PREA AUDIT: AUDITOR’S SUMMARY REPORT
COMMUNITY CONFINEMENT FACILITIES

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Name of Facility:  Alpha Human Services, Inc.
Physical Address:  2712 Fremont Avenue South, Minneapolis, MN 55408
Date of Report: 6/22/15

Auditor Information: Timothy Pippo
Address: 3800 Braddock Ave NE, Buffalo, MN 55313
Email: tim.pippo@co.wright.mn.us
Phone: 763-684-2380
Date of facility visit: 5/29/15

Facility Information
Telephone number: 612-872-8218
The facility is: Private not for profit
Facility type: Community treatment center
Name of Facility Head: Richard Weinberger  Title: Clinical Director
Email address: RickW@alphaservices.org  Telephone number: 612-872-8218 ext. 15
Name of PREA Compliance Manager: Richard Weinberger  Title: Clinical Director

Agency Information
Name of agency: Alpha Human Services, Inc.
Physical address: 2712 Fremont Avenue South, Minneapolis MN 55408
Telephone number: 612-872-8218

Agency Chief Executive Director
Name:
Gerald T. Kaplan  Title: CEO
Email address: GTK@alphaservices.org  Telephone number: 612-872-8218 ext. 17

Agency-Wide PREA Coordinator
Name: Riki Kravitz  Title: Outpatient Program Coordinator
Email address: RikiK@alphaservices.org  Telephone number: 612-822-1357

AUDIT FINDINGS

NARRATIVE:

Alpha Human Services is an intensive Residential Treatment Program for adult males that have a past history of, and or a criminal conviction for sexually deviant behavior. The Treatment Program is nationally recognized for its leadership and innovation for the treatment of sexual offenders. Staff members are comprised of psychologists, counselors and therapists (majority of which are licensed) along with staff that perform security functions. Most staff members have more than one responsibility pertaining to the Agency PREA Policy. The agency refers to the residents as clients. Clients of the facility are committed to a long term multi-phase program that is usually at least 13 months in duration. Treatment consists of individual and group counseling sessions trending towards Behavior Modification. Clients gain more privileges with each phase of the program that they complete up until graduation from the program. The facility is one of few in-patient options for sexual offenders throughout the United States. Some clients are allowed into the program through an interstate compact. The facility operates under a conditional license from the Minnesota Department of Corrections and abides by Minnesota 2920 Rules Governing Adult Community-Based Residential Correctional Facilities.

The facility has two buildings it utilizes to house clients. The building located at 3341 Portland Ave South, Minneapolis, MN (known as Portland) is used as a dormitory for clients. All clients that are assigned house at this location occupy their rooms only in the evening and are monitored by security staff overnight. They are transported to and from the building located at 2712 Fremont Ave South, Minneapolis, MN (known as Fremont) each morning starting around 7:00am. The Fremont building is where all meals are served and where all programming functions take place.

On May 29, 2015 Timothy Pippo, Certified PREA Auditor conducted an on-site audit of Alpha Human Services. I arrived at the facility on Fremont Ave at 7:30am. I was met by the Clinical Director and PREA Compliance Manager Richard Weinberger and was later joined by Riki Kravitz the Agency Outpatient Program Coordinator and PREA Coordinator. I physically toured the building located on Portland Avenue. The facility was at maximum capacity of 23 residents housed; on the day of the audit. Three residents met definitions to qualify them as being part of the LGBTI community. The facility has had 0 reports of sexual abuse or harassment within the last 12 months.

DESCRIPTION OF FACILITY CHARACTERISTICS:

The facility consists of two buildings. The Portland building is a two story renovated apartment building located in a residential area in South Minneapolis. The building is used mainly for sleeping purposes. There are 6 bedrooms and 2 private bathrooms located on the first floor and 3 bedrooms along with 2 private bathrooms located on the second floor, for a total capacity of 16 residents. The basement of the facility has a laundry room along with a television lounge area. The staff office is located in the basement also. This building is staffed from 8:00pm to 8:00am or any time residents are present. The residents are transported to and from the Fremont building every day for meals and programing. The building on Fremont Ave is a 3 story renovated house located in a residential neighborhood in South Minneapolis. This building has two bedroom's on the second floor along with 1 private bathroom. This building can house 7 residents. The third floor of the building is utilized for office space. The main floor of this portion of the facility has a lounge area, staff offices and a kitchen. Residents take turns cooking meals as part of their housing duties assigned to them. The basement of the house has a laundry area and a large classroom area used for group counseling sessions. This building is staffed 24hrs/day.

Mission:

Alpha's mission is to reduce the incidence of the victimization of innocent people by providing treatment to sex offenders, their families, and sexual abuse victims; to reduce the pain and suffering caused by sexual abuse, and to be an educational resource for other agencies, and the public.

The primary objective of the program is to modify deviant criminal and antisocial behavior; i.e., to reduce the likelihood of that behavior recurring. In addition to improved emotional and mental health, the program emphasizes adaptive behavior which generally falls into three basic areas:

  • Meaningful interpersonal relationships and family interaction, including appropriate sexual behavior and social skills.
  • Appropriate work behavior and responsiblel self-support skills.
  • Healthy, responsible interactions with the community.

SUMMARY OF AUDIT FINDINGS

Number of standards exceeded: 0
Number of standards met: 35
Number of standards not met: 0
Number of standards not applicable: 4

Standard Number 115.211 Zero tolerance of sexual abuse and sexual harassment; PREA Coordinator

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) The agency has a policy that covers this standard that is available to all staff.
b) The agency has a designated PREA Coordinator that is also the Outpatient Program Director. Interviews with the PREA Coordinator and the Agency CEO assured the fact that this person has adequate time to take on these responsibilities.

Standard Number 115.212 Contracting with other entities for the confinement of residents

  • Not applicable

The Agency does not contact with any outside vendors or agencies for treatment or security reasons.

Standard Number 115.213 Supervision and monitoring

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)
    a) The Agency has a documented staffing plan that follows the agency PREA policy page 5.
    b) The Agency never varies from the staffing plan; staff is obligated to remain on duty until relieved. A
    c) Interviews with the CEO and PREA Coordinator confirmed adherence to this portion of the standard. Agency policy page 7 refers to this standard also.

Standard Number 115.215 Limits to cross-gender viewing and searches

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)
    a) The facility does not perform any strip searches or body cavity searches of any kind.
    b) The agency does not allow any pat searches of any kind by any gender. Interviews with residents and staff members confirmed no pat searches.
    c) The facility never performs any cross-gender searches of any kind.
    d) Agency policy page 7 along with interviews with staff members and residents confirm compliance with this standard. Female auxiliary counselors that perform security rounds announce themselves when entering a house area during non-routine room checks. Both buildings have private shower areas and female staff members never enter an occupied bathroom. Residential rules prescribe the male residents to be fully clothed when not in bed sleeping or using a bathroom.
    e) The facility is male only and only Transgender males of Intersex residents identifying as males would be allowed in the treatment program. All staff members are trained sexual therapists or counselors and are well versed on how to interview residents about gender identity. There were no transgender or intersex residents housed on the day of the audit.
    f) The facility does not perform pat searches on any residents for any reason.

 Standard Number 115.216 Residents with disabilities and residents who are limited English proficient

  • Not Applicable

The facility's physical design is not fitted for residents with physical disabilities. All residents are pre-screened before acceptance into the program. The agency would be unable to make all of its rigorous programming available to residents with limited English or vocabulary skills. Interviews with staff members however confirmed that they would obtain an interpreter if needed to communicate with any person reporting sexual abuse or harassment.

Standard Number 115.217 Hiring and promotion decisions

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)
    a) Agency policy page 6 and 7 along with Employee Handbook page 18 refer to this standard.
    b) Employee Handbook page 34 and Agency policy refer to zero tolerance of sexual harassment.
    c) d) e) Criminal background checks for all employees are mandated by MN Rule 2920.400 and also by Agency policy. The agency utilizes the Minnesota Bureau of Criminal Apprehension to complete criminal history checks.
    f) g) Agency policy page 7 and Employee Handbook page 34 and 23 refer to employee reviews. The facility incorporates the three qualifiers from section a) of this standard in employee reviews.
    h) Interviews confirmed that the Agency would notify other agencies of allegations as permitted by law.

Standard Number 115.218 Upgrades to facilities and technologies

  • Meets standard

The facility has not had any major upgrades in the last year. An interview with the Agency Executive Director and the PREA Coordinator confirmed that the facility would follow their policy and take into account PREA considerations when determining any new upgrades to the facility.

Standard Number 115.221 Evidence protocol and forensic medical examinations

  • Meets standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Agency policy page 8 covers this standard. The facility also has a "Sexual Assault Checklist" outlining correct procedures for staff to follow.

b) Outlined protocols follow the standard.

c) The facility would use one of three local hospitals for SAFE or SANE examinations. Hennepin County Medical Center in Minneapolis has 24/7 nurse examiners available as posted on web-site http://www.hcmc.org/services/sars/index.html. Methodist Hospital is located in St. Louis Park MN and provides the same services as Hennepin County Medical Center. The third hospital is Abbott Northwestern Hospital in Minneapolis and it offers 24/7 nurse examiners as listed on this web-site http://www.allinahealth.org/Health-Conditions-and-Treatments/Sexual-assault-care-services/

d) e) The Agency has a signed MOU with "Sexual Violence Center" Minneapolis that confirms advocacy and support services for Alpha Human Services residents.

f) g) The Agency will utilize Minneapolis Police Department for sexual abuse investigations.

h) The Sexual Violence Center would provide trained individuals for support of this portion of the standard.

Standard Number 115.222 Policies to ensure referrals of allegations for investigations

  • Meets Standard (substantial compliance complies in all material ways with the standard for the relevant review period)

a) Agency policy page 8 spells out mandatory investigations for all allegations of sexual abuse or sexual harassment.

b) c) The facility will use Minneapolis Police Department for sexual abuse allegations as posted on the Agency web-site at http://www.alphaservices.org/index.php/prea-policy.

d) e) Minneapolis Police Department has specialized sex crime investigators. The police department has investigative procedures on its web-site http://www.ci.minneapolis.mn.us/police/policy/mpdpolicy 10-200 10-200

Standard Number 115.231 Employee Training

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Agency policy page 9 and 10 refer to this standard. All employees were trained using the protocols from an online PREA course "educorr" this information is located at web-site http://educorr.com/. This training course covers all 10 subsections of this standard.

b) Interviews with female staff members indicated that they received appropriate training.

c) Policy meets this requirement of the standard. Most staff members are highly educated sexual therapists or counselors.

d) The agency provided me with signed documents of completion of training requirements.

Standard Number 115.232 Volunteer and contractor training

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

PREA policy page 10 covers this standard. The agency does not have any volunteers and an interview with the facility maintenance person confirmed that he had been trained on the agency policies and procedures. The agency has signed documentation of the training received.

Standard Number 115.233 Resident education

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Policy page 11 and the Resident Handbook page 76 provide direction for resident training.

b) The facility has weekly house meetings for all residents and PREA considerations are or may be discussed during these meetings.

c) The facility pre-screens clients that it allows in the program and does not have the capability to allow persons of limited abilities or disabilities into the program. Interviews with staff members indicated they would obtain interpreters if needed. There have been no limited English proficient or residents with disabilities house in the facility in the last 12 months.

d) The facility requires and has documentation of resident signatures on intake forms and resident handbooks.

e) The facility has posters throughout both buildings and provides information in the resident handbook.

Standard Number 115.234 Specialized training: Investigations

  •  Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

The agency does not conduct criminal sexual abuse investigations; Minneapolis Police Department will perform criminal investigations with trained officers. The agency will investigate all and any allegations of sexual abuse/harassment and does have an incident review team that has received specialized training through the National Institute of Corrections online course for PREA Investigations.

Standard Number 115.235 Specialized training: Medical and mental health care

  • Not Applicable

The agency does not employ or contract with any Medical or Mental Health practitioners that would treat any resident that were sexually victimized. All residents would be transported to Hennepin County Medical Center, Methodist Hospital or Abbott Northwestern Hospital for care. The PRC FAQ General #8 refers to non-applicability of this standard.

Standard Number 115.241 Screening for risk of victimization and abusiveness

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Policy pages 11, 12, 13 refer to screening of residents. Interviews with residents confirmed that the screening was completed.

b) The agency has one person that does risk assessments for the facility. An interview with him indicated that most residents receive the screening before they are admitted to the facility.

c) d) The facility uses a vulnerability assessment tool that covers all the requirements set forth by the standard.

e) All residents of Alpha Human Services have a sexual offending history; therefore the screening is adapted to the unique makeup of the residents.

f) g) Each resident has an assigned case worker. The case workers are constantly monitoring each client and taking sexual vulnerability or aggressiveness into consideration.

h) Policy does not indicate discipline for failure to answer screening questions but the treatment program dwells on the resident's sexual past frequently.

i) The agency provides strict controls on any resident information dissemination.

Standard Number 115.242 Use of screening information

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Agency policy page 12 and 13 refer to this standard. Interviews with staff substantiated the fact that they use the screening to determine housing assignments. New residents are housed in the Fremont house that has more staff supervision; the treatment program itself determines the level of supervision of clients.

b) Since the facility only accommodates 23 residents, each person receives special consideration.

c) d) Only Transgender or Intersex persons identifying as male would be allowed in the treatment program and their personal views would be taken into consideration.

e) The facility has only private showers.

f) The facility would house persons of LGBTI definitions on an individual basis. There were no Transgender or Intersex residents housed in the facility within the last year. I interviewed a resident that identified as Gay; this resident was satisfied with the housing assignment and protections given.

Standard Number 115.251 Resident reporting

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Policy page 13 and 14 and Resident Handbook page 76 provide direction for resident reporting.

b) Interviews with residents confirmed their knowledge of how to report privately.

c) d) Both staff and Residents reported that they were confident that they could report through a third-party person.

Standard Number 115.252 Exhaustion of administrative remedies

  • Meets Standard (substantial compliance complies in all material ways with the standard for the relevant review period)

The agency has a grievance procedure for residents spelled out on page 60 of the Resident Handbook. The agency would, however, treat each and every grievance concerned with sexual abuse/harassment as an emergency grievance and respond to the grievance immediately. Staff interviews affirmed that they would react immediately and appropriately to any potential of a resident being in imminent danger of sexual abuse.

Standard Number 115.253 Resident access to outside confidential support services

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Agency policy page 13 and 14 refer to this standard. The Resident Handbook page 77 has phone numbers listed for the Minnesota Department of Corrections Sexual Assault Helpline and the Minneapolis Sexual Violence Center and the agency PREA coordinator.

b) The Resident Handbook and postings in the facility advise the residents of the confidentiality of reporting. Interviews with residents showed confidence that they may have access to outside agencies for support purposes.

c) The agency has a signed MOU with Sexual Violence Center Minneapolis; the MOU meets the requirements of this standard. There have been no reports made to outside agencies within the last 12 months.

Standard Number 115.254 Third-party reporting

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Policy and the Resident Handbook have information for third-party reporting. Interviews with residents affirmed that they knew they could have someone report for them no their behalf and staff interviews affirmed that they would accept third-party reports. The agency has this information posted on their web-site as part of their policy.

Standard Number 115.261 Staff and agency reporting duties

  • Meets standard (substantial compliance complies in all material ways with the standard for the relevant review period)

a) Policy page 14 and 15 pertain to this standard along with the Employee Handbook page 33 and 34.

b) All employees are obliged to adhere to the "American Psychological Association Ethical Principles of Psychologists and Code of Conduct"

c) The agency will utilize local hospitals for medical and mental health treatment. These hospitals operate under federal and state guidelines.

d) The facility only treats male adults.

e) Agency policy and interviews with staff members indicated that they would report all and any allegations or incidents to superiors.

Standard Number 115.262 Agency protection duties

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Agency policy page 15 prioritizes the safety of at risk residents. Interviews with staff members uphold the priority of a safe environment for staff and clients.

Standard Number 115.263 Reporting to other confinement facilities

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Policy page 16 correlates with this standard. Most residents were previously incarcerated in a Minnesota Correctional Facility. The agency is required by contract to notify the MN Department of Corrections of any sexual assaults reported to them. Residents are asked upon intake if they were ever sexually abused or committed sexual abuse in a confinement setting before. The facility would relay any reports of sexual abuse to any other agency within 72 hours. There have been no residents making such reports within the last year.

Standard Number 115.264 Staff first responder duties

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Policy pages 15, 16, and 17 cover this standard. Alpha Human Services has a limited number of staff members therefore all staff persons are considered first responders and have been trained to react as such. The facility has protocols for first responders to follow. Interviews confirmed that staff members are well versed on how to respond to sexual assault situations.

b) The only non-security staff member was trained on how to correctly respond to an incident.

Standard Number 115.265 Coordinated response

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

The facility has developed a "Sexual Assault Response Checklist" and a PREA Flow Chart for an incident of Staff on Resident Sexual Assault. Alpha Human Services has also formed a Sexual Assault Response Team.

Standard Number 115.266 Preservation of ability to protect residents from contact with abusers

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

The agency does not have a collective bargaining agreement with its employees. Staff members are "At Will" employees and are subject to any discipline and or termination not legally prohibited. There have been no employees disciplined for violations of PREA policies in the last 12 months.

Standard Number 115.267 Agency protection against retaliation

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

The agency PREA policy page 17 covers this standard. The facility has a PREA Compliance Manager tasked to monitor retaliation; however interviews with Case Managers and Case Supervisors confirmed that they also would monitor retaliation within the facility for the entire stay of the resident. The facility has no means to separate abusers from victims within the buildings, so abusers or persons retaliating would be removed from the program. Interviews reinforced the fact that all facility personnel are educated in determining whether a client is a subject of retaliation or not. There have been zero reports of retaliation in the facility in the last year.

Standard Number 115.271 Criminal and administrative agency investigations

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Policy pages 17, 18, and 19 pertain to this standard.

b) The agency will utilize Minneapolis Police Department for investigations of sexual abuse.

c) d) e) The Minneapolis Police Department has its policy and procedure for evidence collection posted on this web-site.
http://www.ci.minneapolis.mn.us/police/policy/mpdpolicy 10-400 10-400

The agency has an investigative team made up by the PREA Coordinator and the PREA Compliance Manager. Interviews with these team members confirmed their knowledge of the standards requirements. The Executive Director of the Agency made assurances that the Agency has a good rapport with the Minneapolis Police Department and that the facility would comply with subsections f) g) h) i) j) k) and l) of the standard. The agency has never had to do an investigation of Sexual abuse/harassment in this facility.

Standard Number 115.272 Evidentiary standard for administrative investigations

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Agency policy page 18 and interviews with the investigative team confirm adherence to the standard of evidence outlined in this standard.

Standard Number 115.273 Reporting to residents

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Policy page 19 covers all aspects of this standard and spells out the facilities obligation and roles in keeping residents informed of any investigation involving them. There have been 0 investigations within the facility in the last 12 months.

Standard Number 115.276 Disciplinary sanctions for staff

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Agency Policy page 20 and Employee Handbook page 24 explain disciplinary sanctions for employees up to and including termination for violation of agency policies. Employees of Alpha Human Services are "At Will" employees and are subject to termination and prosecution for criminal charges. There has been 0 staff members disciplined for violation of Agency PREA policies within the last year.

Standard Number 115.277 Corrective action for contractors and volunteers

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

The agency would discipline up to termination of any person that is contacted to do work in the facility. The agency does not have any volunteers. Any criminal acts would be reported to Minneapolis Police Department immediately for prosecution. There have been no contractor employees disciplined for PREA policy violation in the facility in the last year.

Standard Number 115.278 Disciplinary sanctions for residents

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Policy page 20 and Resident Handbook page 9 describe sanctions for residents. The agency also abides by MN Rule 2920.5700 in regards to resident discipline. The facility has no restrictive confinement for residents that may have to be separated from victims. The facility would have the aggressor removed from the facility and terminated from the program.

Abusive Residents would be transported to Hennepin County Jail or back to a Minnesota Correctional Facility. If the resident were under probation, the governing Probation Officer would also be involved in the discipline. There have been 0 residents disciplined for violation of Agency PREA policies within the last 12 months.

Standard Number 115.282 Access to emergency medical and mental health services

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Policy page 21 and facility "Sexual Assault Checklist" implore staff to seek immediate medical attention for victims of sexual abuse. Residents would be transported immediately to an area hospital for emergency medical and mental health care.

Standard Number 115.283 Ongoing medical and mental health care for sexual abuse victims and abusers

  • Not Applicable

Policy page 20 refers to this standard. The facility is not equipped to provide ongoing medical care. The agency will ensure that the victim is offered medical and mental health care in whichever facility they are transferred to.

Standard Number 115.286 Sexual abuse incident reviews

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

a) Policy page 22 covers this standard. The facility will investigate any and all allegations or incidents of sexual abuse/harassment.

b) Interviews indicated that reviews would occur within a week of an investigation.

c) The agency review team is made up of the Executive Director, Clinical Director and the Outpatient Program Coordinator.

d) e) Interviews with the review team indicated that they would take all factors that are outlined in this standard into consideration when reviewing an incident and making recommendations to prevent a future incident.

Standard Number 115.287 Data Collection

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

The facility would use the Minnesota Statewide Supervision Special Incident Report form for any sexual assault/harassment incidents. The Agency has an annual report and posts data concerning current year sexual assault incidents on its web-site.

Standard Number 115.288 Data review for corrective action

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Agency Policy page 21 and 22 cover this standard substantially. Interviews with the Executive Director and the PREA Coordinator confirmed that they would consider any data collected and take corrective measures based on the data. The agency posts its statistical data on its web-site at http://alphaservices.org/index.php/prea-policy/

Standard Number 115.289 Data storage, publication and destruction

  • Meets Standard (substantial compliance; complies in all material ways with the standard for the relevant review period)

Agency policy page 22 refers to data maintenance. The facility is governed by MN Rule 2920.4800 concerning data retention and follows Minnesota State Statutes relating to data publication.

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AUDITOR CERTIFICATION:

The auditor certifies that the contents of the report are accurate to the best of his/her knowledge and no conflict of interest exists with respect to his or her ability to conduct an audit of the agency under review.

 

_____________Timothy Pippo______________        __________June 22, 2015__________