotes a use of
force team approach to an incident, including
a supervisor, to determine how and what type
of force is appropriate given the
circumstances. This process allows for a
‘natural’ de-escalation and the use of the
least amount of force necessary.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative 511.3.2 Duty to Intervene
action to immediately stop it. ☒ 511.6
☐ ☐
511.6.1
(5) define a standardized reporting format that
includes time period and procedure for documenting
511.6 Reporting UF
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒
☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma
that may have been experienced by staff and /or the
youth involved.
(6) Include an administrative review and a system for
investigating unreasonable use of force. 511.9 UF Review
☒
☐ ☐ 511.91 UF Review Committee
(7) define the role, notification, and follow-up
procedures required after use of force incidents for 511.6.1 Notifications to Medical, Mental
medical, mental health staff and parents or legal ☒ Health and Parent
☐ ☐
guardians. 517.5
(8) describe the limitations of use of force on
pregnant youth in accordance with Penal Code
☒
512.9
Section 6030(f) and Welfare and Institutions Code ☐ ☐
Section 222.
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(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that:
(1) identify who is approved to carry and/or utilize ☒ 511.4 ⁋ 1 and 2
☐ ☐
chemical agents in the facility and the type, size and
the approved method of deployment for those
chemical agents.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or
☒ 511.4.1
the safety of others and only when de-escalation ☐ ☐
efforts have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents.
This shall include that youth who have been exposed 511.4 ⁋ 3 and 5
☒
to chemical agents shall not be left unattended until ☐ ☐
FPO.08.L, 2
that youth is fully decontaminated or is no longer
suffering the effects of the chemical agent. FPO.08.L, 4
(4) define the role, notification, and follow-up
procedures required after use of force incidents
☒
511.6.1 Notifications to Medical, Mental
involving chemical agents for medical, mental health ☐ ☐
Health and Parent
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for
511.6 (g)
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒
☐ ☐ FPO.08.I, 2
of use, decontamination procedures applied and
identification of any injuries sustained as a result of FPO.08. 4
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training
☒
300.3.1
in use of force and chemical agents when appropriate ☐ ☐
511.4
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
☒ 511.10 (i)
☐ ☐
(2) acceptable chemical agents and the methods of
application.
☒ 511.4 ⁋ 2
☐ ☐
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health.
☒
☐ ☐
511.10 (j)
(4) instruction on the Constitutional Limitations of
Use of Force.
☒ 511.10 (i)
☐ ☐
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(5) physical training force options that may require
the use of perishable skills. 511.3 ⁋ 2
☒
☐ ☐ 511.10
(6) timelines the facility uses to define regular
training. 300 Training
☒
☐ ☐ 511.10 Initial and Annual Training
1358 USE OF PHYSICAL RESTRAINTS
512. Use of Restraints UR
The facility administrator, in cooperation with the
301.8 Administration Manual
responsible physician and mental health director, shall
develop and implement written policies and procedures
There has been one use of restraint per this
for the use of restraint devices. Restraint devices ☒
☐ ☐ regulation since April 2022, not involving a
include any devices which immobilize a youth's
SYTF youth.
extremities and/or prevent the youth from being
ambulatory.
This incident is the first UR since 2019.
Physical restraints may be used only for those youth
who present an immediate danger to themselves or 512.3 (c) and (e)
others, who exhibit behavior which results in the
destruction of property, or reveals the intent to cause
☒
self-inflicted physical harm. Physical restraints should ☐ ☐
be utilized only when it appears less restrictive
alternatives would be ineffective in controlling the
youth’s behavior.
In no case shall restraints be used as punishment or
discipline, or as a substitute for treatment. The use of 512.3 (g) and (l)
restraint devices that attach a youth to a wall, floor or 512.5 (a) 1
other fixture, including a restraint chair, or through 512.9 Pregnant Youth
affixing of hands and feet together behind the back ☒ 512.9.1
☐ ☐
(hogtying) is prohibited. The use of restraints on
pregnant youth is limited in accordance with Penal Code
Section 6030(f) and Welfare and Institutions Code
Section 222.
The provisions of this section do not apply to the use of
handcuffs, shackles or other restraint devices when 512.5 UR for Movement and Transportation
used to restrain youth for movement or transportation
☒
within the facility. Movement within the facility shall be ☐ ☐
governed by Section 1358.5, Use of Restraint Devices
for Movement Within the Facility.
Youth shall be placed in restraints only with the approval
of the facility manager or designee. The facility manager 512.3 (d)
may delegate authority to place a youth in restraints to
☒
a physician. Reasons for continued retention in ☐ ☐
restraints shall be reviewed and documented at a
minimum of every hour.
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A medical opinion on the safety of placement and
retention shall be secured as soon as possible, but no 512.3 (j)(1)
later than two hours from the time of placement. The ☒
☐ ☐
youth shall be medically cleared for continued retention
at least every three hours thereafter.
A mental health consultation shall be secured as soon
as possible, but in no case longer than four hours from 512.3 (j)(2)
☒
the time of placement, to assess the need for mental ☐ ☐
health treatment.
Continuous direct visual supervision shall be conducted
to ensure that the restraints are properly employed, and 512.3 (j)
to ensure the safety and well-being of the youth. 512.7 (e)
Observations of the youth's behavior and any staff ☒
☐ ☐
interventions shall be documented at least every 15
minutes, with actual time of the documentation
recorded.
In addition to the requirements above, policies and
procedures shall address: 512.7 Documentation
☒
☐ ☐
(a) documentation of the circumstances leading to an
application of restraints.
(b) known medical conditions that would contraindicate
certain restraint devices and/or techniques. 512.6 (k)
☒
☐ ☐ 512.10 (h)
(c) acceptable restraint devices.
☒ 512.10 (i)
☐ ☐
(d) signs or symptoms which should result in immediate
medical/mental health referral. ☒ 512.10 (j)
☐ ☐
(e) availability of cardiopulmonary resuscitation
equipment. ☒ 512.10 (k)
☐ ☐
(f) protective housing of restrained youth. While in
restraint devices, all youth shall be housed alone or in a 512.10 (d)
☒
specified housing area for restrained youth which makes ☐ ☐ 512.6 (d)
provision to protect the youth from abuse.
(g) provision for hydration and sanitation needs. ☒ 512.3 (m)
☐ ☐
512.10 (l)
(h) exercising of extremities. ☒
☐ ☐ 512.6 (k)
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1358.5 USE OF RESTRAINT DEVICES FOR
MOVEMENT AND TRANSPORTATION 512.4
WITHIN THE FACILITY. 512.5 UR for Movement and Transportation
The Facility Administrator, in cooperation with the
responsible physician and behavioral/mental health
☒
☐ ☐
director, shall develop and implement written policies
and procedures for the use of restraint devices when the
purpose is for movement or transportation within the
facility that shall include the following:
(a) identification of acceptable restraint devices, staff
approved to utilize restraint devices and the required ☒ 512.1
☐ ☐
training.
(b) the circumstances leading to the application of
restraints must be documented. ☒ 512.5 (a)(1)
☐ ☐
(c) an individual assessment of the need to apply
restraints for movement or transportation that includes 512.5 (b)(1)
consideration of less restrictive alternatives, 512.5 (c)(1)
consideration of a youth’s known medical or mental
health conditions, trauma informed approaches, and a The VCPAJF agency has been tracking the
process for documentation and supervisor review and UR as identified in this regulation since last
approval. ☒ cycle. Since April of 2022, there have been
☐ ☐
17 applications of restraints for movement.
Our review of the reports when restraints
were used provided sufficient justification.
From July 2020 to April 2022, 27 of the 57
reports reviewed included restraints as
defined in this regulation.
(d) consideration of safety and security of the facility,
with a clearly defined expectation that restraint devices 512.3 (g)
☒
shall not be used for the purposes of discipline or ☐ ☐
retaliation.
(e) the use of restraints on pregnant youth is limited in
accordance with Penal Code Section 6030(f) and ☒ 512.9
☐ ☐
Welfare and Institutions Code Section 222.
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1359 SAFETY ROOM PROCEDURES
506 Safety Rooms and Camera Rooms
(a) The facility administrator, and where applicable, in
506.3
cooperation with the responsible physician, shall
develop and implement written policies and procedures
There have been 3 safety room placements
governing the use of safety rooms, as described in Title
since April 2022, none involving a SYTF
24, Part 2, Section 1230.1.13. The room shall be used
youth.
to hold only those youth who present an immediate
danger to themselves or others, who exhibit behavior
The amount of time in the safety cell was
which results in the destruction of property, or reveals ☒
☐ ☐ monitored by Medical and Behavior Health
the intent to cause self-inflicted physical harm. A safety
(Crisis Team) and lasted from 2-3 hours. The
room shall not be used for punishment or discipline, or
agency complied with regulation and policy
as a substitute for treatment. Policies and procedures
for each incident and had multiple staff and
shall:
partners in close proximity during each event.
Prior to the above, the agency has had no
safety cell placements since one in 2019 and
4 in 2018.
(1) include provisions for administration of necessary
nutrition and fluids, access to a toilet, and suitable ☒ 506.4 (e)
☐ ☐
clothing to provide for privacy;
(2) provide for approval of the facility manager, or
designee, before a youth is placed into a safety ☒ 506.4 (a)
☐ ☐
room;
(3) provide for continuous direct visual supervision
and documentation of the youth's behavior and any 506.4 (c)
☒
staff interventions every 15 minutes, with actual time ☐ ☐
recorded;
(4) provide that the youth shall be evaluated by the
facility manager, or designee, every four hours; ☒ 506.4 (g)
☐ ☐
(5) provide for immediate medical assessment,
where appropriate, or an assessment at the next 506.4 (h)
daily sick call; and,
☒ The policy states the assessment shall take
☐ ☐
place no longer than 12 hours after
placement.
(6) provide a process for documenting the reason for
placement, including attempts to use less restrictive 506.4 (i)
☒
means of control, and decisions to continue and end ☐ ☐
placement.
(b) The placement of a youth in the safety room shall be
☒
accomplished in accordance with the following: ☐ ☐
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(1) safety room shall not be used before other less
restrictive options have been attempted and 506.4 (j)
☒
exhausted, unless attempting those options poses a ☐ ☐
threat to the safety or security of any youth or staff.
(2) safety room shall not be used for the purposes of
punishment, coercion, convenience, or retaliation by ☒ 506.4 (l)
☐ ☐
staff.
(3) safety room shall not be used to the extent that it
compromises the mental and physical health of the ☒ 506.4 (l)
☐ ☐
youth.
(c) A youth may be held up to four hours in the safety
room. After the youth has been held in the safety room 506.4 (g)
for a period of four hours, staff shall do one or more of ☒
☐ ☐
the following: Refer to 601.4.5, Room Confinement
☒ 506.4 (g)(1)
(1) return the youth to general population. ☐ ☐
☒ 506.4 (g)(1)
(2) consult with mental health or medical staff, ☐ ☐
(3) develop an individualized plan that includes the
☒
goals and objectives to be met in order to reintegrate ☐ ☐ 506.4 (g)(1)
the youth to general population.
(d) If confinement in the safety room must be extended
beyond four hours, staff shall develop an individualized 506.4 (g)(1)
plan that includes the requirements of Section 1354.5 ☒
☐ ☐
and the goals and objectives to be met in order to
integrate the youth to general population.
1360 SEARCHES
513 Searches
The facility administrator shall develop and implement
written policies and procedures governing the search of
youth, the facility, and visitors. Policies and procedures
shall provide that: The agency conducts routine unit and room
searches for the ongoing safety of the facility.
☒
☐ ☐
Due to fentanyl and other drugs coming into
the facility, the VCPAJF has purchased two
body scanners and a mail scanner as tools to
prevent this from occurring. It is expected
they will arrive in August. Prospective
policies for their use are being developed.
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(a) Searches shall be conducted to ensure the safety
and security of the facility, public, visitors, youth, and ☒ 513.2 ⁋ 1
staff. ☐ ☐
(b) Searches shall be conducted in a manner that
preserves the privacy and dignity of the person being ☒ 513.1 ⁋ 1
searched and shall not be conducted for harassment or ☐ ☐ 513.2 ⁋ 1
as a form of discipline or punishment.
(c) Strip searches and visual or physical body cavity
searches shall comply with Penal Code Section 4030. 513.4.1 (a)
513.4.2 (a)
The agency has conducted strip searches of
units and youth more in this past year due to
contraband coming into the facility. Visits
have gone to no contact in some cases as
the agency traced the source. Phone call
coding and recordings reviewed also pointed
to a pathway for contraband.
Since April of 2022, there have been 425 strip
searches conducted, 243 due to contraband
in the units and/or positive drug test of youth
in the facility. Of the 182 additional strip
☒ searches, averaging 13 per month, we found
☐ ☐
documented reasonable suspicion and
authorization by the supervisor in all but 16
incidents. These 16 were approved by a
supervisor but the documentation, other than
the coded reason for the search, was not
verified. We reviewed the strip searches from
April 2020 to June 2022 (334 – average
15/month), finding this average
consistent/less than current practice.
We provided technical assistance to the
agency to ensure the reasonable suspicion
was not just a conversation but documented
in the electronic search authorization and/or
by incident report.
(d) Physical body cavity searches shall only be
conducted by a medical professional. ☒ 513.4,2 (b)
☐ ☐
(e) Any youth held after a detention hearing shall only
be strip searched with prior approval of a supervisor 513.4.2 (b)
when there is reasonable suspicion based on specific
☒
and articulable facts to believe that youth is concealing ☐ ☐
contraband. The reasonable suspicion shall be
documented.
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(f) Searches of transgender and intersex youth shall
comply with Section 1352.5. 501.12 II-A and B
☒ 513.5
☐ ☐
301.5 II Administrative Manual
(g) Cross-gender pat-down searches and strip searches
are prohibited except in exigent circumstances or when ☒ 513.3 Last ⁋
conducted by a medical professional. Such searches ☐ ☐
must be justified and documented in writing.
1361 GRIEVANCE PROCEDURE
606 Youth Grievances
The facility administrator shall develop and implement
606.3 ⁋ 1
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
The VCPAJF agency reported 72 grievances
condition of confinement, including but not limited to
filed from April 2022 to June 2023, an
health care services, classification decisions, program
average of 5.1 per month. There were 34 in
participation, telephone, mail or visiting procedures,
2022, 35 in 2021, and 43 in 2020, reduced
food, clothing, bedding, mistreatment, harassment or
from the 79 in 2019 and 82 in 2018. The
violations of the nondiscrimination policy. There shall be
process and form are compliant with
no time limit on filing grievances. Policies and
regulation and policy, allowing youth to
procedures shall include provisions whereby the facility
communicate and staff to be responsive to
manager ensures:
the operational procedures used.
☐ ☐ ☐ We reviewed all the grievances filed from
April 2022 to June of 2023 and found them to
be timely with appropriate sanctions. Staff
comments appeared to be a documented
conversation, leading the youth to
understand the behavior and sanction, or to
find resolution for a condition of confinement
the youth did not agree with.
There were several beyond the regulation 3-
day receipt of the grievance, but each
involved an agency partner grievance. All
were resolved within 10 days of the receipt of
the grievance.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ 606.3 Bullet 1
☐ ☐
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ 606.3 Bullet 8
☐ ☐
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ 606.3 Bullet 2
☐ ☐
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(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances ☒ 606.4.2 ⁋ 3
that relate to health and safety issues must be ☐ ☐
addressed immediately;
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not 606.4.5 (a)
☒
directly involved in the circumstances which led to ☐ ☐
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ 606.4.5 (b)
☐ ☐
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ 606.4.3
☐ ☐
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly 606.4.5 (a)
☒
involved in the circumstances which led to the ☐ ☐
grievance;
(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer ☒ 606.4.2 ⁋ 4
time frame. The youth shall be notified of any delay; ☐ ☐
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. 606.5
☒
☐ ☐ 606.5.1
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be 606.4.5 (c)
☒
addressed and documented in accordance with written ☐ ☐
policies and procedures within a specified timeframe.
1362 REPORTING OF INCIDENTS
206 Report Preparation
A written report of all incidents which result in physical
206.4.2
harm, use of force, serious threat of physical harm, or
death of an employee, youth or other person(s) shall be ☒
☐ ☐
maintained. Such written record shall be prepared by
the staff and submitted to the facility manager by the end
of the shift, unless additional time is necessary and
authorized by the facility manager or designee.
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1363 USE OF REASONABLE FORCE TO
COLLECT DNA SPECIMENS, SAMPLES, 517 Biological Samples
IMPRESSIONS 517.5 UF to Collect
DHPO 01.P.1.16
(a) Pursuant to Penal Code Section 298.1 authorized
law enforcement, custodial, or corrections personnel
including peace officers, may employ reasonable force
☒
☐ ☐
The VCPAJF policy does not use force to
collect DNA. Staff advise the youth that their
to collect blood specimens, saliva samples, and thumb
failure to cooperate will result in a return to
or palm print impressions from individuals who are
Court.
required to provide such samples, specimens or
impressions pursuant to Penal Code Section 296 and
who refuse following written or oral request.
(1) For the purpose of this section, the “use of
reasonable force” shall be defined as the force that 511.3.1
an objective, trained and competent correctional
☒
employee, faced with similar facts and ☐ ☐
circumstances, would consider necessary and
reasonable to gain compliance with this section.
(2) The use of reasonable force shall be preceded by
efforts to secure voluntary compliance. Efforts to 517.5.2
secure voluntary compliance shall be documented
☒
and include an advisement of the legal obligation to ☐ ☐
provide the requisite specimen, sample or
impression and the consequences of refusal.
(b) The force shall not be used without the prior written
authorization of the supervising officer on duty. The 517.5.2
authorization shall include information that reflects the ☒
☐ ☐
fact that the offender was asked to provide the requisite
specimen, sample, or impression and refused.
(1) If the use of reasonable force includes a cell
extraction, the extraction shall be videotaped. Video 517.5.1
shall be directed at the cell extraction event. The
videotape shall be retained by the agency for the
☒
length of time required by statute. Notwithstanding ☐ ☐
the use of the video as evidence in a court
proceeding, the tape shall be retained
administratively.
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1370 EDUCATION PROGRAM
1003 Youth Education Services
(a) School Programs
1003.3 ⁋ 3
The County Board of Education shall provide for the 1003.4 (b)(1) Education Program
administration and operation of juvenile court schools in Coordination
conjunction with the Chief Probation Officer, or designee
pursuant to applicable State laws. The school and The Ventura County Office of Education
facility administrators shall develop and implement operates the Providence School onsite at the
written policy and procedures to ensure communication facility. The last evaluation continues to
and coordination between educators and probation reveal a good relationship amongst probation
staff. Culturally responsive and trauma-informed and school staff, with daily briefings and
approaches should be applied when providing thorough monthly meetings with agency
instruction. Education staff should collaborate with the administrators.
facility administrator to use technology to facilitate
learning and ensure safe technology practices. The
facility administrator shall request an annual review of While onsite, we met with the Director of
each required element of the program by the Alternative Education for the Ventura County
Superintendent of Schools, and a report or review Office of Education (VCOE), Stephanie
checklist on compliance, deficiencies, and corrective Rodrigues, Teresa Vega, the site Assistant
action needed to achieve compliance with this section. Principal, and Nicole Garr, Counselor. We
Such a review, when conducted, cannot be delegated to once again discussed the early and easy
the principal or any other staff of any juvenile court graduation requirements and whether the
school site. The Superintendent of Schools shall VCOE made independent evaluations to
conduct this review in conjunction with a qualified address the need to provide a diploma to a
outside agency or individual. Upon receipt of the review, youth based on their age, credits to date, and
the facility administrator or designee shall review each anticipated length of stay, mostly to ensure
item with the Superintendent of Schools and shall take that just because a youth is eligible that they
whatever corrective action is necessary to address each ☒ ☐ ☐ evaluate the best-case scenario for each
deficiency and to fully protect the educational interests independent youth. Ms. Garr works most with
of all youth in the facility. this population and assured the process is
independent, indicating there could be a
more robust conversation with the parent and
youth when the situation involves a long stay
in custody.
It is significant to note that while onsite, we
were advised 15 youth had graduated so far
this year, 13 with the limited credits pursuant
to AB 167. This is significant because the
agency and VCOE have limited post-
secondary opportunities for youth beyond
enrollment in an online local college,
AutoTech (not during summer months), and
Paxton Patterson (PP), which is facilitated by
Probation staff. There is a plan for an Ag
Program and Digital Media program to start
this fall.
We discussed the VCOE hard line for not
allowing graduated youth to remain in the
classroom or to provide greater opportunities
for these youth who will remain with the
agency long-term. VCOE continues to
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provide little in terms of opportunities for
graduated youth but allows youth in long-
term custody to graduate early without
consideration of the benefits to remain in the
classroom. The VCPAJF is tentatively
planning to fund a teacher to provide services
in this area that the VCOE does not.
We conducted a ‘group’ interview with SYTF
youth who expressed their frustration with
limited vocational opportunities to use when
reintegrated into the community. We
provided input on pending regulation
changes which would likely include more
robust language regarding post-secondary
opportunities and the hope the VCOE would
illicit more service alternatives for this
population.
(b) Required Elements
1003.2
The facility school program shall comply with the State
1003.3
Education Code and County Board of Education
1003.4 (b)(1)
policies, all applicable federal education statutes and
1003.5
regulations and provide for an annual evaluation of the
educational program offerings. As stated in the 2009
California Standards for the Teaching Profession, ☒
☐ ☐
teachers shall establish and maintain learning
environments that are physically, emotionally, and
intellectually safe. Youth shall be provided a rigorous,
quality educational program that responds to the
different learning styles and abilities of students and
prepares them for high school graduation, career entry,
and post-secondary education.
All youth shall be treated equally, and the education
program shall be free from discriminatory action. Staff 1003.3 (a)
shall refer to transgender, intersex and gender- ☒
☐ ☐
nonconforming youth by their preferred name and
gender.
(1) The course of study shall comply with the State
Education Code and include, but not be limited to, ☒ 1003.5 ⁋ 3
☐ ☐
courses required for high school graduation.
(2) Information and preparation for the High School
Equivalency Test as approved by the California ☒ 1003.5 ⁋ 3
Department of Education shall be made available to ☐ ☐
eligible youth.
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(3) Youth shall be informed of post-secondary
education and vocational opportunities. ☒ 1003.4 (o)(1)
☐ ☐
(4) Administration of the High School Equivalency
Tests as approved by the California Department of ☒ 1003.5 ⁋ 3
☐ ☐
Education, shall be made available when possible.
(5) Supplemental instruction shall be afforded to
youth who do not demonstrate sufficient progress ☒ 1003.5 ⁋ 4
☐ ☐
towards grade level standards.
(6) The minimum school day shall be consistent with
State Education Code Requirements for juvenile 1003.5 ⁋ 2
court schools. The facility administrator, in
conjunction with education staff, must ensure that
operational procedures do not interfere with the time ☒
☐ ☐
afforded for the minimum instructional day.
Absences, time out of class or educational
instruction, both excused and unexcused, shall be
documented.
(7) Education shall be provided to all youth
regardless of classification, housing, security status, 1003.4 (a)
disciplinary or separation status, including room 1003.4 (g)(1)
confinement, except when providing education 1003.8
☒
poses an immediate threat to the safety of self or ☐ ☐
others. Education includes, but is not limited to,
related services as provided in a youth’s Section 504
Plan or Individualized Education Program (IEP).
(c) School Discipline
1003.7 ⁋ 1
(1) Positive behavior management will be
implemented to reduce the need for disciplinary ☒
☐ ☐
action in the school setting and be integrated into the
facility's overall behavioral management plan and
security system.
(2) School staff shall be advised of administrative
decisions made by probation staff that may affect the ☒ 1003.7 ⁋ 2
☐ ☐
educational programming of students.
(3) Except as otherwise provided by the State
Education Code, expulsion/suspension from school 1003.7 ⁋ 3
shall be imposed only when other means of
correction fails to bring about proper conduct.
School staff shall follow the appropriate due process
safeguards as set forth in the State Education Code ☒
☐ ☐
including the rights of students with special needs.
School staff shall document the other means of
correction used prior to imposing expulsion/
suspension if an expulsion/suspension is ultimately
imposed.
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(4) The facility administrator, in conjunction with
education staff will develop policies and procedures 1003.4 (g)
☒
that address the rights of any student who has ☐ ☐
continuing difficulty completing a school day.
(d) Provisions for Special Populations
(1) State and federal laws and regulations shall be 1003.3 ⁋ 2
observed for all individuals with disabilities or 1003.4 (a)
suspected disabilities. This includes but is not limited ☒
☐ ☐
to child find, assessment, continuum of alternative
placements, manifestation determination reviews,
and implementation of Section 504 Plans and
Individualized Education Programs.
(2) Youth identified as English Learners (EL) shall be
afforded an educational program that addresses their 1003.4 (m)
☒
language needs pursuant to all applicable state and ☐ ☐
federal laws and regulations governing programs for
EL students.
(e) Educational Screening and Admission
(1) Youth shall be interviewed after admittance and a 1003.4 (c)(1)
record maintained that documents a youth's ☒ 1003.4 (h)
educational history, including but not limited to: ☐ ☐ 1003.4.1
(A) School progress/school history;
☒ 1003.4.1
☐ ☐
(B) Home Language Survey and the results of the
State Test used for English language proficiency; ☒ 509.9.2
☐ ☐
(C) Needs and services of special populations as
defined by the State Education Code, including but ☒ 701.4 (f)
☐ ☐
not limited to, students with special needs. 1003.4 (e)
(D) Discipline problems.
☒
☐ ☐ 1003.7
(2) Youth will be immediately enrolled in school.
Educational staff shall conduct an assessment to 1003.4 (c)
☒
determine the youth's general academic functioning ☐ ☐ 1003.4.1 ⁋ 1
levels to enable placement in core curriculum
courses.
(3) After admission to the facility, a preliminary
☒
education plan shall be developed for each youth ☐ ☐ 1003.4.1 ⁋ 1
within five school days.
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(4) Upon enrollment, education staff shall comply with
the State Education Code and request the youth's 1003.4.1
records from his/her prior school(s), including, but not
limited to, transcripts, Individual Education Program
(IEP), 504 Plan, state language assessment scores, ☒
☐ ☐
immunization records, exit grades, and partial credits.
Upon receipt of the transcripts, the youth's
educational plan shall be reviewed with the youth and
modified as needed. Youth should be informed of the
credits they need to graduate.
(f) Educational Reporting
(1) The complete facility educational record of the 1003.4 (i)
☒
youth shall be forwarded to the next educational ☐ ☐
placement in accordance with the State Education
Code.
(2) The County Superintendent of Schools shall
provide appropriate credit (full or partial) for course ☒ 1003.4 (i)
☐ ☐
work completed while in juvenile court school in
accordance with the State Education Code.
(g) Transition and Re-Entry Planning
(1) The Superintendent of Schools and the Chief 1003.4 (n)
Probation Officer or designee, shall develop policies
and procedures to meet the transition needs of youth, ☒
☐ ☐
including the development of an education transition
plan, in accordance with the State Education Code
and in alignment with Title 15, Minimum Standards for
Juvenile Facilities, Section 1355.
(h) Post-Secondary Education Opportunities
(1) The school and facility administrator should, 1003.6
whenever possible, collaborate with local post-
secondary education providers to facilitate access to
educational and vocational opportunities for youth that
We noted the VCPAJF Administration made
considers the use of technology to implement these
the decision to defer summer online college
programs.
to facilitate their own college readiness
program. They found youth were unprepared
☒ to understand the responsibilities for
☐ ☐
independent learning and felt a program to
facilitate independent thought, to be
responsive to the curriculums, and to be able
to seek assistance from educational staff not
in the classroom were important for the
young population that was not ready for
‘college’ learning.
1371 PROGRAMS, RECREATION, AND
EXERCISE. 1002 Programs, Recreation and Exercise
1002.2
The facility administrator shall develop and implement
written policies and procedures for programs,
☒
☐ ☐
recreation, and exercise for all youth. The intent is to
minimize the amount of time youth are in their rooms or
their bed area.
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Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three 1002.3 ⁋ 1
hours a day during the week and five hours a day each
☒
Saturday, Sunday or other non-school days, of which ☐ ☐
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding 1002.3 ⁋ 2
by the administrator/manager or designee that a youth ☒ ☐ ☐ 1002.7 ⁋ 4
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ 1002.3 ⁋ 3
☐ ☐
There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to 1000.3 (l)
ensure content offered is current, consistent, and
relevant to the population. A review of Programming at the Juvenile
Facility was completed on July 5, 2023, by
☒
☐ ☐ Chief Deputy Tim Dowler. The review
acknowledged program needs for male and
female youth, noting they would be age-
appropriate and targeted based on identified
needs in the Case Plan.
(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to 1002.6
include, but not be limited to, trauma focused, cognitive,
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
Programming includes responses to Victim
social interventions and activities designed to reduce
Awareness, substance abuse, conflict
recidivism. These programs should be based on the
resolution, anger management, parenting
youth’s individual needs as required by Sections 1355
skills, gender-specific programming, mental
and 1356. Such programs may be provided under the ☒
☐ ☐ health services, positive youth development,
direction of the Chief Probation Officer or the County
building effective decision-making skills, and
Office of Education and can be administered by county
other topics that suits the needs of the youth
partners such as mental health agencies, community
population.
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
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(1) Cognitive Behavior Interventions;
1000.2
(2) Management of Stress and Trauma;
1000.3
(3) Anger Management;
Available programs include: Healthy
(4) Conflict Resolution; Lifestyles - Women of Substance Men of
Honor (WOSMOH); Reins of HOPE (equine
(5) Juvenile Justice System;
therapy); Interactive Journaling; Ventura
(6) Trauma-related interventions; County Arts Council (art, guitar, poetry,
drumming and mural painting); Therapy
(7) Victim Awareness; Dogs; Dating Matters; First 5 Parenting
Program; Brent’s Club; Smart Girls; Boys and
(8) Self-Improvement;
Girls Club Program*; Podcasting; ADPS
(9) Parenting Skills and support; Tablets; STEPS-Y; Word on the Street; City
Impact; Forever Found (CSEC youth);
(10) Tolerance and Diversity; Passport to Manhood; ARISE; Operation
Peace Works; Gender Specific Services; and
(11) Healing Informed Approaches;
Music N Society.
(12) Interventions by Credible Messengers;
Ventura County Behavior Health provides the
(13) Gender Specific Programming;
following: Dialectical Behavior Therapy
(DBT); Drug and Alcohol Programs
(14) Art, creative writing, or self-expression;
☒
☐ ☐ (individual and group); Moral Recognition
(15) CPR and First Aid training; Therapy (MRT); Seeking Safety; Anger
Management and Conflict Resolution;
(16) Restorative Justice or Civic Engagement;
Individual and Group Therapy; Co-Parent
Counseling; and Sex Offender Treatment.
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population. Educational Programs include: Paxton
Patterson (Construction trades program);
Providence Scholars Program (online
college); College Success; Literacy Tutors;
Money Matters; and AutoTech.
Re-Entry Services include: First Aid/CPR;
Alpha Leadership; Forever Found Case
Management; Second Chance Re-entry
Services; Reducing Risks for Girls; Harm to
Healing Restorative Justice; and Court
Appointed Special Advocates.
*These programs are not occurring currently
due to the facilitators not being available.
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(b) Recreation. All youth shall be provided the
opportunity for at least one hour of daily access to 1002.5
unscheduled activities such as leisure reading, letter
writing, and entertainment. Activities shall be supervised
and include orientation and may include coaching of ☒
☐ ☐ Recreation Programs include Library Carts;
youth.
Organized Games; Special Events; and the
Boys and Girls Club Rec Center
(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity 1002.4
each day.
☒
☐ ☐ Exercise other than that facilitated by staff
include Futsal, Basketball, Boys and Girls
Club Gym, and Special Events.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and 1002.7 ⁋ 3
programs. The administrator/manager shall document ☒
☐ ☐
the reasons why suspension of recreation and programs
occurs.
1372 RELIGIOUS PROGRAM
1007 Religious Programs
The facility administrator shall provide access to
1007.3 ⁋ 2
religious services and/or religious counseling at least
1007.3.1
once each week. Attendance shall be voluntary. A youth
shall be allowed to participate in an activity outside of
their room if he/she elects not to participate in religious ☒
☐ ☐
programs. The agency has religious providers in each
unit one day per week. Youth have the
Religious programs shall provide for: opportunity to meet with them or request a
contact anytime.
(a) opportunity for religious services and practices; ☒ 1007.3.1
☐ ☐
(b) availability of clergy; and, ☒ 1007.12
☐ ☐
(c) availability of religious diets. ☒ 1007.5
☐ ☐
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1373 WORK PROGRAM
1005 Youth Work Program
The facility administrator shall develop policies and
procedures regarding the fair and consistent
assignment of youth to work programs. Work assigned ☒
☐ ☐
to a youth shall be meaningful, constructive and related
to vocational training or increasing a youth's sense of
responsibility. Work programs shall not be imposed as a
disciplinary measure
1374 VISITING
1008 Youth Visitation
The facility administrator shall develop and implement
1008.3.2
written policies and procedures for visiting, that include
provisions for special visits. Youth shall be allowed to
receive visits by parents, guardians or persons standing
in loco parentis, and children of youth. Other family At the time of the inspection, youth are able
members, such as grandparents and siblings, and to have 2 visits per week, for an hour each
supportive adults, may be allowed to visit with the visit, on Wednesdays and Sundays. Special
approval of the facility administrator or designee, and in visits occur on Sunday mornings.
☒
conjunction with the youth’s case plan or in the best ☐ ☐
interest of the youth.
In our group interview with SYTF youth, there
was a request for allowing more visiting
opportunities and for those visits to include
an enhanced list of visitors, including
girlfriends and family members outside of
immediate family allowable for special visits.
All visits shall occur at reasonable times, subject only to
the limitations necessary to maintain order and security. 1008.6 (f)
Visitation shall not be denied solely based on the 1008.6 Last Paragraph
visitor’s criminal history. The staff shall determine in 1008.5 Visitation Schedule
each case, whether the visitor’s criminal history ☒
☐ ☐
represents a risk to the safety of youth or staff in the
facility. Any denial of visitation or limitation on visitations
shall be communicated to the youth, person denied and
facility administrator.
Opportunity for visitation shall be a minimum of two
hours per week. Visits may be supervised, but ☒ 1008.3.2 ⁋ 2
conversations shall not be monitored unless there is a ☐ ☐
security or safety need.
Provisions for special visits, in addition to the two-hour
minimum and/or outside of the regular visiting hours, 1008.8
shall be accommodated as necessary and within the
discretion of the facility administrator or designee.
☒
Family therapy and professional visits shall be ☐ ☐
accommodated outside the provisions of this regulation.
Facilities may provide visitation opportunities outside of
normal visiting hours to accommodate special visits.
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The facility may provide access to technology as an
alternative, but not as a replacement, to in-person ☒ 1008.3.2 ⁋ 3
☐ ☐
visiting.
1375 CORRESPONDENCE
1001 Correspondence
The facility administrator shall develop and implement ☒
☐ ☐
written policies and procedures for correspondence
which provide that:
(a) there is no limitation on the volume of mail that youth
may send or receive; ☒ 1001.3 ⁋ 1
☐ ☐
(b) youth may send two letters per week postage free;
1001.8 (a)
☒
☐ ☐ Youth are able to send seven letters each
week, postage-free.
(c) youth may correspond confidentially with state and
federal courts, any member of the State Bar or holder of 1001.4 ⁋ 1
public office, and the Board; however, authorized facility ☒
☐ ☐
staff may open and inspect such mail only to search for
contraband and in the presence of the youth; and,
(d) incoming and outgoing mail, other than that
described in (c), may be read by staff only when there is ☒ 1001.6 ⁋ 2
reasonable cause to believe facility safety and security, ☐ ☐ 1001.6.1
public safety, or youth safety is jeopardized.
1376 TELEPHONE ACCESS
1006.2 Youth Telephone Policy
The administrator of each juvenile facility shall develop
and implement written policies and procedures to
☒
☐ ☐
provide youth with access to telephone
communications.
1377 ACCESS TO LEGAL SERVICES
602 Youth Access to Courts and Counsel
The facility administrator shall develop written
procedures to ensure the right of youth to have access
☒
☐ ☐
to the courts and legal services. Such access shall
include:
(a) access, upon request by the youth, to licensed
attorneys and their authorized representatives; ☒ 602.3 (a)
☐ ☐
(b) provision for confidential consultation with attorneys;
and, ☒ 602.3 (b)
☐ ☐
(c) unlimited postage free, legal correspondence and
cost-free telephone access as appropriate. ☒ 602.3 (c)
☐ ☐
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1390 DISCIPLINE
600 Youth Discipline
The facility administrator shall develop and implement
600.3.1 Rules and Sanctions
written policies and procedures for the discipline of
600.6 Bullet 14
youth that shall promote acceptable behavior; including
1009.3 Behavior Modification Plan
the use of positive behavior interventions and supports. ☒
☐ ☐
Discipline shall be imposed at the least restrictive level
which promotes the desired behavior and shall not
include corporal punishment, group punishment,
physical or psychological degradation. Deprivation of
the following is not permitted:
(a) bed and bedding; ☒ 600.6 Bullet 13 and 14
☐ ☐
(b) daily shower, access to drinking fountain, toilet and
☒ 600.6 Bullet 7
personal hygiene items, and clean clothing; ☐ ☐
(c) full nutrition; ☒ 600.6 Bullet 4
☐ ☐
(d) contact with parent or attorney; ☒ 600.6 Bullet 16 and 19
☐ ☐
(e) exercise; ☒ 600.6 Bullet 11
☐ ☐
(f) medical services and counseling; ☒ 600.6 Bullet 15 and 20
☐ ☐
(g) religious services; ☒ 600.6 Bullet 20
☐ ☐
(h) clean and sanitary living conditions; ☒ 600.6 Bullet 14
☐ ☐
(i) the right to send and receive mail; ☒ 600.6 Bullet 18
☐ ☐
(j) education; and, ☒ 600.6 Bullet 20
☐ ☐
(k) rehabilitative programming. ☒ 600.6 Bullet 20
☐ ☐
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The facility administrator shall establish rules of conduct
and disciplinary penalties to guide the conduct of youth. 600.4 Minor Rules
Such rules and penalties shall include both major 600.5 Major Rules
violations and minor violations, be stated simply and 600.7 Sanctions
☒
affirmatively, and be made available to all youth. ☐ ☐ 1009 Behavior Management Program
Provision shall be made to provide accessible
information to youth with disabilities, limited English
proficiency, or limited literacy.
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1391 DISCIPLINE PROCESS
600.3 Discipline Process
The facility administrator shall develop and implement
written policies and procedures for the administration of
The agency uses two separate forms for
discipline which shall include, but not be limited to:
Disciplinary Due Process. First, the Notice of
Discipline includes a summary of the incident
and proposed sanction. The second form is
the Hearing Form, currently used for every
due process incident. The form allows the
youth to write their version of the incident and
to list any witnesses. There is also an area to
list the staff who assisted with the form or a
box to check if no one was requested to help
the youth.
Prior to the discipline hearing, the assigned
Hearing Officer reviews video of the incident
and all reports. Once a finding is made, the
youth is notified and is offered an opportunity
to appeal. Appeal forms are available in
every living unit.
We provided technical assistance to include
the opportunity to allow the youth to either
☒
☐ ☐ request a hearing or indicate they do not
want a hearing if they agree to the Notice and
Proposed Sanction. If the minor agrees and
does not want a hearing, then the process is
complete. They would then have the youth
sign the form acknowledging no further
action is requested. If the youth wants the
hearing, then the existing process is fine.
Our guidance is to simplify and shorten the
operational responsibilities of staff.
We reviewed 22 of the 133 Due Process
incidents for 2021, including the Incident
Report and subsequent documentation. The
form prompts staff to follow the process and
the documentation was clear. Of the
incidents reviewed, 9 filed an appeal to the
facility manager.
The process for each incident started the
same day as initiated and was resolved that
day. We found the policy and process
exceeds regulation.
(a) designation of personnel authorized to impose
discipline for violation of rules; ☒ 600.3 (a)
☐ ☐
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(b) prohibiting discipline to be delegated to any youth;
☒ 600.6 Bullet 1
☐ ☐
(c) definition of major and minor rule violations and their
consequences, and due process requirements; 600.4
☒
☐ ☐ 600.5
(d) trauma-informed approaches and positive behavior
interventions; ☒ 600.3.1 ⁋ 2
☐ ☐
(e) minor rule violations may be handled informally by
counseling, advising the youth of expected conduct 600.4 Minor Rules
imposing a minor consequence. Discipline shall be ☒ 600.8 Documentation
☐ ☐
accompanied by written documentation and a policy of
review and appeal to a supervisor; and,
(f) major rule violations and the discipline process shall
be documented and require the following: ☒ 600.5
☐ ☐
(1) written notice of violation prior to a hearing; ☒ 600.5.3
☐ ☐
(2) accommodations provided to youth with
disabilities, limited literacy, and English language ☒ 600.5.7
☐ ☐
learners;
(3) hearing by a person who is not a party to the
☒ 600.5.4 ⁋ 2
incident; ☐ ☐
(4) opportunity for the youth to be heard, present
☒ 600.5.5
evidence and testimony; ☐ ☐
(5) provision for youth to be assisted by staff in the
☒ 600.5.3
hearing process; ☐ ☐
(6) provision for administrative review. 600.5.10
☐ ☐ ☐
(g) violations that result in a removal from camp or
commitment program, but not a return to court, will 600.7.1
☒
follow the due process provisions in subsection (e) ☐ ☐
above.
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1410 MANAGEMENT OF COMMUNICABLE
DISEASES.
VCPA: Policy 705 Communicable Disease
The health administrator/responsible physician, in Policy, Youth
cooperation with the facility administrator and the local
health officer, shall develop written policies and ☒ ☐ ☐ Policy 705.3 Procedure
procedures to address the identification, treatment,
Policy 1203 Communicable Disease Policy,
control and follow-up management of communicable
Members (Staff)
diseases. The policies and procedures shall address,
but not be limited to:
VCPA: Policy 705.3 (c) Procedure
Coronavirus (COVID-19) PRE-BOOKING
(a) Intake health screening procedures; ☒ ☐ ☐ PROCEDURES
Intake and Medical Isolation Procedures
(b) Identification of relevant symptoms; ☒
☐ ☐ Intake and Medical Isolation Procedures
Coronavirus (COVID-19) PRE-BOOKING
(c) Referral for medical evaluation; ☒
☐ ☐ PROCEDURES
VCPA Policy 705.3 (d) Compliance with all
relevant laws and regulations related to
communicable diseases.
VCPA Policy 705.4.3 Medical Consultation,
(d) Treatment responsibilities during detention; ☒
☐ ☐ Evaluation and Treatment
VCPA: Youth Face Mask Protocol and
Expectations
(e) Coordination with public and private community-
☒ VCPA Policy 705.3 (d)(2)
based resources for follow-up treatment; ☐ ☐
VCPA Policy 705.4.2 Supervisor Response
(f) Applicable reporting requirements; and, ☒
☐ ☐ and Reporting Requirements
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VCPA Policy 703 (d)(3) Developing
(g) Strategies for handling disease outbreaks. ☒ strategies for handling communicable
☐ ☐
disease outbreaks.
The policies and procedures shall be updated as
necessary to reflect communicable disease priorities
The agency coordinates policies with local
identified by the local health officer and currently
Public Health and CDC directives in
recommended public health interventions. ☒
☐ ☐ response to the Coronavirus Pandemic.
These policies were updated in 2020.
1433 REQUESTS FOR HEALTH CARE SERVICES
(EXCERPT)
702.3 Youth Access to Health Care
The health administrator, in cooperation with the facility
administrator, shall develop policy and procedures to ☒ ☐ ☐ 702.3 (b) and (c) Unimpeded Access to
establish a daily routine for youth to convey requests for Health Care Services
emergency and non-emergency medical, dental and
behavioral/mental health care services.
1480 STANDARD FACILTY CLOTHING ISSUE
The youth’s personal clothing, undergarments and 802.6 Clothing Issue
footwear may be substituted for the institutional clothing ☒
and footwear specified in this regulation. The facility has ☐ ☐ 363.1 Clothing Exchange
the primary responsibility to provide clothing and
footwear. Clothing provisions shall ensure that:
(a) Clothing is clean, reasonably fitted, durable, easily
laundered, in good repair, and free of holes and tears.
☒ 802.6 Paragraph 1
☐ ☐
(b) The standard issue of climatically suitable clothing
for youth shall consist of but not be limited to:
☒
☐ ☐
(1) Socks and serviceable footwear; ☒ 802.6 Paragraph 2 Bullet 1 and 4
☐ ☐
(2) Outer garments; ☒ 802.6 Paragraph 2 Bullet 2
☐ ☐
(3) New non-disposable underwear which shall
remain with the youth throughout their stay, and;
☒ 802.6 Paragraph 2 Bullet 3 and 5
☐ ☐
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(4) Undergarments, that are freshly laundered and
free of stains, including tee shirts and bras.
☒ 802.6 Paragraph 2 Bullet 3
☐ ☐
(c) Clothing is laundered at the temperature required by
local ordinances for the commercial laundries and dried
☒
802.7
completely in a mechanical dryer or other laundry ☐ ☐
method approved by the local health officer.
(d) Suitable clothing is issued to pregnant youth.
☒ 802.6 Paragraph 2 Bullet 6
☐ ☐
1482 CLOTHING EXCHANGE
The facility administrator shall develop and implement 802.6 Paragraph 1, 4, 5, and 6
written policies and site-specific procedures for the
cleaning and scheduled exchange of clothing. Unless
work, climatic conditions, or illness necessitates more
☒
☐ ☐
frequent exchange, outer garments, except for footwear,
shall be exchanged at least once each week. Tee shirts,
bras, and underwear shall be exchanged daily; youth
shall receive their own underwear back at exchange.
1484 CONTROL OF VERMIN IN YOUTH’S
PERSONAL CLOTHING
Procedure 321
There shall be written policies and site-specific
procedures developed and implemented by the facility FPO.07.B, 1
administrator to control the contamination and/or spread
☒
☐ ☐
of vermin and ecto-parasites in all youth’s personal
clothing. Infested clothing shall be cleaned or stored in
a closed container so as to eradicate or stop the spread
of the vermin.
1485 ISSUE OF PERSONAL CARE ITEMS
There shall be written policies and site-specific 802.8 Personal Hygiene of Youth
procedures developed and implemented by the facility
administrator for the availability of personal hygiene ☒ Procedure 362 Personal Hygiene
☐ ☐
items. Each female youth shall be provided with sanitary
FPO.09.E, 1
napkins, panty liners and tampons as requested. Each
youth to be held over 24 hours shall be provided with the
following personal care items;
(a) Toothbrush; ☒ 802.8 Paragraph 2 Bullet 4
☐ ☐
Procedure 362.1 (f)
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802.8 Paragraph 2 Bullet 3
(b) Toothpaste; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 1
(c) Soap; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 2
(d) Comb; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 5
(e) Shaving implements; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 8
(f) Deodorant; ☒
☐ ☐
Procedure 362.1 (f)
(g) Lotion; ☒ 802.8 Paragraph 2 Bullet 9
☐ ☐
802.8 Paragraph 2 Bullet 10
(h) Shampoo; and, ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 11
(i) Post-shower conditioning hair products. ☒
☐ ☐
Procedure 362.1 (f)
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Youth shall not be required to share any personal care
items listed in items (a) through (d). Liquid soap
provided through a common dispenser is permitted.
Youth shall not share disposable razors. Double edged
802.8 Paragraph 4
safety razors, electric razors, and other shaving
☒
instruments capable of breaking the skin, when shared ☐ ☐ 604.4 Shaving
among youth, shall be disinfected between individual
uses by the method prescribed by the State Board of
Barbering and Cosmetology in Sections 979 and 980,
Chapter 9, Title 16, California Code of Regulations.
1486 PERSONAL HYGIENE
There shall be written policies and site specific Procedure 362.1 (a) and (i)
procedures developed and implemented by the facility
administrator for showering/bathing and brushing of ☒
☐ ☐
teeth. Youth shall be permitted to shower/bathe up on
assignment to a housing unit and on a daily basis
thereafter and given an opportunity to brush their teeth
after each meal.
1487 SHAVING
Youth shall have access to a razor daily, unless their 604.4 Shaving
appearance must be maintained for reasons of
identification in Court. All youth shall have equal ☒
☐ ☐
opportunity to shave face and body hair. The facility
administrator may suspend this requirement in relation
to youth who are considered to be a danger to
themselves or others.
1488 HAIR CARE SERVICES (EXCERPT)
Hair care services shall be available in all juvenile 604.3 Haircuts
facilities. Youth shall receive hair care services monthly. ☒
☐ ☐
Equipment shall be cleaned and disinfected after each
haircut or procedure, by a method approved by the State
Board of Barbering and Cosmetology.
1500 STANDARD BEDDING AND LINEN ISSUE
Clean laundered, suitable bedding and linens, in good 802.5 Bedding Issue
repair, shall be provided for each youth entering a living
☒
☐ ☐
area who is expected to remain overnight, shall include,
but not be limited to:
(a) One mattress or mattress-pillow combination which
meets the requirements of Section 1502 of these
☒ 802.5 (b)
regulations; ☐ ☐
(b) One pillow and a pillow case unless provided for in
(a) above;
☒ 802.5 (e)
☐ ☐
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(c) One mattress cover and a sheet or two sheets; ☒ 802.5 (c)
☐ ☐
(d) One towel; and, ☒ 802.5 (d)
☐ ☐
(e) One blanket or more, up on request ☒ 802.5 (a)
☐ ☐
1501 BEDDING LINEN EXCHANGE
The facility administrator shall develop and implement 802.5 Paragraph 2
site specific written policies and procedures for the
scheduled exchange of laundered bedding and linen ☒
☐ ☐
issued to each youth housed. Washable items such as
sheets, mattress covers, pillow cases and towels shall
be exchanged for clean replacement at least once each
week.
The covering blanket shall be cleaned or laundered
once a month.
☒ 802.5 (a)2
☐ ☐
1510 FACILITY SANITATION, SAFETY AND
MAINTENANCE
800 Housekeeping and Maintenance
The facility administrator shall develop and implement
written policies and site-specific procedures for the Procedure 317
maintenance of an acceptable level of cleanliness,
FPO.06.M, 1 Facility Sanitation, Safety and
repair and safety throughout the facility. The plan shall
Maintenance
provide for a regular schedule of housekeeping tasks, ☒
☐ ☐
equipment, including restraint devices, and physical
plant maintenance and inspections to identify and
correct unsanitary or unsafe conditions or work
practices in a timely manner. The use of chemicals shall
be done in accordance to the product label and Safety
Data Sheet which may include the use of Personal
Protection Equipment (PPE).
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REVIEW OF NON REGULATORY REQUIREMENTS
GRANT FUNDING OR CODE REFERENCE YES NO N/A P/P REFERENCE - COMMENTS
JUVENILE PROBATION AND CAMPS FUNDING (JPCF) (Camps Only)
The programs/services identified on the JPCF Camp
Eligibility Form are being provided at the facility.
☐ ☐ ☒
(Refer to the JPCF Camp Eligibility Form)
208.5 WIC CONTACT BETWEEN PERSONS UNDER THE JUVENILE COURT AGES 19- 20 AND MINORS IN THE
FACILITY
The facility houses Juvenile Court Wards 19 years of
age and older. ☒ ☐ ☐
The facility has been approved to hold persons under
the juvenile court who are ages 19 through 21. ☒ ☐ ☐
The facility continues to comply with the requirements
of 208.5 WIC (programming, capacity and security of
☒ ☐ ☐
the facility) as outlined in the county’s application.
JUVENILE JUSTICE DELINQUENCY PREVENTION ACT MONITORING (JJDPA)
WIC 206 SEPARATE FACILITIES FOR WIC 300
MINORS
☐
☐
Dependent or neglected minors who are defined under Viola ☒
Section 300 of the Welfare and Institutions Code (WIC) tion
are held only in non-secure, separate and segregated
facilities.
DETENTION OF STATUS OFFENDERS (WIC 601)
AND FEDERAL MINORS
☐ ☒ ☐
Status Offenders (WIC 601) are held in the facility.
Status Offenders (WIC 601) are kept separate from
☐
Juvenile Delinquents (WIC 602)? (WIC 207[d]). ☐ ☒
Viola
tion
Federal Minors (ICE Holds or ORR Contract) are held
in the facility. ☐ ☒ ☐
If yes to the above, the Monthly Report on the
Detention of Status Offenders/Federal Minors is
☐ ☐ ☒
submitted to the BSCC.
WIC 208 SEPARATION OF MINORS AND ADULT
INMATES (JJDPA 42 USC 5633, Sec 223,
State Plans (a)[12])
Are adult inmates held in the facility? (When a person ☐ ☒ ☐
in detention is proceeding through the adult court,
AND that person is 18 years of age or older that
person is an adult inmate.)
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If adult inmates are held, they are appropriately
☐ ☒
separated from minors. ☐
Viola
tion
Adult inmates from an adult facility (e.g. inmate
☐
workers or “Scared Straight” programs) are not ☐ ☒
allowed in the facility in a manner that allows contact Viola
with minors. tion
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7741
FACILITY NAME: Ventura County Probation Agency Juvenile Facility (VCPAJF) FACILITY TYPE: SYTF
Secure Youth Treatment Facility – Commitment Services
PERSON(S) INTERVIEWED: Gina Johnson, Chief Probation Officer; Tim Dowler, Chief Deputy Probation Officer; Carrie
Vredenburg, Director – Juvenile Facility Programs; Sandy Carrillo, Director, Juvenile Operations; Rebecca Jimenez, Corrections
Service Officer (CSO) III; Chris Martinez, Supervising Deputy Probation Officer (SDPO); Lola Barnette, SDPO; Allysa Hyne,
SDPO; Justin Burdine, CSO III; Adrian Jimenez, CSO II; Chris Mullins, CSO II; Shirley Scott, Wellpath RN; Teresa Vega, Assistant
Principal Ventura County Office of Education; Stephanie Rodriguez, Director Ventura County Office of Education; Nicole Garr,
Counselor Ventura County Office of Education; Stacy Thompson, Ventura County Food Services Manager; Ana Magbitang,
Manager Ventura County Behavior Health; SYTF Youth - Alex, age 17; Joel, age 18, Brayleen, age 23; Jesus, age 22; Rogelio,
age 19; Detention - Landon, age 18; Frank, age 17; Axel, age 20.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: July 10-13, 2023
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1313 COUNTY INSPECTION AND EVALUATION
OF BUILDING AND GROUNDS 104.3.2 Required Local Inspections,
On an annual basis, or as otherwise required by law,
The following Inspections apply to the entire
each juvenile facility administrator shall obtain a
VCPAJF Physical Plant, including Detention,
documented inspection and evaluation from the ☐
☒ ☐ Commitment, and SYTF.
following:
(a) county building inspector or person designated by the
November 1, 2021
Board of Supervisors to approve building safety;
April 11, 2023
(b) fire authority having jurisdiction, including a fire
clearance as required by Health and Safety Code November 15, 2022
☒ ☐ ☐
Section 13146.1(a) and (b); April 18, 2023
(c) local health officer, inspection in accordance with
Health and Safety Code Section 101045; 2022:
Environmental Health May 5, 2022
Medical/Mental Health December 3, 2021
Nutritional Health April 15, 2022
☒ ☐ ☐
2023:
Environmental Health June 8, 2023
Medical/Mental Health November 29, 2022
Nutritional Health July 7, 2023
1 This document is intended for use as a tool during the inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally,
many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please
refer to the complete California Code of Regulations, Title 15, Minimum Standards for Local Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and
text of regulations.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(d) county superintendent of schools on the adequacy
of educational services and facilities as required in October 26, 2021
☒ ☐ ☐
Section 1370; December 7, 2022
(e) juvenile court as required by Section 209 of the
Welfare and Institutions Code; and, November 5, 2021
☒ ☐ ☐
March 14, 2023
(f) the Juvenile Justice Commission as required by
Section 229 of the Welfare and Institutions Code or December 7, 2021
☒ ☐ ☐
Probation Commission as required by Section 240 of the December 6, 2022
Welfare and Institutions Code.
1320 APPOINTMENT AND QUALIFICATIONS
100.1
BSCC Note: Compliance with this section is determined
by receipt of the Chief Probation Officer’s certification
The elements of this regulation are addressed
letter confirming that all elements of regulation are met. in a memorandum completed by Interim Chief
Probation Officer Gina Johnson, dated June
20, 2023.
(a) Appointment
☒ ☐ ☐
In each juvenile facility there shall be a superintendent,
director or facility manager in charge of its program and
employees. Such superintendent, director, facility
manager and other employees of the facility shall be
appointed by the facility administrator pursuant to
applicable provisions of law.
(b) Employee Qualifications
Each facility shall: 1200.3 Recruitment
(1) recruit and hire employees who possess
☒ ☐ ☐
knowledge, skills and abilities appropriate to their job
classification and duties in accordance with
applicable civil service or merit system rules;
(2) require a medical evaluation and physical
examination including tuberculosis screening test
1200.4 (i) Medical and Psychological Exam
and evaluation for immunity to contagious illnesses
☒ ☐ ☐
of childhood (i.e., diphtheria, rubeola, rubella, and
mumps);
100.5 Correction Officer Responsibilities
(3) adhere to the minimum standards for the
302.1 Training Policy
selection and training requirements adopted by the
302.4 Minimum Training Requirements
Board pursuant to Section 6035 of the Penal Code; ☒ ☐ ☐
1200.7 Employment Standards
and
1200.7.1 Standards for Correction Officers
(4) conduct a criminal records review, on each new
employee, and psychological examination in
accordance with Section 1031 of the Government ☒ ☐ ☐
1200.4 (g); 1200.71
Code.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(c) Contract personnel, volunteers, and other non-
employees of the facility, who may be present at the
305.2
facility, shall have such clearance and qualifications as
may be required by law, and their presence at the facility
☒
☐ ☐
305.3
shall be subject to the approval and control of the facility
These sections are related to clearance for
manager.
Volunteers/Interns and Support Personnel.
1321 STAFFING
Each juvenile facility shall: 211 Staffing Plan
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its ☒ ☐ ☐
programming, to provide for safety and security of youth
and staff, and meet established standards and
regulations;
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent 200.3 ⁋ 2 Supervision of Youth
exigent circumstances; 211.3.1 (a)
The facility roster of staff, including mandated
Deputy Probation Officers, and schedules for
all VCPAJF reflect compliance with
regulation. We reviewed staffing for February
and April 2023, as well as schedules leading
up to the onsite inspection, and found youth
are moved to a condensed living unit for the
☒ ☐ ☐ purpose of sleeping to accommodate
coverage.
We have had discussions with the agency
and provided technical assistance to identify
the individual space as one 30-bed unit
rather than two 15-bed individual units. The
space would have significant day space for
programming youth in separate areas to
provide classification-specific programming
or recreation.
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members;
211.3.1 (b)
☒ ☐ ☐
(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has
211.3.1 (c)
completed the Juvenile Corrections Officer Core Course ☒ ☐ ☐
and PC 832 training;
(e) have at least one staff member present on each
living unit whenever there are youth in the living unit;
211.3.1 (e)
☒ ☐ ☐
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(f) have sufficient food service personnel relative to the
number and security of living units, including staff 900 Food Services
qualified and available to: plan menus meeting 900.3 Bullet 2
nutritional requirements of youth; provide kitchen
supervision; direct food preparation and servings;
☒ ☐ ☐
conduct related training programs for culinary staff; and
maintain necessary records; or, a facility may serve food
that meets nutritional standards prepared by an outside
source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance,
200.5
transportation, control room, facility security and other
support staff for the efficient management of the facility,
and to ensure that youth supervision staff shall not be
☒ ☐ ☐
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to
211.3.1 (f)
temporary variations in staff assignments to meet
special program needs. Staffing shall be in compliance ☒ ☐ ☐
with a minimum youth-staff ratio for the following facility
types:
(1) Juvenile Halls
(A) during the hours that youth are awake, one 200.3 ⁋ 2
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
The agency has provided sufficient staffing
for the facility only due to mandated overtime
for the youth supervision staff (JCO’s), core
trained Deputy Probation Officers (DPO’s),
and non-core trained DPO’s who work side
by side with core trained staff. VCPAJF is in
their eleventh 40-hour orientation ‘class’ of
the DPO classification to provide for the
☒ ☐ ☐ necessary coverage. Although the agency
meets required Detention ratio identified as
1:10 per policy, it is a daily task for
administrators to provide coverage for call-
outs of scheduled staff.
We provided technical assistance and
referral information to better plan and audit
the call-off coverage, noting this is a
statewide problem for juvenile facilities.
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(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☒ ☐ ☐ 200.3 ⁋ 2
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an 200.3 ⁋ 3
arrangement has been made for backup support ☒ ☐ ☐
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☒ ☐ ☐
in the facility. 200.3 ⁋ 3
(E) personnel with primary responsibility for other
duties such as administration, supervision of 200.3.1
personnel, academic or trade instruction, clerical, 200.5
☒ ☐ ☐
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- This facility is not a Special Purpose Juvenile
☐ ☐ ☒
awake youth supervision staff member on duty for Hall.
each 10 youth in detention;
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth in detention;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in detention, unless an
arrangement has been made for backup support ☐ ☐ ☒
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one The SYTF Population is not identified as a
☐ ☐ ☒
wide-awake youth supervision staff member on Camp.
duty for each 15 youth in the camp population;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(B) during the hours that youth are confined to
their room for the purpose of sleeping, one wide-
awake youth supervision staff member on duty for ☐ ☐ ☒
each 30 youth present in the facility;
(C) at least two wide-awake youth supervision
staff members on duty at all times, regardless of
the number of youth in residence, unless
arrangements have been made for backup ☐ ☐ ☒
support services which allow for immediate
response to emergencies;
(D) at least one youth supervision staff member
on duty who is the same gender as youth housed
☐ ☐ ☒
in the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be
given to the size, design, and location of the
camp; types of youth committed to the camp; and
☐ ☐ ☒
the function of the camp in determining the level
of supervision necessary to maintain the safety
and welfare of youth and staff;
(F) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical,
☐ ☐ ☒
farm, forestry, kitchen or maintenance shall not
be classified as youth supervision staff positions.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1322 YOUTH SUPERVISION STAFF ORIENTATION
AND TRAINING
300.3 Youth Supervision Orientation
(a) Prior to assuming any responsibilities each youth
supervision staff member shall be properly oriented to 300.3 Bullet 6
their duties, including:
(1) youth supervision duties;
The VCPAJF provides new staff with a
comprehensive orientation and training
program, including a Five Phase process,
starting with a Phase 1, an initial Orientation
of 40 hours. Phase 2 includes Initial Policy
Training; Phase 3 includes Supervision of
Youth with Close Training by the assigned
Training Officer (TO); Phase 4 is Sole
Supervision with Monitoring by the TO and
an assigned mentor/trainer; and Phase 5 is
Working Independently with Supervision by
the TO.
☒ ☐ ☐
The training curriculum includes evaluation
of the Probationary staff of job skills and
learning progress, both of which are
documented at each Phase. A staff’s
competency is reviewed by facility
administrators prior to the staff receiving
permanent status with the agency.
Due to staffing shortages, the agency is
providing Phase 1 to the Deputy Probation
Officer staff, cored and non-cored, to provide
additional youth supervision.
Additionally, the agency provides a significant
annual staff training curriculum to ensure
competency continues.
(2) scope of decisions they shall make; 300.3 Bullet 13
☒ ☐ ☐
(3) the identity of their supervisor; 300.3 Bullet 8
☒ ☐ ☐
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(4) the identity of persons who are responsible to
them;
300.3 Bullet 13
☒ ☐ ☐
(5) persons to contact for decisions that are beyond
their responsibility; and
300.3 Bullet 13
☒ ☐ ☐
(6) ethical responsibilities.
300.3 Bullet 2
☒ ☐ ☐
(b) Prior to assuming any responsibility for the
supervision of youth, each youth supervision staff
302.5 Training
member shall receive a minimum of 40 hours of facility-
specific orientation, including:
The agency’s Five Phased Training Program
☒ ☐ ☐ is a comprehensive effort by tenured facility
staff to ensure new youth supervision staff
are trained in all aspects required to
complete their responsibilities.
(1) individual and group supervision techniques; 300.3.1 Bullet 1
☒ ☐ ☐
(2) regulations and policies relating to discipline and 300.3.1 Bullet 2
rights of youth pursuant to law and the provisions of ☒ ☐ ☐ POC 02.J.1
this chapter;
(3) basic health, sanitation and safety measures; 300.3.1 Bullet 3
☒ ☐ ☐
(4) suicide prevention and response to suicide
300.3.1 Bullet 4
attempts ☒ ☐ ☐
(5) policies regarding use of force, de-escalation
techniques, chemical agents, mechanical and 300.3.1 Bullet 5
☒ ☐ ☐
physical restraints;
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(6) review of policies and procedures referencing
300.3.1 Bullet 10
trauma and trauma-informed approaches; ☒ ☐ ☐
(7) procedures to follow in the event of
300.3.1 Bullet 6
emergencies; ☒ ☐ ☐
(8) routine security measures, including facility
300.3.1 Bullet 11
perimeter and grounds; ☒ ☐ ☐
(9) crisis intervention and mental health referrals to
300.3.1 Bullet 7
mental health services; ☒ ☐ ☐
(10) documentation; and 300.3.1 Bullet 8
☒ ☐ ☐
(11) fire/life safety training 300.3.1 Bullet 9
☒ ☐ ☐
(c) Prior to assuming sole supervision of youth, each
youth supervision staff member shall successfully
complete the requirements of the Juvenile Corrections 302.4 ⁋ 1
☒ ☐ ☐
Officer Core Course pursuant to Penal Code Section
6035.
(d) Prior to exercising the powers of a peace officer
youth supervision staff shall successfully complete
training pursuant to Section 830 et seq. of the Penal ☒ ☐ ☐ 302.4 ⁋ 2
Code.
1323 FIRE AND LIFE SAFETY
103.5 Training
Whenever there is a youth in a juvenile facility, there
300.3.1 Bullet 9
shall be at least one wide awake person on duty at all
☒ ☐ ☐
times who meets the training standards established by
the Board for general fire and life safety which relate
specifically to the facility.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1324 POLICY AND PROCEDURES MANUAL
102 Policy and Procedures Manual
All facility administrators shall develop, publish, and
102.5 Distribution of Manual
implement a manual of written policies and procedures
103.2 Post Orders (Procedures)
that address, at a minimum, all regulations that are
applicable to the facility. Such a manual shall be made
The VCPAJF has adopted Lexipol Policy and
available to all employees, reviewed by all employees,
Procedures (Post Orders) which include all
and shall be administratively reviewed at a minimum
required elements in regulation while
every two years, and updated, as necessary. Those
☒ ☐ ☐
allowing flexibility for changes or
records relating to the standards and requirements set
modifications as necessary.
forth in these regulations shall be accessible to the
Board on request.
There are currently no regulations specific to
The manual shall include: SYTF.
(a) table of organization, including channels of
communications and a description of job classifications; 100 Organization Structure
100.3 (a) Supervising Probation
Officer/Senior Responsibilities
☒ ☐ ☐
100.5 Correction Officer Responsibilities
1102.3 Communications
(b) responsibility of the probation department, purpose
of programs, relationship to the juvenile court, the
101.1 Responsibility and Scope of Juvenile
Juvenile Justice/Delinquency Prevention Commission
Facility
or Probation Committee, probation staff, school ☒ ☐ ☐
personnel and other agencies that are involved in
juvenile facility programs;
(c) responsibilities of all employees;
102.3
☒ ☐ ☐
(d) initial orientation and training program for
employees;
300 Staff Orientation and Training
☒ ☐ ☐
(e) initial orientation, including safety and security issues
and anti-discrimination policies, for support staff, 300 Staff Orientation and Training
contract employees, school, mental/behavioral health 304 Health Care Orientation
and medical staff, program providers and volunteers; ☒ ☐ ☐ 305 Volunteer and Intern Orientation and
Training
(f) maintenance of record-keeping, statistics and
communication system to ensure:
304.5
☒ ☐ ☐
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(1) efficient operation of the juvenile facility; 100.1 Purpose and Scope of the Facility
☒ ☐ ☐
(2) legal and proper care of youth; 100.7.2 Agency Responsibility
☒ ☐ ☐
(3) maintenance of individual youth's records; 205.3
☒ ☐ ☐
(4) supply of information to the juvenile court and
205.4
those authorized by the court or by the law; and, ☒ ☐ ☐
(5) release of information regarding youth. 205.4
☒ ☐ ☐
305.4 Volunteers/Interns
(g) ethical responsibilities; 1200.2 Recruitment
☒ ☐ ☐
1200.5 Background Check
1201.5.2 (g) Standards of Conduct
300.3.1 Bullet 10
512.4
706.4
1000.3 Programs and Education
(h) trauma-informed approaches;
☒ ☐ ☐ The VCPAJF policy includes trauma and
trauma-informed approaches in each
element of facility operations, including
training and orientation of staff, admission,
classification, searches, healthcare, hygiene,
education, and programming.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
300.3.1 Bullet 10
500.1 Admission
1000.3 (m)
1002.6
1003.3 Education
(i) culturally responsive approaches;
☒ ☐ ☐
The VCPAJF policy includes cultural
responses in each element of facility
operations, including training and orientation
of staff, admission, classification, hygiene,
education, and programming.
500.5
501.3
513 3; 513.4.3; 513.5; 513.10
605.2
701.6
802.6.1
1000.3 (b)
(j) gender responsive approaches;
☒ ☐ ☐
The VCPAJF policy includes gender
responses in each element of facility
operations including training and orientation
of staff, admission, classification, searches,
healthcare, hygiene, education, and
programming.
(k) a non-discrimination provision that provides that all
youth within the facility shall have fair and equal access 605 Non-Discrimination Provision (NDP)
to all available services, placement, care, treatment, and 605.2
benefits, and provides that no person shall be subject to
discrimination or harassment on the basis of actual or
perceived race, ethnic group identification, ancestry,
☒ ☐ ☐ The VCPAJF has the NDP posted in all living
national origin, immigration status, color, religion,
units and Intake.
gender, sexual orientation, gender identity, gender
expression, mental or physical disability, or HIV status,
including restrictive housing or classification decisions
based solely on any of the above mentioned categories;
(l) storage and maintenance requirements for any
chemical agents related security devices, and weapons 202 Inventory and Supplies
and ammunition, where applicable; ☒ ☐ ☐ 209.3 (i) Weapons Storage
(m) establishment of procedures for collection of Medi-
Cal eligibility information and enrollment of eligible 500.5.4
☒ ☐ ☐
youth; and,
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(n) establishment of a policy that prohibits all forms of
sexual abuse, sexual assault and sexual harassment. 303 Sexual Abuse and Harassment Training
The policy shall include an approach to preventing, 501.6.1 Classification
detecting and responding to such conduct and any 502.4 (n) Orientation
retaliation for reporting such conduct, as well as a ☒ ☐ ☐ 503.3 Assessments
provision for reporting such conduct by youth, staff or a 606.5 Grievances
third party. 701.4 (j) Screenings
1325 FIRE SAFETY PLAN
The facility administrator shall consult with the local fire 401 Fire Safety
department having jurisdiction over the facility, or with
the State Fire Marshal, in developing a plan for fire 401.3 (b)
☒ ☐ ☐
safety which shall include, but not be limited to:
(a) a fire prevention plan to be included as part of the
manual of policy and procedures;
(b) monthly fire and life safety inspections by facility
staff with two-year retention of the inspection record;
401.3 (c)
We reviewed Fire and Life Safety Inspections
for the VCPAJF from April 2022 to June 2023.
The agency has a systematic approach to the
inspection in every space of the facility,
recording any non-working or required
elements of space to confirm it is safe for
youth and staff.
☒ ☐ ☐
The form includes: Fire Extinguishers, Fire
Alarms, First Aid Kits, Exit/Evacuation
Routes, Storage Areas, Electric/Lighting,
Lint Traps/Dryer Exhaust, Flashlights, Door
Locks, Cameras/Monitors, Panic Alarms,
Radios and Cell Phones, and AED’s. Each
area is checked by one of the CSO III’s. If
there is a required fix or referral to
maintenance, it is tracked by administration
to ensure it is addressed and remedied.
(c) fire prevention inspections as required by Health
and Safety Code Section 13146.1(a) and (b);
401.7
☒ ☐ ☐
The last fire inspection for the VCPAJF was
completed on April 18, 2023.
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(d) an evacuation plan;
403 Evacuation Plan
☒ ☐ ☐
(e) documented fire drills not less than quarterly;
401.3 (e)
The agency completes Emergency
Fire/Earthquake or Emergency procedures
Drills monthly. We reviewed documentation
for all drills from April 2022 to June 2023. The
facility conducts monthly drills as a training
mechanism while walking through the facility
to ensure staff individually know how to react
☒ ☐ ☐
given an emergency “training” drill.
Documented evacuation drills of youth by
unit occur quarterly, as required by
regulation.
We provided technical assistance to ensure
full evacuations of all youth, at least annually,
as required by VCPAJF Policy 403.4.
(f) a written plan for the emergency housing of youth in
the case of fire; and,
400.12
☒ ☐ ☐
(g) development of a fire suppression pre-plan in
cooperation with the local fire department.
401.3
☒ ☐ ☐
1326 SECURITY REVIEW
Each facility administrator shall develop policies and 209.3
procedures to annually review, evaluate, and document
security of the facility. The review and evaluation shall
include internal and external security, including, but not
Chief Probation Officer Gina Johnson
limited to, key control, equipment, and staff training.
☒ ☐ ☐ completed a memo outlining an
Administrative and Supervisor review of
Security practices conducted on April 19,
2023, and May 30, 2023.
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1327 EMERGENCY PROCEDURES
The facility administrator shall develop facility-specific 400 Facility Emergencies
policies and procedures for emergencies that shall
include, but not be limited to:
Chief Probation Officer Gina Johnson
completed a memo outlining an
Administrative and Supervisor review of
Emergency Procedures conducted on April
19, 2023, and May 30, 2023.
☒ ☐ ☐
It was noted during the meetings several
Emergency Procedures need updating which
is being done now. The agency is compliant
and will forward any new policies or
operational procedures relating to this when
completed.
400.3 (a), (b) and (c)
400.7 Disturbances
(a) escape, disturbances, and the taking of hostages;
☒ ☐ ☐ 400.8 Hostages
400.9 Escape
400.3 (d) and (i)
(b) civil disturbance, active shooter and terrorist
400.7 Disturbances
attack; ☒ ☐ ☐
400.6 Active Shooter and Terrorist Attack
400.3 (e)
(c) fire and natural disasters;
☒ ☐ ☐ 401
400.3 (f)
(d) periodic testing of emergency equipment;
☒ ☐ ☐ 402.5
400.3 (h)
(e) emergency evacuation of the facility; and
☒ ☐ ☐ 403
(f) a program to provide all youth supervision staff
400.13
with an annual review of emergency procedures. ☒ ☐ ☐
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1328 SAFETY CHECKS
The facility administrator shall develop and implement 505.3 (a), (b) and (d)
policy and procedures that provide for direct visual
observation of youth at a minimum of every 15 minutes,
at random or varied intervals during hours when youth
We reviewed safety checks audits for the
are asleep or when youth are in their rooms, confined in
months of December 2022, January and April
holding cells or confined to their bed in a dormitory.
2023 for all occupied facility operational
Supervision is not replaced, but may be supplemented
units. Overall, the electronic checks are
by, an audio/visual electronic surveillance system
random, typically between 11 and 15
designed to detect overt, aggressive or assaultive
minutes, recording the youth room and the
behavior and to summon aid in emergencies. All safety
total number of youths in the unit.
checks shall be documented with the actual time the
check is completed.
☒ ☐ ☐
A CSO III now reviews safety checks for all
units, checking for late or missed checks, as
well as patterned checks. We found few late,
missed, or patterned checks. The staff
responsible and the circumstance is
recorded in the Supervisors Log to allow the
incident to be formally addressed. Our
recommendation is that the audits occur
daily, to ensure all are done per policy, by the
graveyard CSO III.
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1329 SUICIDE PREVENTION PLAN
The facility administrator, in collaboration with the 706.4 Suicide Prevention Plan
healthcare and behavioral/mental health administrators,
shall plan and implement written policies and
procedures which delineate a Suicide Prevention Plan.
Youth are administered the MAYSI-2 upon
The plan shall consider the needs of youth experiencing
admission or whenever a significant event
past or current trauma. Suicide prevention responses
occurs while in custody. The assessment tool
shall be respectful and in the least invasive manner
identifies cautions or warnings for behavior
consistent with the level of suicide risk. The plan shall
involving suicidal ideation or tendencies. A
include the following elements:
Classification Questionnaire during booking
to determine appropriate housing and
supervision status also is responsive to this
regulation.
The agency has had three suicide incidents
that resulted in a safety room placement,
none involving SYTF youth. There have been
☒ ☐ ☐
13 incidents of youth, with a caution or
warning from the MAYSI assessment, that
have been referred to Behavior Health.
Youth are placed on special watch in these
situations, pending being seen and/or
evaluated by Behavior Health.
We note Behavior Health has taken a much
more involved and consistent approach to all
intake, assessment, and crisis incidents,
observed by documented responses to
incidents. The clinicians are proactive and
engaged with the processes and staff
engagement for successful treatment
approaches to youth in crisis.
(a) Suicide prevention training as required in Section
1322, Youth Supervision Staff Orientation, and Training 300.3.1 Bullet 4
and the Juvenile Corrections Officer Core Course. ☒ ☐ ☐ 304.5 (e)
(b) Screening, Identification Assessment and
Precautionary Protocols 501.3 Bullet 8
(1) All youth shall be screened for risk of suicide at ☒ ☐ ☐ 701.4 (c)
intake and as needed during detention.
(2) All youth supervision staff who perform intake
processes shall be trained in screening youth for risk
☒ ☐ ☐ 501.11 Staff Training in Classification
of suicide.
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(3) All youth who have been identified during the
intake screening process to be at risk of suicide shall
701.4 (c)(2)
be referred to behavioral/mental health staff for a ☒ ☐ ☐
suicide risk assessment.
(4) Precautionary protocols shall be developed to
ensure the youth’s safety pending the
☒ ☐ ☐ 706.5
behavioral/mental health assessment.
(c) Referral process to behavioral/mental health staff for
assessment and/or services. 703.4 ⁋ 2
☒ ☐ ☐ 706.3
(d) Procedures for monitoring of youth identified at risk
for suicide. 706.3
☒ ☐ ☐ 706.5
(e) Safety Interventions
(1) Procedures to address intervention protocols for
☒ ☐ ☐
youth identified at risk for suicide which may include,
but are not limited to:
(A) Housing consideration
501.3
☒ ☐ ☐
706.5 ⁋
1
(B) Treatment strategies including trauma-
informed approaches
706.4
☒ ☐ ☐
(2) Procedures to instruct youth supervision staff
how to respond to youth who exhibit suicidal
FPO.07.F, 6 Caution Status
behaviors.
☒ ☐ ☐
FPO.07.F, 2
(f) Communication
(1) The intake process shall include communication
701.4, C-1
with the arresting officer and family guardians
☒ ☐ ☐
regarding the youth’s past or present suicidal
ideations, behaviors or attempts.
(2) Procedures for clear and current information
sharing about youth at risk for suicide with youth
supervision, healthcare, and behavioral/mental 706.3 ⁋ 1
health staff.
706.8 ⁋ 1 and 2
☒ ☐ ☐
FPO.07.F, 2 (a)
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(g) Debriefing of Critical Incidents Related to Suicides or
Attempts
(1) Process for administrative review of the 706.9 ⁋ 1 Debriefing
☒ ☐ ☐
circumstances and responses proceeding, during
and after the critical incident.
(2) Process for a debriefing event with affected
706.9 ⁋ 2
staff. ☒ ☐ ☐
(3) Process for a debriefing event with affected
youth.
706.9 ⁋ 2
☒ ☐ ☐
(h) Documentation
(1) Documentation processes shall be developed to 706.6 Observation Logs
ensure compliance with this regulation ☒ ☐ ☐ 706.7 Documentation
Youth identified at risk for suicide shall not be denied the
opportunity to participate in facility programs, services 706.4 ⁋ 2
and activities which are available to other non-suicidal
youth, unless deemed necessary for the safety of the
youth or security of the facility. Any deprivation of ☒ ☐ ☐
programs, services or activities for youth at risk of
suicide shall be documented and approved by the
facility manager.
1340 REPORTING OF LEGAL ACTIONS
101.5
Each facility shall submit to the Board a letter of
notification on each legal action, pertaining to conditions
☒ ☐ ☐ There are no legal issues pending at the
of confinement, filed against persons or legal entities
VCPAJF.
responsible for juvenile facility operation.
1341 DEATH AND SERIOUS ILLNESS OR INJURY
OF A YOUTH WHILE DETAINED 518.3 In Custody Death
518.3 ⁋ 3 In Custody Death Notifications
(1) Death of a Youth.
(a) The facility administrator, in cooperation with
the health administrator and the behavioral/mental
health director, shall develop written policies and ☒ ☐ ☐
procedures in the event of the death of a youth while
detained, which include notifications to necessary
parties, which may include the Juvenile Court, the
parent, guardian or person standing in loco parentis
and the youth’s attorney of record.
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(b) The health administrator, in cooperation with the
facility administrator, shall develop written policies
and procedures to assure there is a medical and 518.4 ⁋ 2
operational review of every in-custody death of a
youth. The review team shall include the facility
☒ ☐ ☐
administrator and/or facility manager, the health
administrator, the responsible physician and other
health care and supervision staff who are relevant to
the incident.
(c) The administrator of the facility shall provide to
the Board a copy of the report submitted to the
Attorney General under Government Code Section 518.3 ⁋ 5
☒ ☐ ☐
12525. A copy of the report shall be submitted to the
Board within 10 calendar days after the death.
(d) Upon receipt of a report of the death of a youth
from the administrator, the Board may within 30
The facility administrators are aware of this
calendar days inspect and evaluate the juvenile
regulation.
facility, jail, lockup or court holding facility pursuant to
☒ ☐ ☐
the provisions of this subchapter. Any inquiry made
by the Board shall be limited to the standards and
requirements set forth in these regulations.
(2) Serious Illness or Injury of Youth.
(a) The facility administrator, in cooperation with 700.3.1 (b)5
the health administrator, shall develop written
700.3.1 (b)14
policies and procedures for the notification to
☒ ☐ ☐
necessary parties, which may include the Juvenile
700.3.1 (b)18 Responsibilities of the Health
Court, the parent, guardian or person standing in
Care Administrator (Illness)
loco parentis and the youth’s attorney of record in the
case of a serious illness or injury of a youth. 801.7 Youth Safety (Injury)
1342 POPULATION ACCOUNTING
Each juvenile facility shall submit required population and ☒ 1101.6.1
profile survey reports to the Board within 10 working days ☐ ☐
after the end of each reporting period, in a format to be
provided by the Board.
1343 JUVENILE FACILITY CAPACITY (EXCERPT)
When the number of youth detained in a living unit of a 1101.3
juvenile facility exceeds its rated capacity for more than ☒
☐ ☐
fifteen (15) calendar days in a month, the facility
administrator shall provide a crowding report to the
Board in a format provided by the Board.
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1350 ADMITTANCE PROCEDURES
The facility administrator shall develop and implement 500.1 Admission
written policies and procedures for admittance of youth
that emphasize respectful and humane engagement
with youth, and reflect that the admission process may
The VCPAJF has a comprehensive
be traumatic to youth who may have already
admission process and includes many
experienced trauma. Policies shall be trauma-informed,
advisals and assessments to assist in
culturally relevant, and responsive to the language and
determining appropriate classification.
literacy needs of youth. In addition to the requirements
These tools articulate detention criteria,
of Sections 1324 and 1430 of these regulations:
housing location, security status, suicidal
tendencies, and the propensity for violence
or victimization. The intake and booking
process provides information to acclimate
the youth to detention as well as orient the
youth to expectations, rights, and rules. The
assessments continue to the youth file when
committed to SYTF.
Staff complete a Juvenile Risk Assessment
Tool to determine if detention is appropriate,
with override and mitigation factors. If
☒ ☐ ☐ detained, the MAYSI-2 Questionnaire and
Classification Assessment Questionnaire are
administered to assist in placement and any
security status needs. Youth then
acknowledge the Prison Rape Elimination
Act (PREA) policy as it relates to Sexual
Abuse, Harassment, and Assault. The Zero
Tolerance for Gang or Violence is also part of
the admission documents the youth signs to
acknowledge. Added this cycle is the Youth
Bill of Rights and Ombudsman information
provided through the Office of Youth and
Community Restoration.
We reviewed numerous intake and remand
Admission paperwork and documentation
outlining the procedures in policy and
regulation. We found the process is lengthy
and exceeds regulatory requirements to
make the best admission decisions.
(a) the admittance process shall include:
(1) Access to two free phone calls within one hour of
500.8
admittance in accordance with the provisions of ☒ ☐ ☐
Welfare and Institution Code Section 627;
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(2) Offer of a shower; 500.9
☒ ☐ ☐
(3) Documented secure storage of personal
500.7.2
belongings; ☒ ☐ ☐
(4) Offer of food upon arrival; 500.5.5
☒ ☐ ☐
(5) Screening for physical and behavioral health
304.6 Initial Youth Screening
and safety issues, intellectual or developmental
☒ ☐ ☐ 501.3 Bullet 10
disabilities;
(6) Screening for physical and developmental
disabilities in accordance with Sections 1329, 1413, 501.3 Bullet 10
☒ ☐ ☐
and 1430 of these regulations;
(7) Contact with Regional Center for the
Developmentally Disabled for youth that are
702.7 Last Paragraph
suspected of or identified as having a
☒ ☐ ☐
developmental disability, pursuant to Section 1413;
and,
501.12
(8) Procedures consistent with Section 1352.5.
☒ ☐ ☐
802.6.1
(b) juvenile hall administrators shall establish written
criteria for detention that considers the least restrictive
☒ ☐ ☐ 500.3 (h)
environment.
(c) juvenile camps and post-dispositional programs in
juvenile halls shall develop policies and procedures that
500.5.3
advise the youth of the estimated length of stay, inform
them of program guidelines and provide written ☒ ☐ ☐
screening criteria for inclusion and exclusion from the
program.
(d) juvenile halls shall develop policies and procedures
that advise any committed youth of the estimated length
☒ ☐ ☐ 500.5.3
of his/her stay.
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1350.5 SCREENING FOR THE RISK OF SEXUAL
ABUSE
501.3
The facility administrator shall develop and implement 701.4 (j) (1)
written policies and procedures to reduce the risk of
sexual abuse by or upon youth. The policy shall require The MAYSI-2 and Classification
☒ ☐ ☐
facility staff to assess each youth within 72 hours of Questionnaire are responsive to this
admission based on the following information: regulation. Youth also watch a PREA video
and read agency policies on how to report
sexual abuse, assault, or discrimination.
(a) Prior sexual victimization or abusiveness; 501.3 Bullet 19 and 21
☒ ☐ ☐
(b) Gender nonconforming appearance or manner; or
identification as lesbian, gay or bisexual, transgender,
501.3 Bullet 20 and 24
queer or intersex, and whether the youth may, therefore, ☒ ☐ ☐
be vulnerable to sexual abuse;
(c) Current charges and offense history; 501.3 Bullet 4-6
☒ ☐ ☐
(d) Age; 501.3 Bullet 1
☒ ☐ ☐
(e) Level of emotional and cognitive development; 501.3 Bullet 7
☒ ☐ ☐
(f) Physical size and stature; 501.3 Bullet 3
☒ ☐ ☐
(g) Mental illness or mental disabilities; 501.3 Bullet 10 and 13
☒ ☐ ☐
(h) Intellectual or developmental disabilities; 501.3 Bullet 14
☒ ☐ ☐
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(i) Physical disabilities; 501.3 Bullet 12
☒ ☐ ☐
(j) The youth’s perception of vulnerability; and, 501.3 Bullet 22
☒ ☐ ☐
(k) Any other specific information about the individual
youth that may indicate heightened needs for
501.3 Bullets 1-24
supervision, additional safety precautions, or separation ☒ ☐ ☐
from certain other youth.
Staff shall ascertain this information through
conversations with the youth during the admittance
501.4
process, medical and behavioral health screenings;
during classification assessments; and by reviewing ☒ ☐ ☐
court records, case files, facility behavioral records, and
other relevant documentation from the youth’s files.
The facility administrator shall implement appropriate
controls on the dissemination of information within the
501.3 Last Paragraph
facility relative to responses received pursuant to this
assessment in order to ensure that sensitive information ☒ ☐ ☐
is not exploited to the youth’s detriment by staff or other
youth.
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1351 RELEASE PROCEDURES
The facility administrator shall develop and implement 516 Releases
written policies and procedures for release of youth from
custody which provide for:
The process for release from all VCPAJF
programs includes transition planning and
linkage to appropriate community services.
We were provided and reviewed the Ventura
County Community Resource List which
outlines available services in different
geographical areas of the county.
The agency identifies youth needing special
release services in the Multi-Disciplinary
Team (MDT), Critical Care Team (CCT), and
Treatment Team (TTM) meetings which
occur weekly. Participation includes
representatives from Behavior Health,
☒ ☐ ☐
Medical, and the VCOE school personnel, as
well as CSO or DPO probation staff.
We reviewed the Release Form, which
includes the youth’s information at booking,
disposition, release authorization, and
signature and identification of the person the
youth is released to. Also included is
acknowledgment of property released to the
youth.
Four youth have been released from SYTF,
one to the family on community supervision
and 3 to the California Conservation Corp as
a step-down.
(a) verification of identity/release papers; 516.3 (a)
☒ ☐ ☐
516.3 (d)
(b) return of personal clothing and valuables;
☒ ☐ ☐
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(c) notification to the youth's parents or guardian; 516.3 (l)
☒ ☐ ☐
(d) notification to the facility health care provider in
accordance with Sections 1408 and 1437 of these
☒ ☐ ☐ 516.3 (c) and (m)
regulations, for coordination with outside agencies; and,
(e) notification of school staff; 516.3 (n)
☒ ☐ ☐
(f) notification of facility mental health personnel. 516.3 (m)
☒ ☐ ☐
The facility administrator shall develop and implement
policies and procedures for post-disposition youth to
516.3 (g) and (n)
coordinate the provision of transitional and reentry
services including, but not limited to, medical and ☒ ☐ ☐
behavioral health, education, probation supervision and
community-based services.
The facility administrator shall develop and implement
written policies and procedures for the furlough of youth
☒ ☐ ☐ 526.4
from custody.
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1352 CLASSIFICATION
The facility administrator shall develop and implement 501 Classification
written policies and procedures on classification of youth
for the purpose of determining housing placement in the
facility.
The Classification Questionnaire used at
Such procedures shall: booking assists staff in determining the most
appropriate placement of youth at admission
and to address observed security or safety
needs of youth.
We reviewed admission documentation
including this form and found it to be
consistent with regulation requirements and
policy. Additionally, youth are re-classified
based on circumstances as they occur while
in the facility via the Critical Case Team
meetings. This is memorialized in the youth’s
☒ ☐ ☐ electronic file, the Ventura County Integrated
Justice Information System. SYTF youth are
in their own unit and classified as ‘younger’
or ‘older’ youth. Since there are only 11
committed and legislation has provided a
clear direction for sight and sound
separation, the agency is moving forward to
consider housing all youth in one unit and
allowing a second unit as they advance in the
program.
It is significant to note the agency works with
medical and behavior health staff to assist in
special classification needs, as well as
reviewing the youth’s behavior which may
prompt a new classification.
(a) provide for the safety of the youth, other youth,
facility staff, and the public by placing youth in the
501.7
appropriate, least restrictive housing and program
settings. Housing assignments shall consider the need ☒ ☐ ☐
for single, double or dormitory assignment or location
within the dormitory;
(b) consider facility populations and physical design of
the facility;
501.8
☒ ☐ ☐
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(c) provide that a youth shall be classified upon
admittance to the facility; classification factors shall
501.3
include, but not be limited to: age, maturity,
sophistication, emotional stability, program needs, legal
☒ ☐ ☐
status, public safety considerations, medical/mental
health considerations, gender and gender identity of the
youth;
(d) provide for periodic classification reviews, including
provisions that consider the level of supervision and the
501.6.1 Periodic Reviews
youth's behavior while in custody; and,
501.6.2 Staff Initiated Reviews
Classification status is reviewed by the CSO
☒ ☐ ☐ III, SDPO, and/or the Watch Commander as
necessary to ensure youth are reintegrated
in the least restrictive classification as
necessary based on their security, medical,
or mental health status.
(e) provide that facility staff shall not separate youth from
the general population or assign youth to a single
occupancy room based solely on the youth's actual or 501.10.1 ⁋ 2 Non-Discrimination Provision
perceived race, ethnic group identification, ancestry,
605.2 ⁋ 1 Non-Discrimination Provision
national origin, color, religion, gender, sexual
orientation, gender identity, gender expression, mental
☒ ☐ ☐
or physical disability, or HIV status. This section does
not prohibit staff from placing youth in a single
occupancy room at the youth's specific request or in
accordance with Title 15 regulations regarding
separation.
(f) facility staff shall not consider lesbian, gay, bisexual,
transgender, questioning or intersex identification or
status as an indicator of likelihood of being sexually ☒ ☐ ☐ 501.10 ⁋ 3
abusive.
1352.5 TRANSGENDER AND INTERSEX YOUTH.
The facility administrator shall develop written policies 501.12 Transgender and Intersex Youth
and procedures ensuring respectful and equitable
☒ ☐ ☐
treatment of transgender and intersex youth. The 501.6.1 ⁋ 2
policies shall provide that:
(a) Facility staff shall respect every youth’s gender
identity and shall refer to the youth by the youth’s
501.12 I-A
preferred name and gender pronoun, regardless of the
youth’s legal name. Facilities may prohibit the use of
☒ ☐ ☐
gang or slang names or names that otherwise
compromise facility operations as determined by the
facility manager or designee, and shall document any
decision made on this basis.
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(b) Facility staff shall permit youth to dress and present
themselves in a manner consistent with their gender
501.12 I-B
identity and shall provide youth with the institution’s ☒ ☐ ☐
clothing and undergarments consistent with their gender
802.6.1 Clothing Issue
identity.
(c) Facility staff shall house youth in the unit or room that
best meets their individual needs and promotes their
500.6.2
safety and well-being. Staff may not automatically house
youth according to their external anatomy and shall
501.3 Bullet 9, 19-22
document the reasons for any decision to house youth ☒ ☐ ☐
in a unit that does not match their gender identity. In 501.12 I-C
making a housing decision, staff shall consider the
youth’s preferences, as well as any recommendations
from the youth’s health or behavioral health provider.
(d) Facility administrators shall ensure that transgender
and intersex youth have access to medical and
501.12 I-D
behavioral health providers qualified to provide care and ☒ ☐ ☐
treatment to transgender and intersex youth.
702.7 (f)
(e) Consistent with the facility’s reasonable and
necessary security considerations and physical plant,
501.12 I-E
facility staff shall make every effort to ensure the safety
☒ ☐ ☐
and privacy of transgender and intersex youth when the
802.11 Showers
youth are using the bathroom or shower, or dressing or
undressing.
Facility staff shall not conduct physical searches of any
youth for the purpose of determining the youth’s
501.12 II-A and B
anatomical sex. Whenever feasible, the facility shall
respect the youth’s preference regarding the gender of ☒ ☐ ☐
513.5
the staff member who conducts any search of the youth.
POC.04.F.3
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1353 ORIENTATION
The facility administrator shall develop and implement 502 Youth Orientation
written policies and procedures to orient a youth prior to 502.2
placement in a living area. Both written and verbal
information shall be provided and supplemented with The intake and booking process for all
video orientation if feasible. Provision shall be made to VCPAJF includes a review of facility
provide accessible orientation information to all detained operations, youth rights, and the rules that
youth including those with disabilities, limited literacy, or guide youth through the program. The
English language learners. Orientation shall include Orientation for each facility type includes all
information that addresses: aspects of programming and activities while
detained.
Facility expectations and opportunities are
explained in both verbal and written formats
☒ ☐ ☐ to allow a youth to understand the material
while in-custody. The individual program is
outlined in a handbook to promote progress
through positive behavior to earn incentives.
We provided technical assistance to
consolidate the booking forms requiring
youth acknowledgment relating to the
Ombudsman and Youth Bill of Rights for a
more streamlined approach and training
opportunity for youth to better understand the
program expectations. The new Youth
Handbook is descriptive as it relates to all
Orientation components.
(a) facility rules including contraband and searches and
disciplinary procedures;
502.4 (a)
☒ ☐ ☐
(b) facility’s system of positive behavior interventions
and supports, including behavior expectations, 502.4 (b)
incentives that youth will receive for complying with 1009.3 (a) BMP
☒ ☐ ☐
facility rules, and consequences that may result when
youth violate the rules of the facility;
(c) age appropriate information that explains the
facility’s policy prohibiting sexual abuse and sexual 502.4 (n)
harassment and how to report incidents or suspicions of ☒ ☐ ☐
sexual abuse or sexual harassment;
(d) identification of key staff and their roles;
502.4 (v)
☒ ☐ ☐ 1208.7 (a)
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(e) the existence of the grievance procedure, the steps
that must be taken to use it, the youth’s right to be free 502.4 (e)
of retaliation for reporting a grievance, and the name of ☒ ☐ ☐
the person or position designated to resolve the issue;
(f) access to legal services and information on the
502.4 (i)
court process; ☒ ☐ ☐
(g) access to routine and emergency health and mental
502.4 (f)
health care; ☒ ☐ ☐
(h) access to education, religious services, and
502.4 (g)
recreational activities; ☒ ☐ ☐
(i) housing assignments; 502.4 (h)
☒ ☐ ☐
(j) opportunity for personal hygiene and daily showers
including the availability of personal care items 502.4 (d)
☒ ☐ ☐
(k) rules and access to correspondence, visits and
telephone use; 502.4 (c)
☒ ☐ ☐
(l) availability of reading materials, programming, and
other activities; 502.4 (k)
☒ ☐ ☐
(m) facility policies on the use of force, use of restraints,
chemical agents and room confinement; 502.4 (l), (m) and (w)
☒ ☐ ☐
(n) immigration legal services; 502.4 (p)
☒ ☐ ☐
(o) emergencies including evacuation procedures; 502.4 (r)
☒ ☐ ☐
(p) non-discrimination policy and the right to be free from
physical, verbal or sexual abuse and harassment by 303.1 (g)
other youth and staff; 502.4 (n) and (u)
☒ ☐ ☐
603.1
(q) availability of services and programs in a language
other than English if appropriate;
502.4 Last 2 Paragraphs
☒ ☐ ☐
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(r) the process for requesting different housing,
education, programming and work assignments;
502.4 (x)
☒ ☐ ☐
(s) a process for which parents/guardians receive
information regarding the youth’s stay in the facility that
502.4 (y)
at a minimum includes answers to frequently asked
☒ ☐ ☐
questions and provides contact information for the
facility, medical, school and mental health; and,
(t) a process by which youth may request access to Title
15 Minimum Standards for Juvenile Facilities.
502.4 (z)
☒ ☐ ☐
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1354 SEPARATION
The facility administrator shall develop and implement 519 Youth Separation
written policies and procedures that address:
519 Second to last ⁋
500.6.2
The VCPAJF agency has a well-documented
practice of recording a youth’s request to
decline participation in unit programs and
activities. There has been some confusion
amongst staff for what is referred to as
‘decliners’ versus those that self-separate for
protective custody reasons.
We reviewed self-separation half sheets,
revealing the youth’s request for non-
participation in an activity or program,
including their signature detailing the reason.
☒ ☐ ☐ These are short-term separations and are
well-documented.
We also reviewed four incidents of long-term
self-separations that turned into a re-
classification. The incident report or youth’s
signed request to self-separate and notes
from Critical Case Meetings articulated
efforts by staff and/or Behavior Health to
reintegrate the youth. The case logs also
detail unit staff efforts to get a youth back into
programming. These long-term ‘separations’
are a classification the agency is working on
to facilitate needs and activities in an
environment where the youth feels safe to
engage in unit activities. We provided
technical assistance to encourage a ‘re-
branding’ for these youth that is positive-
focused.
(a) separation of youth for reasons that include, but are
not be limited to, medical and mental health conditions, 519 Medical Separation
assaultive behavior, disciplinary consequences and 519.3 Self Separation
protective custody. 501.7
☒ ☐ ☐
600.3.1
601.4
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(b) consideration of positive youth development and
trauma-informed care.
519 ⁋ 3
☒ ☐ ☐
501.7.1 ⁋ 1
(c) separated youth shall not be denied normal
privileges available at the facility, except when
necessary to accomplish the objective of separation. 519 ⁋ 4
☒ ☐ ☐
501.7.1 ⁋ 2
(d) when the objective of the separation is discipline,
Title 15 Section 1390 shall apply.
519 ⁋ 5
☒ ☐ ☐
501.7.1 ⁋ 1
(e) when separation results in room confinement, the
separation shall occur in accordance with Welfare and
Institutions Code Section 208.3 and Section 1354.5 of ☒ ☐ ☐ 519 ⁋ 1
these regulations.
601 Room Confinement
(f) policies and procedures shall ensure a daily review
of separated youth to determine if separation remains
necessary. 519 Last ⁋
☒ ☐ ☐
501.7.1 ⁋ 4
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1354.5 ROOM CONFINEMENT
(a) The facility administrator shall develop and 601 Room Confinement (RC)
implement written policies and procedures addressing
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
The VCPAJF agency reported 119 incidents
208.3. The placement of a youth in room confinement
of Room Confinement from April 2022 to
shall be accomplished in accordance with the following
June 2023. This is slightly more than the 50
guidelines:
in 2021, but less than the previous ‘time outs’
recorded in 2018-2019 before the regulation
and legislation were implemented.
After a safety and security-related incident,
staff initiated an RC Log which prompts them
to initiate specific documentation practices
and alerts to senior staff. Agency policy and
procedures include the staff recording
behavior and attempts to remove the youth
from RC status as soon as the threat is
minimized. When this happens, youth must
agree to respond with appropriate behaviors
in a contract format to document the
expectations when removed. In most cases,
the youth return to regular unit activities.
☒ ☐ ☐
We reviewed 7 RC incidents and 10 UF
incidents resulting in RC, including 4 SYTF
youth, and found the agency utilizes RC for
applicable behavior-related incidents that
pose a safety and security risk to other youth,
staff, or the facility operations.
Staff and supervisors provided appropriate
responses to reintegrate youth to
programming, including behavior health input
and involvement. Safety check logs and
behavior health intervention documentation
was included in the reviewed incidents.
The agency has adopted an early morning
review of youth on RC going into the
following day, in an effort to return the youth
to normal activities as the youth starts their
day.
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(1) Room confinement shall not be used before
other, less restrictive, options have been attempted
601.4 (a)
and exhausted, unless attempting those options
☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or
☒ ☐ ☐ 601.4 (b)
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health
☒ ☐ ☐ 601.4 (c)
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room
601.4.5 (a)
confinement for a period of four hours, staff shall do one ☒ ☐ ☐
or more of the following:
(1) Return the youth to general population. 601.4.5 (a) (1)
☒ ☐ ☐
(2) Consult with mental health or medical staff. 601.4.5 (a) (2)
☒ ☐ ☐
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate
☒ ☐ ☐ 601.4.5 (a) (3)
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following:
601.4.5 (b)
☒ ☐ ☐
(A) Document the reasons for room confinement
and the basis for the extension, the date and time
601.4.5 (b)(1)
the youth was first placed in room confinement,
☒ ☐ ☐
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to
☒ ☐ ☐ 601.4.5 (b)(2)
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee
☒ ☐ ☐ 601.4.5 (b)(3)
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth
601.1.1
in juvenile facilities and does not apply to normal ☒ ☐ ☐
sleeping hours.
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(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional
☒ ☐ ☐ 102.2.1
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires 400 Facility Emergencies
a significant departure from normal institutional 400.3.1 Emergency Suspension of
operations, including a natural disaster or facility- Standards
wide threat that poses an imminent and substantial ☒ ☐ ☐
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and
501.7.2
protect against the spread of a communicable
disease for the shortest amount of time required to
519 Medical Separation
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an
☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1355 INSTITUTIONAL ASSESSMENT AND PLAN
The facility administrator shall develop and implement 503 Case Management
written policies and procedures for assessment and
case planning.
The VCPAJF agency has an operational
process to complete and update Institutional
Assessments and Plans originally done by
the field DPO with ongoing updates by the
assigned CSO. Documents included the
original case plan with identified risks and
needs and ongoing plans targeting service
delivery for the youth. Educational progress
from Providence School, case notes and
number of hours with Behavior Health
Services, and youth chrono notes from
facility staff all contribute to the overall plan
while the youth is detained.
The plans are completed by staff and
reviewed by supervisors. The plan
documents education, substance abuse,
aggression, anti-social environments, family,
impulsivity, remorse, and violence,
articulating a plan and discussion points for
☒ each.
☐ ☐
We reviewed 3 six-month review reports to
the Court specific to SYTF youth. The
individualized plans were detailed and
comprehensive of all the youth that had been
involved during the period covered.
Numerous agency partners provide input
specific to their programs, allowing for a well-
rounded description of services and
successes.
SYTF also have initial, ongoing, and
Transitional Plans during their stay. We
reviewed 10 ongoing IAP’s and 8 Transitional
MDTs for 18 youth and found each had an
individualized plan, including the most
significant areas to address with targeted
services. The plans are reviewed every 30
days to show progress or to re-direct
services. They are individualized and
inclusive of chrono entry discussions with the
youth.
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(a) Assessment:
The assessment is based on information collected
during the admission process with periodic review, 503.3 ⁋ 2
which includes the youth's risk factors, needs and
☒
strengths including, but not limited to, identification of ☐ ☐
substance abuse history, educational, vocational,
counseling, behavioral health, consideration of known
history of trauma, and family strengths and needs.
(b) Institutional Case Plan:
(1) A case plan shall be developed for each youth
☒
503.3.1
held for at least 30 days or more and created within ☐ ☐
40 days of admission.
(2) The institutional plan shall include, but not be
limited to, written documentation that provides:
☒
☐ ☐
(A) objectives and time frame for the resolution of
problems identified in the assessment;
☒ 503.3.1 (c)
☐ ☐
(B) a plan for meeting the objectives that includes
a description of program resources needed and
☒
503.3.1 (b)
individuals responsible for assuring that the plan ☐ ☐
is implemented;
(3) periodic evaluation of progress towards meeting
the objectives, including periodic review and ☒
☐ ☐ 503.3.1 (c)
discussion of the plan with the youth;
(4) a transition plan, the contents of which shall be
subject to existing resources, shall be developed for 503.3.1
☒
post dispositional youth in accordance with Section ☐ ☐ 516.3; 516.5 (Releases)
1351; and,
(5) in as much as possible and if appropriate, the
plan, including the transition plan, shall be developed
with input from the family, supportive adults, youth, ☒ 503.3.1 (a)
☐ ☐
and Regional Center for the Developmentally
Disabled.
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1356 COUNSELING AND CASEWORK SERVICES
503.5
The facility administrator shall develop and implement
703.3 Counseling Services
written policies and procedures ensuring the availability
POC.03.C, 1
of appropriate counseling and casework services for all
youth. Policies and procedures shall ensure:
The VCPAJF agency requires the assigned
CSO to meet with the youth weekly to ensure
☒ he or she is progressing as expected or to
☐ ☐
assist with any difficulty in the program.
We reviewed case Chrono’s and Critical
Case Team meeting notes which address
any noted positive or negative behaviors
displayed in the program.
(a) youth will receive assistance with needs or concerns
that may arise;
703.3 (a)(1)
☒
☐ ☐
POC.03.C, 1(a)
(b) youth will receive assistance in requesting contact
with parents, other supportive adults, attorney, clergy,
703.3 (a)(2)
probation officer, or other public official; and,
☒
☐ ☐
POC.03.C, 1 (b)
(c) youth will be provided access to available resources
to meet the youth’s needs.
☒ 703.3 (a)(2)
☐ ☐
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1357 USE OF FORCE
511 Use of Force (UF)
The facility administrator, in cooperation with the
511.3 ⁋ 6
responsible physician, shall develop and implement
511.3.3 Health Care assistance in developing
written policies and procedures for the use of force,
policy
which may include chemical agents. Force shall never
301 Use of Force-Administration Manual
be applied as punishment, discipline, retaliation or
treatment.
There were 138 UF incidents from April 2022
(a) At a minimum, each facility shall develop policies and to June 2023, 95 included physical force and
procedures which: 93 included the use of OC Spray at the
VCPAJF. There were 97 UF incidents in 2022
and 130 UF in 2021. This is down
significantly from the 183 in 2019 and 178 in
2018.
We reviewed 15 UF incidents reports and
found the agency documents the efforts to
use the least restrictive option when
available. Staff are required to include the
circumstances leading to the use of force and
☒ justify why force was used. The Supervisor
☐ ☐
on duty is also required to write a Use of
Force Report to include a summary of the
incident, Supervisor actions (including review
of video and interviews with involved staff),
and, lastly, the Supervisors Evaluation, which
details the assessment of staff response and
critique of the staff actions.
Each month the agency conducts a UF
Review with a committee consisting of the
Facility Managers, Supervisors, and staff
involved. All documentation and video
footage are presented so the committee can
determine if the incident was within policy.
The outcome for the Review Committee is: A
– Within Policy; B – Within Policy but training
identified; C – Staff actions referred to
Professional Standards Unit; and D – Other.
Each of the incidents we reviewed were
cleared by Administration as ‘Within Policy’.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 511.3 ⁋ 1
1302 to ensure the safety and security of youth, staff, ☒ 511.3.1 Factors to determine
☐ ☐
others and the facility. Reasonableness of Force.
(2) outline the force options available to staff
including both physical and non-physical options and 511.5
☒
define when those force options are appropriate. ☐ ☐ 511.5.1
FPO.08.F, 1
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(3) describe force options or techniques that are
expressly prohibited by the facility.
511.10 (l)
511.5.1 ⁋ 1 and 3
In policy, the only prohibited use of force is
the Carotid Hold. If time allows, the agency
☒
☐ ☐ operational procedure promotes a use of
force team approach to an incident, including
a supervisor, to determine how and what type
of force is appropriate given the
circumstances. This process allows for a
‘natural’ de-escalation and the use of the
least amount of force necessary.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative 511.3.2 Duty to Intervene
action to immediately stop it. ☒ 511.6
☐ ☐
511.6.1
(5) define a standardized reporting format that
includes time period and procedure for documenting
511.6 Reporting UF
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒
☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma
that may have been experienced by staff and /or the
youth involved.
(6) Include an administrative review and a system for
investigating unreasonable use of force. 511.9 UF Review
☒
☐ ☐ 511.91 UF Review Committee
(7) define the role, notification, and follow-up
procedures required after use of force incidents for 511.6.1 Notifications to Medical, Mental
medical, mental health staff and parents or legal ☒ Health and Parent
☐ ☐
guardians. 517.5
(8) describe the limitations of use of force on
pregnant youth in accordance with Penal Code
☒
512.9
Section 6030(f) and Welfare and Institutions Code ☐ ☐
Section 222.
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(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that:
(1) identify who is approved to carry and/or utilize ☒ 511.4 ⁋ 1 and 2
☐ ☐
chemical agents in the facility and the type, size and
the approved method of deployment for those
chemical agents.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or
☒ 511.4.1
the safety of others and only when de-escalation ☐ ☐
efforts have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents.
This shall include that youth who have been exposed 511.4 ⁋ 3 and 5
☒
to chemical agents shall not be left unattended until ☐ ☐
FPO.08.L, 2
that youth is fully decontaminated or is no longer
suffering the effects of the chemical agent. FPO.08.L, 4
(4) define the role, notification, and follow-up
procedures required after use of force incidents
☒
511.6.1 Notifications to Medical, Mental
involving chemical agents for medical, mental health ☐ ☐
Health and Parent
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for
511.6 (g)
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒
☐ ☐ FPO.08.I, 2
of use, decontamination procedures applied and
identification of any injuries sustained as a result of FPO.08. 4
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training
☒
300.3.1
in use of force and chemical agents when appropriate ☐ ☐
511.4
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
☒ 511.10 (i)
☐ ☐
(2) acceptable chemical agents and the methods of
application.
☒ 511.4 ⁋ 2
☐ ☐
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health.
☒
☐ ☐
511.10 (j)
(4) instruction on the Constitutional Limitations of
Use of Force.
☒ 511.10 (i)
☐ ☐
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(5) physical training force options that may require
the use of perishable skills. 511.3 ⁋ 2
☒
☐ ☐ 511.10
(6) timelines the facility uses to define regular
training. 300 Training
☒
☐ ☐ 511.10 Initial and Annual Training
1358 USE OF PHYSICAL RESTRAINTS
512. Use of Restraints UR
The facility administrator, in cooperation with the
301.8 Administration Manual
responsible physician and mental health director, shall
develop and implement written policies and procedures
There has been one use of restraint per this
for the use of restraint devices. Restraint devices ☒
☐ ☐ regulation since April 2022, not involving a
include any devices which immobilize a youth's
SYTF youth.
extremities and/or prevent the youth from being
ambulatory.
This incident is the first UR since 2019.
Physical restraints may be used only for those youth
who present an immediate danger to themselves or 512.3 (c) and (e)
others, who exhibit behavior which results in the
destruction of property, or reveals the intent to cause
☒
self-inflicted physical harm. Physical restraints should ☐ ☐
be utilized only when it appears less restrictive
alternatives would be ineffective in controlling the
youth’s behavior.
In no case shall restraints be used as punishment or
discipline, or as a substitute for treatment. The use of 512.3 (g) and (l)
restraint devices that attach a youth to a wall, floor or 512.5 (a) 1
other fixture, including a restraint chair, or through 512.9 Pregnant Youth
affixing of hands and feet together behind the back ☒ 512.9.1
☐ ☐
(hogtying) is prohibited. The use of restraints on
pregnant youth is limited in accordance with Penal Code
Section 6030(f) and Welfare and Institutions Code
Section 222.
The provisions of this section do not apply to the use of
handcuffs, shackles or other restraint devices when 512.5 UR for Movement and Transportation
used to restrain youth for movement or transportation
☒
within the facility. Movement within the facility shall be ☐ ☐
governed by Section 1358.5, Use of Restraint Devices
for Movement Within the Facility.
Youth shall be placed in restraints only with the approval
of the facility manager or designee. The facility manager 512.3 (d)
may delegate authority to place a youth in restraints to
☒
a physician. Reasons for continued retention in ☐ ☐
restraints shall be reviewed and documented at a
minimum of every hour.
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A medical opinion on the safety of placement and
retention shall be secured as soon as possible, but no 512.3 (j)(1)
later than two hours from the time of placement. The ☒
☐ ☐
youth shall be medically cleared for continued retention
at least every three hours thereafter.
A mental health consultation shall be secured as soon
as possible, but in no case longer than four hours from 512.3 (j)(2)
☒
the time of placement, to assess the need for mental ☐ ☐
health treatment.
Continuous direct visual supervision shall be conducted
to ensure that the restraints are properly employed, and 512.3 (j)
to ensure the safety and well-being of the youth. 512.7 (e)
Observations of the youth's behavior and any staff ☒
☐ ☐
interventions shall be documented at least every 15
minutes, with actual time of the documentation
recorded.
In addition to the requirements above, policies and
procedures shall address: 512.7 Documentation
☒
☐ ☐
(a) documentation of the circumstances leading to an
application of restraints.
(b) known medical conditions that would contraindicate
certain restraint devices and/or techniques. 512.6 (k)
☒
☐ ☐ 512.10 (h)
(c) acceptable restraint devices.
☒ 512.10 (i)
☐ ☐
(d) signs or symptoms which should result in immediate
medical/mental health referral. ☒ 512.10 (j)
☐ ☐
(e) availability of cardiopulmonary resuscitation
equipment. ☒ 512.10 (k)
☐ ☐
(f) protective housing of restrained youth. While in
restraint devices, all youth shall be housed alone or in a 512.10 (d)
☒
specified housing area for restrained youth which makes ☐ ☐ 512.6 (d)
provision to protect the youth from abuse.
(g) provision for hydration and sanitation needs. ☒ 512.3 (m)
☐ ☐
512.10 (l)
(h) exercising of extremities. ☒
☐ ☐ 512.6 (k)
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1358.5 USE OF RESTRAINT DEVICES FOR
MOVEMENT AND TRANSPORTATION 512.4
WITHIN THE FACILITY. 512.5 UR for Movement and Transportation
The Facility Administrator, in cooperation with the
responsible physician and behavioral/mental health
☒
☐ ☐
director, shall develop and implement written policies
and procedures for the use of restraint devices when the
purpose is for movement or transportation within the
facility that shall include the following:
(a) identification of acceptable restraint devices, staff
approved to utilize restraint devices and the required ☒ 512.1
☐ ☐
training.
(b) the circumstances leading to the application of
restraints must be documented. ☒ 512.5 (a)(1)
☐ ☐
(c) an individual assessment of the need to apply
restraints for movement or transportation that includes 512.5 (b)(1)
consideration of less restrictive alternatives, 512.5 (c)(1)
consideration of a youth’s known medical or mental
health conditions, trauma informed approaches, and a The VCPAJF agency has been tracking the
process for documentation and supervisor review and UR as identified in this regulation since last
approval. ☒ cycle. Since April of 2022, there have been
☐ ☐
17 applications of restraints for movement.
Our review of the reports when restraints
were used provided sufficient justification.
From July 2020 to April 2022, 27 of the 57
reports reviewed included restraints as
defined in this regulation.
(d) consideration of safety and security of the facility,
with a clearly defined expectation that restraint devices 512.3 (g)
☒
shall not be used for the purposes of discipline or ☐ ☐
retaliation.
(e) the use of restraints on pregnant youth is limited in
accordance with Penal Code Section 6030(f) and ☒ 512.9
☐ ☐
Welfare and Institutions Code Section 222.
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1359 SAFETY ROOM PROCEDURES
506 Safety Rooms and Camera Rooms
(a) The facility administrator, and where applicable, in
506.3
cooperation with the responsible physician, shall
develop and implement written policies and procedures
There have been 3 safety room placements
governing the use of safety rooms, as described in Title
since April 2022, none involving a SYTF
24, Part 2, Section 1230.1.13. The room shall be used
youth.
to hold only those youth who present an immediate
danger to themselves or others, who exhibit behavior
The amount of time in the safety cell was
which results in the destruction of property, or reveals ☒
☐ ☐ monitored by Medical and Behavior Health
the intent to cause self-inflicted physical harm. A safety
(Crisis Team) and lasted from 2-3 hours. The
room shall not be used for punishment or discipline, or
agency complied with regulation and policy
as a substitute for treatment. Policies and procedures
for each incident and had multiple staff and
shall:
partners in close proximity during each event.
Prior to the above, the agency has had no
safety cell placements since one in 2019 and
4 in 2018.
(1) include provisions for administration of necessary
nutrition and fluids, access to a toilet, and suitable ☒ 506.4 (e)
☐ ☐
clothing to provide for privacy;
(2) provide for approval of the facility manager, or
designee, before a youth is placed into a safety ☒ 506.4 (a)
☐ ☐
room;
(3) provide for continuous direct visual supervision
and documentation of the youth's behavior and any 506.4 (c)
☒
staff interventions every 15 minutes, with actual time ☐ ☐
recorded;
(4) provide that the youth shall be evaluated by the
facility manager, or designee, every four hours; ☒ 506.4 (g)
☐ ☐
(5) provide for immediate medical assessment,
where appropriate, or an assessment at the next 506.4 (h)
daily sick call; and,
☒ The policy states the assessment shall take
☐ ☐
place no longer than 12 hours after
placement.
(6) provide a process for documenting the reason for
placement, including attempts to use less restrictive 506.4 (i)
☒
means of control, and decisions to continue and end ☐ ☐
placement.
(b) The placement of a youth in the safety room shall be
☒
accomplished in accordance with the following: ☐ ☐
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(1) safety room shall not be used before other less
restrictive options have been attempted and 506.4 (j)
☒
exhausted, unless attempting those options poses a ☐ ☐
threat to the safety or security of any youth or staff.
(2) safety room shall not be used for the purposes of
punishment, coercion, convenience, or retaliation by ☒ 506.4 (l)
☐ ☐
staff.
(3) safety room shall not be used to the extent that it
compromises the mental and physical health of the ☒ 506.4 (l)
☐ ☐
youth.
(c) A youth may be held up to four hours in the safety
room. After the youth has been held in the safety room 506.4 (g)
for a period of four hours, staff shall do one or more of ☒
☐ ☐
the following: Refer to 601.4.5, Room Confinement
☒ 506.4 (g)(1)
(1) return the youth to general population. ☐ ☐
☒ 506.4 (g)(1)
(2) consult with mental health or medical staff, ☐ ☐
(3) develop an individualized plan that includes the
☒
goals and objectives to be met in order to reintegrate ☐ ☐ 506.4 (g)(1)
the youth to general population.
(d) If confinement in the safety room must be extended
beyond four hours, staff shall develop an individualized 506.4 (g)(1)
plan that includes the requirements of Section 1354.5 ☒
☐ ☐
and the goals and objectives to be met in order to
integrate the youth to general population.
1360 SEARCHES
513 Searches
The facility administrator shall develop and implement
written policies and procedures governing the search of
youth, the facility, and visitors. Policies and procedures
shall provide that: The agency conducts routine unit and room
searches for the ongoing safety of the facility.
☒
☐ ☐
Due to fentanyl and other drugs coming into
the facility, the VCPAJF has purchased two
body scanners and a mail scanner as tools to
prevent this from occurring. It is expected
they will arrive in August. Prospective
policies for their use are being developed.
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(a) Searches shall be conducted to ensure the safety
and security of the facility, public, visitors, youth, and ☒ 513.2 ⁋ 1
staff. ☐ ☐
(b) Searches shall be conducted in a manner that
preserves the privacy and dignity of the person being ☒ 513.1 ⁋ 1
searched and shall not be conducted for harassment or ☐ ☐ 513.2 ⁋ 1
as a form of discipline or punishment.
(c) Strip searches and visual or physical body cavity
searches shall comply with Penal Code Section 4030. 513.4.1 (a)
513.4.2 (a)
The agency has conducted strip searches of
units and youth more in this past year due to
contraband coming into the facility. Visits
have gone to no contact in some cases as
the agency traced the source. Phone call
coding and recordings reviewed also pointed
to a pathway for contraband.
Since April of 2022, there have been 425 strip
searches conducted, 243 due to contraband
in the units and/or positive drug test of youth
in the facility. Of the 182 additional strip
☒ searches, averaging 13 per month, we found
☐ ☐
documented reasonable suspicion and
authorization by the supervisor in all but 16
incidents. These 16 were approved by a
supervisor but the documentation, other than
the coded reason for the search, was not
verified. We reviewed the strip searches from
April 2020 to June 2022 (334 – average
15/month), finding this average
consistent/less than current practice.
We provided technical assistance to the
agency to ensure the reasonable suspicion
was not just a conversation but documented
in the electronic search authorization and/or
by incident report.
(d) Physical body cavity searches shall only be
conducted by a medical professional. ☒ 513.4,2 (b)
☐ ☐
(e) Any youth held after a detention hearing shall only
be strip searched with prior approval of a supervisor 513.4.2 (b)
when there is reasonable suspicion based on specific
☒
and articulable facts to believe that youth is concealing ☐ ☐
contraband. The reasonable suspicion shall be
documented.
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(f) Searches of transgender and intersex youth shall
comply with Section 1352.5. 501.12 II-A and B
☒ 513.5
☐ ☐
301.5 II Administrative Manual
(g) Cross-gender pat-down searches and strip searches
are prohibited except in exigent circumstances or when ☒ 513.3 Last ⁋
conducted by a medical professional. Such searches ☐ ☐
must be justified and documented in writing.
1361 GRIEVANCE PROCEDURE
606 Youth Grievances
The facility administrator shall develop and implement
606.3 ⁋ 1
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
The VCPAJF agency reported 72 grievances
condition of confinement, including but not limited to
filed from April 2022 to June 2023, an
health care services, classification decisions, program
average of 5.1 per month. There were 34 in
participation, telephone, mail or visiting procedures,
2022, 35 in 2021, and 43 in 2020, reduced
food, clothing, bedding, mistreatment, harassment or
from the 79 in 2019 and 82 in 2018. The
violations of the nondiscrimination policy. There shall be
process and form are compliant with
no time limit on filing grievances. Policies and
regulation and policy, allowing youth to
procedures shall include provisions whereby the facility
communicate and staff to be responsive to
manager ensures:
the operational procedures used.
☒
☐ ☐ We reviewed all the grievances filed from
April 2022 to June of 2023 and found them to
be timely with appropriate sanctions. Staff
comments appeared to be a documented
conversation, leading the youth to
understand the behavior and sanction, or to
find resolution for a condition of confinement
the youth did not agree with.
There were several beyond the regulation 3-
day receipt of the grievance, but each
involved an agency partner grievance. All
were resolved within 10 days of the receipt of
the grievance.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ 606.3 Bullet 1
☐ ☐
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ 606.3 Bullet 8
☐ ☐
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ 606.3 Bullet 2
☐ ☐
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(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances ☒ 606.4.2 ⁋ 3
that relate to health and safety issues must be ☐ ☐
addressed immediately;
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not 606.4.5 (a)
☒
directly involved in the circumstances which led to ☐ ☐
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ 606.4.5 (b)
☐ ☐
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ 606.4.3
☐ ☐
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly 606.4.5 (a)
☒
involved in the circumstances which led to the ☐ ☐
grievance;
(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer ☒ 606.4.2 ⁋ 4
time frame. The youth shall be notified of any delay; ☐ ☐
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. 606.5
☒
☐ ☐ 606.5.1
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be 606.4.5 (c)
☒
addressed and documented in accordance with written ☐ ☐
policies and procedures within a specified timeframe.
1362 REPORTING OF INCIDENTS
206 Report Preparation
A written report of all incidents which result in physical
206.4.2
harm, use of force, serious threat of physical harm, or
death of an employee, youth or other person(s) shall be ☒
☐ ☐
maintained. Such written record shall be prepared by
the staff and submitted to the facility manager by the end
of the shift, unless additional time is necessary and
authorized by the facility manager or designee.
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1363 USE OF REASONABLE FORCE TO
COLLECT DNA SPECIMENS, SAMPLES, 517 Biological Samples
IMPRESSIONS 517.5 UF to Collect
DHPO 01.P.1.16
(a) Pursuant to Penal Code Section 298.1 authorized
law enforcement, custodial, or corrections personnel
including peace officers, may employ reasonable force
☒
☐ ☐
The VCPAJF policy does not use force to
collect DNA. Staff advise the youth that their
to collect blood specimens, saliva samples, and thumb
failure to cooperate will result in a return to
or palm print impressions from individuals who are
Court.
required to provide such samples, specimens or
impressions pursuant to Penal Code Section 296 and
who refuse following written or oral request.
(1) For the purpose of this section, the “use of
reasonable force” shall be defined as the force that 511.3.1
an objective, trained and competent correctional
☒
employee, faced with similar facts and ☐ ☐
circumstances, would consider necessary and
reasonable to gain compliance with this section.
(2) The use of reasonable force shall be preceded by
efforts to secure voluntary compliance. Efforts to 517.5.2
secure voluntary compliance shall be documented
☒
and include an advisement of the legal obligation to ☐ ☐
provide the requisite specimen, sample or
impression and the consequences of refusal.
(b) The force shall not be used without the prior written
authorization of the supervising officer on duty. The 517.5.2
authorization shall include information that reflects the ☒
☐ ☐
fact that the offender was asked to provide the requisite
specimen, sample, or impression and refused.
(1) If the use of reasonable force includes a cell
extraction, the extraction shall be videotaped. Video 517.5.1
shall be directed at the cell extraction event. The
videotape shall be retained by the agency for the
☒
length of time required by statute. Notwithstanding ☐ ☐
the use of the video as evidence in a court
proceeding, the tape shall be retained
administratively.
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1370 EDUCATION PROGRAM
1003 Youth Education Services
(a) School Programs
1003.3 ⁋ 3
The County Board of Education shall provide for the 1003.4 (b)(1) Education Program
administration and operation of juvenile court schools in Coordination
conjunction with the Chief Probation Officer, or designee
pursuant to applicable State laws. The school and The Ventura County Office of Education
facility administrators shall develop and implement operates the Providence School onsite at the
written policy and procedures to ensure communication facility. The last evaluation continues to
and coordination between educators and probation reveal a good relationship amongst probation
staff. Culturally responsive and trauma-informed and school staff, with daily briefings and
approaches should be applied when providing thorough monthly meetings with agency
instruction. Education staff should collaborate with the administrators.
facility administrator to use technology to facilitate
learning and ensure safe technology practices. The
facility administrator shall request an annual review of While onsite, we met with the Director of
each required element of the program by the Alternative Education for the Ventura County
Superintendent of Schools, and a report or review Office of Education (VCOE), Stephanie
checklist on compliance, deficiencies, and corrective Rodrigues, Teresa Vega, the site Assistant
action needed to achieve compliance with this section. Principal, and Nicole Garr, Counselor. We
Such a review, when conducted, cannot be delegated to once again discussed the early and easy
the principal or any other staff of any juvenile court graduation requirements and whether the
school site. The Superintendent of Schools shall VCOE made independent evaluations to
conduct this review in conjunction with a qualified address the need to provide a diploma to a
outside agency or individual. Upon receipt of the review, youth based on their age, credits to date, and
the facility administrator or designee shall review each anticipated length of stay, mostly to ensure
item with the Superintendent of Schools and shall take that just because a youth is eligible that they
whatever corrective action is necessary to address each ☒ ☐ ☐ evaluate the best case scenario for each
deficiency and to fully protect the educational interests independent youth. Ms. Garr works most with
of all youth in the facility. this population and assured the process is
independent, indicating there could be a
more robust conversation with the parent and
youth when the situation involves a long stay
in custody.
It is significant to note that while onsite, we
were advised 15 youth had graduated so far
this year, 13 with the limited credits pursuant
to AB 167. This is significant because the
agency and VCOE have limited post-
secondary opportunities for youth beyond
enrollment in an online local college,
AutoTech (not during summer months), and
Paxton Patterson (PP), which is facilitated by
Probation staff. There is a plan for an Ag
Program and Digital Media program to start
this fall.
We discussed the VCOE hard line for not
allowing graduated youth to remain in the
classroom or to provide greater opportunities
for these youth who will remain with the
agency long-term. VCOE continues to
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provide little in terms of opportunities for
graduated youth but allows youth in long-
term custody to graduate early without
consideration of the benefits to remain in the
classroom. The VCPAJF has tentative plans
to fund a teacher to provide services in this
area that the VCOE does not.
We conducted a ‘group’ interview with SYTF
youth who expressed their frustration with
limited vocational opportunities to use when
reintegrated into the community. We
provided input on pending regulation
changes which would likely include more
robust language regarding post-secondary
opportunities and the hope the VCOE would
illicit more service alternatives for this
population.
(b) Required Elements
1003.2
The facility school program shall comply with the State
1003.3
Education Code and County Board of Education
1003.4 (b)(1)
policies, all applicable federal education statutes and
1003.5
regulations and provide for an annual evaluation of the
educational program offerings. As stated in the 2009
California Standards for the Teaching Profession, ☒
☐ ☐
teachers shall establish and maintain learning
environments that are physically, emotionally, and
intellectually safe. Youth shall be provided a rigorous,
quality educational program that responds to the
different learning styles and abilities of students and
prepares them for high school graduation, career entry,
and post-secondary education.
All youth shall be treated equally, and the education
program shall be free from discriminatory action. Staff 1003.3 (a)
shall refer to transgender, intersex and gender- ☒
☐ ☐
nonconforming youth by their preferred name and
gender.
(1) The course of study shall comply with the State
Education Code and include, but not be limited to, ☒ 1003.5 ⁋ 3
☐ ☐
courses required for high school graduation.
(2) Information and preparation for the High School
Equivalency Test as approved by the California ☒ 1003.5 ⁋ 3
Department of Education shall be made available to ☐ ☐
eligible youth.
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(3) Youth shall be informed of post-secondary
education and vocational opportunities. ☒ 1003.4 (o)(1)
☐ ☐
(4) Administration of the High School Equivalency
Tests as approved by the California Department of ☒ 1003.5 ⁋ 3
☐ ☐
Education, shall be made available when possible.
(5) Supplemental instruction shall be afforded to
youth who do not demonstrate sufficient progress ☒ 1003.5 ⁋ 4
☐ ☐
towards grade level standards.
(6) The minimum school day shall be consistent with
State Education Code Requirements for juvenile 1003.5 ⁋ 2
court schools. The facility administrator, in
conjunction with education staff, must ensure that
operational procedures do not interfere with the time ☒
☐ ☐
afforded for the minimum instructional day.
Absences, time out of class or educational
instruction, both excused and unexcused, shall be
documented.
(7) Education shall be provided to all youth
regardless of classification, housing, security status, 1003.4 (a)
disciplinary or separation status, including room 1003.4 (g)(1)
confinement, except when providing education 1003.8
☒
poses an immediate threat to the safety of self or ☐ ☐
others. Education includes, but is not limited to,
related services as provided in a youth’s Section 504
Plan or Individualized Education Program (IEP).
(c) School Discipline
1003.7 ⁋ 1
(1) Positive behavior management will be
implemented to reduce the need for disciplinary ☒
☐ ☐
action in the school setting and be integrated into the
facility's overall behavioral management plan and
security system.
(2) School staff shall be advised of administrative
decisions made by probation staff that may affect the ☒ 1003.7 ⁋ 2
☐ ☐
educational programming of students.
(3) Except as otherwise provided by the State
Education Code, expulsion/suspension from school 1003.7 ⁋ 3
shall be imposed only when other means of
correction fails to bring about proper conduct.
School staff shall follow the appropriate due process
safeguards as set forth in the State Education Code ☒
☐ ☐
including the rights of students with special needs.
School staff shall document the other means of
correction used prior to imposing expulsion/
suspension if an expulsion/suspension is ultimately
imposed.
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(4) The facility administrator, in conjunction with
education staff will develop policies and procedures 1003.4 (g)
☒
that address the rights of any student who has ☐ ☐
continuing difficulty completing a school day.
(d) Provisions for Special Populations
(1) State and federal laws and regulations shall be 1003.3 ⁋ 2
observed for all individuals with disabilities or 1003.4 (a)
suspected disabilities. This includes but is not limited ☒
☐ ☐
to child find, assessment, continuum of alternative
placements, manifestation determination reviews,
and implementation of Section 504 Plans and
Individualized Education Programs.
(2) Youth identified as English Learners (EL) shall be
afforded an educational program that addresses their 1003.4 (m)
☒
language needs pursuant to all applicable state and ☐ ☐
federal laws and regulations governing programs for
EL students.
(e) Educational Screening and Admission
(1) Youth shall be interviewed after admittance and a 1003.4 (c)(1)
record maintained that documents a youth's ☒ 1003.4 (h)
educational history, including but not limited to: ☐ ☐ 1003.4.1
(A) School progress/school history;
☒ 1003.4.1
☐ ☐
(B) Home Language Survey and the results of the
State Test used for English language proficiency; ☒ 509.9.2
☐ ☐
(C) Needs and services of special populations as
defined by the State Education Code, including but ☒ 701.4 (f)
☐ ☐
not limited to, students with special needs. 1003.4 (e)
(D) Discipline problems.
☒
☐ ☐ 1003.7
(2) Youth will be immediately enrolled in school.
Educational staff shall conduct an assessment to 1003.4 (c)
☒
determine the youth's general academic functioning ☐ ☐ 1003.4.1 ⁋ 1
levels to enable placement in core curriculum
courses.
(3) After admission to the facility, a preliminary
☒
education plan shall be developed for each youth ☐ ☐ 1003.4.1 ⁋ 1
within five school days.
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(4) Upon enrollment, education staff shall comply with
the State Education Code and request the youth's 1003.4.1
records from his/her prior school(s), including, but not
limited to, transcripts, Individual Education Program
(IEP), 504 Plan, state language assessment scores, ☒
☐ ☐
immunization records, exit grades, and partial credits.
Upon receipt of the transcripts, the youth's
educational plan shall be reviewed with the youth and
modified as needed. Youth should be informed of the
credits they need to graduate.
(f) Educational Reporting
(1) The complete facility educational record of the 1003.4 (i)
☒
youth shall be forwarded to the next educational ☐ ☐
placement in accordance with the State Education
Code.
(2) The County Superintendent of Schools shall
provide appropriate credit (full or partial) for course ☒ 1003.4 (i)
☐ ☐
work completed while in juvenile court school in
accordance with the State Education Code.
(g) Transition and Re-Entry Planning
(1) The Superintendent of Schools and the Chief 1003.4 (n)
Probation Officer or designee, shall develop policies
and procedures to meet the transition needs of youth, ☒
☐ ☐
including the development of an education transition
plan, in accordance with the State Education Code
and in alignment with Title 15, Minimum Standards for
Juvenile Facilities, Section 1355.
(h) Post-Secondary Education Opportunities
(1) The school and facility administrator should, 1003.6
whenever possible, collaborate with local post-
secondary education providers to facilitate access to
educational and vocational opportunities for youth that
We noted the VCPAJF Administration made
considers the use of technology to implement these
the decision to defer summer online college
programs.
to facilitate their own college readiness
program. They found youth were unprepared
☒ to understand the responsibilities for
☐ ☐
independent learning and felt a program to
facilitate independent thought, to be
responsive to the curriculums, and to be able
to seek assistance from educational staff not
in the classroom were important for the
young population that was not ready for
‘college’ learning.
1371 PROGRAMS, RECREATION, AND
EXERCISE. 1002 Programs, Recreation and Exercise
1002.2
The facility administrator shall develop and implement
written policies and procedures for programs,
☒
☐ ☐
recreation, and exercise for all youth. The intent is to
minimize the amount of time youth are in their rooms or
their bed area.
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Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three 1002.3 ⁋ 1
hours a day during the week and five hours a day each
☒
Saturday, Sunday or other non-school days, of which ☐ ☐
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding 1002.3 ⁋ 2
by the administrator/manager or designee that a youth ☒ ☐ ☐ 1002.7 ⁋ 4
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ 1002.3 ⁋ 3
☐ ☐
There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to 1000.3 (l)
ensure content offered is current, consistent, and
relevant to the population. A review of Programming at the Juvenile
Facility was completed on July 5, 2023, by
☒
☐ ☐ Chief Deputy Tim Dowler. The review
acknowledged program needs for male and
female youth, noting they would be age-
appropriate and targeted based on identified
needs in the Case Plan.
(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to 1002.6
include, but not be limited to, trauma focused, cognitive,
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
Programming includes responses to Victim
social interventions and activities designed to reduce
Awareness, substance abuse, conflict
recidivism. These programs should be based on the
resolution, anger management, parenting
youth’s individual needs as required by Sections 1355
skills, gender-specific programming, mental
and 1356. Such programs may be provided under the ☒
☐ ☐ health services, positive youth development,
direction of the Chief Probation Officer or the County
building effective decision-making skills, and
Office of Education and can be administered by county
other topics that suit the needs of the youth
partners such as mental health agencies, community
population.
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
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(1) Cognitive Behavior Interventions;
1000.2
(2) Management of Stress and Trauma;
1000.3
(3) Anger Management;
Available programs include: Healthy
(4) Conflict Resolution; Lifestyles - Women of Substance Men of
Honor (WOSMOH); Reins of HOPE (equine
(5) Juvenile Justice System;
therapy); Interactive Journaling; Ventura
(6) Trauma-related interventions; County Arts Council (art, guitar, poetry,
drumming, and mural painting); Therapy
(7) Victim Awareness; Dogs; Dating Matters; First 5 Parenting
Program; Brent’s Club; Smart Girls; Boys and
(8) Self-Improvement;
Girls Club Program*; Podcasting; ADPS
(9) Parenting Skills and support; Tablets; STEPS-Y; Word on the Street; City
Impact; Forever Found (CSEC youth);
(10) Tolerance and Diversity; Passport to Manhood; ARISE; Operation
Peace Works; Gender Specific Services; and
(11) Healing Informed Approaches;
Music N Society.
(12) Interventions by Credible Messengers;
Ventura County Behavior Health provides the
(13) Gender Specific Programming;
following: Dialectical Behavior Therapy
(DBT); Drug and Alcohol Programs
(14) Art, creative writing, or self-expression;
☒
☐ ☐ (individual and group); Moral Recognition
(15) CPR and First Aid training; Therapy (MRT); Seeking Safety; Anger
Management and Conflict Resolution;
(16) Restorative Justice or Civic Engagement;
Individual and Group Therapy; Co-Parent
Counseling; and Sex Offender Treatment.
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population. Educational Programs include: Paxton
Patterson (Construction trades program);
Providence Scholars Program (online
college); College Success; Literacy Tutors;
Money Matters; and AutoTech.
Re-Entry Services include: First Aid/CPR;
Alpha Leadership; Forever Found Case
Management; Second Chance Re-entry
Services; Reducing Risks for Girls; Harm to
Healing Restorative Justice; and Court
Appointed Special Advocates.
*These programs are not occurring currently
due to the facilitators not being available.
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(b) Recreation. All youth shall be provided the
opportunity for at least one hour of daily access to 1002.5
unscheduled activities such as leisure reading, letter
writing, and entertainment. Activities shall be supervised
and include orientation and may include coaching of ☒
☐ ☐ Recreation Programs include Library Carts;
youth.
Organized Games; Special Events; and the
Boys and Girls Club Rec Center.
(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity 1002.4
each day.
☒
☐ ☐ Exercise other than that facilitated by staff
include Futsal, Basketball, Boys and Girls
Club Gym, and Special Events.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and 1002.7 ⁋ 3
programs. The administrator/manager shall document ☒
☐ ☐
the reasons why suspension of recreation and programs
occurs.
1372 RELIGIOUS PROGRAM
1007 Religious Programs
The facility administrator shall provide access to
1007.3 ⁋ 2
religious services and/or religious counseling at least
1007.3.1
once each week. Attendance shall be voluntary. A youth
shall be allowed to participate in an activity outside of
their room if he/she elects not to participate in religious ☒
☐ ☐
programs. The agency has religious providers in each
unit one day per week. Youth have the
Religious programs shall provide for: opportunity to meet with them or request a
contact anytime.
(a) opportunity for religious services and practices; ☒ 1007.3.1
☐ ☐
(b) availability of clergy; and, ☒ 1007.12
☐ ☐
(c) availability of religious diets. ☒ 1007.5
☐ ☐
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1373 WORK PROGRAM
1005 Youth Work Program
The facility administrator shall develop policies and
procedures regarding the fair and consistent
assignment of youth to work programs. Work assigned ☒
☐ ☐
to a youth shall be meaningful, constructive and related
to vocational training or increasing a youth's sense of
responsibility. Work programs shall not be imposed as a
disciplinary measure
1374 VISITING
1008 Youth Visitation
The facility administrator shall develop and implement
1008.3.2
written policies and procedures for visiting, that include
provisions for special visits. Youth shall be allowed to
receive visits by parents, guardians or persons standing
in loco parentis, and children of youth. Other family At the time of the inspection, youth are able
members, such as grandparents and siblings, and to have 2 visits per week, for an hour each
supportive adults, may be allowed to visit with the visit, on Wednesdays and Sundays. Special
approval of the facility administrator or designee, and in visits occur on Sunday mornings.
☒
conjunction with the youth’s case plan or in the best ☐ ☐
interest of the youth.
In our group interview with SYTF youth, there
was a request for allowing more visiting
opportunities and for those visits to include
an enhanced list of visitors, including
girlfriends and family members outside of
immediate family allowable for special visits.
All visits shall occur at reasonable times, subject only to
the limitations necessary to maintain order and security. 1008.6 (f)
Visitation shall not be denied solely based on the 1008.6 Last Paragraph
visitor’s criminal history. The staff shall determine in 1008.5 Visitation Schedule
each case, whether the visitor’s criminal history ☒
☐ ☐
represents a risk to the safety of youth or staff in the
facility. Any denial of visitation or limitation on visitations
shall be communicated to the youth, person denied and
facility administrator.
Opportunity for visitation shall be a minimum of two
hours per week. Visits may be supervised, but ☒ 1008.3.2 ⁋ 2
conversations shall not be monitored unless there is a ☐ ☐
security or safety need.
Provisions for special visits, in addition to the two-hour
minimum and/or outside of the regular visiting hours, 1008.8
shall be accommodated as necessary and within the
discretion of the facility administrator or designee.
☒
Family therapy and professional visits shall be ☐ ☐
accommodated outside the provisions of this regulation.
Facilities may provide visitation opportunities outside of
normal visiting hours to accommodate special visits.
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The facility may provide access to technology as an
alternative, but not as a replacement, to in-person ☒ 1008.3.2 ⁋ 3
☐ ☐
visiting.
1375 CORRESPONDENCE
1001 Correspondence
The facility administrator shall develop and implement ☒
☐ ☐
written policies and procedures for correspondence
which provide that:
(a) there is no limitation on the volume of mail that youth
may send or receive; ☒ 1001.3 ⁋ 1
☐ ☐
(b) youth may send two letters per week postage free;
1001.8 (a)
☒
☐ ☐ Youth are able to send seven letters each
week, postage-free.
(c) youth may correspond confidentially with state and
federal courts, any member of the State Bar or holder of 1001.4 ⁋ 1
public office, and the Board; however, authorized facility ☒
☐ ☐
staff may open and inspect such mail only to search for
contraband and in the presence of the youth; and,
(d) incoming and outgoing mail, other than that
described in (c), may be read by staff only when there is ☒ 1001.6 ⁋ 2
reasonable cause to believe facility safety and security, ☐ ☐ 1001.6.1
public safety, or youth safety is jeopardized.
1376 TELEPHONE ACCESS
1006.2 Youth Telephone Policy
The administrator of each juvenile facility shall develop
and implement written policies and procedures to
☒
☐ ☐
provide youth with access to telephone
communications.
1377 ACCESS TO LEGAL SERVICES
602 Youth Access to Courts and Counsel
The facility administrator shall develop written
procedures to ensure the right of youth to have access
☒
☐ ☐
to the courts and legal services. Such access shall
include:
(a) access, upon request by the youth, to licensed
attorneys and their authorized representatives; ☒ 602.3 (a)
☐ ☐
(b) provision for confidential consultation with attorneys;
and, ☒ 602.3 (b)
☐ ☐
(c) unlimited postage free, legal correspondence and
cost-free telephone access as appropriate. ☒ 602.3 (c)
☐ ☐
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1390 DISCIPLINE
600 Youth Discipline
The facility administrator shall develop and implement
600.3.1 Rules and Sanctions
written policies and procedures for the discipline of
600.6 Bullet 14
youth that shall promote acceptable behavior; including
1009.3 Behavior Modification Plan
the use of positive behavior interventions and supports. ☒
☐ ☐
Discipline shall be imposed at the least restrictive level
which promotes the desired behavior and shall not
include corporal punishment, group punishment,
physical or psychological degradation. Deprivation of
the following is not permitted:
(a) bed and bedding; ☒ 600.6 Bullet 13 and 14
☐ ☐
(b) daily shower, access to drinking fountain, toilet and
☒ 600.6 Bullet 7
personal hygiene items, and clean clothing; ☐ ☐
(c) full nutrition; ☒ 600.6 Bullet 4
☐ ☐
(d) contact with parent or attorney; ☒ 600.6 Bullet 16 and 19
☐ ☐
(e) exercise; ☒ 600.6 Bullet 11
☐ ☐
(f) medical services and counseling; ☒ 600.6 Bullet 15 and 20
☐ ☐
(g) religious services; ☒ 600.6 Bullet 20
☐ ☐
(h) clean and sanitary living conditions; ☒ 600.6 Bullet 14
☐ ☐
(i) the right to send and receive mail; ☒ 600.6 Bullet 18
☐ ☐
(j) education; and, ☒ 600.6 Bullet 20
☐ ☐
(k) rehabilitative programming. ☒ 600.6 Bullet 20
☐ ☐
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The facility administrator shall establish rules of conduct
and disciplinary penalties to guide the conduct of youth. 600.4 Minor Rules
Such rules and penalties shall include both major 600.5 Major Rules
violations and minor violations, be stated simply and 600.7 Sanctions
☒
affirmatively, and be made available to all youth. ☐ ☐ 1009 Behavior Management Program
Provision shall be made to provide accessible
information to youth with disabilities, limited English
proficiency, or limited literacy.
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1391 DISCIPLINE PROCESS
600.3 Discipline Process
The facility administrator shall develop and implement
written policies and procedures for the administration of
The agency uses two separate forms for
discipline which shall include, but not be limited to:
Disciplinary Due Process. First, the Notice of
Discipline includes a summary of the incident
and proposed sanction. The second form is
the Hearing Form, currently used for every
due process incident. The form allows the
youth to write their version of the incident and
to list any witnesses. There is also an area to
list the staff who assisted with the form or a
box to check if no one was requested to help
the youth.
Prior to the discipline hearing, the assigned
Hearing Officer reviews video of the incident
and all reports. Once a finding is made, the
youth is notified and is offered an opportunity
to appeal. Appeal forms are available in
every living unit.
We provided technical assistance to include
the opportunity to allow the youth to either
☒
☐ ☐ request a hearing or indicate they do not
want a hearing if they agree to the Notice and
Proposed Sanction. If the minor agrees and
does not want a hearing, then the process is
complete. They would then have the youth
sign the form acknowledging no further
action is requested. If the youth wants the
hearing, then the existing process is fine.
Our guidance is to simplify and shorten the
operational responsibilities of staff.
We reviewed 22 of the 133 Due Process
incidents for 2021, including the Incident
Report and subsequent documentation. The
form prompts staff to follow the process and
the documentation was clear. Of the
incidents reviewed, 9 filed an appeal to the
facility manager.
The process for each incident started the
same day as initiated and was resolved that
day. We found the policy and process
exceeds regulation.
(a) designation of personnel authorized to impose
discipline for violation of rules; ☒ 600.3 (a)
☐ ☐
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(b) prohibiting discipline to be delegated to any youth;
☒ 600.6 Bullet 1
☐ ☐
(c) definition of major and minor rule violations and their
consequences, and due process requirements; 600.4
☒
☐ ☐ 600.5
(d) trauma-informed approaches and positive behavior
interventions; ☒ 600.3.1 ⁋ 2
☐ ☐
(e) minor rule violations may be handled informally by
counseling, advising the youth of expected conduct 600.4 Minor Rules
imposing a minor consequence. Discipline shall be ☒ 600.8 Documentation
☐ ☐
accompanied by written documentation and a policy of
review and appeal to a supervisor; and,
(f) major rule violations and the discipline process shall
be documented and require the following: ☒ 600.5
☐ ☐
(1) written notice of violation prior to a hearing; ☒ 600.5.3
☐ ☐
(2) accommodations provided to youth with
disabilities, limited literacy, and English language ☒ 600.5.7
☐ ☐
learners;
(3) hearing by a person who is not a party to the
☒ 600.5.4 ⁋ 2
incident; ☐ ☐
(4) opportunity for the youth to be heard, present
☒ 600.5.5
evidence and testimony; ☐ ☐
(5) provision for youth to be assisted by staff in the
☒ 600.5.3
hearing process; ☐ ☐
(6) provision for administrative review. ☒ 600.5.10
☐ ☐
(g) violations that result in a removal from camp or
commitment program, but not a return to court, will 600.7.1
☒
follow the due process provisions in subsection (e) ☐ ☐
above.
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1410 MANAGEMENT OF COMMUNICABLE
DISEASES.
VCPA: Policy 705 Communicable Disease
The health administrator/responsible physician, in Policy, Youth
cooperation with the facility administrator and the local
health officer, shall develop written policies and ☒ ☐ ☐ Policy 705.3 Procedure
procedures to address the identification, treatment,
Policy 1203 Communicable Disease Policy,
control and follow-up management of communicable
Members (Staff)
diseases. The policies and procedures shall address,
but not be limited to:
VCPA: Policy 705.3 (c) Procedure
Coronavirus (COVID-19) PRE-BOOKING
(a) Intake health screening procedures; ☒ ☐ ☐ PROCEDURES
Intake and Medical Isolation Procedures
(b) Identification of relevant symptoms; ☒
☐ ☐ Intake and Medical Isolation Procedures
Coronavirus (COVID-19) PRE-BOOKING
(c) Referral for medical evaluation; ☒
☐ ☐ PROCEDURES
VCPA Policy 705.3 (d) Compliance with all
relevant laws and regulations related to
communicable diseases.
VCPA Policy 705.4.3 Medical Consultation,
(d) Treatment responsibilities during detention; ☒
☐ ☐ Evaluation and Treatment
VCPA: Youth Face Mask Protocol and
Expectations
(e) Coordination with public and private community-
☒ VCPA Policy 705.3 (d)(2)
based resources for follow-up treatment; ☐ ☐
VCPA Policy 705.4.2 Supervisor Response
(f) Applicable reporting requirements; and, ☒
☐ ☐ and Reporting Requirements
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VCPA Policy 703 (d)(3) Developing
(g) Strategies for handling disease outbreaks. ☒ strategies for handling communicable
☐ ☐
disease outbreaks.
The policies and procedures shall be updated as
necessary to reflect communicable disease priorities
The agency coordinates policies with local
identified by the local health officer and currently
Public Health and CDC directives in
recommended public health interventions.
☒
☐ ☐ response to the Coronavirus Pandemic.
These policies were updated in 2020.
1433 REQUESTS FOR HEALTH CARE SERVICES
(EXCERPT)
702.3 Youth Access to Health Care
The health administrator, in cooperation with the facility
administrator, shall develop policy and procedures to ☒ ☐ ☐ 702.3 (b) and (c) Unimpeded Access to
establish a daily routine for youth to convey requests for Health Care Services
emergency and non-emergency medical, dental and
behavioral/mental health care services.
1480 STANDARD FACILTY CLOTHING ISSUE
The youth’s personal clothing, undergarments and 802.6 Clothing Issue
footwear may be substituted for the institutional clothing ☒
and footwear specified in this regulation. The facility has ☐ ☐ 363.1 Clothing Exchange
the primary responsibility to provide clothing and
footwear. Clothing provisions shall ensure that:
(a) Clothing is clean, reasonably fitted, durable, easily
laundered, in good repair, and free of holes and tears.
☒ 802.6 Paragraph 1
☐ ☐
(b) The standard issue of climatically suitable clothing
for youth shall consist of but not be limited to:
☒
☐ ☐
(1) Socks and serviceable footwear; ☒ 802.6 Paragraph 2 Bullet 1 and 4
☐ ☐
(2) Outer garments; ☒ 802.6 Paragraph 2 Bullet 2
☐ ☐
(3) New non-disposable underwear which shall
remain with the youth throughout their stay, and;
☒ 802.6 Paragraph 2 Bullet 3 and 5
☐ ☐
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(4) Undergarments, that are freshly laundered and
free of stains, including tee shirts and bras.
☒ 802.6 Paragraph 2 Bullet 3
☐ ☐
(c) Clothing is laundered at the temperature required by
local ordinances for the commercial laundries and dried
☒
802.7
completely in a mechanical dryer or other laundry ☐ ☐
method approved by the local health officer.
(d) Suitable clothing is issued to pregnant youth.
☒ 802.6 Paragraph 2 Bullet 6
☐ ☐
1482 CLOTHING EXCHANGE
The facility administrator shall develop and implement 802.6 Paragraph 1, 4, 5, and 6
written policies and site-specific procedures for the
cleaning and scheduled exchange of clothing. Unless
work, climatic conditions, or illness necessitates more
☒
☐ ☐
frequent exchange, outer garments, except for footwear,
shall be exchanged at least once each week. Tee shirts,
bras, and underwear shall be exchanged daily; youth
shall receive their own underwear back at exchange.
1484 CONTROL OF VERMIN IN YOUTH’S
PERSONAL CLOTHING
Procedure 321
There shall be written policies and site-specific
procedures developed and implemented by the facility FPO.07.B, 1
administrator to control the contamination and/or spread
☒
☐ ☐
of vermin and ecto-parasites in all youth’s personal
clothing. Infested clothing shall be cleaned or stored in
a closed container so as to eradicate or stop the spread
of the vermin.
1485 ISSUE OF PERSONAL CARE ITEMS
There shall be written policies and site-specific 802.8 Personal Hygiene of Youth
procedures developed and implemented by the facility
administrator for the availability of personal hygiene ☒ Procedure 362 Personal Hygiene
☐ ☐
items. Each female youth shall be provided with sanitary
FPO.09.E, 1
napkins, panty liners and tampons as requested. Each
youth to be held over 24 hours shall be provided with the
following personal care items;
(a) Toothbrush; ☒ 802.8 Paragraph 2 Bullet 4
☐ ☐
Procedure 362.1 (f)
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802.8 Paragraph 2 Bullet 3
(b) Toothpaste; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 1
(c) Soap; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 2
(d) Comb; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 5
(e) Shaving implements; ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 8
(f) Deodorant; ☒
☐ ☐
Procedure 362.1 (f)
(g) Lotion; ☒ 802.8 Paragraph 2 Bullet 9
☐ ☐
802.8 Paragraph 2 Bullet 10
(h) Shampoo; and, ☒
☐ ☐
Procedure 362.1 (f)
802.8 Paragraph 2 Bullet 11
(i) Post-shower conditioning hair products. ☒
☐ ☐
Procedure 362.1 (f)
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Youth shall not be required to share any personal care
items listed in items (a) through (d). Liquid soap
provided through a common dispenser is permitted.
Youth shall not share disposable razors. Double edged
802.8 Paragraph 4
safety razors, electric razors, and other shaving
☒
instruments capable of breaking the skin, when shared ☐ ☐ 604.4 Shaving
among youth, shall be disinfected between individual
uses by the method prescribed by the State Board of
Barbering and Cosmetology in Sections 979 and 980,
Chapter 9, Title 16, California Code of Regulations.
1486 PERSONAL HYGIENE
There shall be written policies and site specific Procedure 362.1 (a) and (i)
procedures developed and implemented by the facility
administrator for showering/bathing and brushing of ☒
☐ ☐
teeth. Youth shall be permitted to shower/bathe up on
assignment to a housing unit and on a daily basis
thereafter and given an opportunity to brush their teeth
after each meal.
1487 SHAVING
Youth shall have access to a razor daily, unless their 604.4 Shaving
appearance must be maintained for reasons of
identification in Court. All youth shall have equal ☒
☐ ☐
opportunity to shave face and body hair. The facility
administrator may suspend this requirement in relation
to youth who are considered to be a danger to
themselves or others.
1488 HAIR CARE SERVICES (EXCERPT)
Hair care services shall be available in all juvenile 604.3 Haircuts
facilities. Youth shall receive hair care services monthly. ☒
☐ ☐
Equipment shall be cleaned and disinfected after each
haircut or procedure, by a method approved by the State
Board of Barbering and Cosmetology.
1500 STANDARD BEDDING AND LINEN ISSUE
Clean laundered, suitable bedding and linens, in good 802.5 Bedding Issue
repair, shall be provided for each youth entering a living
☒
☐ ☐
area who is expected to remain overnight, shall include,
but not be limited to:
(a) One mattress or mattress-pillow combination which
meets the requirements of Section 1502 of these
☒ 802.5 (b)
regulations; ☐ ☐
(b) One pillow and a pillow case unless provided for in
(a) above;
☒ 802.5 (e)
☐ ☐
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(c) One mattress cover and a sheet or two sheets; ☒ 802.5 (c)
☐ ☐
(d) One towel; and, ☒ 802.5 (d)
☐ ☐
(e) One blanket or more, up on request ☒ 802.5 (a)
☐ ☐
1501 BEDDING LINEN EXCHANGE
The facility administrator shall develop and implement 802.5 Paragraph 2
site specific written policies and procedures for the
scheduled exchange of laundered bedding and linen ☒
☐ ☐
issued to each youth housed. Washable items such as
sheets, mattress covers, pillow cases and towels shall
be exchanged for clean replacement at least once each
week.
The covering blanket shall be cleaned or laundered
once a month.
☒ 802.5 (a)2
☐ ☐
1510 FACILITY SANITATION, SAFETY AND
MAINTENANCE
800 Housekeeping and Maintenance
The facility administrator shall develop and implement
written policies and site-specific procedures for the Procedure 317
maintenance of an acceptable level of cleanliness,
FPO.06.M, 1 Facility Sanitation, Safety and
repair and safety throughout the facility. The plan shall
Maintenance
provide for a regular schedule of housekeeping tasks, ☒
☐ ☐
equipment, including restraint devices, and physical
plant maintenance and inspections to identify and
correct unsanitary or unsafe conditions or work
practices in a timely manner. The use of chemicals shall
be done in accordance to the product label and Safety
Data Sheet which may include the use of Personal
Protection Equipment (PPE).
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REVIEW OF NON REGULATORY REQUIREMENTS
GRANT FUNDING OR CODE REFERENCE YES NO N/A P/P REFERENCE - COMMENTS
JUVENILE PROBATION AND CAMPS FUNDING (JPCF) (Camps Only)
The programs/services identified on the JPCF Camp
Eligibility Form are being provided at the facility.
☐ ☐ ☒
(Refer to the JPCF Camp Eligibility Form)
208.5 WIC CONTACT BETWEEN PERSONS UNDER THE JUVENILE COURT AGES 19- 20 AND MINORS IN THE
FACILITY
The facility houses Juvenile Court Wards 19 years of
age and older. ☒ ☐ ☐
The facility has been approved to hold persons under
the juvenile court who are ages 19 through 21. ☒ ☐ ☐
The facility continues to comply with the requirements
of 208.5 WIC (programming, capacity and security of
☒ ☐ ☐
the facility) as outlined in the county’s application.
JUVENILE JUSTICE DELINQUENCY PREVENTION ACT MONITORING (JJDPA)
WIC 206 SEPARATE FACILITIES FOR WIC 300
MINORS
☐
☐
Dependent or neglected minors who are defined under Viola ☒
Section 300 of the Welfare and Institutions Code (WIC) tion
are held only in non-secure, separate and segregated
facilities.
DETENTION OF STATUS OFFENDERS (WIC 601)
AND FEDERAL MINORS
☐ ☒ ☐
Status Offenders (WIC 601) are held in the facility.
Status Offenders (WIC 601) are kept separate from
☐
Juvenile Delinquents (WIC 602)? (WIC 207[d]). ☐ ☒
Viola
tion
Federal Minors (ICE Holds or ORR Contract) are held
in the facility. ☐ ☒ ☐
If yes to the above, the Monthly Report on the
Detention of Status Offenders/Federal Minors is
☐ ☐ ☒
submitted to the BSCC.
WIC 208 SEPARATION OF MINORS AND ADULT
INMATES (JJDPA 42 USC 5633, Sec 223,
State Plans (a)[12])
Are adult inmates held in the facility? (When a person ☐ ☒ ☐
in detention is proceeding through the adult court,
AND that person is 18 years of age or older that
person is an adult inmate.)
7741 Ventura JF SYTF Commitment PRO 23-24 Page 73 of 74 A453 JUV PRO eff. 1/2019 (23-24).dot
If adult inmates are held, they are appropriately
☐ ☒
separated from minors. ☐
Viola
tion
Adult inmates from an adult facility (e.g. inmate
☐
workers or “Scared Straight” programs) are not ☐ ☒
allowed in the facility in a manner that allows contact Viola
with minors. tion
7741 Ventura JF SYTF Commitment PRO 23-24 Page 74 of 74 A453 JUV PRO eff. 1/2019 (23-24).dot
JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
PHYSICAL PLANT EVALUATION
Board of State and Community Corrections
APPLICABLE TITLE 24 REGULATIONS: 4/98; 2001; 2003; 2009; 2014; 2018
BSCC Code: 7727 7728 7740 7741
FACILITY NAME: Ventura County Detention Facility (7727); Ventura County FACILITY TYPE: JH/Camp/SYTF
Commitment Facility (7728); Ventura County SYTF Detention (7740); Ventura County
SYTF Commitment (7741)
4/98: 2001: 2003: 2009: 2014: 2018:
APPLICABLE REGULATIONS (Check All That
XXX
Apply):
FIELD REPRESENTATIVE: Elizabeth Gong DATE: July 10, 2023 – July 13,
2023
TITLE 24 SECTION YES NO N/A COMMENTS
1230.1.1 Reception/intake admission.
In each juvenile hall, space used for the reception of
youth pending admission to juvenile hall shall have the
following space and equipment:
1. Weapons lockers as specified in Section 1230.2.9;
There are four weapons locker areas in the
facilities: two at the staff entrance, one at the
☒
☐ ☐ Court entrance, and one at the Public
entrance.
2. A secure room for the confinement of youth pending
admission to juvenile hall as specified in Section
1230.1.2;
In each juvenile hall, camp and ranch, space used ☒
☐ ☐
for the reception of youth pending admission to these
facilities shall have the following space and
equipment:
3. Access to a shower; ☒
☐ ☐
4. A secure vault or storage space for youth, valuables;
The facilities have a small safe in the staff
☒
☐ ☐ station and a larger safe in property storage.
5. Telephone accessible to youth; and ☒
☐ ☐
6. Access to hot and cold running water for staff use. ☒
☐ ☐
1230.1.2 Locked holding room.
☒ All Holding Rooms are wet rooms.
☐ ☐
A locked holding room shall:
1. Contain a minimum of 15 square feet of floor area
☒
per youth; ☐ ☐
2. Provide no less than 45 square feet of floor space
☒
and have a clear ceiling height of 8 feet or more; ☐ ☐
3. Contain seating to accommodate all youth as
☒
specified in Section 1230.2.8; ☐ ☐
4. Be equipped with a toilet, wash basin, mirror and
drinking fountain unless as specified in Section
1230.2, unless a procedure is in effect to give the ☒
☐ ☐
youth access to a toilet, wash basin and drinking
fountain;
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TITLE 24 SECTION YES NO N/A COMMENTS
5. Maximize visual supervision of youth by staff; and ☒
☐ ☐
6. Have an outward swinging or lateral sliding door. ☒
☐ ☐
1230.1.3 Natural light.
Outer-facing exterior windows where youth’s privacy is
not at risk shall be provided in locked sleeping rooms,
single occupancy sleeping rooms, double occupancy ☒
sleeping rooms, dormitories and dayrooms. Natural ☐ ☐
light may be provided by, but is not limited to, skylights
or windows in dayrooms, windows in adjacent exterior
exercise areas, and in sleeping rooms and/or
dormitories.
1230.1.4 Corridors
☒
Corridors in living areas shall be at least eight feet ☐ ☐
wide.
1230.1.5 Living unit.
A living unit shall be a self-contained unit containing
locked sleeping rooms, single and double occupancy ☒
☐ ☐
sleeping rooms, or dormitories, dayroom space, toilet,
wash basins, drinking fountains and showers
commensurate to the number of youth housed.
A living unit shall not be divided in a way that hinders
direct access, supervision, immediate intervention or
☒
other action if needed. In juvenile halls, the number of ☐ ☐
youth housed in a living unit shall not exceed 30.
1230.1.6 Locked sleeping rooms.
Locked sleeping rooms shall be equipped with an ☒
☐ ☐
individual or combination toilet, wash basin, mirror and
drinking fountain.
Doors to locked sleeping rooms shall swing outward or
☒
slide laterally. ☐ ☐
1230.1.7 Single occupancy sleeping rooms.
Single occupancy sleeping rooms shall provide the ☒
☐ ☐
following:
1. A minimum of 70 square feet of floor area;
2. A minimum ceiling height of eight feet; and, ☒
☐ ☐
3. The door into this room shall swing outward or
slide laterally and be provided with a view panel, a
☒
minimum of 144 square inches, constructed of security ☐ ☐
glazing.
4. Contain a bed as specified in 1230.2.5. ☒
☐ ☐
1230.1.8 Double occupancy sleeping rooms.
Double occupancy sleeping rooms shall provide the ☒
☐ ☐
following:
1. A minimum of 100 square feet of floor area;
2. A minimum clear ceiling height of 8 feet and a
☒
minimum width of 7 feet; and, ☐ ☐
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TITLE 24 SECTION YES NO N/A COMMENTS
3. The door into this room shall swing outward or
slide laterally and be provided with a view panel, a
☒
minimum of 144 square inches, constructed of security ☐ ☐
glazing.
4. Contain a bed as specified in 1230.2.5. ☒
☐ ☐
1230.1.9 Dormitories
The agency has dorms in the Commitment
Dormitories shall provide the following: housing buildings; however, they have not
1. A minimum of 50 square feet of floor area per ☐ ☒ been occupied since 2019. The buildings: Ana
youth with the minimum size of a dormitory being ☐ Capa, Santa Rosa, and Santa Cruz, are being
200 square feet of floor area and a minimum 8- used for alternative purposes due to low
foot clear ceiling height; population and staffing.
2. Designed for no fewer than four youth; ☐ ☒
☐
3. Dormitories in juvenile halls shall be designed for
☐ ☒
no more than 30 youth; ☐
4. Camps shall conform to Items 1 and 2. ☐ ☒
☐
1230.1.10 Dayrooms
Dayrooms shall contain 35 square feet of floor area per ☒
youth, contain tables and seating to accommodate the ☐ ☐
maximum numbers of youth allowed access at a given
time.
Access must be provided to toilets, wash basins,
drinking fountains and showers as specified in Section ☒
☐ ☐
1230.2.
1230.1.11 Physical activity and recreation areas.
Each unit has a paved outside space as well
Indoor/outdoor physical activity and recreation areas as a multipurpose indoor area.
shall be designed as follows:
1. Minimum indoor outdoor recreation space for ☒
facility capacity: 40 or less is 9,000 square feet; ☐ ☐
41-274 is 225 square feet per youth up to 61,650
square feet; 275 or more is 61,650 square feet,
plus 145 square feet for each youth beyond 274
[up to a maximum of 87,120 square feet]
1.1 At least one quarter of the dedicated
indoor/outdoor space shall be a paved or like ☒
☐ ☐
surface.
1.2 The required recreation area shall contain no
single dimension less than 40 feet. Each unit has small outdoor recreation areas
☒ that are not included in the total recreation
☐ ☐
area requirements due to size limits.
2. A portion of the dedicated space for physical
activity and recreation shall be out-of-doors and be
sufficient size and equipped in such a manner to allow
☒
compliance with Title 15, Section 1371, which requires ☐ ☐
at least one hour per day of outdoor activity for each
detained youth.
3. Lighting of outdoor recreation areas shall be
provided to allow for evening activities and to provide ☒
☐ ☐
security.
4. Access must be provided to a toilet, wash basin
☒
and drinking fountain as specified in Section 1230.2. ☐ ☐
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TITLE 24 SECTION YES NO N/A COMMENTS
1230.1.12 Academic classrooms.
☒
There shall be a dedicated classroom space for every ☐ ☐
juvenile in every facility.
The primary purpose for the academic classroom shall
☒
be for education. ☐ ☐
Each academic classroom shall contain a minimum of
160 square feet of floor space for the teacher’s desk
☒
and work area and a minimum of 28 square feet of ☐ ☐
floor space per minor.
A communication system shall be provided in each
classroom to allow for immediate response to ☒
☐ ☐
emergencies.
The classroom shall be designed for a maximum of 20
☒
minors. ☐ ☐
There shall be space available in every juvenile facility
that may be used for specialized, one-on-one or small ☒
☐ ☐
group educational purposes.
1230.1.13 Safety room.
A safety room shall: ☒
☐ ☐
1. Contain a minimum of 48 square feet of floor area
and a minimum clear ceiling height of 8 feet;
2. Be limited to one youth; ☒
☐ ☐
3. Be padded as specified in Section 1230.2.7; ☒
☐ ☐
4. Provide one or more vertical view panels
constructed of security glazing. These view panels
shall be no more than 4 inches wide nor less than 24 ☒
☐ ☐
inches long, which shall provide a view of the entire
room;
5. Provide an audio monitoring system as specified
☒
in Section 1230.1.22; ☐ ☐
6. Contain a flushing ring toilet, capable of accepting
solid waste, mounted flush with the floor, the controls ☒
☐ ☐
for which must be located outside of the room;
7. Be equipped with a variable intensity, security-
type lighting fixture with controls located outside the ☒
☐ ☐
room;
8. Any wall or ceiling-mounted devices must be
designed to prohibit access to the youth occupant; ☒
☐ ☐
and,
9. Provide a food pass with lockable shutter, no more
than 4 inches high, and located between 26 inches
☒
and 32 inches as measured from the bottom of the ☐ ☐
food pass to the floor.
1230.1.14 Medical examination room.
The facilities’ medical area is large and
There must be a minimum of one suitably equipped exceeds minimum standard as there are two
☒
medical examination room in every juvenile facility. ☐ ☐ rooms for medical exams/procedures and one
room for dental services.
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TITLE 24 SECTION YES NO N/A COMMENTS
Medical examination rooms shall provide the following:
1. Space for carrying out routine medical ☒
☐ ☐
examinations and emergency care and used for no
other purpose;
2. Privacy for youth; ☒
☐ ☐
3. Lockable storage space for medical supplies; ☒
☐ ☐
4. Not less than 144 square feet of floor space with
no single dimension less than 7 feet; ☒ The total floor space is 155 sq. feet.
☐ ☐
5. Hot and cold running water; ☒
☐ ☐
6. Smooth, nonporous, washable surface; ☒
☐ ☐
7. A medical exam table; and, ☒
☐ ☐
8. Adequate lighting. ☒
☐ ☐
1230.1.15 Pharmaceutical storage.
Provide lockable storage space for medical supplies ☒
☐ ☐
and pharmaceutical preparations as specified by Title
15, Section 1438.
1230.1.16 Dining areas.
There are permanent tables in each dayroom
Dining areas in juvenile facilities shall contain a ☒ space for consuming meals.
☐ ☐
minimum of 15 square feet of floor space and sufficient
tables and seating for each person being fed.
Persons being fed include youth, staff and visitors. ☒
☐ ☐
Dining areas shall not contain toilets or showers in the
☒
same room without appropriate visual barrier. ☐ ☐
1230.1.17 Visiting space.
Space shall be provided in all juvenile facilities for in- ☒
☐ ☐
person visiting which shall be unobstructed by barriers
such as, but not limited to, security glazing for mesh.
1230.1.18 Institutional storage.
One or more storage rooms shall be provided to ☒
☐ ☐
accommodate a minimum of 80 cubic feet of storage
space per minor.
Items to be stored shall be institutional clothing,
☒
bedding, supplies and activity equipment. ☐ ☐
1230.1.19 Personal storage.
Each youth in a juvenile facility shall be provided with ☒
☐ ☐
a minimum of 9 cubic feet of secure storage space for
personal clothing and belongings.
1230.1.20 Safety equipment storage.
In all juvenile facilities, a secure area shall be provided ☒
for the storage of safety equipment, such as fire ☐ ☐
extinguishers, self-contained breathing apparatus,
wire and bar cutters, emergency lights, etc.
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TITLE 24 SECTION YES NO N/A COMMENTS
1230.1.21 Janitorial closet.
In all juvenile facilities, at least one securely lockable ☒
janitorial closet, containing a mop sink and sufficient ☐ ☐
area for the storage of cleaning implements, must be
provided within a security area of the facility.
1230.1.22 Audio monitoring system.
In safety rooms, locked holding rooms, locked
sleeping rooms, single and double occupancy rooms ☒
☐ ☐
and dormitories, there must be an audio monitoring
system capable of actuation by the minor that alerts
personnel.
1230.1.23 Emergency power.
The facilities have an Emergency power
There shall be a source of emergency power in all backup generator powered by gasoline which
juvenile facilities capable of providing minimal lighting ☒ can provide power up to three days and be
in all living units, activities areas, corridors, stairs and ☐ ☐ refilled as necessary.
central control points, and to maintain fire and life
safety, security, communications and alarm systems
(Title 24, Part 2, Chapter 27).
Such an emergency power source shall conform to the
requirements specified in Title, 24, Part 3, Article 700,
☒
California Electrical Code, California Code of ☐ ☐
Regulations.
1230.1.24 Confidential interview room.
☒
Confidential interview rooms shall contain a minimum ☐ ☐
of 60 square feet of floor area.
In juvenile halls there shall be a minimum of one
☒
suitably furnished interview room for each 30 youth. ☐ ☐
In camps there shall be a minimum of one suitably
☒
furnished interview room for each facility. ☐ ☐
This interview room shall provide for confidential
☒
consultations with youth. ☐ ☐
1230.1.25 Special-purpose juvenile halls.
Special-purpose juvenile halls shall conform to all ☐ ☒
☐
minimum standards for juvenile facilities contained in
this section with the following exceptions:
1. Physical activity and recreation areas as specified
☐ ☒
in Section 1230.1.11; ☐
2. Academic classrooms as specified in Section
☐ ☒
1230.1.12; ☐
3. Medical examination room as specified in Section
☐ ☒
1230.1.14; and, ☐
4. Dining areas as specified in Section 1230.1.16. ☐ ☒
☐
1230.1.26 Court holding room for youth.
A court holding room shall: ☒
☐ ☐
1. Contain a minimum of 10 square feet of floor area
per youth;
2. Be limited to no more than 16 youth; ☒
☐ ☐
3. Provide no less than 40 square feet of floor area
☒
and have a ceiling height of 8 feet or more; ☐ ☐
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TITLE 24 SECTION YES NO N/A COMMENTS
4. Contain seating to accommodate all youth as
☒
specified in Section 1230.2.8; ☐ ☐
5. Contain a toilet, wash basin and drinking fountain
☒
as specified in Section 1230.2; ☐ ☐
6. Maximize visual supervision of youth by staff; and,
Probation staff provide supervision of youth in
☒ the basement of the Court Building adjacent to
☐ ☐
the facility.
7. A mirror of material appropriate to the level of
security shall be provided as specified in Section ☒
☐ ☐
1230.2.11.
1230.1.27 Programs and activity areas.
All juvenile facilities shall include adequate space for ☒
☐ ☐
specific programs in addition to recreation and
exercise areas.
1230.2.1 Toilets/urinals.
All toilet areas shall provide privacy for the youth and ☒
☐ ☐
help reduce the risk of voyeurism without mitigating
staff’s ability to supervise.
Toilets must be available in a ratio to youth as follows:
☒
1. Juvenile halls 1:6; ☐ ☐
2. Camps 1:10; and ☒
☐ ☐
3. Locked holding rooms 1:8: ☒
☐ ☐
One toilet and one urinal may be substituted for every
☒
15 males. ☐ ☐
1230.2.2 Wash basins.
In living units, wash basins must be available in a ratio ☒
☐ ☐
to youth as follows:
1. Juvenile halls 1:6;
2. Camps 1:10; and ☒
☐ ☐
3. Locked holding rooms 1:8: ☒
☐ ☐
Wash basis must be provided with hot and cold or
☒
tempered water. ☐ ☐
1230.2.3 Drinking fountains.
In living areas and indoor and outdoor recreation ☒
☐ ☐
areas, drinking fountains must be accessible to youth
and to staff.
1. The drinking fountain bubbler shall be on an angle
which prevents waste water from flowing over the ☒
☐ ☐
drinking bubbler; and,
2. The water flow shall be actuated by a mechanical
☒
means. ☐ ☐
1230.2.4 Showers.
Shower areas shall provide privacy for the youth and ☒
☐ ☐
help reduce the risk of voyeurism without mitigating
staff’s ability to supervise.
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TITLE 24 SECTION YES NO N/A COMMENTS
Showers shall be available to all youth on a ratio of at
least one shower or bathtub to every six youth. ☒
☐ ☐
Showers shall be provided with tempered water.
1230.2.5 Beds.
☒
Beds shall be at least 30 inches wide and 76 inches ☐ ☐
long and be of the solid bottom type.
Beds shall be at least 12 inches off the floor and
☒
spaced no less than 36 inches apart ☐ ☐
Bunk beds must have no less than 33 inches vertically
☒
between the solid bottoms. ☐ ☐
In secure facilities, the bunks shall be securely
☒
anchored and flushed against the floor and/or wall. ☐ ☐
1230.2.6 Lighting.
Lighting in locked sleeping rooms, single occupancy ☒
rooms, double occupancy rooms, dormitories, day ☐ ☐
rooms and activity areas shall provide not less than 20
foot candles of illumination at desk level.
Night lighting is required in these areas to provide for
good visibility for supervision and be conducive to ☒
☐ ☐
sleep.
1230.2.7 Padding.
Padding in safety rooms, padding shall cover the ☒
☐ ☐
entire floor, door, walls and everything on walls to a
clear height of eight feet.
Benches or platforms are not to be placed on the floor
☒
of this room. ☐ ☐
All padded rooms must be equipped with a tamper
resistant fire sprinkler as approved by the State Fire ☒
☐ ☐
Marshal.
All padding must be:
☒
1. Approved for use by the State Fire Marshal; ☐ ☐
2. Nonporous to facilitate cleaning; ☒
☐ ☐
3. At least 112 inch thick; ☒
☐ ☐
4. Of a unitary or laminated construction to prevent
its destruction by teeth, hand tearing or small metal ☒
☐ ☐
objects;
5. Firmly bonded to all padded surfaces to prevent
☒
tearing or ripping; and, ☐ ☐
6. Without any exposed seams susceptible to tearing
☒
or ripping. ☐ ☐
1230.2.8 Seating.
☒
☐ ☐
Seating shall be designed for the level of security.
When bench seating is used, 18 inches of bench is
☒
seating for one person. ☐ ☐
1230.2.9 Weapons lockers.
There are four weapons locker areas in the
Weapons lockers are required in all secure juvenile ☒ facilities: two at the staff entrance, one at the
facilities and shall be located outside the secure area ☐ ☐ Court entrance, and one at the Public
of the facility. entrance.
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TITLE 24 SECTION YES NO N/A COMMENTS
Weapons lockers shall be equipped with individual
☒
compartments, each with an individual locking device. ☐ ☐
1230.2.10 Security glazing.
Security glazing shall comply with the minimum
requirements of one of the following test standards:
American Society for Testing and Materials, ASTM F ☒
☐ ☐
1233-98, Class III glass, or; California Department of
Corrections, CDC 860-94d, Class C glass or; H.P.
White Laboratory, Inc., HPW-TP-0500.02, Forced
Entry Level III.
1230.2.11 Mirrors.
A mirror of a material appropriate to the level of ☒
☐ ☐
security must be provided near each wash basin
specified in these regulations.
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS, AND CAMPS
LIVING AREA SPACE EVALUATION
Board of State and Community Corrections
BSCC Code: 7727 7728 7740 7741
FACILITY: Ventura County Probation Agency Juvenile Facilities TYPE: RC: 420
Juvenile Detention RC 150 (7727); Juvenile Commitment RC 210 JH/Camp/SYTF
(7728); Juvenile Detention SYTF RC 30 (7740); Juvenile Commitment
SYTF RC 30 (7741)
FIELD REPRESENTATIVE: Elizabeth Gong DATE: July 13, 2023
ROOMS EACH ROOM
Unit Room Applicable # EACH ROOM Total DIMENSIONS FIXTURES*
Designation Type Standards Rooms # RC RC (L x W x H) T U W F S
Beds
Court Basement Holding
Holding A Holding 2001 1 (10) (10) 15.4’ X 14.3’ 1
1 Holding 2001 1 (5) (5) 8.5’ X 8.2’ 1 1
2 Holding 2001 1 (4) (4) 8.5’ X 6.8’ 1 1
3 Holding 2001 1 (4) (4) 8.5’ X 6.8’ 1 1
4 Holding 2001 1 (4) (4) 8.5’ X 6.8’ 1 1
5 Holding 2001 1 (4) (4) 8.5’ X 6.8’ 1 1
6 Holding 2001 1 (5) (5) 8.5’ X 7.4’ 1 1
Holding B Holding 2001 1 (12) (12) 17.3’ X 18.5’ 1 1
Note: The basement holding area is staffed and operated by the Probation Department and inspected in conjunction with
the JH. Floors 1 and 2 are staffed and operated by the Sheriff’s Department and inspected as an adult court holding facility.
Intake
Group 2001 1 0 (6) 11’3” x 9’3.5”
Holding
Safety 2001 1 (1) 70.4 sq. feet
Room
1-5 Holding 2001 5 (5) 66 sq. feet 1 1 1
1-2 Medical 2001 2 155.11 sq. feet
Multi- 2001 1 94’ x 29’4” =
Purpose 2757.02 sq. feet
Program
Room
Notes: There are 3 showers in the Intake area. The Multi-Purpose Program room is used for programming space in the
event a youth is maintained in this area for a long period of time.
*T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit. If "Total RC" appears in brackets ( ), it is not part of the facility's rated
capacity.
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ROOMS EACH ROOM
Unit Room Applicable # EACH ROOM Total DIMENSIONS FIXTURES*
Designation Type Standards Rooms # RC RC (L x W x H) T U W F S
Beds
Balcom I: On the date of the Inspection, 3 Detention and 4 Commitment Female Youth occupied this space, as well as
one SYTF youth solely for sleeping purposes.
Dayroom 2001 1 1 1 1 3
70 sq. feet
Single 2001 20 1 1 20 1 1 1
Classroom 2001 1 (20) 728 sq. feet
Notes: Of the 20 single rooms, 2 are ADA rooms measuring 110 sq. feet.
Balcom II: This unit was unoccupied on the date of the Inspection. It is being used as Recreation Space, Canteen Area,
and a Multi-Sensory De-escalation Room. There is also a library in the space.
Dayroom 2001 1 1 1 1 3
70 sq. feet
Single 2001 12 1 1 12 1 1 1
Double 2001 4 2 2 8
Classroom 2001 2 (10) (20) 450 sq. feet
Note: Of the 20 single rooms, 2 are ADA rooms measuring 110 sq. feet.
Balcom III: This unit was unoccupied during the Inspection.
Dayroom 2001 1 1 1 1 3
70 sq. feet
Single 2001 20 1 1 20 1 1 1
Classroom 2001 1 (20) 727 sq. feet
Balcom Safety 2001 2 (1) (2) 64.66 sq. feet
Hallway Room
Note: Of the 20 single rooms, 2 are ADA rooms measuring 110 sq. feet. The Safety Room has not been used in years. If
necessary, the Safety Room in Booking is used.
Sycamore 1: Unit 100 This Unit houses 12 Detention Youth
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Sycamore 1: Unit 200 This unit houses 9 Commitment Youth
Dayroom 2001 1 1 1 1 3
*T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit. If "Total RC" appears in brackets ( ), it is not part of the facility's rated
capacity.
7727+ Ventura Probation LASE 23-34 - 2 - J460 LAS JUV-05.dot (rev.12/2022)
ROOMS EACH ROOM
Unit Room Applicable # EACH ROOM Total DIMENSIONS FIXTURES*
Designation Type Standards Rooms # RC RC (L x W x H) T U W F S
Beds
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Sycamore 3: Unit 300 This unit houses 11 Commitment Youth
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Sycamore 3: Unit 400 This unit houses 13 Detention Youth
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Matilija 1: Unit 100 This unit was unoccupied during the Inspection.
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Matilija 1: Unit 200 This unit is housed with 6 Special Program Youth.
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Matilija 3: 300 Unit This Unit houses 7 SYTF youth.
*T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit. If "Total RC" appears in brackets ( ), it is not part of the facility's rated
capacity.
7727+ Ventura Probation LASE 23-34 - 3 - J460 LAS JUV-05.dot (rev.12/2022)
ROOMS EACH ROOM
Unit Room Applicable # EACH ROOM Total DIMENSIONS FIXTURES*
Designation Type Standards Rooms # RC RC (L x W x H) T U W F S
Beds
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Matilija 3: Unit 400 This unit houses 4 SYTF youth.
Dayroom 2001 1 1 1 1 3
ADA 2001 1 1 1 1 10’3” x 10’ 1 1 1
single
Single 2001 14 1 1 14 7’ x 10’ 1 1 1
Classroom 2001 1 (15) 594 sq. feet
Ana Capa Buildings 1-4: This space is used for the Boys and Girls Club, Commitment Programming, and the Paxton
Patterson Construction Program. Since it is not sleeping space, we are recording the capacity for all four areas.
Units 1-4 Classroom 2001 4 (15) (60) 590 sq. feet
Dayroom 2001 4 (132) 998 sq. feet 2 2 3 3
each
ADA 2001 4 4 4 4 7’7” x 9’10” each 1 1 1
single
Single 2001 8 1 1 8 7’ x 10’ each 1 1 1
Dorm 2001 12 4 4 48 10’ x 20’4” each
Santa Cruz Buildings 1-4: All 4 living areas are vacant and only occasionally used for Commitment Schooling.
Units 1-4 Classroom 2001 4 (15) (60) 590 sq. feet
Dayroom 2001 4 (132) 998 sq. feet 2 2 3 3
each
ADA 2001 4 4 4 4 7’7” x 9’10” each 1 1 1
single
Single 2001 8 1 1 8 7’ x 10’ each 1 1 1
Dorm 2001 12 4 4 48 10’ x 20’4” each
Santa Rosa Buildings 1-4: The buildings are used for storage and Staff Training.
Units 1-4 Classroom 2001 4 (15) (60) 590 sq. feet
*T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit. If "Total RC" appears in brackets ( ), it is not part of the facility's rated
capacity.
7727+ Ventura Probation LASE 23-34 - 4 - J460 LAS JUV-05.dot (rev.12/2022)
ROOMS EACH ROOM
Unit Room Applicable # EACH ROOM Total DIMENSIONS FIXTURES*
Designation Type Standards Rooms # RC RC (L x W x H) T U W F S
Beds
Dayroom 2001 4 (132) 998 sq. feet 2 2 3 3
each
ADA 2001 4 4 4 4 7’7” x 9’10” each 1 1 1
single
Single 2001 8 1 1 8 7’ x 10’ each 1 1 1
Dorm 2001 12 4 4 48 10’ x 20’4” each
Wheeler 1: This Unit was unoccupied during the Inspection.
Dayroom 2001 1 2 2 2 6
ADA 2001 2 1 1 2 10’3” x 10’ 1 1 1
single
Single 2001 28 1 1 28 7’ x 10’ 1 1 1
Classroom 2001 2 (15) 594 sq. feet
Wheeler II: This Unit was unoccupied during the Inspection.
Dayroom 2001 1 2 2 2 6
ADA 2001 2 1 1 2 10’3” x 10’ 1 1 1
single
Single 2001 28 1 1 28 7’ x 10’ 1 1 1
Classroom 2001 2 (15) 594 sq. feet
*T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit. If "Total RC" appears in brackets ( ), it is not part of the facility's rated
capacity.
7727+ Ventura Probation LASE 23-34 - 5 - J460 LAS JUV-05.dot (rev.12/2022)