JUVENILE JUSTICE SERVICES

Michigan Office of the
Auditor General
Thomas H. McTavish, C.P.A.
Auditor General

EXECUTIVE DIGEST #4327197
JUVENILE JUSTICE SERVICES

INTRODUCTION
This report, issued in April 1999, contains the results of our performance audit of Juvenile Justice Services, Family Independence Agency (FIA).

AUDIT PURPOSE
This performance audit was conducted as part of the constitutional responsibility of the Office of the Auditor General. Performance audits are conducted on a priority basis related to the potential for improving effectiveness and efficiency.

BACKGROUND
FIA administers juvenile justice services. The Child and Family Services Administration oversees policy development for services provided to youths and families through FIA's local offices, State-operated residential treatment facilities, and private residential treatment facilities under contract with FIA. The Field Operations Administration oversees delinquency field staff.

The purpose of providing juvenile justice services is to carry out Section 712A.1 of the Michigan Compiled Laws, which mandates that each youth under FIA's jurisdiction be provided:
. . . care, guidance and control, preferably in his or her own home, conducive
to the juvenile's welfare and the best interest of the state. If a juvenile is
removed from the control of his or her parents, the juvenile shall be placed
in care as nearly as possible equivalent to the care which should have been
given to the juvenile by his or her parents.

The goals of juvenile justice services are:

1.    To divert youths from the juvenile justice system at the point of entry.

2.    To protect the community from harm by youthful offenders.

3.    To reduce recidivism within the juvenile justice system.

4.    To assist youths in becoming contributing members of society.

5.    To reduce escalation from the juvenile justice system to the adult criminal justice system.

FIA directs adjudicated delinquent youths through the continuum of treatment services determined to be most appropriate for their individual needs. The treatment services are meant to provide youths and families with the knowledge and skills needed to reduce delinquent behavior, promote appropriate attitudes, and strengthen their capacity for self-sufficiency to enable them to function responsibly in their home communities.

As of March 31, 1998, FIA was responsible for 5,874 delinquent youths. Juvenile justice services were administered by 1,249 employees: 25 central office staff, 198 field staff at local county offices, and 1,026 staff at State-operated residential treatment facilities and detention centers. In addition, substantially more staff were employed by private residential treatment facilities and detention centers.

OVERALL AUDIT OBJECTIVE AND CONCLUSION
Audit Objective: To assess the overall effectiveness of FIA's juvenile justice services.

Conclusion: Based on our individual audit findings, we concluded that FIA's juvenile justice services often were not effective in ensuring the availability of treatment programs, identifying youths' placement and treatment needs, and providing appropriate residential services and community reintegration services to reduce delinquency.

INDIVIDUAL AUDIT OBJECTIVES, CONCLUSIONS, AND NOTEWORTHY ACCOMPLISHMENTS
Audit Objective: To assess the effectiveness of FIA's intake and placement process.

Conclusion: We concluded that FIA's intake and placement process was moderately effective; however, our assessment disclosed one material condition:

FIA's intake and placement process did not ensure that delinquent youths received the most effective treatment for meeting their assessed needs (Finding 1).

FIA agreed with the finding and recommendation and responded that it has initiated corrective action.
Our assessment also disclosed other reportable conditions related to both initial risk assessments and needs assessments, selection of out-of-State residential treatment facilities, out-of-State residential placements, delinquency services worker (DSW) work load standards, and preparation of intake and placement documents (Findings 2 through 6).

Noteworthy Accomplishments: Effective April 1, 1995, FIA implemented, on a Statewide basis, a structured decision making (SDM) model that was developed in conjunction with the National Council on Crime and Delinquency. The SDM model is based on set standards and systematic criteria and seeks to balance a youth's need for services and the need for public safety.

FIA's SDM model includes the use of standardized tools, such as forms for making initial risk and needs assessments and reassessments, to evaluate the risk and needs of delinquent youths. FIA then assigns treatment resources accordingly. These standardized tools uniformly guide and structure decisions regarding initial placement security level, treatment programs, escalation and de-escalation of placement security level, and placement release. The SDM model lessens individual discretion and the subjective nature of decisions by organizing decision making criteria to promote greater consistency and equity.

Audit Objective: To assess the effectiveness of private residential treatment facilities in identifying and providing appropriate services to youths placed in their care.

Conclusion: We concluded that private residential treatment facilities sometimes were not effective in identifying and providing appropriate services to youths placed in their care. Our assessment disclosed one material condition:

FIA had not established a comprehensive continuous quality improvement process to evaluate and improve the effectiveness of overall juvenile justice services and significant components of those services (Finding 7).

FIA agreed with the finding and recommendation and responded that it has initiated corrective action.
Our assessment also disclosed other reportable conditions related to quarterly risk and needs reassessments, initial and updated service plans, discharge services plans and treatment release plans, and contacts with released youths and final reports (Findings 8 through 11).

Audit Objective: To assess the effectiveness of FIA's contracting for and monitoring of services provided by private residential treatment facilities.

Conclusion: We concluded that FIA was moderately effective in contracting for the services of private residential treatment facilities. However, we concluded that FIA was not effective in monitoring the services provided by private residential treatment facilities. Our assessment disclosed two material conditions:

FIA did not have an effective process to project and meet bed space needs for delinquent youths (Finding 12).

FIA agreed with the finding and recommendation and responded that it has initiated corrective action.

FIA did not conduct periodic, comprehensive, on-site monitoring visits at all private residential treatment facilities (Finding 15).
FIA agreed with the finding and recommendation and responded that it will initiate corrective action.
Our assessment also disclosed other reportable conditions regarding contracts with private residential treatment facilities, the per diem rate-setting process, reimbursement for home visit days, and competitive bidding of contracts with private residential treatment facilities (Findings 13, 14, 16, and 17).

Audit Objective: To assess FIA's efforts to provide youths released from residential treatment facilities with appropriate community reintegration services.

Conclusion: We concluded that FIA's efforts frequently did not provide the youths released from residential treatment facilities with appropriate community reintegration services. Our assessment disclosed two material conditions:

FIA had not taken effective action to ensure that appropriate community reintegration services were made available and provided to delinquent youths (Finding 18).

FIA agreed with the finding and recommendation and responded that it has initiated corrective action.

FIA had not developed comprehensive guidelines to help ensure that youths released from residential treatment facilities received appropriate community reintegration services (Finding 19).

FIA agreed with the finding and recommendation and responded that it will initiate corrective action.
In addition, as reported under our second objective, our assessment disclosed a material condition related to the lack of a comprehensive continuous quality improvement process to evaluate and improve the effectiveness of overall juvenile justice services and significant components of those services, including community reintegration services (Finding 7).

Our assessment also disclosed a reportable condition related to DSW contacts and case closure summaries (Finding 20).

AUDIT SCOPE AND METHODOLOGY
Our audit scope was to examine the program and other records related to juvenile justice services. The audit scope included the examination of case file and other records at six private residential treatment facilities and six Family Independence Agency county offices: Clare, Genesee, Huron, Kalamazoo, Saginaw, and Wayne. The audit scope did not include State-operated residential treatment facilities because of our performance audit of W. J. Maxey Training School, issued in November 1996. Our audit was conducted in accordance with Government Auditing Standards issued by the Comptroller General of the United States and, accordingly, included such tests of the records and such other auditing procedures as we considered necessary in the circumstances.

Our audit procedures included an examination of records and activities primarily for the period January 1, 1995 through March 31, 1998.

To accomplish our objectives, we reviewed pertinent FIA policy and administrative rules and interviewed staff at FIA's central office. We visited six private residential treatment facilities and interviewed facility staff. We also visited six FIA county offices and interviewed DSWs and supervisory staff. During these visits, we examined case files for delinquent youths who were committed or referred to FIA between June 1, 1995 and February 28, 1997; placed at private facilities after June 1, 1995 and released by February 28, 1997; released from both private and State-operated facilities to community settings after January 1, 1995 and discharged from FIA supervision by February 28, 1997; and released to community settings between January 1, 1995 and February 28, 1997. We also examined case files for certain delinquent youths who were placed in out-of-State facilities between January 1, 1997 and October 1, 1997. We established these time frames for our case file review to ensure that we evaluated juvenile justice services' outcomes resulting from FIA's most current program policies.

In connection with our first objective, we evaluated the use of FIA's SDM model and reports pertaining to intake and placement decisions made for selected youths. We assessed the operational practices of the Central Intake Committee, reviewed FIA's evaluation of out-of-State residential treatment facilities and the rationale for selected out-of-State residential placements, and assessed DSW work loads and related work load standards.

In connection with our second objective, we reviewed selected facility contracts, observed treatment programs, and examined documentation of services needed by and provided to selected youths. Also, we examined risk and needs reassessments, initial and updated service plans, discharge services plans, and treatment release plans. In addition, we reviewed performance indicators, standards established by FIA, and FIA's management information system.

In connection with our third objective, we assessed the adequacy of FIA's policy and processes for contracting and monitoring the services of private residential treatment facilities. We evaluated contract specifications, the per diem rate-setting process, reimbursements for home visit days, and the competitive bidding of certain contracts. Also, we assessed FIA's efforts to project and meet bed space needs and reviewed FIA's monitoring of private residential treatment facilities.

In connection with our fourth objective, we examined case files of selected youths to determine DSW contacts with youths after their release, the provision of recommended community reintegration services to youths, and the length of time that youths received community reintegration services. We analyzed FIA's records pertaining to community reintegration services available Statewide and the funding available by county. Also, we examined FIA's guidelines for determining appropriate community reintegration services and reviewed performance indicators, standards established by FIA, and FIA's management information system.

AGENCY RESPONSES
Our audit report includes 20 findings and 24 corresponding recommendations. FIA's preliminary response indicated that it agreed with all of the findings and recommendations. Also, FIA's preliminary response indicated that it had initiated a timely and comprehensive corrective action plan. FIA's initiation of such a plan was the result of management's acknowledgment and follow-up of preliminary audit findings during and soon after the completion of our audit fieldwork.

Full Audit Report - #4327197 - JUVENILE JUSTICE SERVICES

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INTRODUCTION This report, issued in April 1999, contains the results of our performance audit of Juvenile Justice Services, Family Independence Agency (FIA).

AUDIT PURPOSE This performance audit was conducted as part of the constitutional responsibility of the Office of the Auditor General. Performance audits are conducted on a priority basis related to the potential for improving effectiveness and efficiency.

BACKGROUND FIA administers juvenile justice services. The Child and Family Services Administration oversees policy development for services provided to youths and families through FIA's local offices, State-operated residential treatment facilities, and private residential treatment facilities under contract with FIA. The Field Operations Administration oversees delinquency field staff. The purpose of providing juvenile justice services is to carry out Section 712A.1 of the Michigan Compiled Laws, which mandates that each youth under FIA's jurisdiction be provided: . . . care, guidance and control, preferably in his or her own home, conducive to the juvenile's welfare and the best interest of the state. If a juvenile is removed from the control of his or her parents, the juvenile shall be placed in care as nearly as possible equivalent to the care which should have been given to the juvenile by his or her parents. The goals of juvenile justice services are: 1. To divert youths from the juvenile justice system at the point of entry. 2. To protect the community from harm by youthful offenders. 3. To reduce recidivism within the juvenile justice system. 4. To assist youths in becoming contributing members of society. 5. To reduce escalation from the juvenile justice system to the adult criminal justice system. FIA directs adjudicated delinquent youths through the continuum of treatment services determined to be most appropriate for their individual needs. The treatment services are meant to provide youths and families with the knowledge and skills needed to reduce delinquent behavior, promote appropriate attitudes, and strengthen their capacity for self-sufficiency to enable them to function responsibly in their home communities. As of March 31, 1998, FIA was responsible for 5,874 delinquent youths. Juvenile justice services were administered by 1,249 employees: 25 central office staff, 198 field staff at local county offices, and 1,026 staff at State-operated residential treatment facilities and detention centers. In addition, substantially more staff were employed by private residential treatment facilities and detention centers.

OVERALL AUDIT OBJECTIVE AND CONCLUSION Audit Objective: To assess the overall effectiveness of FIA's juvenile justice services. Conclusion: Based on our individual audit findings, we concluded that FIA's juvenile justice services often were not effective in ensuring the availability of treatment programs, identifying youths' placement and treatment needs, and providing appropriate residential services and community reintegration services to reduce delinquency.

INDIVIDUAL AUDIT OBJECTIVES, CONCLUSIONS, AND NOTEWORTHY ACCOMPLISHMENTS Audit Objective: To assess the effectiveness of FIA's intake and placement process. Conclusion: We concluded that FIA's intake and placement process was moderately effective; however, our assessment disclosed one material condition: FIA's intake and placement process did not ensure that delinquent youths received the most effective treatment for meeting their assessed needs (Finding 1). FIA agreed with the finding and recommendation and responded that it has initiated corrective action. Our assessment also disclosed other reportable conditions related to both initial risk assessments and needs assessments, selection of out-of-State residential treatment facilities, out-of-State residential placements, delinquency services worker (DSW) work load standards, and preparation of intake and placement documents (Findings 2 through 6). Noteworthy Accomplishments: Effective April 1, 1995, FIA implemented, on a Statewide basis, a structured decision making (SDM) model that was developed in conjunction with the National Council on Crime and Delinquency. The SDM model is based on set standards and systematic criteria and seeks to balance a youth's need for services and the need for public safety. FIA's SDM model includes the use of standardized tools, such as forms for making initial risk and needs assessments and reassessments, to evaluate the risk and needs of delinquent youths. FIA then assigns treatment resources accordingly. These standardized tools uniformly guide and structure decisions regarding initial placement security level, treatment programs, escalation and de-escalation of placement security level, and placement release. The SDM model lessens individual discretion and the subjective nature of decisions by organizing decision making criteria to promote greater consistency and equity. Audit Objective: To assess the effectiveness of private residential treatment facilities in identifying and providing appropriate services to youths placed in their care. Conclusion: We concluded that private residential treatment facilities sometimes were not effective in identifying and providing appropriate services to youths placed in their care. Our assessment disclosed one material condition: FIA had not established a comprehensive continuous quality improvement process to evaluate and improve the effectiveness of overall juvenile justice services and significant components of those services (Finding 7). FIA agreed with the finding and recommendation and responded that it has initiated corrective action. Our assessment also disclosed other reportable conditions related to quarterly risk and needs reassessments, initial and updated service plans, discharge services plans and treatment release plans, and contacts with released youths and final reports (Findings 8 through 11). Audit Objective: To assess the effectiveness of FIA's contracting for and monitoring of services provided by private residential treatment facilities. Conclusion: We concluded that FIA was moderately effective in contracting for the services of private residential treatment facilities. However, we concluded that FIA was not effective in monitoring the services provided by private residential treatment facilities. Our assessment disclosed two material conditions: FIA did not have an effective process to project and meet bed space needs for delinquent youths (Finding 12). FIA agreed with the finding and recommendation and responded that it has initiated corrective action. FIA did not conduct periodic, comprehensive, on-site monitoring visits at all private residential treatment facilities (Finding 15). FIA agreed with the finding and recommendation and responded that it will initiate corrective action. Our assessment also disclosed other reportable conditions regarding contracts with private residential treatment facilities, the per diem rate-setting process, reimbursement for home visit days, and competitive bidding of contracts with private residential treatment facilities (Findings 13, 14, 16, and 17). Audit Objective: To assess FIA's efforts to provide youths released from residential treatment facilities with appropriate community reintegration services. Conclusion: We concluded that FIA's efforts frequently did not provide the youths released from residential treatment facilities with appropriate community reintegration services. Our assessment disclosed two material conditions: FIA had not taken effective action to ensure that appropriate community reintegration services were made available and provided to delinquent youths (Finding 18). FIA agreed with the finding and recommendation and responded that it has initiated corrective action. FIA had not developed comprehensive guidelines to help ensure that youths released from residential treatment facilities received appropriate community reintegration services (Finding 19). FIA agreed with the finding and recommendation and responded that it will initiate corrective action. In addition, as reported under our second objective, our assessment disclosed a material condition related to the lack of a comprehensive continuous quality improvement process to evaluate and improve the effectiveness of overall juvenile justice services and significant components of those services, including community reintegration services (Finding 7). Our assessment also disclosed a reportable condition related to DSW contacts and case closure summaries (Finding 20).

AUDIT SCOPE AND METHODOLOGY Our audit scope was to examine the program and other records related to juvenile justice services. The audit scope included the examination of case file and other records at six private residential treatment facilities and six Family Independence Agency county offices: Clare, Genesee, Huron, Kalamazoo, Saginaw, and Wayne. The audit scope did not include State-operated residential treatment facilities because of our performance audit of W. J. Maxey Training School, issued in November 1996. Our audit was conducted in accordance with Government Auditing Standards issued by the Comptroller General of the United States and, accordingly, included such tests of the records and such other auditing procedures as we considered necessary in the circumstances. Our audit procedures included an examination of records and activities primarily for the period January 1, 1995 through March 31, 1998. To accomplish our objectives, we reviewed pertinent FIA policy and administrative rules and interviewed staff at FIA's central office. We visited six private residential treatment facilities and interviewed facility staff. We also visited six FIA county offices and interviewed DSWs and supervisory staff. During these visits, we examined case files for delinquent youths who were committed or referred to FIA between June 1, 1995 and February 28, 1997; placed at private facilities after June 1, 1995 and released by February 28, 1997; released from both private and State-operated facilities to community settings after January 1, 1995 and discharged from FIA supervision by February 28, 1997; and released to community settings between January 1, 1995 and February 28, 1997. We also examined case files for certain delinquent youths who were placed in out-of-State facilities between January 1, 1997 and October 1, 1997. We established these time frames for our case file review to ensure that we evaluated juvenile justice services' outcomes resulting from FIA's most current program policies. In connection with our first objective, we evaluated the use of FIA's SDM model and reports pertaining to intake and placement decisions made for selected youths. We assessed the operational practices of the Central Intake Committee, reviewed FIA's evaluation of out-of-State residential treatment facilities and the rationale for selected out-of-State residential placements, and assessed DSW work loads and related work load standards. In connection with our second objective, we reviewed selected facility contracts, observed treatment programs, and examined documentation of services needed by and provided to selected youths. Also, we examined risk and needs reassessments, initial and updated service plans, discharge services plans, and treatment release plans. In addition, we reviewed performance indicators, standards established by FIA, and FIA's management information system. In connection with our third objective, we assessed the adequacy of FIA's policy and processes for contracting and monitoring the services of private residential treatment facilities. We evaluated contract specifications, the per diem rate-setting process, reimbursements for home visit days, and the competitive bidding of certain contracts. Also, we assessed FIA's efforts to project and meet bed space needs and reviewed FIA's monitoring of private residential treatment facilities. In connection with our fourth objective, we examined case files of selected youths to determine DSW contacts with youths after their release, the provision of recommended community reintegration services to youths, and the length of time that youths received community reintegration services. We analyzed FIA's records pertaining to community reintegration services available Statewide and the funding available by county. Also, we examined FIA's guidelines for determining appropriate community reintegration services and reviewed performance indicators, standards established by FIA, and FIA's management information system.

AGENCY RESPONSES Our audit report includes 20 findings and 24 corresponding recommendations. FIA's preliminary response indicated that it agreed with all of the findings and recommendations. Also, FIA's preliminary response indicated that it had initiated a timely and comprehensive corrective action plan. FIA's initiation of such a plan was the result of management's acknowledgment and follow-up of preliminary audit findings during and soon after the completion of our audit fieldwork.